Flying	Squirrel,	Inc. 22	Adams	Ave
Groton
, MA 01450 andy@flyingsquirrelrentals.com

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 Regulations

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	“Reform	Act”)	and	14 C.F.R.	Part	11, Flying	Squirrel,	Inc

. (“ FLYING	SQUIRREL ”),	an	operator	of	the	eBee	Unmanned	Air craft System	(“eBee”)	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.	9 1.109(a)

• 14	C.F.R.	91.119

• 14	C.F.R.	91.121

• 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	for	mapping	and survey	applications.	These	operations	w ill	be	subject	to	strict	operating	requirements	defined	in	the eBee	user	manual	( FLYING	SQUIRREL requests	the	FAA	treat	the	eBee	user	manual	as	proprietary	under 14	C.F.R.	11.35(b)	and	does	not	include	this	document	in	the	public	docket)	and	conditions	def ined	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.

The	eBee	will	be	operated	by	an	individual	who	fulfills	the	fol lowing	requirements:

• Has	successfully	passed	a	manufacturer’s	training	program	for	the	eBee; FLYING	SQUIRREL 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;

• H as	a	Private	Pilot	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	precision	aerial	mapping	missions thanks	to	the	on

- board	GPS	and	the	related	flight	management	software	(eMotion)	that	allows	the operator	to	plan	safely	and	efficiently	a	mission	in	3D,	and	then	monitor	it	in	real

- time.

Thanks	to	the	embedded	camera,	protected	by	a	foam	envelope,	the	eB ee	takes	a	collection	of	high

definition	still	images	that	are	used	later	to	generate	maps	and	contour	lines	of	the	surveyed

The	four	main	characteristics	of	the	eBee	are:

a.	Very	light	weight

The	eBee	is	so	light	that	the	operator	can	launch	it	by	hand	a nd	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
eB ee	are	detachable	and	made	of	flexible	foam	with	no	sharp	or	hard	edges	and almost	no	internal strengthening	structure.

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.

c.	Semi

- automatic	flight

The	artificial	intelligence	incorporated	within	the	eBee	autopilot	system	continuously	analyzes	data	from
the	Inertia l	Measurement	Unit	and	from	the	onboard	GPS	and	takes	care	of	all	the	aspects	of	the	flight 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	a ctions 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	emergency circumstances,	thanks	to	the	remote	controller	prov ided	with	the	system.

2.	APPLICATIONS

The	requested	exemption	would	allow F LYING	SQUIRREL to	operate	the	eBee	for	the	purposes	of	aerial inspections	and	surveying.	These	applications	would	include Land	Surveying	and	Mapping	for:
Environmental	Assessments	& Permitting,	Mining,	Utilities,	Oil	&	Gas	Well	Sites,	Pipelines,	Landfills, Construction	Sites,	Agriculture,	and	Topography

. Using	the	eBee	offers	a	safety	advantage	when	compared	to	inspecting	these	locations	in	person	or using	manned	aircraft.	Due	to	it s	small	size	and	the	fact	it	carries	no	fuel	the	eBee	poses	a	very	low	risk of	damage	to	persons	or	structures	on	the	ground.	Additionally,	using	the	eBee	offers	significant	time savings	when	compared	to	completing	these	inspections	and	surveys	in	person	o n	the	ground.	Because the	eBee	is	electric	powered,	it	creates	no	harmful	emissions	and	makes	very	little	noise.	The	ability	toprogram	a	specific	flight	pattern	will	allow	repeatable	collection	of	data	that	is	otherwise	difficult	or impossible	to	gather.

3.	APPLICABLE	LEGAL	STANDARD	UNDER	SECTION	333

a.	Airworthiness	assessment	of	the	eBee

FLYING	SQUIRREL 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

- flight

- test

center

- conducts

- ebee

- airworthiness

- 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,	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	operation s)

• Norway	(flight	approval	for	VLOS	operations)

• Sweden	(flight	approval	for	VLOS	operations)

• Denmark	(flight	approval	for	VLOS	operations)

b .	Operating	requirements

Grant	of	the	exemption	to FLYING	SQUIRREL for	the	eBee	will	be	subject	to	the	following	ope rating 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

- ac cess,	or	public	property	where	a pproved;

• Per mission	from	the	land	owner/authority	required	before	commencing	any	flight;

• Operations	over	congested	areas	shall	be	avoided;

• Operations	must	not	interfere	with	manned	aircraft	operation s,	must	yield	the	right	of	way	t o 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	h ours

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

• VLOS	guaranteed	with	a	GPS	geo

- fence	around	operator	of	0.5	miles ;

• Flight	ceiling	pre

- programed	at	400	feet;

• All	operations	conducted	within	5	miles	from	an	airport	shall only	be	initiated	after	verbal

c oordination	with	the	airport	authority,	or	air	tr affic	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

go vernmental	agencies.

