June 12, 2015 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Request for an UAS Amendmentto Exemption No. 11294, Regulatory Docket No. FAA-2014-0961 Dear Sir or Madam: On April 8th, 2015 Idaho Forest Group (IFG) received notice thatwe were granted our request for exemption pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11. This amendment request is to add SenseFly's eBee fixed wing UAS to our above referenced exemption. Attached are related documentation related to the eBee. IFG requests the FAA treatthe Justification ofairworthiness and safety assessment, maintenance procedures, and training documentation and Annex Bas proprietaryunder 14 C.F.R. 11.35(b) and not include this documentin the public docket. This UAS has been proven acceptable based on numerous preceding exemption approvals. We have chosen this UAS based on safety, weight and range. This amendmentwould authorize commercial operations using the eBee for aerial data acquisition. These operations will be subject to strict operating and conditions defined by the manufacturer's standards and procedures in orderto ensure at least an equivalentlevel ofsafety to currently authorized operations using manned aircrafts.

CHARACTERISTICS OF THE AIRCRAFT The eBee is a small (37.8 inches wingspan) and ultra-light (maximum take-offweight of 1.7 pounds) platform made offlexible-foam thatperforms pre-programmed aerial mapping missions with an on-board GPS, and a related flight-management software (eMotion). eMotion allows the operatorto 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 ofhigh-definition still images used to generate dynamic maps and contour lines ofthetargeted terrain. The four main characteristics ofthe eBee are:

a. Very light weight The eBee is so lightthatthe operator can launch it by hand and let it land on almost any surface without requiring a parachute orlanding net (belly land). Its low impact energy (38 

### Iin case ofa controlled emergency landing) also significantly reduces the risk ofhazardous situations. Finally, the wings ofthe eBee are detachable and made offlexible foam with no sharp orhard edges, and almost no internal strengthening

1structure. b. Electric-powered The eBee is electric powered. Abrushless engine technology makes it silent and reliable. The propeller is attached with a rubber band to the body ofthe plane so that it can easily flex away in case ofcontact with any object.

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 ofall the aspects ofthe flight underthe supervision of the operator. d. Option for Manual control Additionally, the eBee provides an override capability that allows the operatorto 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 ofthe aircraft should itbecome necessary to respond to emergent circumstances, thanks to the remote controller provided with the system.

APPLICATIONS IFG intends to utilize the eBee for the purpose ofcollecting aerial data over properties for design, management and planning purposes. Using the eBee's sensortechnology, IFG will be able to collect time-specific imagery and elevation information. Once the entire terrain ofinterestis flown, images collected during the flight will be merged together in a software program to make a topographic model. Using specific mathematical equations within the Postflight Terra 3D software, project field conditions, terrain characteristics and potential hazard areas can be easily identified. The eBee will be used to evaluate information, including but notlimited 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 The end goal at IFG is to use data produced by the eBee to provide real-time, aerial imagery and terrain models to manage lands.



### 2• Annex Bdescribes applications and reasoning in more detail. Overall, this UAS technology offers a substantial safety and economic benefitto our industry. The eBee would allow IFG the ability to provide significant cost and time savings for ourwork flow. This will also allow us to conduct regular flyovers and also immediately use the data to work more efficiently. This will also save time and money by minimizing the amount offield work needed. This technology is not only cost effective, butwill also reduce IFG'S fuel and maintenance expenses by reducing the amount oftime a technician needs to spend collecting field information.
APPLICABLE LEGAL STANDARD UNDER SECTION 333

a. Airworthiness assessmentofthe eBee IFG notes thatthe airworthiness ofthe eBee has alreadybeen demonstrated for differentprojects in the United States, involving state/federal agencies or universities (among othersthe New Mexico State University: https://newscenter.nmsu.edu/Articles/yiew/10208/nmsu-uas-flight-test-centerconducts-ebee-airworthiness-assessment and the USACE New Orleans, who coordinated with the Department ofArmy and the FAA to obtain all authorizations required in orderto operatethe eBee UAS). Moreover, IFG notes that senseFly obtained flight approvals for the eBee (delivered bynational 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) b. Operating requirements Grant ofthe exemption to IFG for the eBee will be subjectto the following operating conditions:

