November 12, 2015 

U.S. Department of Transportation 

Docket Operations M-30 

West Building Ground Floor, Room w12-140 

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 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, Mount Shasta Aerial Imagery ("MSAI"), an 

operator of the Sense Fly eBee Unmanned Aircraft Systems ( 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) 

MSAI is comprised of commercial pilots, biological, environmental, and ecological 

research scientists, environmental education instructors, and Geographic 

Information Systems (GIS) and software specialists trained in working in the land 

management, education and environmental fields. Our pilots have over 5 years of 

experience that includes flying unmanned aircraft. The requested exemption would 

authorize commercial operations using the eBee for aerial data collection for the 

purposes of land mapping/surveying, land assessment, inventory and long-term 

monitoring, scientific/biological research and conservation restoration. 

These operations will be subject to strict operating requirements defined in the 

eBee Extended User Manual (see Appendix G) (MSAI requests the FAA treat the 

eBee Handbook 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 Aeronautics (see Appendix B), in order to ensure at least an 

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

1 
The eBee will be operated by an individual who fulfills the following requirements: 

• Has successfully passed a factory UAS training program; 

• Has a Private Pilot license; 

1. CHARACTERISTICS OF THE AIRCRAFT 

The eBee is a small (38 inch wingspan) and ultra-light (maximum take-off weight of 

1.5 pounds), platform made of flexible foam that performs pre-programmed 

precision aerial mapping missions thanks to 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. The eBee's embedded 

camera, protected by a foam envelope, 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 Joules in case of a controlled emergency landing), also significantly 

reduces the risk of hazardous situations. 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, and therefore inherently low-risk for fire hazards. A 

brushless engine technology makes it silent and reliable. The propeller is attached 

to the rear of the aircraft with a rubber band to the body of the plane so that is 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 to continuously update and confirm all aspects of the flight under the 

supervision of the Pilot in Command (PIC). 

d. Option for Manual control 

Additionally, the eBee provides an override capability that allows the PIC 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 

2 
aircraft should it become necessary to respond to emergent circumstances, utilizing 

the remote controller provided with the system. 

2. APPLICATIONS 

The aircraft will be utilized for gathering scientific data (biological, ecological, 

environmental, and land assessment) for forestry management, biological research 

and restoration, and education-related studies and projects. 

Those data will be used for creating highly accurate maps and geo-rectified 

orthophotographs. In addition, the aircraft will allow gathering of scientific data in 

areas where access to the terrain is difficult or dangerous, thus increasing the safety 

of the scientists and professionals. 

Additionally, the use of the eBee will negate the need for conventional manned 

helicopters in many situations, thus, reducing risk to pilot and passenger of the 

helicopter, and personnel on the ground. The use of UAV will also reduce the need 

for conventional aircraft in gathering photogrammetric data, thus improving public 

safety. The use of UAV will also reduce the amount of greenhouse gas emissions 

from conventional aircraft for jobs that now can be performed with battery 

operated UAV equipment, a benefit to public health and safety. 

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

a. Airworthiness assessment of the eBee 

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: 1/newscenter.nmsu.edu/Articles /view /10 208/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, 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) 

3 
• Denmark (flight approval for VLOS operations) 

MSAI believes that Sense Fly has shown compliance with the requirements of Order 

8130.34C, Airworthiness Certification of Unmanned Aircraft Systems and Optionally 

Piloted Aircraft, in its pending SAC application for the eBee. The criteria set forth in 

the Order specify the substantive showings of the device's safety and fitness for 

operation to ensure that the FAA has sufficient basis to evaluate the aircraft's safety. 

MSAI submits that completion of the SAC process for the eBee provides assurance of 

the public safety for the aircraft type. 

b. Operating Requirements 

Grant of the exemption to MSAI 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 Appendix B). The main restrictions are summarized below: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Operations to be conducted over private or public controlled-access 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. Use of an ADS-B receiver by the VO will 

assist in monitoring the presence of other proximal aircraft; 

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. 

c. Operator Requirements 

The eBee Pilot in Command (PIC) will have a Private Pilot license. The PIC and 

Visual Observer (VO) will meet the requirements outlined in FAA Policy N 8900.227 

Section 16 Personnel Qualifications. Additionally, the PIC and VO will perform 

4 
maintenance on the system and will complete a course of maintenance instruction 

as part of their initial training. Due to the simplicity of the system, we do not 

anticipate the need for a supplemental pilot in the field. 

3. CONCLUSION 

We submit that the combination of the aircrafts' light weight, historically 

demonstrated flight performance, fully qualified flight crew and strict operation 

under the guidelines established in 8900.227, the FAA can have confidence that the 

operation will have an equivalent or greater level of safety of manned aircraft 

performing the same mission. 

The name and contact information of the applicant are: 

Mount Shasta Aerial Imagery 

Attn: Ian Fitton 

6224 Hill Street 

Dunsmuir, CA 96025 

Phone: 530-859-1411 

Email: ianweissfitton@gmail.com 

Respectfully Submitted, 

Ian Weiss 

~~ Fitton, Commercial Rotorcraft Pilot, CFI 

President 

Mount Shasta Aerial Imagery 

Appendices 

A Exemption Request and Equivalent Level of Safety 

B. Academy of Model Aeronautics Safety Requirements 

C. Privacy Issues 

D. Safety Case 

E. eBee Brochure 

F. Maintenance Procedures 

G. Extended User Manual 

H. Training Program 

I. Aviation Experience 

J. Justification of Airworthiness and Safety Assessment 

5 
APPENDIX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

MSAI 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 

This part establishes the procedures for the issuance of an airworthiness certificate. 

