Quiet Creek

Corporation

5130 N Prairie Clover Trail

Tucson, AZ 85704

29 October 2014

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Filed with www.regulations.gov

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

Aviation Regulations

Annex A: Exemption request and equivalent level of safety showings under applicable rules 

subject to exemption.

B: Academy of model aeronautics safety requirements.

Enclosure (1) eBee Owner’s Manual. (Request the FAA treat the eBee user manual (used here 

with permission of Sensefly) as proprietary under 14 C.F.R. 11.35(b) and not 

include this document in the public docket.)

(2) eBee operators training program. (Request the FAA treat the eBee training 

program (used here with permission of Sensefly) as proprietary under 14 C.F.R. 

11.35(b) and not include this document in the public docket.)

(3) Justification of airworthiness. (Request the FAA treat this justification (used here 

with permission of Sensefly) as proprietary under 14 C.F.R. 11.35(b) and not 

include this document in the public docket.)

(4) eBee maintenance procedures. (Request the FAA treat these maintenance 

procedures (used here with permission of Sensefly) as proprietary under 14 

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

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, Quiet Creek Corporation (“Quiet Creek”), a Service Connected Disabled 

Veteran Owned Small Business seeks an exemption from the Federal Aviation Regulations 

listed below:

• 14 C.F.R. Part 21

• 14 C.F.R. 45.23

• 14 C.F.R. 45.29

• 14 C.F.R. 61.23

• 14 C.F.R. 61.3

• 14 C.F.R. 61.113(a) & (b)

• 14 C.F.R. 61.133(a)

• 14 C.F.R. 91.7(a)

Quiet Creek’s petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Page 1
• 14 C.F.R. 91.9

• 14 C.F.R. 91.109(a)

• 14 C.F.R. 91.119

• 14 C.F.R. 91.121

• 14 C.F.R. 91.151(a)

• 14 C.F.R. 91.203

• 14 CFR Subpart E (91.401 - 91.417)

The requested exemption would authorize commercial operations using Sensfly Ltd’s eBee for 

mapping and precision agriculture applications. These operations will be subject to strict 

operating requirements and conditions defined by the Safety Program of the Academy of Model 

Aeronautics (“AMA”) (see Annex B), to ensure at least an equivalent level of safety to currently 

authorized operations using manned aircrafts.

Given the technical specifications of the eBee (especially its very light weight), Quiet Creek, 

SenseFly, and the AMA think it is relevant to use the AMA rules to meet the required level of 

safety of operations with the eBee. Indeed, the AMA has a proven track record in supervising 

operations conducted by operators using Remote Control Aircrafts and provides the most 

relevant expertise in terms of providing safety guidelines for operators using ultra-light remote 

control aircrafts. Hobbyists and modelers have been safely operating unmanned aircrafts 

(model aircrafts) for years in compliance with AMA standards.

By this petition, Quiet Creek seeks an exemption to use the eBee for commercial purposes 

provided the operator complies with any terms and conditions of this exemption, including the 

procedures and requirements set forth in the eBee owner’s manual (enclosure (1)) and the AMA 

Safety Program. Quiet Creek and Sensefly requests the FAA treat the eBee owner’s manual 

(used here with permission of Sensefly) as proprietary under 14 C.F.R. 11.35(b) and not include 

this document in the public docket.

Under the requested exemption, Quiet Creek will ensure that the aircraft will be operated by an 

individual who meets all of the following requirements:

• Is a registered member of the AMA;

• and has passed SenseFly’s training program for the eBee (enclosure (2)). (Quiet Creek 

and SenseFly requests the FAA treat the eBee training program as proprietary under 14 

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

• and has passed the written examination for a Private Pilot’s License.

• Or, has a private pilot certificate with current third class medical certificate and has 

passed SenseFly’s training program for the eBee.

1. CHARACTERISTICS OF THE AIRCRAFT

The eBee is a small (38 inches wingspan) and ultra-light (maximum take-off weight of 1.7 

pounds) platform made of flexible foam that performs precision aerial mapping missions thanks 

to the onboard 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. Thanks to 

the embedded camera, protected by a foam envelope, the eBee takes a collection of highdefinition still images that are used later to generate maps and contour lines of the surveyed 

area. The four main characteristics of the eBee are:

Quiet Creek’s petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Page 2
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 kinetic 

energy (60 Joules (“J”) at cruise speed) also significantly reduces the risk of hazardous 

situations. Finally, the wings of the eBee are detachable and made of flexible foam with no 

sharp or hard edges and almost no internal strengthening structure.

b. Electric-powered. The eBee is electric-powered. A brushless engine technology makes it 

silent and reliable. The propeller is attached with two rubber bands to the body of the plane so 

that it can easily flex away in case of contact with any object.

c. Semi-automatic flight. The artificial intelligence incorporated within the eBee autopilot system 

continuously analyzes data from the Inertial Measurement Unit and from the onboard GPS and 

takes care of all the aspects of the flight under the supervision of the operator.

d. Option for Manual control. Additionally, the eBee provides an override capability that allows 

the operator to take manual actions during the flight (Go to Home, Go Land, Hold and Resume 

the mission) and also suspend automated operations and take manual control of the aircraft 

should it become necessary to respond emergent circumstances, thanks to the remote 

controller provided with the system.