• Operations to be conducted over private, controlled-access, orpublic propertywhere approved with permission from the land owner/authority required before commencing any flight; • Operations over congested areas shall be avoided; • Operations mustnotinterfere with manned aircraft operations, mustyield the right ofwayto manned aircraft, and operators must See & Avoid other

3aircraft and obstacles at all times; • Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours; • Aircraft operations must remain within Visual Line ofSight (VLOS) and will be visually monitored at all times; • Visual Line ofSight operations guaranteed with a GPS geo-fence around operator of0.5 miles; • Flight ceiling pre-programed at orbelow approved COA; • All operations conducted within five miles from an airport shall only be initiated afterverbal coordination with the airport authority, or air traffic control when a control tower is present atthe airport; • All operations shall comply with required permissions and permits established byterritorial, state, county or cityjurisdictions; including local law enforcement, fire, or otherappropriate governmental agencies. • The eBee operations will be compliant with existing safety procedures inherentto the activities ofthe related company. Alarge percentage ofproject locations serviced by IFG is in isolated, rural, nonresidential areas. Before an area is flown, IFG will request written permission from each property owner. Residents within the vicinity ofeach project area will also be notified and educated on the purpose ofthe flight. With the geo-fence incorporated within the flight management software, IFG will avoid flying over houses and yards as much as reasonably possible. The flight ceiling will be preprogrammed no higher than the height specified byour COA. By staying belowthis level, the eBee should notinterfere with manned aircraft operations. IFG takes pride in providing a safe working environment for its members and currently has excellent safety procedures in place.

c. Operator Requirements As outlined in our granted exemption. The eBee operatorwill have a Pilot license. The eBee is an ultra-light UAV platform made offlexible foam with no sharp orhard edges characterized by a high level ofpre-programmed controls and various technical capabilities (programming ofa geo-fence, automatic wind detection) that preventthe operatorfrom doing a mission outside ofthe operatinglimits. All flights are pre-programmed with GPS guidance and do notrequire human intervention; nevertheless human override is possible by clicking on one ofthe multiple "action" buttons or by using the remote controller provided with each eBee system. In the case ofunplanned events, eitherthe autopilot reacts immediately orthe operator can choose between different pre-programmed or manual actions. Those procedures include a Flight Termination System (emergency landing procedure, triggered bythe autopilot orthe operatorin charge: given its very lightweight, the eBee will initiate a gliding approach to the ground atvery low speed around the currentlocation). Moreover, the kinetic energy ofthe aircraft is 60 

### Jin-flight at cruise speed. In comparison, the kinetic energy ofa football is about 110

### Jwhen thrown byhand.

Given these safety features recognized bythe U.S. Army Corps ofEngineers and the national aviation authority ofseveral countries, IFG requests an exemption from the

4airworthiness 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 ofthe eBee will have passed SenseFly's training program for operation ofthe UAS. The manufacturer's training program for operators has been already satisfactorilyreviewed through theApplication for Airworthiness Qualification Level (AQL) 3Airworthiness Release (AWR).

IFG 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 ofeach regulation from which an exemption is sought and the equivalentlevel ofsafety showing. CONCLUSION This amendmentrequestto our granted exemption is for the addition ofthe eBee UAS system. Itwill produce several safety, efficiency and production benefits to our facility operations and land assessments. The demand for improved, accurate data will continue to increase as the economywithin IFG's industry continues to progress. The safe integration ofthe eBee system will greatlybenefitthe company economically and professionally.

ob Idaho Forest Group Director Land Improvement

5ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION IFG requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation ofthe eBee: 14 C.F.R. Part 21, SubpartH: Airworthiness Certificates 14 CFR § 91.203(a)(1) Section 91.203 requires all civil aircraftto have a certificate ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR§ 91.203(a). Given the size ofthe eBee, its very light weight (the maximum take-off weight is 1.7 pounds) and the limited operating area associated with its utilization, it is unnecessaryto go through the certificate ofairworthiness process under Part 21 Subpart Hin orderto achieve or exceed current safetylevels.