While the FAA continues to work to develop airworthiness standards for UAS, we 

request an experimental certificate be issued for the eBee under either or both of 

the following provisions: 

21.191 Experimental certificates. 

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, 

new aircraft equipment, new aircraft installations, new aircraft 

operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests 

and other operations to show compliance with the airworthiness 

regulations including flights to show compliance for issuance of type 

and supplemental type certificates, flights to substantiate major 

design changes, and flights to show compliance with the function and 

reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as 

market surveys, sales demonstrations, and customer crew training, we would expect 

that an experimental certificate would permit our commercial purpose as well. 

The aircraft will not carry persons or property, will not carry fuel, and will only fly 

under strict operational requirements. Combined with the fact that the aircraft are 

lightweight, we propose that the eBee will be at least as safe, if not safer, than a 

conventionally certificated aircraft performing the same mission. 

If an experimental airworthiness certificate is not appropriate for this application, 

then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement 

for an airworthiness certificate in general, citing the equivalent level of safety 

outlined in the previous paragraph. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration 

number assigned to the aircraft and a registration certificate must be aboard the 

aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate 

be "displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew." The eBee are too small to carry documentation, do not have an entrance, and 

are not capable of carrying passengers or crew. 

6 
To obtain an equivalent level of safety and meet the intent of 91.203, we propose 

that documents deemed appropriate for these aircraft by the FAA will be co-located 

with the crew at the ground control station and available for inspection upon 

request. In order to identify the aircraft, we propose that the information found on 

airworthiness and registration certificates be permanently affixed to the aircraft via 

placard: 

Manufacturer: SenseFly 

Model: "eBee" 

Serial Number: 15-XXXX 

Registered to: 

Mount Shasta Aerial Imagery 

6224 Hill Street 

Dunsmuir, CA 96025 

If found please contact: (530) 859-1411. 

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 38 inches, 1.5 pounds), this requirement is 

impossible to match. We feel that the permanent placard discussed in the previous 

paragraph will provide the aircraft's registration information should it be found on 

the ground. We will also display at the ground station a high contrast flag or banner 

that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high 

or greater. 

Since the aircraft will operate within 1/2 NM of the ground station, the banner 

should be visible to anyone that observes the aircraft and chooses to investigate its 

point of origin. 

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. An equivalent level of safety will be achieved by insuring 

compliance with the eBee Pilot Operating Handbook (flight manual) prior to each 

flight. 

14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard 

requirements. 

7 
This regulation provides that no person may operate an aircraft unless a current, 

approved flight manual is in the aircraft. MSAI assumes that the intent of this 

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

while operating the aircraft. MSAI requests an exemption to this requirement since 

the aircraft is not only too small to carry documentation, that the documentation 

would not be available to the crew. 

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a 

current, approved Extended Users Manual (Appendix G) must be available to the 

crew at the ground station anytime the aircraft is in, or preparing for, flight. 

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." 

The eBee ground control stations are based on a small hand-held computer and 

while they do not offer a second set of "controls", both the student and instructor 

can, and will, operate the single set of controls simultaneously. Both the eBee can be 

controlled from a ground station tablet or from the transmitter so, in essence, they 

have dual control capability and redundancy. 

With both student and instructor having "hands-on" the controls during flight, we 

feel that this technique meets the intent 91.109 and provides an equivalent level of 

safety. 

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 

property with the permission of the landowner( s) or public agencies. The operator 

will define before every flight a working area radius and a flight area ceiling, 

preventing the eBee from going 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 it 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. 

8 
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. 

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. 

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, MSAI believes that an equivalent level of 

safety is already achieved with the specific procedure preventing the eBee from 

accepting a take-off order if the battery level is below a given value. The Pilot in 

Command will monitor the battery levels of the eBee during flight and return the 

aircraft to home when battery levels reach 25 to 30 percent capacity. Moreover, 

Sense Fly has integrated "low" and "critical" battery level warnings into controllers 

operated for these aircraft, and implemented automatic "Return 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. 

9 
The eBee weighs only 1.5 pounds (maximum 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, MSAI 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. 

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 Part 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. 

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

owner/operator according to the maintenance manual, provided by SenseFly. MSAI 

requests the FAA treat the eBee training programs as proprietary under 14 C.F.R. 

11.35(b) and not include these documents in the public docket. 

An equivalent level of safety will be achieved because the eBee is small in size, is not 

a complex mechanical device, and 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. 

10 
APPENDIX B: ACADEMY OF MODEL AERONAUTICS SAFETY REQUIREMENTS 

11 
Academy of Model Aeronautics National Model Aircraft Safety Code 

Effective January 1, 2014 

A. GENERAL: A model aircraft is a non-human-carrying aircraft capable of sustained flight in the atmosphere. It may not exceed limitations of this code and is 

intended exclusively for sport, recreation, education and/or competition. All model flights must be conducted in accordance with this safety code and any 

additional rules specific to the flying site. 

1. Model aircraft will not be flown: 

(a) In a careless or reckless manner. 

(b) At a location where model aircraft activities are prohibited. 

2. Model aircraft pilots will: 

(a) Yield the right of way to all human-carrying aircraft. 

(b) See and avoid all aircraft and a spotter must be used when appropriate. (AMA Document #540-D.) 

(c) Not fly higher than approximately 400 feet above ground level within three (3) miles of an airport without notifying the airport operator. 

(d) Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed use agreement. 