• The	eBee	operations	will	be	compliant	with	existing	safety	procedures	inherent	t o	the activities of	the	related	company.

c .	Operator	Requirements

The	eBee	operator	will	have	a	Private	Pilot	license	and	w ill	successfully	have	passed	a m anufacturer’s training	program	for	the	eBee.

3.	CONCLUSION

Flying	Squirrel believes	that	the	eBee	has	demonstrated	its	safety	and	re liability	in	its	numerous	uses throughout	the	world	and	thus	has	proven	it	can	be	safely	operated	in	the	national	air	space (NAS). Additionally,	the	combination	of	its	light	weight,	the	strict	operating	guidelines	proposed herein,	and	the required	qualifications	of	the	operators	form	an	equivalent	or	greater	level	of	safety	compared	to manned	aircraft	performing	the	same	missio ns. Flying	Squirrel therefore	requests	that	the	FAA	consider this	as	adequate	justification	for	the	granting	of	the	requested	exemption	allowing	safe	commercial operations	of	the	eBee	in	the	NAS.

Yours	sincerely,

Andrew	Young FLYING	SQUIRREL ,	INC.
Pr esident 22	Adams	Ave
Groton
, MA 01450 andy@flyingsquirrelrentals.comANNEX	A:	EXEMPTION	REQUEST	AND	EQUIVALENT	LEVEL	OF	SAFETY

SHOWINGS	UNDER	APPLICABLE	RULES	SUBJECT	TO	EXEMPTION

Flying	Squirrel requests	an	exemption	from	the	following	regulations as	well	as	any	additional regulations	that	may	technically	apply	to	the	operation	of	the	eBee:

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

Section	91.203(a)(1)	requires	all	civil	aircraft	to	have	a	certificate	of	airwor thiness.	Part	21,	Subpart	H, entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for	the	issuance	of airworthiness	certificates	as	required	by	FAR	§	91.203(a)(1).	Given	the	size	of	the	eBee,	its	very	light weight	and	the	limited	(t he	maximum	take

- off	weight	is	1.7	pounds)	operating	area	associated	with	its utilization,	it	is	unnecessary	to	go	through	the	certificate	of	airworthiness	process	under	Part	21	Subpart H	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,	u pon	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	operated	without	an	airworthiness certificate,	unde r	the	conditions	proposed	in	that	exemption,	will	be	at	least	as	safe,	or	safer,	than	a conventional	aircraft	with	an	airworthiness	certificate.	A	risk	assessment	for	operations	with	the	eBee, which	demonstrates	that	assertion,	was	submitted	as	part	of	thi s	application.

The	eBee	weighs	1.7	pounds	maximum	at	take

- off.	It	is	made	of	flexible	foam,	does	not	carry	a	pilot	or passengers,	does	not	carry	flammable	fuel,	and	will	operate	exclusively	within	a	pre

- disclosed	area	and in	compliance	conditions	set	fort h	herein.	Operations	under	this	exemption	will	be	continuously monitored	and	controlled	by	the	operator	via	radio	communication	link	between	the	eBee	and	its ground	control	station.	Additionally,	a	geo

- fence	and	flight	ceiling	will	be	defined	for	each	flig ht	prior	to launch	to	ensure	the	eBee	does	not	operate	beyond	its	designated	flight	area.

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	registratio n	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	(wingspan	of	37.8	inches), this	requirement	is	impossible	to	match.The	equivalent	level	of	safety	will	be	achieved	by	having	the	upper	part	of	the	eBee	stick	with	a	copy	of the	AMA	membership	of	the	operator	in	charge.	The	AMA	agrees	to	provide	2	original	copies	of	the
AMA	license to	every	eBee	operator.

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	regul ation	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	e mployment	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.

Flying	Squirrel proposes	the	following	requirements	for	its	eBee	operators:

- Has	successfully	passed a	manufacturer’s	training	program	for	the	eBee;

- Has	a	current	Academy	of	Model	Aeronautics	(AMA)	membership;

- Has	a	Private	Pilot	certificate.

An	equivalent	level	of	safety	will	be	achieved	by	having	an	operator	who	is	adequately	trained	and proficient	in the	operation	of	traditional	aircraft,	model	aircraft,	and	the	eBee	unmanned	aircraft.

