### November 12, 2015 U.S. Department ofTransportation Docket Operations M-30 West Building Ground Floor, Room w12-140 1200 New JerseyAve., SE Washington, DC 20590 Re: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe FederalAviation Regulations Dear Madam, Sir, Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14C.F.R. Part 11, Mount ShastaAerial Imagery ("MSAI"), an operator ofthe SenseFly eBee Unmanned Aircraft Systems (eBee) seeks an exemption from the FederalAviation Regulations ("FARs") listedbelow:

• 14 C.F.R. 21 • 14 C.F.R. 45.23 • 14 C.F.R 45.29 • 14 C.F.R. 61.133(a) • 14C.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 • 14C.F.R. 91.151(a) • 14 C.F.R. 91.203(a) & 

### (b) • 14CFR SubpartE (91.401- 91.417) MSAI is comprised ofcommercial 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 ofland mapping/surveying, land assessment, inventory and long-term monitoring, scientific/biological research and conservation restoration. These operations will be subjectto strict operatingrequirements defined in the eBee Extended User Manual (see Appendix G) (MSAI requests the FAA treatthe eBee Handbook as proprietaryunder 14 C.F.R. 11.35(b) and does not include this documentin the public docket) and conditions defined by the Safety Code ofthe Academy ofModel Aeronautics (see Appendix B), in orderto ensure atleast an equivalentlevel ofsafetyto currently authorized operations using manned aircrafts.

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### The eBee will be operatedby an individual who fulfills the following requirements: • Has successfully passed a factory UAS trainingprogram; • Has a Private Pilot license; 1. CHARACTERISTICS OF THE AIRCRAFT 

### The eBee is a small (38 inch wingspan) and ultra-light (maximum take-offweight of 1.5 pounds), platform made offlexible foam thatperforms pre-programmed precision aerial mapping missions thanks to on-board GPS and the related flight management software (eMotion) that allows the operatorto plan safely and efficiently a mission in 3D, and then monitor it in real-time. The eBee's embedded camera, protectedby a foam envelope, takes a collection ofhigh-definition still images that are used laterto generate maps and contourlines ofthe surveyed area. The four main characteristics ofthe eBee are:

a. Very light weight The eBee is so light thatthe operatorcan launch it byhand and let itland on almost any surface withoutrequiring a parachute orlanding net (belly land). Its low impact energy (38 Joules in case ofa controlled emergencylanding), also significantly reduces the risk ofhazardous situations. The wings ofthe eBee are detachable and made offlexible foam with no sharp orhard edges and almost no internal strengthening structure. b. Electric-powered The eBee is electric powered, and therefore inherentlylow-riskfor fire hazards. A brushless engine technology makes it silent and reliable. The propeller is attached to the rear ofthe aircraft with a rubberband to the body ofthe plane so thatis can easily flex away in case ofcontactwith any object.

c. Semi-automatic flight The artificial intelligence incorporatedwithin the eBee autopilot system continuouslyanalyzes data from the Inertial Measurement Unit and from the onboard GPS to continuouslyupdate and confirm all aspects ofthe flight under the supervision ofthe Pilot in Command (PIC). d. Option for Manual control Additionally, the eBee provides an override capabilitythat 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 andtake manual control ofthe

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### aircraft should it become necessaryto respond to emergent circumstances, utilizing the remote controller providedwith the system. 2. APPLICATIONS 

### The aircraftwill 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 aircraftwill allow gathering ofscientific data in areas where access to the terrain is difficult or dangerous, thus increasingthe safety ofthe scientists and professionals. Additionally, the use ofthe eBee will negate the need for conventional manned helicopters in many situations,thus, reducing risk to pilot and passenger ofthe helicopter, and personnel onthe ground. The use ofUAV will also reduce the need for conventional aircraftin gatheringphotogrammetric data, thus improvingpublic safety. The use ofUAV will also reduce the amount ofgreenhouse gas emissions from conventional aircraftfor jobs that now can be performedwith battery operated UAV equipment, a benefitto public health and safety. 3. APPLICABLE LEGAL STANDARD UNDER SECTION 333