Such an exemption meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe UAS involved. An analysis ofthese different criteria demonstrates thatthe eBee operated without an airworthiness certificate, underthe conditions proposed in that exemption, will be atleast as safe, or safer, than a conventional aircraftwith an airworthiness certificate. Aproprietaryrisk assessment for operations with the eBee, which demonstrates that assertion, is also being submittedto the FAA as partofthis application. IFG requests the FAA treatthe eBee risk assessment as proprietary under 14 C.F.R. 11.35(b) and notinclude this document in the public docket.

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Displayofmarks; size ofmarks These regulations provide thateach aircraft must display "N" and the aircraft's registration number in letters atleast 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters atleast 2 inches high nearthe entrance tothe cabin, cockpit, orpilot station. Given the size ofthe eBee (wingspan of37.8 inches), this requirementis impossible to match. 14 C.F.R. § 61.3: Requirements for certificates, ratings andauthorizations 14 C.F.R. § 61.113(a) & (b); 61.133(a): Private PilotPrivileges and Limitations; Pilot in Command; Commercial Pilot Privilegesand Limitations The regulation provides thatno person may serve as a required pilot flight crewmember ofa civil aircraft ofthe United States, unless thatperson:

6(1) Has a pilot certificate or special purpose pilot authorization issued underthis partin thatperson's physical possession or readily accessible in the aircraft when exercisingthe privileges ofthatpilot certificate or authorization. However, when the aircraft is operated within a foreign country, a pilot license issued by that country maybe used. The regulation provides also thatno person thatholds a private pilot certificate may act as pilot in command ofan aircraft for compensation orhire. Subparagraph (b) allows a private pilotto act as pilot in command ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to thatbusiness or employment; (2) The aircraft does not carrypassengers or propertyfor compensation or hire. Given the safety features ofthe eBee and the fact thatthe missions are preprogrammed and monitored in real-time with a specific flight management software (eMotion), IFG proposes that operators ofthe eBee should notbe 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. 14 C.F.R. § 91.7(a): Civil aircraft airworthiness This regulation requires that no person may operate a civil aircraft unless itis in airworthy condition. Should the exemption be granted allowing commercial operation ofthe eBee without an airworthiness certificate, no standardwill exist for airworthiness ofthe eBee. Given the size ofthe aircraft and the previous airworthiness assessments given to the eBee, among others:

• New Mexico State University:https:f/newscenter.nmsu.edu/Articlesfview/10208/nmsu-uas-flight-testcenter-conducts-ebee-airworthiness-assessment

• USACE New Orleans, who coordinated with the DepartmentofArmy and the FAA to obtain all authorizations required in orderto operate the eBee UAS for levee system monitoring, documentation ofconstruction progress, and extensive oblique photography ofUSACE structures & activities An equivalent level ofsafetywill be achieved by insuring compliance with the SenseFly manuals prior to each flight. 14 C.F.R. § 91.9: Civil aircraftflight manual, marking, and placard requirements. This regulation provides thatno person may operate an aircraft unless a current, approved flight manual is in the aircraft. IFG assumes thatthe intent ofthis requirementis to ensure thatflight manual information is available to the aircrew while operatingthe aircraft. IFG 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.

