October 22, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

KANAWHA STONE COMPANY, INC. 

ROCK BRANCH INDUSTRIAL PARK 

409 Jacobson Drive, Poca, WV 25159 Phone: 304-755-8271 Fax: 304-755-8274 

WV006094 

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

Aviation Regulations 

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, KANAWHA STONE COMPANY, Inc. ("KSC, Inc."), an operator of the eBee 

Unmanned Aircraft 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. 61.133(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 t he eBee for mapping 

and survey applications. These operations will be subject to strict operating requirements defined 

in the eBee user manual, KSC, Inc. 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 Aeronaut ics (see Annex B), in order to ensure 

at least an equivalent level of safety to currently authorized operations using manned aircrafts. 

"AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EM PLOYER" 
The eBee will be operated by an individual who fulfill the following requirements: 

• Has successfully passed a manufacturer's training program for the eBee; 

KSC, Inc. 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. 

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 30, and then monitor it in real-time. 

Thanks to the embedded camera, protected by a foam envelope, the eBee takes a collection of 

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

area. 

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 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. 

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 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 

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

2. APPLICATIONS 

The eBee will be used to map natural resources, endangered species and plant life, topography, 

as-built construction conditions and progress, quarry and mining operations (noncongested 

areas), demonstrations and crew training. 

"AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER" 
3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

a. Airworthiness assessment of the eBee 

KSC, Inc. 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-uasflight-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, SenseFiy 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 KSC, Inc. for the eBee 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; 

• 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; 

• 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 

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. 

"AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER" 
c. Operator Requirements 

The eBee operator will have successfully completed the written test of the Private Pilot license. 

3. CONCLUSION 

Kanawha Stone Company, Inc. is a progressive construction company dedicated to providing 

diversified and superior construction services to our clients. We utilize advanced technologies 

to provide our public, private, State Government, and Federal Government Clients, time saving 

solutions to complex construction site issues. We specialize in civil construction, site 

development, road construction, bridge construction, and coal, oil, and gas industrial site 

development. By granting Kanawha Stone Company, Inc. this 333 Exemption, you provide us 

the capability to offer another valuable service to our clients and the public. On most of our 

projects, the use of the Sensfly eBee Precision Mapping and Aerial Photography System will 

save our client's time and money. Having this capability will also provide our Engineers current 

precise mapping to insure that our designs protect the general public's interest as well as our 

specific client's interest. The eBee is also a considerably safer method of mapping than placing a 

KSC, Inc.'s employee on foot in a hazardous environment with a conventional ground based 

mapping system. We believe the eBee is also very safe for other aircraft because of the mission 

specifications (below 400ft.), and the eBee integrated safety features. 

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. We look forward to working with your office. Please contact us at any time if you 

require additional information or clarification 

Yours sincerely, 

Freddie Doss, PS 

Manager of Surveying 

Kanawha Stone Company, Inc. 

"AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER"