GeoDrone International, LLC

637 Zuni Circle

Fort Collins, Colorado 80526

December 16th, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulation

Dear Madam, Sir,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14

C.F.R. Part 11, GeoDrone International, LLC (henceforth referred to as “GeoDrone”), an operator of

the Sensefly eBee Unmanned Aircraft System (“eBee”) and DJI Phantom 2 Vision Plus (“Phantom 2

Vision Plus”) seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below:

14 C.F.R. 21

14 C.F.R. 45.23

14 C.F.R. 45.29

14 C.F.R. 61.3

14 C.F.R. 61.113(a)&(b)

14 C.F.R. 61.133(a)

14 C.F.R. 91.7(b)

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.109(a)

14 C.F.R. 91.119

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)
14 CFR Subpart E (91.401 - 91.417)

The requested exemption would authorize commercial operations using the eBee and Phantom 2

Vision Plus for precision aerial imaging applications by GeoDrone. These operations will be subject to

strict operating requirements defined in the eBee and Phantom 2 Vision Plus user manuals (GeoDrone

requests the FAA treat the eBee training program as proprietary under 14 C.F.R. 11.35(b) and does

not include this document in the public docket) and conditions defined by the Safety Code of the

Academy of Model Aeronautics (see Annex B), in order to ensure at least an equivalent level of safety

to currently authorized operations using manned aircrafts.

GeoDrone is an aerial imaging and mapping company based in Northern Colorado. Our team of

employees is specialized to provide high-resolution, accurate spatial data and consulting services to

clients seeking services of the aerial imaging industry. GeoDrone is committed to providing innovative

products and dependable service to help its clients excel in their highly competitive industries.

Unmanned Aerial Vehicle (UAV) technology, and its associated data, is becoming a desirable

deliverable within the aerial imaging industry. As client requirements continue to evolve, traditional

GPS data collection, available imagery, and surface models lack resolution and accuracy necessary for

elite project planning, assessments and hazard identification. UAV collected data allows a consultant

to depict the project area with greater accuracy, resolution and efficiency to better aid clients with

project design and analysis. As an added benefit, the unmanned aspect reduces the risk of placing

employees in perilous environments.

Given the technical specifications of the eBee and Phantom 2 Vision Plus, GeoDrone believes it is

relevant to use the Academy of Model Aeronautics (AMA) rules to meet the required level of safety of

future eBee and Phantom 2 Vision Plus operations. The AMA has a proven track record in supervising

operations conducted by operators using remote controlled aircrafts and provides the most relevant

expertise in terms of providing safety guidelines for operators using ultra-light remote controlled

aircraft.

Both the eBee and Phantom 2 Vision Plus will be operated by an individual who fulfills the following

requirements:

Has successfully passed a manufacturer’s training program for the eBee and Phantom 2 Vision Plus;

GeoDrone requests the FAA treat the eBee training program as proprietary under 14 C.F.R. 11.35(b)

and does not include this document in the public docket.

Is a registered member of the AMA.

Has a valid driver’s license.

Has a Private Pilot’s license.

1. CHARACTERISTICS OF THE AIRCRAFT

The eBee is a small (37.8 inches wingspan) and ultra-light (maximum take-off weight of 1.7 pounds)

platform made of flexible-foam that performs pre-programmed aerial mapping missions with an

on-board GPS, and a related flight-management software (eMotion). eMotion allows the operator to

safely and efficiently plan a flight in 3D, and then monitor the mission in real-time. Thanks to the
embedded camera, protected by a foam envelope, the eBee takes a collection of high-definition still

images used to generate dynamic maps and contour lines of the targeted terrain.

The Phantom 2 Vision Plus is a small (13.78 inch diagonal motor-motor distance) and ultra-light (2.74

pounds) platform that performs pre-programmed aerial mapping missions with an on-board GPS, and

a related flight-management software (Pix4DMapper Capture). Pix4DMapper Capture allows the

operator to safely and efficiently plan a flight and monitor the mission in real-time. The Phantom 2

Vision Plus takes a collection of high-definition still images used to generate dynamic maps and

contour lines of the targeted terrain.

The four main characteristics of both the eBee and Phantom 2 Vision Plus are:

a. Very light weight

The eBee is so light that the operator can launch it by hand and let it land on almost any surface

without requiring a parachute or landing net (belly land). Its low impact energy (38 J in case of a

controlled emergency landing) also significantly reduces the risk of hazardous situations. Finally, the

wings of the eBee are detachable and made of flexible foam with no sharp or hard edges, and almost

no internal strengthening structure.