### a. Airworthiness assessment ofthe eBee The airworthiness ofthe eBee has alreadybeen demonstrated for different projects in the United States, involving state/federal agencies oruniversities (among others the New Mexico State University: https: 1/newscenter.nmsu.edu/Articles/view/10208/nmsu-uas-flight-test-centerconducts-ebee-airworthiness-assessment, and the USACE New Orleans, who coordinated with the Department ofArmy and the FAA to obtain all authorizations required in orderto operatethe eBee UAS). Moreover, SenseFly obtained flight approvals for the eBee (delivered bynational civil aviation authorities) in many countries, among others:


### • 

### • • • • 

### • • • Switzerland (flight approval for VLOS operations) Canada (flight approval for VLOS operations) Australia (flight approval for VLOS operations) France (flight approval for Extended-VLOS operations) Germany (flight approval for VLOS operations) United Kingdom (flight approval for VLOS operations) Norway (flight approval for VLOS operations) Sweden (flight approval for VLOS operations)

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### • Denmark (flight approval for VLOS operations) MSAI believes that SenseFly has shown compliance with the requirements ofOrder 8130.34C, Airworthiness Certification ofUnmanned Aircraft Systems and Optionally Piloted Aircraft, in its pending SAC application for the eBee. The criteria setforth in the Order specify the substantive showings ofthe device's safety and fitness for operation to ensure thatthe FAA has sufficient basis to evaluate the aircraft's safety. MSAI submits that completion ofthe SAC process for the eBee provides assurance of the public safetyfor the aircraft type. b. Operating Requirements Grant ofthe exemptionto MSAI for the eBee will be subjectto the following operating conditions, based onthe operating conditions setforth bytheAcademy of Model Aeronautics (see Appendix B). The main restrictions are summarizedbelow:


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• • •

•



### • Operations to be conducted overprivate orpublic controlled-access property where approved; Permission from the land owner/authorityrequired before commencing any flight; Operations over congested areas shall be avoided; Operations must not interfere with manned aircraft operations, mustyield the right ofwayto manned aircraft, and operators must See & 

### Avoid other aircraft and obstacles atall times. Use ofan ADS-B receiverbythe VO will assist in monitoring the presence ofotherproximal aircraft; Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours; Aircraft operations mustremain within Visual Line ofSight (VLOS) and will be visuallymonitored at all times; VLOS guaranteedwith a GPS geo-fence around operator of0.5 miles; Flight ceiling pre-programed at 400 feet; All operations conducted within 5 miles from an airport shall only be initiated afterverbal coordination with the airport authority, or air traffic control when a control tower is present atthe airport; All operations shall complywith required permissions and permits established byterritorial, state, county or cityjurisdictions; including local law enforcement, fire, or other appropriate governmental agencies; The EBee operations will be compliantwith existing safetyprocedures inherentto the activities ofthe related company.

c. Operator Requirements The eBee Pilot in Command (PIC) will have a Private Pilot license. The PIC and Visual Observer (VO) will meetthe requirements outlined in FAA Policy N8900.227 Section 16 Personnel Qualifications. Additionally, the PIC andVO will perform

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### maintenance onthe system and will complete a course ofmaintenance instruction as part oftheir initial training. Due to the simplicity ofthe system, we do not anticipate the need for a supplemental pilot in the field. 3. CONCLUSION 

### We submitthatthe combination ofthe aircrafts' lightweight, historically demonstrated flight performance, fully qualified flight crewand strict operation under the guidelines established in 8900.227, the FAA can have confidence thatthe operationwill have an equivalent or greater level ofsafety ofmanned aircraft performingthe same mission. The name and contact information ofthe applicant are: Mount ShastaAerial 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 ShastaAerial Imagery Appendices A 

### Exemption Request and Equivalent Level ofSafety B. Academy ofModel 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 ofAirworthiness and SafetyAssessment



### 5APPENDIX 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 applyto the operation ofthe eBee: 14 C.F.R. Part21, Subpart H: Airworthiness Certificates 

### This partestablishes the procedures for the issuance ofan airworthiness certificate. While the FAA continues to workto develop airworthiness standards for UAS, we request an experimental certificate be issued for the eBee under either orboth of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a)

### Research anddevelopment. Testing newaircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operatingtechniques, or newuses for aircraft. (b) 

### Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to showcompliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crewtraining, wewould expect that an experimental certificate would permit our commercial purpose as well. The aircraftwill not carrypersons orproperty, will not carryfuel, and will onlyfly under strictoperational requirements. Combined with the fact that the aircraft are lightweight, we propose thatthe eBee will be at least as safe, ifnot safer, than a conventionally certificated aircraft performingthe same mission. If

### an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafety 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 numberassigned to the aircraft and a registration certificate mustbe aboard the aircraft. Additionally, subparagraph (b) provides thatthe airworthiness certificate be "displayed atthe cabin orcockpit entrance so that itis legible to passengers or crew." The eBee are too small to carry documentation, do not have an entrance, and are not capable ofcarrying passengers or crew.
6To obtain an equivalentlevel ofsafety and meetthe intent of91.203, we propose that documents deemed appropriate for these aircraftbythe FAA will be co-located with the crewatthe ground control station and available for inspection upon request. In orderto identifythe aircraft, we propose thatthe information found on airworthiness and registration certificates be permanentlyaffixed to the aircraftvia placard: Manufacturer: SenseFly Model: "eBee" Serial Number: 15-XXXX Registered to: Mount ShastaAerial Imagery 6224 Hill Street Dunsmuir, CA 96025 Iffound please contact: (530) 859-1411. 14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Displayofmarks; size ofmarks These regulations provide that each aircraft must display "N" andthe aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters atleast 2 inches high nearthe entranceto the cabin, cockpit, orpilot station. Given the size ofthe eBee (wingspan 38 inches, 1.5 pounds), this requirement is impossible to match. We feel thatthe permanentplacard discussed in the previous paragraphwill provide the aircraft's registration information should itbe found on the ground. We will also display atthe ground station a high contrastflag orbanner that contains thewords "UnmannedAircraft Ground Station" in letters 3 inches high orgreater. Since the aircraft will operatewithin 1/2 NM ofthe ground station, the banner shouldbe visible to anyone that observes the aircraft and chooses to investigate its point oforigin. 14 C.F.R. § 91.7(a): Civil aircraftairworthiness This regulation requires that no person may operate a civil aircraftunless it is in airworthy condition. Shouldthe exemption be granted allowing commercial operation ofthe eBee without an airworthiness certificate, no standardwill existfor airworthiness ofthe eBee. An equivalentlevel ofsafetywill be achieved byinsuring compliance with the eBee Pilot Operating Handbook (flight manual) priorto each flight. 14 C.F.R. § 91.9: Civil aircraftflight manual, marking, andplacard requirements.

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### This regulation provides that no person may operate an aircraftunless a current, approved flight manual is in the aircraft. MSAI assumes thatthe intent ofthis requirement is to ensure thatflight manual information is available to the aircrew while operatingthe aircraft. MSAI requests an exemption to this requirement since the aircraftis not only too small to carry documentation, thatthe documentation would notbe available to the crew. To obtain an equivalentlevel ofsafety and meetthe intent of91.9, we proposethata current, approved Extended Users Manual (Appendix G) mustbe available to the crewatthe ground station anytime the aircraft is in, orpreparingfor, flight. 14 C.F.R. § 91.109(a) &

### 91.319(a)(1): Flight Instruction 

### The regulation provides that "No person may operate a civil aircraftthat is being used for flight instruction unless that aircrafthas fully functioning dual controls." The eBee ground control stations are based on a small hand-held computerand while they do not offer a second set of "controls", both the studentand instructor can, and will, operatethe single set ofcontrols simultaneously. Both the eBee can be controlled from a ground station tablet orfrom the transmitter so, in essence, they have dual control capability and redundancy. With both student and instructorhaving "hands-on" the controls during flight, we feel thatthis technique meets the intent 91.109 and provides an equivalentlevel of safety. 14 CFR§ 91.119: Minimum SafeAltitudes 

### The regulation provides that over sparselypopulated areas the aircraft cannotbe operated closerthan 500 feet to anyperson, vessel, vehicle, or structure. Since the aircraftwill be operating at a maximum of400 feet AGL, the eBee cannot comply with this requirement. The equivalentlevel ofsafetywill be achieved because the eBee will only fly over propertywith the permission ofthe landowner(s) orpublic agencies. The operator will define before everyflight a working area radius and a flight area ceiling, preventing the eBee from goingbeyond the flight area. The landowner and the persons who maybe on the ground in the flight areawill be briefed ofthe expected route offlight andthe associated risks to persons and propertyon the ground. Due to the small size ofthe 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 grantingthe exemption. Moreover, the aircraft will notbe operated over congested areas nor over any openair assembly ofpersons. The aircraft will be operated atan altitude allowing, ifa powerunitfails, an emergencylanding withoutundue hazardto persons or property on the surface.

814 CFR 91.121- Altimeter Settings 

### This section requires that each person operating an aircraft shall maintain the cruising altitude orflight level ofthataircraft, as the case maybe, by reference to an altimeterthat is set, when operatingbelow 18,000 feet MSL to: • The currentreported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; • If

### there is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the currentreported altimeter setting ofan appropriate available station; • In the case ofan aircraft not equippedwith a radio, the elevation ofthe departure airport oran appropriate altimeter setting available before departure. To provide an equivalent level ofsafety, the eBee autopilot calculates the reference altitude (ground level) with the on-board GPS duringthe pre-flight tests. 14 C.F.R. § 91.151(a): Fuel Requirements for Flightin 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 pointofintended landing and to fly afterthatfor atleast 30 minutes. Given the area ofoperation for the eBee, MSAI believes thatan equivalentlevel of safetyis already achieved with the specific procedurepreventing the eBee from accepting a take-offorderifthe batterylevel is below a given value. The Pilot in Command will monitorthe batterylevels ofthe eBee during flight and return the aircraft to home when batterylevels reach 25 to 30 percent capacity. Moreover, SenseFly has integrated "low" and "critical" batterylevel warnings into controllers operatedfor 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 byparagraph (a) ofthis section ora special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew.

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### The eBee weighs only 1.5 pounds (maximum take-offweight). As such, there is no ability orplace to carrycertification and registration documents orto displaythem onthe UAS. In addition, there is no pilot orpassengers on board the aircraft. To obtain an equivalent level ofsafety and meetthe intent of91.203, MSAI proposes that documents deemed appropriate for this aircraftbythe FAA 

### will be co-located with the operator atthe ground control station in the eBee box and available for inspection upon request. 14 CFR Subpart E(91.401 - 91.417) -Maintenance, Preventive Maintenance, andAlterations The regulation provides thatthe operatoris primarilyresponsible for maintaining the aircraft in an airworthycondition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraftbe "approved for return to serviceby a person authorized under Part43.7" after maintenance and inspection. Section 91.409(a)(2) requires an annual inspection for the issuance ofan airworthiness certificate. Section 91.417(a) requires the owner or operatorto keep records showing certain maintenance workthathas been accomplished by certificated mechanics, under Part43, orlicensed pilots and records ofapproval of the aircraft for return to service. MSAI proposes that the maintenance ofthe eBee will be accomplished bythe owner/operator accordingto the maintenance manual, provided by SenseFly. MSAI requests the FAA 

### treatthe eBee trainingprograms as proprietaryunder 14 C.F.R. 11.35(b) and notinclude these documents in the public docket. An equivalent level ofsafetywill be achieved becausethe eBee is small in size, is not a complex mechanical device, and will operate onlyin restricted predetermined areas. Moreover, the operatoris the person mostfamiliar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalentlevel ofsafety.