(e) Not exceed a takeoff weight, including fuel, of 55 pounds unless in compliance with the AMA Large Model Airplane program. (AMA Document 520-A.) 

(n Ensure the aircraft is identified with the name and address or AMA number of the owner on the inside or affixed to the outside of the model aircraft. (This 

does not apply to model aircraft flown indoors.) 

(g) Not operate aircraft with metal-blade propellers or with gaseous boosts except for helicopters operated under the provisions of AMA Document #555. 

(h) Not operate model aircraft while under the influence of alcohol or while using any drug that could adversely affect the pilot's ability to safely control the 

model. 

(i) Not operate model aircraft carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a 

hazard to persons or property. 

Exceptions: 

• Free Flight fuses or devices that burn producing smoke and are securely attached to the model aircraft during flight. 

• Rocket motors (using solid propellant) up to a G-series size may be used provided they remain attached to the model during flight. Model rockets may 

be flown in accordance with the National Model Rocketry Safety Code but may not be launched from model aircraft. 

• Officially designated AMA Air Show Teams (AST) are authorized to use devices and practices as defined within the Team AMA Program Document. 

(AMA Document #718.) 

0) Not operate a turbine-powered aircraft, unless in compliance with the AMA turbine regulations. (AMA Document #510-A.) 

3. Model aircraft will not be flown in AMA sanctioned events, air shows or model demonstrations unless: 

(a) The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event. 

(b) An inexperienced pilot is assisted by an experienced pilot. 

4. When and where required by rule, helmets must be properly worn and fastened. They must be OSHA, DOT, ANSI, SNELL or NOCSAE approved or comply 

with comparable standards. 

B. RADIO CONTROL (RC} 

1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others. 

2. A successful radio equipment ground-range check in accordance with manufacturer's recommendations will be completed before the first flight of a new or 

repaired model aircraft. 

3. At all flying sites a safety line(s) must be established in front of which all flying takes place. (AMA Document #706.) 

(a) Only personnel associated with flying the model aircraft are allowed at or in front of the safety line. 

(b) At air shows or demonstrations, a straight safety line must be established. 

(c) An area away from the safety line must be maintained for spectators. 

(d) Intentional flying behind the safety line is prohibited. 

4. RC model aircraft must use the radio-control frequencies currently allowed by the Federal Communications Commission (FCC). Only individuals properly 

licensed by the FCC are authorized to operate equipment on Amateur Band frequencies. 

5. RC model aircraft will not knowingly operate within three (3) miles of any pre-existing flying site without a frequency-management agreement. (AMA 

Documents #922 and #923.) 

6. With the exception of events flown under official AMA Competition Regulations, excluding takeoff and landing, no powered model may be flown outdoors 

closer than 25 feet to any individual, except for the pilot and the pilot's helper(s) located at the flightline. 

7. Under no circumstances may a pilot or other person touch an outdoor model aircraft in flight while it is still under power, except to divert it from striking an 

individual. 

8. RC night flying requires a lighting system providing the pilot with a clear view of the model's attitude and orientation at all times. Hand-held illumination 

systems are inadequate for night flying operations. 

9. The pilot of an RC model aircraft shall: 

(a) Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot. 

(b) Fly using the assistance of a camera or First-Person View (FPV) only in accordance with the procedures outlined in AMA Document #550. 

(c) Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document #560. 

C. FREE FLIGHT 

1. Must be at least 100 feet downwind of spectators and automobile parking when the model aircraft is launched. 

2. Launch area must be clear of all individuals except mechanics, officials, and other fliers. 

3. An effective device will be used to extinguish any fuse on the model aircraft after the fuse has completed its function. 

D. CONTROL LINE 

1. The complete control system (including the safety thong where applicable) must have an inspection and pull test prior to flying. 

2. The pull test will be in accordance with the current Competition Regulations for the applicable model aircraft category. 

3. Model aircraft not fitting a specific category shall use those pull-test requirements as indicated for Control Line Precision Aerobatics. 

4. The flying area must be clear of all utility wires or poles and a model aircraft will not be flown closer than 50 feet to any above-ground electric utility lines. 

5. The flying area must be clear of all nonessential participants and spectators before the engine is started. 
Academy of Model Aeronautics 

5161 East Memorial Drive Muncie, Indiana 47302 

(800) 435-9262- Membership Services 

www.modelaircraft.org 

11SEE AND AVOID11 GUIDANCE 

A. General: 

•• 

At.~ ACADEMY OF 

MODEL AERONAUTICS 

1. The primary means to avoid collisions between all aircraft flying within our National Airspace System 

(NAS) is 11See and Avoid." 

2. Vigilance must be maintained by each person operating an aircraft (whether model or manned) so as to 

"see and avoid" other aircraft. 

3. Model aircraft must avoid manned aircraft. Our privilege to fly model aircraft in the NAS depends on our 

commitment to remain "well clear" of manned aircraft. 

4. Simply avoiding an actual collision is not enough. A "near miss" is not acceptable. 

5. Unless flying at a mixed-use site where manned and model aircraft routinely share airspace through 

their own site-specific rules, model aircraft must fly sufficiently far away from manned aircraft so as not to 

create a collision hazard. 

6. Model aircraft flying must not only be safe, it must be perceived to be safe by the greater manned 

aviation community. Modelers must continually demonstrate their respect for the safety of manned 

aircraft by remaining vigilant and well clear. 

7. Whenever a potential conflict arises between model aircraft and manned aircraft, the pilot of the model 

aircraft must always give way to the manned aircraft. 