2. APPLICATIONS AND ADDED PUBLIC VALUE OF THE EBEE

Mapping applications with the eBee may include agricultural applications, mining, construction 

and survey/GIS operations. The reason why the eBee solution has been very successful 

worldwide (thousands of operations in more than 50 countries) is that there are many 

operational benefits related to the use of this solution:

a. First, the eBee brings safety to daily survey operations: there is no need for the humans to 

access dangerous working areas anymore (mines, quarries, or polluted sites). The missions can 

be programmed and reproduced reliably as often as needed for regularly updated maps.

b. Second, the eBee is a cost-effective solution. It is cheaper to operate a UAS rather than an 

aircraft or other ground systems for the same results. Moreover, small UAS like the eBee can 

help Ag businesses and farmers face the growing needs of the population while reducing 

operational costs. The eBee also enables the ability to take up new challenges - like water or 

environmental management through analysis of vegetation index maps.

c. Third, users can save time and work more efficiently by using the eBee. A mission does not 

need a long preparation time or long deployment constraints, or long waiting time for perfect 

weather conditions unlike, for example, the use of satellites. Initial results are accessible directly 

on-site, which is impossible with images provided by satellites or manned aircrafts.

d. The eBee has social benefits too: it is eco-friendly (electric-powered), and its affordability 

allows many high-valued applications like data gathering for sustainability projects 

(agribusiness, reforestation) or post-disaster management missions.

Quiet Creek’s petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Page 3
3. APPLICABLE LEGAL STANDARD UNDER SECTION 333

a. Airworthiness assessment of the eBee. Quiet Creek notes that the airworthiness of the eBee 

has already been demonstrated for different projects in the United States, involving state/federal 

agencies or universities (among others the New Mexico State University: 

https://newscenter.nmsu.edu/Articles/view/10208/nmsu-uas-flighttest-center-conducts-ebeeairworthiness-assessment, and the US Army Corps of Engineers (“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 has obtained flight approvals for the eBee 

from the national civil aviation authority in many countries, including:

• Switzerland (flight approval for Visual Line of Sight “VLOS” operations)

• Canada (flight approval for VLOS operations)

• Australia (flight approval for VLOS operations)

• France (flight approval for Extended-VLOS operations)

• Germany (flight approval for VLOS operations)

• United Kingdom (flight approval for VLOS operations)

• Norway (flight approval for VLOS operations)

• Sweden (flight approval for VLOS operations)

• Denmark (flight approval for VLOS operations)

b. Operating Conditions

Grant of the exemption to Quiet Creek for the eBee who will be subject to the following 

operating conditions, based on the operating conditions set forth by the AMA (see Annex B), 

and the factors the FAA is to consider under section 333. The main restrictions are summarized 

below: 

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

• approved;

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

• Operations over congested areas shall be avoided;

• Operations must not interfere with manned aircraft operations, must yield the right of 

way to manned aircraft, and operators must See & Avoid other aircraft and obstacles at 

all times;  Operations limited to Visual Flight Rules Meteorological Conditions (VMC) 

and daylight hours;

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

monitored at all times;

• VLOS guaranteed with a GPS geo-fence around operator of 0.5 miles;  Flight ceiling 

pre-programed at 400 feet AGL;

• 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.

Quiet Creek’s petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Page 4
c. Operating Requirements. The eBee is an ultra-light UAV platform made of flexible foam with 

no sharp or hard edge characterized by a high level of pre-programmed control and various 

built-in technical capabilities (programming of a geo-fence, automatic wind detection) that 

prevent the operator doing a mission outside of the operating limits. All flights are preprogrammed with GPS guidance and do not require human intervention; nevertheless human 

override is possible by clicking on one of the multiple “action” buttons or by using the remote 

controller provided with each eBee system. In the case of unplanned events, either the autopilot 

reacts immediately or the operator can choose between different pre-programmed or manual 

actions. Those procedures include a Flight Termination System (emergency landing procedure, 

triggered by the autopilot or the operator in charge: given its very light weight, the eBee will 

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

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

kinetic energy of a football is about 110 J when thrown by hand. Given those safety features, 

recognized by the U.S. Army Corps of Engineers and the national aviation authority of several 

countries, Quiet Creek requests an exemption from the airworthiness certification requirements 

in Part 21 and the concomitant requirements in 14 C.F.R. 91.7(a)) and 91.203 to operate an 

airworthy aircraft.