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### APPENDIX B: ACADEMY OF MODEL AERONAUTICS SAFETY REQUIREMENTS

11Academy ofModelAeronautics National ModelAircraft Safety Code Effective January 1, 2014 A. GENERAL: Amodel aircraft is anon-human-carrying aircraft capable of sustained flight in the atmosphere. It may not exceed limitations ofthis code and is intended exclusivelyforsport, recreation, education and/orcompetition. All model flights must be conducted in accordance with this safety code and any additional rules specific to the flying site. 1. Model aircraftwill not be flown: (a) In acareless or reckless manner. (b) At alocation where model aircraft activities are prohibited. 2. Model aircraft pilots will: (a) Yield the right ofway to all human-carrying aircraft. (b) See and avoid all aircraft and aspotter must be used when appropriate. (AMA Document#540-D.) (c) Notfly higherthan approximately 400 feet above ground level within three (3) miles of an airport without notifying the airportoperator. (d) Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is amixed use agreement. (e) Notexceed atakeoffweight, including fuel, of 55 pounds unless in compliance with the AMA Large Model Airplane program. (AMA Document520-A.) (n Ensure the aircraft is identified with the name and address orAMA numberofthe owner on the inside or affixed to the outside ofthe model aircraft. (This does not apply to model aircraft flown indoors.) (g) Not operate aircraftwith metal-blade propellers orwith gaseous boosts exceptfor helicopters operated underthe provisions ofAMA Document#555. (h) Notoperate model aircraftwhile underthe influence of alcohol orwhile using any drug that could adversely affectthe pilot's abilityto safely control the model. (i) Not operate model aircraft carrying pyrotechnicdevices that explode or burn, or any device which propels aprojectile or drops any objectthat creates a hazard to persons or property. Exceptions: • Free Flightfuses or devices that burn producing smoke and are securely attached to the model aircraft duringflight. • Rocket motors (using solid propellant) up to aG-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 aturbine-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 priorto the specific event. (b) An inexperienced pilot is assisted by an experienced pilot. 4. When and where required by rule, helmets must be properlyworn and fastened. They must be OSHA, DOT, ANSI, SNELL or NOCSAE approved orcomply 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. Asuccessful radio equipment ground-range check in accordance with manufacturer's recommendations will be completed before the first flight of anew or repaired model aircraft. 3. At all flying sites asafety 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, astraight safety line must be established. (c) An area awayfrom 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 afrequency-management agreement. (AMA Documents #922 and #923.) 6. With the exception ofevents flown underofficial AMA Competition Regulations, excluding takeoff and landing, no powered model may be flown outdoors closerthan 25 feet to any individual, exceptforthe pilot and the pilot's helper(s) located at the flightline. 7. Under no circumstances may apilot or other person touch an outdoor model aircraft in flight while it is still under power, exceptto divert itfrom striking an individual. 8. RC nightflying requires alighting system providing the pilotwith aclearview ofthe 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 aircraftshall: (a) Maintain control during the entire flight, maintaining visual contactwithout enhancement otherthan by corrective lenses prescribed forthe pilot. (b) Fly using the assistance ofacamera 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 otherfliers. 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 priorto flying. 2. The pull testwill be in accordance with the current Competition Regulations for the applicable model aircraft category. 3. Model aircraft notfitting aspecific category shall use those pull-test requirements as indicated for Control Line Precision Aerobatics. 4. The flying area must be clearof all utilitywires or poles and amodel aircraftwill 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