7The equivalent level ofsafetywill be achieved by keeping a hard copy ofthe flight manual in the eBee transportation box. 14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction The regulation provides that "No person may operate a civil aircraft thatis being used for flight instruction unless that aircraft has fully functioning dual controls." Flight instruction will be accomplished through an elaboratedtraining program, using first the simulation mode ofthe flight management software eMotion. The equivalent level ofsafety during the training will be achieved by the manufacturer or authorized distributor providing the training and through the use ofexperienced and qualified operators familiar with the eBee

. 14 CFR § 91.119: Minimum Safe Altitudes The regulation provides that over sparselypopulated areas the aircraft cannotbe operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraftwill be operating at a maximum of400 feet AGL, the eBee cannot comply with this requirement. The equivalent level ofsafetywill be achieved because the eBee will only fly over private propertywith the permission ofthe landowner. The operatorwill define before everyflight a working area radius and a flight area ceiling, preventingthe eBee to go beyond the flight area. The landowner and the personswho may be on the ground in the flight area will be briefed ofthe expected route offlight and the associated risks to persons and property on the ground. Due to the small size ofthe eBee and the material with which the eBee is built, the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in granting the exemption. Moreover, the aircraftwill notbe operated over congested areas nor over any openair assembly ofpersons. The aircraft will be operated atan altitude allowing, ifa powerunit fails, an emergencylanding withoutundue hazard to persons orproperty on the surface. 14 CFR 91.121- Altimetersettings This section requires that each person operating an aircraft shall maintain the cruising altitude orflight level ofthat aircraft, as the case maybe, by reference to an altimeterthat is set, when operatingbelow 18,000 feet MSL to:

• The current reported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; • Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the currentreported altimeter settingofan appropriate available station; • In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airportor an appropriate altimeter setting available before departure.

8To provide an equivalent level ofsafety, 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 merged with respect to their respective precisions. The GPS provides reliable information to correctpotential barometric bias, while rapid variations in altitude are detected through the barometer. Hence, barometric bias induced byenvironmental 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 underdayVFR conditions unless there is enough fuel to fly to the first point ofintended landing and to fly after that for atleast 30 minutes. Given the area ofoperation for the eBee, IFG believes that an equivalent level of safety is already achieved with the specific procedure preventing the eBee to accept a take-offorder is the batterylevel is below a given value. Moreover, SenseFly has integrated "low" and "critical" batterylevel warnings and implemented a "returnto 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 ithas an appropriate and current airworthiness certificate. • No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew. The eBee weighs only 1.7 pounds (max take-off weight). As such, there is no ability or place to carry certification and registration documents orto display them on the UAS. In addition, there is no pilot orpassengers on board the aircraft. To obtain an equivalentlevel ofsafety and meetthe intentof91.203, IFG propose that documents deemed appropriate for this aircraftbythe FAA will be co-located with the operator atthe ground control station in the eBee box and available for inspection upon request 14 CFR Subpart E(91.401- 91.417)- Maintenance, Preventive Maintenance, andAlterations The regulation provides thatthe 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 thatthe aircraftbe "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 ofan airworthiness certificate. Section 91.417(a) requires the owner or operatorto keep records showing certain maintenance workthathas been accomplished by

9certificated mechanics, under Part 43, orlicensed pilots and records ofapproval of the aircraft for return to service. IFG proposes thatthe maintenance ofthe eBee will be accomplished by the owner

### Ioperator accordingto the maintenance manual, provided by SenseFly. IFG requests the FAA treatthe eBee training program as proprietaryunder 14 C.F.R. 11.35(b) and not include this document in the public docket.

An equivalent level ofsafety will be achieved because the eBee is small in size, itis not a complex mechanical device, it will carry no external payload, and itwill 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 ofsafety. Finally, before every flight, the eBee runs automatically a sequence ofpre-flight tests to make sure that every sensor and every critical partis running properly. Ifa problem is detected, the eBee will not be able to be switched-on and a message error is displayed on the main screen of The flight management software. The operator can then refer to the maintenance manual to troubleshootthis issue. Several parts ofthe eBee are easily interchangeable (propellers, wings), which allows the operatorto make sure the wings and propulsion system are always airworthy when a mission is initiated. ANNEX B: EBEE AND SENSEFLY DOCUMENTATION, PROPRIETARY DOCUMENTS See email attachment referencing confidential documents regarding this petition filing and comment number. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012- -size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security- provide more than adequatejustification for the grant ofthe requested exemptions allowing commercial operation ofapplicant's sUAS in timber industrypursuantto the Manual appended hereto.

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