8. The pilot of a model aircraft must never assume the pilot of a manned aircraft can see the= model or will 

perform any maneuver to avoid the model's flight path. 

9. Visual Line of Sight is required by the Safety Code. It means that visual contact with the aircraft must be 

maintained without enhancement other than by corrective lenses prescribed for the model aircraft pilot. 

All RC flying must remain clear of clouds smoke or any other obstruction to the line of sight. 

10. "Blue Sky" is a term used to explain the method used to increase separation between a model and a 

manned aircraft in the same vicinity. The modeler should maneuver the aircraft in such a way as to 

increase the amount of blue sky perceived between the model and the manned aircraft. By increasing the 

blue sky separation, the question about depth perception is taken out of the equation and the modeler 

need not worry whether the model is closer to him than the manned aircraft or further away. Increasing 

the blue sky between the model and the manned aircraft automatically increases separation between 

them. 

Academy of Model Aeronautics 5161 East Memorial Drive Muncie, Indiana 47302 

(800) 435-9262 I Membership Services I www.modelaircraft.org 
Academy of Model Aeronautics 

5161 East Memorial Drive Muncie, Indiana 47302 

(800) 435-9262- Membership Services 

www.modelaircraft.org 

•• 

Ail~~ A: 

ACADEMY OF 

MODEL AERONAUTICS 

11. A modeler should never place any consideration for the well-being of the model aircraft above the 

safety of manned aircraft. Maneuvering to avoid the conflict may require that the model aircraft be 

sacrificed. 

12. Free flight models should not be launched with relatively low altitude manned 

aircraft in sight and downwind or headed downwind from the launch site. 

B. Spotters: 

1. Before a flight, the pilot must insure that the spotter understands his/her duties 

and expectations. 

2. A spotter should be used to assist in monitoring the surrounding airspace for manned aircraft whenever 

a flight is expected to exceed 400 feet above the ground and that operation is expected to be in proximity 

to known manned aircraft traffic such as at a mixed-use facility or within three miles of an airport. The 

spotter must have sufficient visual acuity and be mature enough to take this responsibility very seriously. 

3. A spotter should also be prepared to assist his/her pilot in the event that another model aircraft or 

spectators become endangered or in turn are perceived to be a danger to the pilot or the pilot's model 

aircraft. 

4. If a model aircraft pilot experiences what he or she considers a near miss with a manned aircraft, that 

model aircraft pilot should notify AMA Headquarters with a written report of the incident, including action 

taken by the model aircraft pilot to avoid the manned aircraft. This report is intended to help the modeler, 

the club, and the AMA capture as much detail as possible so that it may be used to assist all parties in 

recalling the particulars of the incident at a later time. Call1-800-435-9262 (1-800-IFLYAMA) extension 230 

or 251 for assistance with this report. 

Academy of Model Aeronautics 5161 East Memorial Drive Muncie, Indiana 47302 

(800) 435-9262 1 Membership Services 1 www.modelaircraft.org 
'\ A~.6: 1 

SINCE 1936 

Academy of Model Aeronautics 

AMA Advanced Flight Systems Committee 

amaflightsystems@gmail.com 

AMA Document# 560 

Radio Controlled Model Aircraft Operation 

Utilizing Failsafe, Stabilization and Autopilot Systems 

1. DEFINITION OF TERMS: 

Please refer to Page 3, section 7 which contains an alphabetical listing of the definitions of the 

terms in italics that are used in this document. 

2. GENERAL: 

All model aircraft flights utilizing stabilization and autopilot control systems must be conducted 

in accordance with AMA's current National Model Aircraft Safety Code and any additional rules 

specific to a flying site/location. 

3. OPERATIONS- REQUIREMENTS- LIMITATIONS: 

a) AMA members flying radio controlled model aircraft equipped with flight stabilization and 

autopilot systems must maintain VLOS with the aircraft at all times including programmed 

autopilot waypoint flight. 

b) AMA Pilots must be able to instantaneously deactivate programmed flight of autopilot 

systems at any time during flight and resume manual control of the model aircraft. 

c) AMA Pilots must perform an RIC Test Flight of a model aircraft before activating a newly 

installed autopilot or stabilization system and/or after any repairs or replacement of model 

aircraft essential flight systems. 

d) Model aircraft exceeding 151bs and/or ?Om ph may only use an autopilot for a programmed 

"return to launch" (RTL) flight and not for programmed waypoint flying of a predetermined 

course. 

e) STABILIZATION & AUTOPILOT SYSTEMS MAY BE USED FOR/TO: 

• Stabilization/automatically stabilize aircraft to level flight when control sticks are centered. 

• Recovery/activate TRX switch to recover an out of control aircraft to level flight. 

• Heading/activate TRX switch to hold a model aircraft's heading for precision flight path. 

• Altitude/activate TRX switch to maintain fixed aircraft altitude while allowing directional control. 

• Return GPS/activate TRX switch to return aircraft via GPS to launch point. 

• Return FSS/failsafe activated from radio signal loss to return aircraft via GPS to launch point. 

• Fixed circle/activate TRX switch to circle aircraft at point of activation at fixed altitude. 

• Waypoint/activate TRX switch to initiate an autopilot programmed flight path via waypoints. 

• Fencing/autopilot programed to display site unique boundaries on video monitor/goggles. 