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# SEE AND AVOID 11 

# 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 ofthe 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 orwill perform any maneuver to avoid the model's flight path. 9. Visual Line of Sight is required by the Safety Code. It means thatvisual contact with the aircraft must be maintained without enhancement otherthan by corrective lenses prescribed for the model aircraft pilot. All RC flying must remain clear of clouds smoke or any other obstruction tothe 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 ofthe equation and the modeler need not worry whether the model is closer to him than the manned aircraft orfurther 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 forthe well-being ofthe 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 thatthe spotter understands his/her duties and expectations. 2. A spotter should be used to assist in monitoring the surrounding airspace for manned aircraft whenever aflight 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 eventthat another model aircraft or spectators become endangered or in turn are perceived to be a danger to the pilot orthe pilot's model aircraft. 4. Ifa model aircraft pilot experiences what he or she considers a near miss with a manned aircraft, that model aircraft pilot should notifyAMA Headquarters with awritten report ofthe 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 ofthe incident at a latertime. 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 autopilotcontrol 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 autopilotsystems 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 ofthe model aircraft. c) AMA Pilots must perform an RIC Test Flightof a model aircraft before activating a newly installed autopilotor stabilization system and/or after any repairs or replacement of model aircraft essential flight systems. d) Model aircraft exceeding 151bs and/or ?Omph may only use an autopilotfor 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 ofthe 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 ofthe 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 autopilotfor 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) Ifyour 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 autopilotfor return to base/launch (RTL). b) When using an autopilotsystem 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 autopilotsystems for model aircraft flying to enhance flight performance, correct bad tendencies ofthe 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 generallyjust to make an airplane easier and safer to fly. e) When purchasing stabilization and autopilotsystems, 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 autopilotor 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 ifthe 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 ofSight (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 beflown over sterile, unpopulatedto lightly populated areas. In addition, we propose to obtain landowner permission to fly over properties as part ofour services andto notify and obtain waivers ofconsent from non-landowners overwhich we will be flying. Finally, mostofourflights will be 300 to 400 feet above ground surface, making visual recognition ofpeople on the ground difficult. Because ofthe sterile environmentand the prenotification oflandowners and personnel on the ground, privacy compromises due to MSAI activities are anticipated to be alleviated. Under no circumstances will MSAI's aircraftbe utilized to purposefully invade the privacy ofpeoples orproperties in areas within our studies or outside ofour studyboundaries.



### 12APPENDIX D: SAFETY CASE 

### Safety ofourflight 

### crew, otheraircraft, people on the ground, and public andprivate properties is ofutmost importance to MSAI. MSAI's Pilot in Command (PIC) will be responsible for all safetyprocedures and protocols while on the ground. The Visual Observer (VO) will assistthe PIC in maintaining safetyprocedures throughoutthe course ofa project. Safety procedures to be utilized in the field include the following:

• A 

### full diagnostic check ofthe aircraftbythe PIC and VO using a pre-flight checklistwill be performed on the ground priorto commencement ofeach project; • High visibility (day-glow orange orgreen) will be wornbythe flight crew during each project. In addition, atthe ground station, a high contrastflag or bannerthatcontains the words "UnmannedAircraft Ground Station" will be placed priorto any flights; • Operations to be conducted over private orpublic controlled-access property where approved; • Permission from the land owner/authorityrequired before commencing any flight; • Operations over congested areas shall be avoided; • Operations will not interfere with manned aircraft operations, will yield the right ofwayto manned aircraft, and operators must See &

### Avoid other aircraft and obstacles atall times. Use ofan ADS-B receiverby the VO will assist in monitoring the presence ofotherproximal aircraft; • Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours; • Aircraft operationswill remain within Visual Line ofSight (VLOS) and will be visually monitored atall times; • Use ofa high-definition first-person view from the aircraftwill assistthe PIC and VO identify potential flight conflicts and terminate or alterthe preprogrammed flight plan; • VLOS guaranteedwith a GPS geo-fence around operator of0.5 miles; • Flight ceiling pre-programed at400 feet; • All operations conducted within 5 miles from an airport shall onlybe initiated after verbal coordination with the airport authority, or airtraffic control when a control tower is present atthe airport; • All operations will complywith required permissions and permits established byterritorial, state, county or cityjurisdictions; including local law enforcement, fire, or other appropriate governmental agencies; • Post-flight inspection ofthe aircraftwill be performedbythe PIC andVO utilizing a postflight checklist; • The eBee operations will be compliantwith existing safetyprocedures inherentto the activities ofthe 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) ofdown to 1.5 em per pixel. 