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	th e	exemption	be	granted	allowing	commercial	operation	of	the	eBee	without	an	airworthiness certificate,	no	standard	will	exist	for	airworthiness	of	the	eBee.	Given	the	size	of	the	aircraft	and	the previous	airworthiness	assessments	given	to	the	eBee,	among others:

- New	Mexico	State	University:	https://newscenter.nmsu.edu/Articles/view/10208/nmsu

uasflight

- test

- center

- conducts

- ebee

- airworthiness

- 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	t he	SenseFly	eBee 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. We	assume	that	the	intent	of	this	requirement	is	to	ensure	that	flight	manual information	is	available	to	the	aircrew	while	operating	the	aircraft.	We	request	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 transportation	box.

14	C.F.R.	§	91.109(a):	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
in

- flight	training	will	be	achieved	by	the	manufacturer	or	affiliate	providing	the	training	as	described	in the	eBee	training	program	and	through	the	use	of	experienced	and qualified	instructors	familiar	with	the eBee	and	also	members	of	the	AMA.

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,	vehic le,	or	structure.	Since	the	aircraft	will	be	operating	at	a	maximum	of 400	feet	AGL,	the	eBee	cannot	comply	with	this	requirement.

The	equivalent	level	of	safety	will	be	achieved	because	the	eBee	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	eBee	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	th e expected	route	of	flight	and	the	associated	risks	to	persons	and	property	on	the	ground.	Due	to	the small	size	of	the	eBee,	the	material	with	which	the	eBee	is	built	and	its	specific	safety	procedures (among	others	ground	detection),	the	hazard	to	person s,	vessels,	vehicles,	and	structures	is	not comparable	to	manned	aircraft	and	should	be	considered	in	granting	the	exemption.	Additionally,	the aircraft	will	be	operated	at	an	altitude	allowing,	if	a	power	unit	fails,	an	emergency	landing	without
undue	haz ard	to	persons	or	property	on	the	surface.Moreover,	the	aircraft	will	not	be	operated	over	congested	areas	or	over	any	open

- air	assembly	of

persons.

14	CFR	91.121:	Altimeter	settings

This	section	requires	that	each	person	operating	an	aircraft	shall	m aintain	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 nauti cal	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	eleva tion	of	the	departure airport	or	an appropriate	altimeter	setting	available	before	departure.

To	provide	an	equivalent	level	of	safety,	the	eBee	autopilot	calculates	the	reference	altitude	(ground level)	with	the	on

- board	GPS	during	the	pre

- flight	tests. The	GPS	and	barometer	data	are	then	used	to
calculate	the	altitude	in

- flight.	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, Flying	Squirrel believes	that	an	equivalen t	level	of	safety	is already	achieved	with	the	specific	procedure	preventing	the	eBee	to	accept	a take

- off	order	is	the battery	level	is	below	a	given	value.	Moreover,	the	eBee	has	integrated	“low”	and	“critical”	battery	level warnings	and	implemented	a	“return	to	Home”	(and	“Go	Land”)	actions	in	these situations.

14	C.F.R.	§	91.203	(a)	&	(b):	Carryi ng	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	airworthine ss	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.To	obtain	an	equivalent	level	of	safety	and	meet	the intent	of	91.203, Flying	Squirrel proposes	that documents	deemed	appropriate	for	this	aircraft	by	the	FAA	will	be	co

- located	with	the	operator	at	the ground	control	station	in	the	eBee	box	and	available	for	inspection	upon	request.	In	order	to	identify	th e aircraft, Flying	Squirrel proposes	that	a	copy	of	the	AMA	membership	of	the	operator	will	be permanently	affixed	to	the	eBee	on	the	upper	side	of	the	body.

14	CFR	Subpart	E	(91.401

- 91.417)

- Maintenance,	Preventive	Maintenance,	and	Alterations

The	re gulation	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	p erson	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.

Flying	Squirrel proposes	that	the	maintenance	of	the	eBee	will	be	accomplished	by	the	owner/opera tor according	to	the	maintenance	manual,	such	as	Exhibit	3,	provided	by	SenseFly.	An	equivalent	level	of safety	will	be	achieved	because	the	eBee	is	small	in	size,	it	is	not	a	complex	mechanical	device,	it	will carry	no	external	payload,	and	it	will	operat e	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, the	eBee 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,	the	eBee	will	not	be	able	to	be	switched

- on	and	a	message error	is	displayed	on	the	main	screen of	eMotion.	The	operator	can	then	refer	to	the	maintenance manual	to	troubleshoot	this	issue.	Several	parts	of	the	eBee	are	easily	interchangeable	(propellers, wings),	which	allows	the	operator	to	make	sure	the	wings	and	propulsion	system	are	always	airwo rthy 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