PAGE 1 OF 3 (Revision 01/14/2013) 
4. RANGE - ALTITUDE -WEIGHT- SPEED: 

a) One of the requirements in Federal Law (Public Law 112-95 Sec 336 (c) (2) February 14, 

2012) for model aircraft to be excluded from FAA regulations is that model aircraft be 

flown within VLOS of the operator. 

b) Model aircraft must be flown at or below 400 feet AGL when within 3 miles of an airport as 

stated in the AMA Safety Code. 

c) Model aircraft utilizing an autopilot for waypoint flying are limited to a maximum weight 

(including fuel, batteries, and onboard autopilot systems) of 151bs and a speed of 

70mph. 

5. RECOMMENDATIONS & INFORMATION: 

a) If your radio system lacks failsafe capability, consider using programmable digital servos or 

auxiliary failsafe modules. In the event of a radio signal failure these components will 

activate desired safe servo settings or an autopilot for return to base/launch (RTL). 

b) When using an autopilot system the "return to launch" (RTL) feature should be 

programmed to return the aircraft to a safe location and safely terminate the flight should 

manual control of the aircraft be lost. When using RTL, pay particular attention to the 

manufacturer's throttle recommendations to prevent stalling. 

c) The use of stabilization systems is recommended when flying FPV to improve flight 

stability and video quality. 

d) Pilots usually choose to incorporate stabilization and autopilot systems for model aircraft 

flying to enhance flight performance, correct bad tendencies of the model aircraft, 

maintain stability in windy weather, establish precision heading holds for 

takeoffs/landings, flight training for novice pilots, create a steady flight platform for 

cameras, and generally just to make an airplane easier and safer to fly. 

e) When purchasing stabilization and autopilot systems, always try to select quality equipment 

from reputable dealers, ensure for compatibility with other onboard systems, and install 

components according to manufacturers' instructions. 

6. PRIVACY PROTECTION SAFEGUARDS: 

The use of imaging technology for aerial surveillance with radio control model aircraft 

having the capability of obtaining high-resolution photographs and/or video, or using any 

types of sensors, for the collection, retention, or dissemination of surveillance data or 

information on individuals, homes, businesses, or property at locations where there is 

a reasonable expectation of privacy is strictly prohibited by the AMA unless written 

expressed permission is obtained from the individual property owners or managers. 

PAGE2 OF 3 (Revision 01/14/2013) 
7. DEFINITIONS OF TERMS: 

AMA Pilot is an AMA member who is capable of manually operating an R/C transmitter to 

control a model aircraft's flight path within its safe intended flight envelope without losing 

control or having a collision. 

Autopilot Systems incorporate programmable flight stabilization with an altitude sensor and 

a GPS receiver for accurate positioning and to navigate/control a radio controlled model 

aircraft's flight path. Advanced systems offer software for entering navigable waypoints. The 

flight data waypoints may be saved to autopilot's/GPS memory for programmed flight. 

Essential Flight Systems are any systems or components necessary to maintain 

stable flight within a model aircraft's flight envelope. (This includes primary R/C systems 

and any stabilization or gyros required to maintain stability and heading in certain 

types of model aircraft that would be uncontrollable/unstable without their use). 

Failsafe Systems are designed to minimize or prevent damage and safely terminate a 

flight when a radio controlled model aircraft loses radio signal. Modern radio systems can 

be programmed to position servos to a desired control setting in the event of radio signal 

failure. 

First Person View (FPV) refers to the operation of a radio controlled (R/C) model aircraft 

using an onboard camera's cockpit view to orient and control the aircraft. (AMA Document 

#550). 

Flight Envelope is defined as the range of airspeeds, attitudes and flight maneuvers which 

a model aircraft can safely perform/operate for its intended use. 

Non-Essential Flight Systems are any systems or components that are not necessary to 

maintain stable flight within the model aircraft's intended flight envelope. (This includes 

autopilot or stabilization systems that can be activated and deactivated in flight by the pilot 

without affecting manually controlled stable flight). 

RIC Test Flight requires an AMA Pilot to manually operate an R/C transmitter to control 

a model aircraft's flight path and determine if the aircraft is capable of maintaining stable 

flight within its safe intended flight envelope. 

Stabilization Systems are designed to maintain intended model aircraft flight attitudes. 

The pilot can install, program and/or activate a system to stabilize yaw, pitch, or roll or any 

one attitude or combination of attitudes. Systems are often based on rate/heading hold 

gyros or inertial motion sensors utilizing multi-axis gyros and accelerometers for 

attitude stabilization. 

Visual Line of Sight (VLOS) is the distance at which the pilot is able to maintain visual 

contact with the aircraft and determine its orientation and attitude without enhancements 

other than corrective lenses. 

PAGE 3 OF 3 (Revision 07 /20/2013) 
APPENDIX C: PRIVACY ISSUES 

The eBee is proposed to be flown over sterile, unpopulated to lightly populated 

areas. In addition, we propose to obtain landowner permission to fly over 

properties as part of our services and to notify and obtain waivers of consent from 

non-landowners over which we will be flying. Finally, most of our flights will be 300 

to 400 feet above ground surface, making visual recognition of people on the ground 

difficult. Because of the sterile environment and the prenotification of landowners 

and personnel on the ground, privacy compromises due to MSAI activities are 

anticipated to be alleviated. Under no circumstances will MSAI's aircraft be utilized 

to purposefully invade the privacy of peoples or properties in areas within our 

studies or outside of our study boundaries. 