### 02. Noflying skills required The eBee is the easiest to use mini drone on the market. To launch, just throw it intothe 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 ofdown to 1.5 em, and image overlap. eMotion automatically generates afull 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 ofeBee's flight Super lightweight ·Durable EPP foam body & wings ·Take-offweight 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 ofdown to 3 em I 5 em per pixel

Green technology ·Brushless 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 km 2 (4.6 mi 2 )

# 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 ofthe 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 atime), 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 S110 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 ofsolar panels).



# Radio tracker Ifyou are planning to fly your eBee in extreme situations, such as those with high winds, in mountainous areas, out of line ofsight, 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 X45 X25 em (21.6 X 17.7 X9.8 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 km 214.6 mi 2 (at 974 mI 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 ofdetachable 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)

# \-V

# senseFiy

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 LtdAPPENDIX F: MAINTENANCE PROCEDURES For the use ofthe 

### eBee, MSAI will follow SenseFly's eBee Maintenance Procedures Manual enclosed in this Appendix. In addition, MSAI's general maintenance proceduresfor ourUAS aircraft are as follows: WING CARE 

### • • Wings mustbe checked each flight for nicks or cracks Wings are designed to lastindefinitelyiftheydo not impact dust, dirt or more. PROPELLERAND MOTOR INSPECTION • The motorwill be inspected for dirt and debris and manually spun before and after everyflight. • The propellerwill be examined for cracks and dings before and after every flight. • The propeller fasteners and attachments will be checked for securityand any damages before and after everyflight. BATTERY CARE AND USE Refer to instruction sheetincluded from the batterymanufacturer. Typical information follows:


### •
•

• 

### •
•
•

•


### • • •


### • Batteries are highly flammable and can explode, especiallywhen fully charged. Improper charging, vibration, impact, high discharge, etc. can lead to explosion and fire. Batteries mustbe charged under constant supervision and using properprecautions. Batteries fully charged mustbehandled with extreme care. Any batterythat puffs up is considered damaged and must not be used. It is in a dangerous state. Never charge a puffed up battery. Any batterywhich holds less than 80% ofits rated capacity should be discarded. Cycle test each batteryafter every 50 cycles orifa batteryis suspected to have lost as significant amount ofits capacityto determine the current capacity. Properlydispose ofbatteries. First discharge the batteryfully 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 Cwhich takes approximately 1 hourto charge Flight BatteryMaximum Charge Rate: May exceed SC. Charge rates higher than 1 Cwill decrease life cycles. Maximum charge rating perthe manufacturerwill provide


### 15

### • 300+ cycles. Use the lowest charge ratewhich is practical. • Battery Rest Time between discharging and charging: 30 minutes minimum, 1 hour maximum. • Do not charge ifthe batteryis more than

## zoe warmerthan ambient, especially ifthe temperature is above

## zooc. The outersurface is cooler than the inner core after use. • Damage will occurwhen charging a warm battery. • Recommended BatteryDischarge Amount: 80%. Using more ofthe capacity ofthe batterywill decrease the life cycles • As batterytemperature approaches freezing the capacity ofLithium Polymer batteries decrease. Keep warmerthan 

## soc before installing into the UV (unmanned vehicle). • Battery capacity decreases at higher discharge rates. Using more batteries decreases the discharge rate ofeach batterytherebyextendingindividual batterycapacity slightly. • Lower discharge rates improve the life cycles. • Batteries are rated atgreaterthan 300 life cycles. 1,000+ 

### life cycles are possible. • Batteries must notbe stored above 60% charged state for extended periods. • Batteries should be storedbelow

## zsoc for extended periods • Store batteries between 40%

- 60% charged state. Fully chargejustbefore


### • use. Fully charged batteries which are notto be used within 24 hours should be discharged to 40%

- 60% charged state using the batterydischarger. 

