October 22 , 2015 U.S. Department ofTransportation 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 : 304-75 5-8271 Fax: 30 4-755-8274 WV006094

Re: E xemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Dear Madam , Sir, Pursuant to Section 333 ofthe 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 Ai rcraft 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 reques ted exemption would authorize commercial operations using t he eBee fo r mapping and survey appli cations. These operations w ill be subject to strict operati ng requirements defined in the eBee user manual, KSC, Inc. reque s ts 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 p ub l ic docket ) and conditions defined by the Safety Code ofthe Academy of Model Aeronaut ics (see Annex B ), i n orderto ensure at least an equivalent level of safety to current ly authorized operations us i ng manned aircrafts.

"AN EQUAL OPPORTUNITY /A FFIRMATI V E 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 doc ket. 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 l ines ofthe surveyed area. The four main characteristics ofthe 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 ofthe eBee are detachable and made offlexible 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 ofthe plane so that it can easily fl ex away in case of contact with any object. c. Semi-automatic flight The artificial intelligence incorporated within the eBee autopilot s ystem continuously analyzes data from the Inertial Measurement Unit and from the onboard GPS and takes care of all the aspects ofthe flight under the supervision ofthe 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 OPPORT UNITY/AFFIRMATIVE ACTION EMPLOYER "3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 a. Airworthiness assessment ofthe 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 ofway 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 cityjurisdictions; 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 anothervaluable service to our clients and the public
. On most of our projects, the use ofthe 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 ofthis 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"