12 
APPENDIX D: SAFETY CASE 

Safety of our flight crew, other aircraft, people on the ground, and public and private 

properties is of utmost importance to MSAI. MSAI's Pilot in Command (PIC) will be 

responsible for all safety procedures and protocols while on the ground. The Visual 

Observer (VO) will assist the PIC in maintaining safety procedures throughout the 

course of a project. Safety procedures to be utilized in the field include the 

following: 

• A full diagnostic check of the aircraft by the PIC and VO using a pre-flight 

checklist will be performed on the ground prior to commencement of each 

project; 

• High visibility (day-glow orange or green) will be worn by the flight crew 

during each project. In addition, at the ground station, a high contrast flag or 

banner that contains the words "Unmanned Aircraft Ground Station" will be 

placed prior to any flights; 

• Operations to be conducted over private or public controlled-access property 

where approved; 

• Permission from the land owner/authority required before commencing any 

flight; 

• Operations over congested areas shall be avoided; 

• Operations will not interfere with manned aircraft operations, will yield the 

right of way to manned aircraft, and operators must See & Avoid other 

aircraft and obstacles at all times. Use of an ADS-B receiver by the VO will 

assist in monitoring the presence of other proximal aircraft; 

• Operations limited to Visual Flight Rules Meteorological Conditions (VMC) 

and daylight hours; 

• Aircraft operations will remain within Visual Line of Sight (VLOS) and will be 

visually monitored at all times; 

• Use of a high-definition first-person view from the aircraft will assist the PIC 

and VO identify potential flight conflicts and terminate or alter the preprogrammed flight plan; 

• 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 will comply with required permissions and permits 

established by territorial, state, county or city jurisdictions; including local 

law enforcement, fire, or other appropriate governmental agencies; 

• Post-flight inspection of the aircraft will be performed by the PIC and VO 

utilizing a postflight checklist; 

• The eBee operations will be compliant with existing safety procedures 

inherent to the activities of the related company. 

13 
APPENDIX E. EBEE BROCHURE 

14 
~eBee ---senseFiy 

4 reasons to 

choose 

the eBee 

01. Map more, more accurately 

The eBee can cover up to 12 sq. km (4.6 sq. mi) in a single flight, while 

flights over smaller areas, flown at lower altitude, can acquire images with 

a Ground Sampling Distance (GSD) of down to 1.5 em per pixel. 

02. No flying skills required 

The eBee is the easiest to use mini drone on the market. To launch, just 

throw it into the air! It then flies, captures images and lands itself. (However 

you can reprogram its flight or land the drone manually if required.) 

03. Because safety matters 

The eBee uses a rear-mounted propeller and due to its flexible foam 

construction it weighs 700 g (1.5 lbs), minimising its impact energy. 

04.1t's all you need 

The eBee is supplied with a sturdy carry case and two advanced software 

packages: eMotion (flight planning and control) and Postflight Terra 30 

(professional photogrammetry). 
eMotion 

-----senseFiy 
01. Plan your flight 

senseFiy's intuitive eMotion software makes 

it easy to plan and simulate your mapping 

mission. 

Plan: Import your preferred base map and 

define the area you want to cover. Then 

specify your required ground resolution, with 

a GSD of down to 1.5 em, and image overlap. 

eMotion automatically generates a full flight 

plan, calculating the eBee's required altitude 

and displaying its projected trajectory. 

Flying over uneven terrain? Use eMotion's 3D 

mission planning feature to take elevation 

data into account when setting the altitude 

of waypoints and the resulting flight linesimproving ground resolution and increasing 

safety. 

Simulate: To ensure your mission's success, 

run a virtual flight that simulates wind 

strength and direction. Then make any flight 

plan updates required and prepare to launch. 


Oblique imaging function Multiple drone operation 

~" '« ,. ~ ' ;~o~, 

Onboard artificial intelligence 

·Analyses data from Inertial Measurement 

Unit & onboard GPS 

·Optimises every aspect of eBee's flight 

Super lightweight 

·Durable EPP foam body & wings 

·Take-off weight 0.69 kg (1.52 lbs) 
16 MP still camera 

·Controlled by eBee's autopilot 

·Captures images automatically 

·Images transformed into 20 orthomosaics 

& 3D models with absolute horizontal/ 

vertical accuracy of down to 3 em I 5 em 

per pixel 

Green technology 

·Brush less electric motor 

·Low noise, low pollution 

·Re-chargeable lithium-polymer 

battery 

Fully automated 

·Create your flight plan 

·Throw eBee into the air 

·Flies, acquires images & lands itself 

2.4GHz radio link 

·Communicates with eMotion 

flight planning software via the USB 

ground modem 

Optimised range 

·Up to 50 min flight time 

·For coverage of up 12 km2 (4.6 mi2

) 

03. Create 

Process: Use the eBee's supplied Postflight 

Terra 30 software to easily process your 

flight's photos. 

In just a few clicks you can transform 

this imagery into geo-referenced 20 

orthomosaics, 30 point clouds, triangle 

models and Digital Elevation Models (DEMs). 

Trust: With the eBee's GSD of down to 1.5 

em, relative orthomosaic/30 model accuracy 

of l-3x GSO, and absolute horizontal/vertical 

accuracy of down to 3/5 em, you can have 

full confidence in the accuracy of the outputs 

you produce. 

Choose your accessory ---~--~ -~-~~~~~~ 

The eBee is supplied, as standard, with 

a 16 MB RGB camera. However two 

additional cameras are also available 

(always usable one at a time), plus a handy 

radio tracker for missions undertaken in 

the most challenging environments. 

IXUS/ELPH RGB Supplied 

Like all eBee cameras, this 16MB model has been adapted 

so that it can be controlled by the drone's autopilot. It 

acquires regular image data in the visible spectrum and its 

exposure parameters are set automatically. 