### • Using more than one batteryat a time requires the properwiringharness so thatthe 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 of300 hours in a oneyear period, an annual inspection mustbe completed by an approvedtechnician. 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 latestrevisions.



### 16APPENDIX G: EXTENDED USER MANUAL 

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



### 17APPENDIXH: TRAINING PROGRAM MSAI's ChiefPilot Ian Fitton completed a UAS FactoryTrained Individual Course with Troy Built Models (TBM) in June 2015 and received his certification. His trainingwas performed on the DJI Phantom 2 Vision+ andthe DJI S1000. The training course teaches the basics ofsafe operation for UAS. The director offlight training is Gene Payson. Payson is the Director ofUAS Flight Training at Unmanned Vehicle University and owner ofTroy Built Models. This certificate is from Troy Built Models. DJI-Innovations, the FAA, and other entities do not currentlyhave certifications. The testwas developed entirelyby UAV Flight Schools. The training curriculum offered through TBM that our CP completed included:

General UAVcharacteristics, types, uses Principals of Flight • WeightandBalance- Center of Gravity calculations andmethods • Operational/imitations [vertical speed, horizontalspeed, weight, horizontal distance, altitude, endurance, weather, etc.) • Subsystem Operation andMaintenance [Flight controller, IMU, GPS, Compass, Gyros, Accelerometers, Brushless motors, Speed controllers, Propeller, Retractable landinggear,Airframe, Video Transmission andReception, Antennas, Video displays, etc.) Battery care Transponder operation Maintenance • RecordKeeping, Logbooks, and otherDocumentation • Insurance Requirements • Remotesensing theory andpractical application • Autopilotoperation andMission Planning Aircraft flight simulation • Federal, State, andLocal laws, rules, regulations, policies, andgoodpractice • RightofWay rules FAA Certificate of Authority (COA) process Pilot in Command [PIC) qualifications and responsibilities Observer qualifications and responsibilities Sensor Operator qualifications and responsibilities Recognizing andsetting Early WarningAlarms/Signals • Emergency Procedures



### 18• Integration with otheraircraftin the nationalairspace • Reading a sectional map for aircraft • Preflight Checklist Inflight Checklist • Post flight Checklist • AutonomousFlight • Preflightbriefing Checklist reviews Flight • Certification Testing • How to starta UAVbusiness • Typical income for UAVbusinesses • Typical charges forphotography 

### MSAI's CP Ian Fitton is UAS factory trained andwill train future MSAI pilots. Ian Fitton is also a Certified Flight Instructor (see Appendix I). Training for the eBee will be performedin accordance with procedures from the TBM training and SenseFly distributertraining, and in accordance with the attached eBee training manuals. MSAI requests the FAA treatthe eBee trainingprogram as proprietaryunder 14 C.F.R. 11.35(b) and does not include this document in the public docket.



### 19

### APPENDIX I: AVIATION EXPERIENCE MSAI's ChiefPilot (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 ofthe DJI Phantom 2 Vision+, and has logged hours on theVision, S-1000 and eBee Sensefly.

20UNITED STATES OF AMERICA Department ofTransportation Federal Aviation Administration MEDICAL CERTIFICATE SECOND CLASS

This certifies that (Fullname andaddress): IAN Weiss FITTON 6224 Hill Street Dunsmuir CA 96025 USAThisistocertifythatlanFittonhascompletedtrainingwithTBMonsUASsystemsJune5,2015President

### APPENDIX J. JUSTIFICATION OF AIRWORTHINESS AND SAFETYASSESSMENT



### 21