Similarly, the Phantom 2 Vision Plus at under 3 pounds is a very light weight platform. Given its

vertical take-off and landing capabilities and its light weight, it presents a low risk for hazardous

situations.

b. Electric-powered

The eBee is electric powered. A brushless engine technology makes it silent and reliable. The propeller

is attached with a rubber band to the body of the plane so that it can easily flex away in case of

contact with any object.

The Phantom 2 Vision Plus is similarly electric powered employing four separate brushless motors.

The propellers are detachable and guarded for added safety.

c. Semi-automatic flight

The artificial intelligence incorporated within the eBee autopilot system continuously analyzes data

from the Inertial Measurement Unit and from the onboard GPS and takes care of all the aspects of the

flight under the supervision of the operator.

The Phantom 2 Vision Plus’s autopilot guidance system utilizes inertial measurement, onboard GPS,

and battery life data to perform autonomous flight plans under the supervision of the operator.

d. Option for Manual control

Additionally, the eBee provides an override capability that allows the operator to take manual actions

during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend automated

operations and take manual control of the aircraft should it become necessary to respond to

emergent circumstances, thanks to the remote controller provided with the system.

Similarly, the Phantom 2 Vision Plus provides an override capability that allows the operator to take

manual actions during the flight and also suspend automated operations and take manual control of

the aircraft using the remote controller.
2. APPLICATIONS

GeoDrone intends to plan and implement an aerial data collection program using precision GIS

techniques employing senseFly’s eBee and DJI’s Phantom 2 Vision Plus in order to assist its clients in

project decision-making and to increase data accuracy.

Using the eBee and Phantom 2 Vision Plus sensor technology, the consultants at GeoDrone will be

able to collect time specific imagery and elevation information. Once the entire terrain of interest is

flown, images collected during the flight will be merged together in a software program to make a

complete photographic and terrain project map. Using specific mathematical equations within

post-flight software, project field conditions, terrain characteristics and potential hazard areas can be

easily identified.

Both the eBee and Phantom 2 Vision Plus will be used to evaluate information, including but not

limited to:

Topographic characteristics

Volumetric estimates

Slope and terrain impediments

Natural and cultural resource identification

As-built feature identification and analysis

Hazard evaluation

Project design evaluations

Frequently, the client’s geophysicist or engineer will generate a project design, but will be limited by

the lack of high-resolution information available. Project conditions and terrain information are

exponentially important to project success and design. Especially with regard to information gathered

during the specific time period the field operations are expected to occur within.

The most readily available information either lacks the required detail, or was captured during a time

period that is not relevant to the expected field operation schedule. GeoDrone strives to eliminate the

guesswork of project planning and design. By using real-time, aerial imagery to study time-specific

field conditions and three dimensional terrain data, GeoDrone can better provide clients, and the

general public impacted by these projects, with a clear picture of the potential complications and

hazards regarding project completion. This would aid in meeting project deadlines, and allow clients

to create informed decisions while also ensuring field crews are operating in a safe manner.

The end goal at GeoDrone is to use data produced by the eBee and Phantom 2 Vision Plus to provide

clients and stakeholders with real-time, aerial imagery and terrain models to evaluate project design,

gather volumetric measurements, assess cultural and biological resources for mitigation as well as

providing health and safety information to lower risk exposure to field operation personnel.

Annex C describes applications and reasoning in more detail. GeoDrone requests the FAA treat the

eBee training program and Annex C as proprietary under 14 C.F.R. 11.35(b) and not include this

document in the public docket.

Overall, UAV technology offers a substantial economic benefit to the aerial imaging industry. The eBee

and Phantom 2 Vision Plus would allow GeoDrone the ability to provide significant cost and time
savings for our clientele. The terrain data would allow clients to tailor project designs to field

conditions, and mitigate potential areas of risk to productivity or personnel. This will also save time

and money by minimizing the amount of design modifications required to complete a project. This

technology is not only cost effective for our clients, but will also reduce GeoDrone’s fuel and

maintenance expenses by reducing the amount of time a technician needs to spend collecting field

information with a handheld GPS.

Many companies have received approval from the FAA to perform similar operations. Trimble

Navigation Limited, VDOS Global, Clayco Inc. and Woolpert Inc. are currently approved in the United

States to perform similar operations with UAV equipment. GeoDrone is hoping to stay competitive in

the aerial imaging industry. Implementing UAV technology will improve GeoDrone’s services and

increase efficiency and safety within our industry.