5110 RGB 

The 12 MB S 110 RGB acquires regular image data in the 

visible spectrum. However unlike the slightly higher 

resolution IXUS/ELPH, its exposure parameters can be set 

manually and it can also output RAW format image files. 

thermoMAP 

thermoMAP enables the eBee to capture thermal video and 

still images, allowing you to create full thermal maps of a 

site (for example, to assess a mine's water distribution or 

check the functionality of solar panels). 

Radio tracker 

If you are planning to fly your eBee in extreme situations, 

such as those with high winds, in mountainous areas, out of 

line of sight, or over very large areas, this accessory is a useful 

final safeguard against unexpected aircraft loss. It comprises 

a small transmitter that fits snugly next to the eBee's battery 

bay, plus a portable handheld receiver. 
Technical specifications 

Hardware 

Weight (inc. supplied camera) 

Wingspan 

Material 

Propulsion 

Battery 

Camera (supplied) 

Cameras (optional) 

Carry case dimensions 

Approx. 0.69 kg (1.52 lbs) 

96 em (38 in) 

, EPP foam, carbon structure & composite parts 

Electric pusher propeller, 160 W brush less DC motor 

11.1 V, 21 50 mAh 

16 MP IXUS/ELPH 

S 11 0 RGB, thermoMAP 

55 X 45 X 25 em (21.6 X 17.7 X 9.8 in) 

Operation 

Maximum flight time 

Nominal cruise speed 

Radio link range 

Maximum coverage (single flight) 

Wind resistance 

Ground Sampling Distance (GSD) 

Relative orthomosaic/3D model accuracy 

Absolute horizontal/vertical accuracy (w/GCPs) 

Absolute horizontal/vertical accuracy (no GCPs) 

Multi-drone operation 

Automatic 3D flight planning 

Linear landing accuracy 

50 minutes 

40-90 km/h (11-25 m/s or 25-56 mph) 

Up to 3 km (1.86 miles) 

12 km2 14.6 mi2 (at 974 m I 3,195 ft altitude AGL) 

Up to 45 km/h (12m/s or 28 mph) 

Down to 1.5 em (0.6 in) per pixel 

1-3x GSD 

Down to 3 em (1.2 in) I 5 em (2 in) 

1-5 m (3.3-16.4 ft) 

Yes (inc. mid-air collision avoidance) 

Yes 

Approx. 5 m (16.4 ft) 

Package contents 

eBee foam body (inc. all electronics & built-in autopilot) 

Pair of detachable wings 

16 MP IXUS/ELPH still camera (inc. 16GB SD card, battery, USB 

cable & charger) 

• 2.4 GHz USB radio modem for data link (inc. USB cable) 

Two Lithium-Polymer battery packs & charger 

Spare propeller 

• Carry case with foam protection 

• Remote control & accessories (for safety pilots) 

User manual 

• Software included: eMotion (flight planning & control) & 

PostflightTerra 3D (professional photogrammetry) 
\-VsenseFiy 

a Parrot company 

www.sensefly.com 

Where can you buy your eBee? Visit www.sensefiy.com/about/where-to-buy to locate your 

nearest distributor. 

senseFiy Ltd 

Route de Geneve 38 

1033 Cheseaux-Lausanne 

Switzerland 

C Swiss made 

About senseFiy: senseFiy designs, assembles and markets autonomous mini-drones and 

related software solutions for civil professional applications such as precision agriculture, land 

surveying, GIS, construction, environmental conservation and more. 

Content and images non contractual© 2014 senseFiy Ltd 

APPENDIX F: MAINTENANCE PROCEDURES 

For the use of the eBee, MSAI will follow SenseFly's eBee Maintenance Procedures 

Manual enclosed in this Appendix. In addition, MSAI's general maintenance 

procedures for our UAS aircraft are as follows: 

WING CARE 

• 

• 

Wings must be checked each flight for nicks or cracks 

Wings are designed to last indefinitely if they do not impact dust, dirt or 

more. 

PROPELLER AND MOTOR INSPECTION 

• The motor will be inspected for dirt and debris and manually spun before 

and after every flight. 

• The propeller will be examined for cracks and dings before and after every 

flight. 

• The propeller fasteners and attachments will be checked for security and any 

damages before and after every flight. 

BATTERY CARE AND USE 

Refer to instruction sheet included from the battery manufacturer. Typical 

information follows: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Batteries are highly flammable and can explode, especially when fully 

charged. 

Improper charging, vibration, impact, high discharge, etc. can lead to 

explosion and fire. Batteries must be charged under constant supervision and 

using proper precautions. 

Batteries fully charged must be handled with extreme care . 

Any battery that puffs up is considered damaged and must not be used. It is 

in a dangerous state. Never charge a puffed up battery. 

Any battery which holds less than 80% of its rated capacity should be 

discarded. 

Cycle test each battery after every 50 cycles or if a battery is suspected to 

have lost as significant amount of its capacity to determine the current 

capacity. 

Properly dispose of batteries. First discharge the battery fully using a battery 

cycler. 

Bring to a recycler such as a home improvement store . 

Always charge flight batteries under "balance" mode . 

Flight Battery Recommended Charge Rate: 1 C which takes approximately 1 

hour to charge 

Flight Battery Maximum Charge Rate: May exceed SC. Charge rates higher 

than 1 C will decrease life cycles. Maximum charge rating per the 

manufacturer will provide 

15 
• 300+ cycles. Use the lowest charge rate which is practical. 

• Battery Rest Time between discharging and charging: 30 minutes minimum, 

1 hour maximum. 

