June 12, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Request for an UAS Amendment to Exemption No. 11294, Regulatory Docket No. 

FAA-2014-0961 

Dear Sir or Madam: 

On April 8th, 2015 Idaho Forest Group (IFG) received notice that we were granted 

our request for exemption pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (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 treat the Justification of airworthiness and safety assessment, maintenance 

procedures, and training documentation and Annex B as proprietary under 14 C.F.R. 

11.35(b) and not include this document in 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 

amendment would 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 order to ensure at least 

an equivalent level of safety 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-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 four main characteristics of the eBee 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 I 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 

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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 Inertial Measurement Unit and from the 

on board 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 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. 

APPLICATIONS 

IFG intends to utilize the eBee for the purpose of collecting aerial data over 

properties for design, management and planning purposes. 

Using the eBee's sensor technology, IFG 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 

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 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 

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. 

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• Annex B describes applications and reasoning in more detail. 

Overall, this UAS technology offers a substantial safety and economic benefit to our 

industry. The eBee would allow IFG the ability to provide significant cost and time 

savings for our work 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 of field work needed. This technology is not only cost effective, but will also 

reduce IFG'S fuel and maintenance expenses by reducing the amount of time a 

technician needs to spend collecting field information. 

APPLICABLE LEGAL STANDARD UNDER SECTION 333 

a. Airworthiness assessment of the eBee 

IFG 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/yiew /10208/nmsu-uas-flight-test-centerconducts-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, IFG 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) 

b. Operating requirements 

Grant of the exemption to IFG for the eBee will be subject to the following operating 

conditions: 

• 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 

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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 approved COA; 

• 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. 

• The eBee operations will be compliant with existing safety procedures 

inherent to the activities of the related company. 

A large percentage of project 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 of each project area will also 

be notified and educated on the purpose of the 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 by our CO A. By staying below this 

level, the eBee should not interfere 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 operator will have a Pilot license. 

The eBee is an ultra-light UAV platform made of flexible foam with no sharp or hard 

edges 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 eBee 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 (emergency landing procedure, triggered by the 

autopilot or the operator in charge: given its very light weight, the eBee will initiate a 

gliding approach to the ground at very low speed around the current location). 

Moreover, the kinetic energy of the aircraft is 60 J in-flight at cruise speed. In 

comparison, the kinetic energy of a football is about 110 J when thrown by hand. 

Given these safety features recognized by the U.S. Army Corps of Engineers and the 

national aviation authority of several countries, IFG requests an exemption from the 

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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 will 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). 

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 of each regulation from which an exemption is sought and the 

equivalent level of safety showing. 

CONCLUSION 

This amendment request to our granted exemption is for the addition of the eBee 

UAS system. It will 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 economy within IFG's industry continues to 

progress. The safe integration of the eBee system will greatly benefit the company 

economically and professionally. 

ob 

Idaho Forest Group 

Director Land Improvement 

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ANNEX 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 of the e Bee: 

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 the 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 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 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 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, under the conditions proposed in that 

exemption, will be at least as safe, or safer, than a conventional aircraft with an 

airworthiness certificate. A proprietary risk assessment for operations with the eBee, 

which demonstrates that assertion, is also being submitted to the FAA as part of this 

application. IFG requests the FAA treat the eBee risk assessment as proprietary 

under 14 C.F.R. 11.35(b) and not include this document in the public docket. 

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 (wingspan of 37.8 inches), 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: 

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(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 

maybe 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 ofthe eBee and the fact that the missions are preprogrammed and monitored in real-time with a specific flight management software 

(eMotion), IFG proposes that operators of the eBee 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. 

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 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:f/newscenter.nmsu.edu/Articlesfview/10208/nmsu-uas-flight-testcenter-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 the 

Sense Fly 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. IFG assumes that the intent of this 

requirement is to ensure that flight manual information is available to the aircrew 

while operating the 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. 

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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) & 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 eBee. 

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, 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 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 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 aircraft will not be operated over congested areas nor over any openair 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. 

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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 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 dayVFR 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, IFG believes that an equivalent 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, SenseFly 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): 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. 

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 or to display them on the UAS. 

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, IFG 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 eBee 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 

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certificated mechanics, under Part 43, or licensed pilots and records of approval of 

the aircraft for return to service. 

IFG proposes that the maintenance of the eBee will be accomplished by the 

owner I operator according to the maintenance manual, provided by Sense Fly. IFG 

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 the eBee is small in size, it is 

not a complex mechanical device, it will carry no external payload, and it 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, 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 

The flight management software. 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 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 of the criteria provided in Section 333 of the Reform Act of 2012-

-size, weight, speed, operating capabilities, proximity to airports and populated 

areas and operation within visual line of sight and national security- provide more 

than adequate justification for the grant of the requested exemptions allowing 

commercial operation of applicant's sUAS in timber industry pursuant to the Manual 

appended hereto. 

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