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333

a. Airworthiness assessment of the eBee and Phantom 2 Vision Plus

GeoDrone notes that the airworthiness of the eBee has already been demonstrated for different

projects in the United States, involving state/federal agencies or universities (among others the New

Mexico State University:

https://newscenter.nmsu.edu/Articles/view/10208/nmsu-uas-flighttest-center-conducts-ebee-airwor

thiness-assessment, and the USACE New Orleans, who coordinated with the Department of Army and

the FAA to obtain all authorizations required in order to operate the eBee UAS).

Moreover, GeoDrone notes that senseFly obtained flight approvals for the eBee (delivered by national

civil aviation authorities) in many countries, among others:

Switzerland (flight approval for VLOS operations)

Canada (flight approval for VLOS operations)

Australia (flight approval for VLOS operations)

France (flight approval for Extended-VLOS operations)

Germany (flight approval for VLOS operations)

United Kingdom (flight approval for VLOS operations)

Norway (flight approval for VLOS operations)

Sweden (flight approval for VLOS operations)

Denmark (flight approval for VLOS operations)

Furthermore GeoDrone asserts that the Phantom 2 Vision Plus does not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, GeoDrone will ensure that the

eBee and Phantom 2 Vision Plus are in airworthy condition based upon its compliance with the

operating documents (i.e., Monthly Maintenance Log, and eBee and Phantom 2 Vision Plus Instruction

Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight

b. Operating requirements
Grant of the exemption to GeoDrone for the eBee and Phantom 2 Vision Plus will be subject to the

following operating conditions, based on the operating conditions set forth by the Academy of Model

Aeronautics (see Annex B). The main restrictions are summarized below:

Operations to be conducted over private, controlled-access, or public property where approved with

permission from the land owner/authority required before commencing any flight;

Operations over congested areas shall be avoided;

Operations must not interfere with manned aircraft operations, must yield the right of way to

manned aircraft, and operators must See & Avoid other aircraft and obstacles at all times;

Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours;

Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually monitored at all

times;

Visual Line of Sight operations guaranteed with a GPS geo-fence around operator of 0.5 miles;

Flight ceiling pre-programed at or below 400 feet;

All operations conducted within five miles from an airport shall only be initiated after verbal

coordination with the airport authority, or air traffic control when a control tower is present at the

airport;

All operations shall comply with required permissions and permits established by territorial, state,

county or city jurisdictions; including local law enforcement, fire, or other appropriate governmental

agencies.

Both the eBee and Phantom 2 Vision Plus operations will be compliant with existing safety procedures

inherent to the activities of the related company. Before an area is flown, GeoDrone will request

written permission from each property owner. With the geo-fence incorporated within the flight

management software, GeoDrone will avoid flying over houses and yards as much as reasonably

possible. The flight ceiling will be pre-programmed no higher than 400 feet to ensure the aircraft will

not fly over the height specified by the AMA. By staying below this level, the eBee should not interfere

with manned aircraft operations.

GeoDrone takes pride in providing a safe working environment for its members and currently has

excellent safety procedures in place.

c. Operator Requirements

The eBee and/or Phantom 2 Vision Plus operator will have a Private Pilot license.

Both the eBee and Phantom 2 Vision Plus are ultra-light UAV platforms characterized by a high level of

pre-programmed controls and various technical capabilities (programming of a geo-fence, automatic

wind detection) that prevent the operator from doing a mission outside of the operating limits. All

flights are pre-programmed with GPS guidance and do not require human intervention; nevertheless

human override is possible by clicking on one of the multiple “action” buttons or by using the remote

controller provided with each system. In the case of unplanned events, either the autopilot reacts

immediately or the operator can choose between different pre-programmed or manual actions. Those

procedures include a Flight Termination System and an emergency Return To Home Function.
Given these safety features recognized by the U.S. Army Corps of Engineers and the national aviation

authority of several countries, GeoDrone requests an exemption from the airworthiness certification

requirements in Part 21 and the concomitant requirements in 14 C.F.R. 91.7(a)) and 91.203 to operate

an airworthy aircraft. Instead, operators of the eBee and Phantom 2 Vision Plus will:

Have completed an AMA affiliated small UAS education and training program and achieved an AMA

UAS endorsement, or have successfully completed a small UAS education and training program

provided by any FAA qualified entity, and;

Have passed SenseFly’s training program for operation of the UAS. The manufacturer’s training

program for operators has been already satisfactorily reviewed through the Application for

Airworthiness Qualification Level (AQL) 3 Airworthiness Release (AWR).