• Do not charge if the battery is more than zoe warmer than ambient, 

especially if the temperature is above zooc. The outer surface is cooler than 

the inner core after use. 

• Damage will occur when charging a warm battery. 

• Recommended Battery Discharge Amount: 80%. Using more of the capacity 

of the battery will decrease the life cycles 

• As battery temperature approaches freezing the capacity of Lithium Polymer 

batteries decrease. Keep warmer than soc before installing into the UV 

(unmanned vehicle). 

• Battery capacity decreases at higher discharge rates. Using more batteries 

decreases the discharge rate of each battery thereby extending individual 

battery capacity slightly. 

• Lower discharge rates improve the life cycles. 

• Batteries are rated at greater than 300 life cycles. 1,000+ life cycles are 

possible. 

• Batteries must not be stored above 60% charged state for extended periods. 

• Batteries should be stored below zsoc for extended periods 

• Store batteries between 40% - 60% charged state. Fully charge just before 

• 

use. 

Fully charged batteries which are not to be used within 24 hours should be 

discharged to 40% - 60% charged state using the battery discharger. 

• Using more than one battery at a time requires the proper wiring harness so 

that the voltage is no more than 25.2V. Over voltage will cause serious 

damage to electrical equipment. 

PREVENTATIVE MAINTENANCE 

ANNUAL INSPECTION (SUGGESTED) 

• 

• 

• 

• 

If the airframe has in excess of 3 00 hours in a one year period, an annual 

inspection must be completed by an approved technician. 

An approved technician should disassemble the UAV and inspect all 

components for wear and replace any components as required. 

Test all batteries for capacity . 

Upgrade firmware and software to latest revisions 

500 HOUR PM (SUGGESTED) 

• An approved technician should disassemble the UAV and inspect all 

components for wear and replace any components as required. 

• Replace all motors. 

• Test all batteries for capacity. 

• Upgrade firmware and software to latest revisions. 

16 
APPENDIX G: EXTENDED USER MANUAL 

The user manual for the SenseFly eBee is included in this appendix. 

17 
APPENDIXH: TRAINING PROGRAM 

MSAI's Chief Pilot Ian Fitton completed a UAS Factory Trained Individual Course 

with Troy Built Models (TBM) in June 2015 and received his certification. His 

training was performed on the DJI Phantom 2 Vision+ and the DJI S1000. The 

training course teaches the basics of safe operation for UAS. The director of flight 

training is Gene Payson. Payson is the Director of UAS Flight Training at Unmanned 

Vehicle University and owner of Troy Built Models. This certificate is from Troy 

Built Models. DJI-Innovations, the FAA, and other entities do not currently have 

certifications. The test was developed entirely by UAV Flight Schools. 

The training curriculum offered through TBM that our CP completed included: 

General UAV characteristics, types, uses 

Principals of Flight 

• Weight and Balance- Center of Gravity calculations and methods 

• Operational/imitations [vertical speed, horizontal speed, weight, horizontal 

distance, altitude, endurance, weather, etc.) 

• Subsystem Operation and Maintenance [Flight controller, IMU, GPS, Compass, 

Gyros, Accelerometers, Brushless motors, Speed controllers, Propeller, 

Retractable landing gear, Airframe, Video Transmission and Reception, 

Antennas, Video displays, etc.) 

Battery care 

Transponder operation 

Maintenance 

• Record Keeping, Logbooks, and other Documentation 

• Insurance Requirements 

• Remote sensing theory and practical application 

• Autopilot operation and Mission Planning 

Aircraft flight simulation 

• Federal, State, and Local laws, rules, regulations, policies, and good practice 

• Right of Way rules 

FAA Certificate of Authority (COA) process 

Pilot in Command [PIC) qualifications and responsibilities 

Observer qualifications and responsibilities 

Sensor Operator qualifications and responsibilities 

Recognizing and setting Early Warning Alarms/Signals 

• Emergency Procedures 

18 
• Integration with other aircraft in the national airspace 

• Reading a sectional map for aircraft 

• Preflight Checklist 

In flight Checklist 

• Post flight Checklist 

• Autonomous Flight 

• Preflight briefing 

Checklist reviews 

Flight 

• Certification Testing 

• How to start a UAV business 

• Typical income for UAV businesses 

• Typical charges for photography 

MSAI's CP Ian Fitton is UAS factory trained and will train future MSAI pilots. Ian 

Fitton is also a Certified Flight Instructor (see Appendix I). Training for the eBee will 

be performed in accordance with procedures from the TBM training and SenseFly 

distributer training, and in accordance with the attached eBee training manuals. 

MSAI 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. 

19 
APPENDIX I: AVIATION EXPERIENCE 

MSAI's Chief Pilot (CP), Ian Fitton, has a Private Pilot's Certification, Commercial 

Pilot's Certification, and is a Certified Flight Instructor. His relevant certifications 

are attached to this appendix. In addition, our CP is an experienced operator of the 

DJI Phantom 2 Vision+, and has logged hours on the Vision, S-1000 and eBee 

Sensefly. 

20 
UNITED STATES OF AMERICA 

Department of Transportation 

Federal Aviation Administration 

MEDICAL CERTIFICATE SECOND CLASS 

This certifies that (Full name and address): 

IAN Weiss FITTON 

6224 Hill Street 

Dunsmuir CA 96025 USA 
This is to certify that 

lan Fitton 

completed training with TBM on sUAS systems 

June 5, 2015 

President 
APPENDIX J. JUSTIFICATION OF AIRWORTHINESS AND SAFETY ASSESSMENT 

21