GeoDrone also seeks an exemption from certain requirements in Parts 45 and 91 that are impractical

as well as unnecessary for UAS operations. Please see Annex A for a detailed explanation of each

regulation from which an exemption is sought and the equivalent level of safety showing.

3. CONCLUSION

GeoDrone, in association with senseFly, DJI and the Academy of Model Aeronautics organization, who

has a deep and well-known experience in terms of safe integration of remote controlled aircrafts in

the National airspace for low-level operations, provides here adequate justification for the grant of

the requested exemption allowing safe precision aerial imaging operations of the eBee and Phantom

2 Vision Plus in the National Airspace System.

The benefits that these UAV’s could bring to the aerial imaging industry are invaluable. The demand

for improved, accurate, timely data and hazard identification will continue to increase as the economy

within GeoDrone’s industry continues to progress. Furthermore, the integration of UAS into

workflows that may otherwise put human lives at risk will be of great safety benefit. The safe

integration of these systems will greatly benefit the company economically and professionally.

Yours sincerely,

Colter Seitz

Co-Founder GeoDrone Int, LLC

ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE

RULES SUBJECT TO EXEMPTION
GeoDrone requests an exemption from the following regulations as well as any additional regulations

that may technically apply to the operation of the eBee and Phantom 2 Vision Plus:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H,

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of

airworthiness certificates as required by FAR § 91.203(a). Given the size of both the eBee and

Phantom 2 Vision Plus, their very light weight, and the limited operating area associated with thier

utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21

Subpart H in order to achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section

333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of

the size, weight, speed, operational capability, and proximity to airports and populated areas of the

UAS involved. An analysis of these different criteria demonstrates that the eBee and Phantom 2 Vision

Plus operated without an airworthiness certificate, under the conditions proposed in that exemption,

will be at least as safe, or safer, than a conventional aircraft with an airworthiness certificate.

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration number in

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in

letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station.

Given the size of the eBee and Phantom 2 Vision Plus, this requirement is impossible to match.

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 14 C.F.R. § 61.113(a) & (b);

61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and

Limitations

The regulation provides that no person may serve as a required pilot flight crewmember of a civil

aircraft of the United States, unless that person:

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's

physical possession or readily accessible in the aircraft when exercising the privileges of that pilot

certificate or authorization. However, when the aircraft is operated within a foreign country, a pilot

license issued by that country may be used.

The regulation provides also that no person that holds a private pilot certificate may act as pilot in

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as

pilot in command of an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; (2) The aircraft does not carry

passengers or property for compensation or hire.

Given the safety features of the eBee and Phantom 2 Vision Plus and the fact that the missions are

pre-programmed and monitored in real-time with a specific flight management software (eMotion,

Pix4DMapper Capture), GeoDrone proposes that operators of these UAV’s should not be required to

hold a commercial pilot certification. Instead, operators should be required to:
Have a private pilot license and have successfully passed a manufacturer’s training program for the

eBee and Phantom 2 Vision Plus.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.

Should the exemption be granted allowing commercial operation of the eBee and Phantom 2 Vision

Plus without an airworthiness certificate, no standard will exist for airworthiness of the eBee or

Phantom 2 Vision Plus. Given the size of these aircraft and the previous airworthiness assessments

given to these UAV’s, among others:

New Mexico State University:

https://newscenter.nmsu.edu/Articles/view/10208/nmsuuas-flight-test-center-conducts-ebee-airwor

thiness-assessment

USACE New Orleans, who coordinated with the Department of Army and the FAA to obtain all

authorizations required in order to operate the eBee UAS for levee system monitoring,

documentation of construction progress, and extensive oblique photography of USACE structures &

activities

An equivalent level of safety will be achieved by insuring compliance with the both SenseFly and DJI

manuals prior to each flight.

14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. GeoDrone assumes that the intent of this requirement is to ensure that flight

manual information is available to the aircrew while operating the aircraft. GeoDrone requests an

exemption to this requirement since the aircraft is not only too small to carry documentation, the

documentation would not be available to the crew.

The equivalent level of safety will be achieved by keeping a hard copy of the flight manual in the eBee

and Phantom 2 Vision Plus’ transportation boxes.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

The regulation provides that "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls."

Flight instruction will be accomplished through an elaborated training program, using first the

simulation mode of the flight management software eMotion. The equivalent level of safety during

the training will be achieved by the manufacturer or authorized distributor providing the training and

through the use of experienced and qualified operators familiar with the both the eBee and Phantom

2 Vision Plus.

14 CFR § 91.119: Minimum Safe Altitudes

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a

maximum of 400 feet AGL, neither the eBee nor the Phantom 2 Vision Plus cannot comply with this

requirement.

The equivalent level of safety will be achieved because both UAV’s in question will only fly over

private property with the permission of the landowner. The operator will define before every flight a
working area radius and a flight area ceiling, preventing the UAV to go beyond the flight area. The

landowner and the persons who may be on the ground in the flight area will be briefed of the

expected route of flight and the associated risks to persons and property on the ground. Due to the

small size of the eBee and Phantom 2 Vision Plus, the hazard to persons, vessels, vehicles, and

structures is not comparable to manned aircraft and should be considered in granting the exemption.

Moreover, the aircraft will not be operated over congested areas nor over any open-air assembly of

persons. The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency

landing without undue hazard to persons or property on the surface.

14 CFR 91.121 – Altimeter settings

This section requires that each person operating an aircraft shall maintain the cruising altitude or

flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

below 18,000 feet MSL to:

The current reported altimeter setting of a station along the route and within 100 nautical miles of

the aircraft; If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the

current reported altimeter setting of an appropriate available station; In the case of an aircraft not

equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting

available before departure.

To provide an equivalent level of safety, the eBee and Phantom 2 Vision Plus autopilot calculates the

reference altitude (ground level) with the on-board GPS during the pre-flight tests. The GPS and

barometer data are merged with respect to their respective precisions. The GPS provides reliable

information to correct potential barometric bias, while rapid variations in altitude are detected

through the barometer. Hence, barometric bias induced by environmental factors is rejected.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions

unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least

30 minutes.

Given the area of operation for the eBee and Phantom 2 Vision Plus, GeoDrone believes that an

equivalent level of safety is already achieved with the specific procedure preventing these UAV’s to

accept a take-off order if the battery level is below a given value. Moreover, both SenseFly and DJI

have integrated “low” and “critical” battery level warnings and implemented “return to Home” (and

“Go Land”) actions in these situations.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows: No person may operate a civil aircraft unless it has an appropriate

and current airworthiness certificate. No person may operate a civil aircraft unless the airworthiness

certificate required by paragraph (a) of this section or a special flight authorization issued under

§91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Given the very light weight and small size of both the eBee and Phantom 2 Vision Plus, there is no

ability or place to carry certification and registration documents or to display them on these UAV’s. In

addition, there is no pilot or passengers on board the aircraft.
To obtain an equivalent level of safety and meet the intent of 91.203, GeoDrone propose that

documents deemed appropriate for this aircraft by the FAA will be co-located with the operator at the

ground control station in the UAV’s transportation box and available for inspection upon request

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an

airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409

require that the aircraft be "approved for return to service by a person authorized under 43.7" after

maintenance and inspection. Section 91.409(a)(2) requires an annual inspection for the issuance of an

airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing

certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or

licensed pilots and records of approval of the aircraft for return to service.

GeoDrone proposes that the maintenance of the eBee and Phantom 2 Vision Plus will be

accomplished by the owner/operator according to the maintenance manuals, provided by SenseFly

and DJI . GeoDrone requests the FAA treat the eBee training program as proprietary under 14 C.F.R.

11.35(b) and not include this document in the public docket.

An equivalent level of safety will be achieved because both the eBee and Phantom 2 Vision Plus are

small in size, are not complex mechanical devices, will carry no external payload, and will operate only

in restricted predetermined areas. Moreover, the operator is the person most familiar with the

aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an

equivalent level of safety. Finally, before every flight, both the eBee and Phantom 2 Vision Plus runs

automatically a sequence of pre-flight tests to make sure that every sensor and every critical part is

running properly. If a problem is detected, a message error is displayed on the main screen of the

flight management software. The operator can then refer to the maintenance manual to troubleshoot

this issue. Several parts of both the eBee and Phantom 2 Vision Plus are easily interchangeable

(propellers, wings), which allows the operator to make sure the wings and propulsion system are

always airworthy when a mission is initiated.

ANNEX B: ACADEMY OF MODEL AERONAUTICS SAFETY REQUIREMENTS

http://www.modelaircraft.org/files/105.pdf http://www.modelaircraft.org/files/540-D.pdf

http://www.modelaircraft.org/files/560.pdf