Quiet Creek also proposes its operators of the eBee should not be required to hold a 

commercial or private pilot certification, and hereby requests an exemption from the pilot 

certification requirements in the Federal Aviation Act and Part 61. Pilot certification requirements 

for manned aircraft are neither necessary nor appropriate in many respects for operators of 

small, ultra lightweight UAVs. However, Quiet Creek’s owner is currently enrolled in a PPL 

program. There are undoubtedly ATP-certificated pilots who nonetheless would need training to 

operate a UAV safely; conversely, the UAV training regimen includes instruction for noncertificated operators in those aspects of safe operation in the National Airspace System 

(“NAS”) that are relevant to the UAV and the UAS operation. The FAA has authority under both 

section 333 and its general waiver and exemption authority in 49 U.S.C. 44701(f) to waive the 

statutory pilot certification requirement upon a showing that the required UAS training achieves 

an equivalent level of safety.

To achieve as well as exceed an equivalent level of safety, operators will be required to:

• Have completed an AMA affiliated small UAS education and training program and 

achieved an AMA UAS endorsement, or have successfully completed a small UAS 

education and training program provided by any FAA qualified entity, and; 

• Have passed SenseFly’s training program for operation of the UAS. The manufacturer’s 

training program for operators has been already satisfactorily reviewed through the 

Application for Airworthiness Qualification Level (AQL) 3 Airworthiness Release (AWR). 

Quiet Creek also seeks an exemption from certain requirements in Parts 45 and 91 that are 

impractical as well as unnecessary for UAS operations. Please see Annex A for a detailed 

explanation of each regulation from which an exemption is sought and the equivalent level of 

safety showing.

Quiet Creek’s petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Page 5

ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS 

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

Quiet Creek 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

14 CFR § 91.203

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR § 91.203(a). Given the size of the eBee, its very 

light weight (the maximum take-off weight is 1.7 pounds) and the limited operating area 

associated with its utilization, it is unnecessary to go through the certificate of airworthiness 

process under Part 21 Subpart H in order to achieve or exceed current safety levels. Such an 

exemption meets the requirements of an equivalent level of safety under Part 11 and Section 

333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and 

populated areas of the UAS involved. An analysis of these different criteria demonstrates that 

the eBee operated without an airworthiness certificate, under the conditions proposed in that 

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

certificate. A proprietary risk assessment (enclosure (3)) (authored by Sensefly and used here 

with permission) for operations with the eBee, which demonstrates that assertion, is also being 

submitted to the FAA as part of this application. Quiet Creek and Sensefly requests the FAA 

treat the eBee risk assessment as proprietary under 14 C.F.R. 11.35(b) and not include this 

document in the public docket.

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. Given the size of the eBee (wingspan of 37.8 inches), this requirement is 

impossible to match. The equivalent level of safety will be achieved by having the upper part of 

the eBee stick with a copy of the AMA membership of the operator in charge. The AMA agrees 

to provide 2 original copies of the AMA license to every eBee operator.

14. CFR §61.23: Medical certificates: Requirement and duration

Regulations provide that a person:

(1) Must hold a first-class medical certificate:

• When exercising the pilot-in-command privileges of an airline transport pilot certificate;

• When exercising the second-in-command privileges of an airline transport pilot 

certificate in a flag or supplemental operation in part 121 of this chapter that requires 

three or more pilots; or

• When serving as a required pilot flight crewmember in an operation conducted under 

part 121 of this chapter if the pilot has reached his or her 60th birthday.

Quiet Creek’s petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Annex (A) p. 1
(2) Must hold at least a second class medical certificate when exercising:

• Second-in-command privileges of an airline transport pilot certificate in part 121 of this 

chapter (other than operations specified in paragraph (a)(1)(ii) of this section); or

• Privileges of a commercial pilot certificate

Given the size of the eBee, its structure, the limited flight area, and the safety features 

integrated in the autopilot (among others the Flight Termination System), Quiet Creek believes 

that an Equivalent Level of Safety can be reached if the operator has a valid driver’s license.

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations

The regulation provides that no person may serve as a required pilot flight crewmember of a 

civil aircraft of the United States, unless that person: (1) Has a pilot certificate or special 

purpose pilot authorization issued under this part in that person's physical possession or readily 

accessible in the aircraft when exercising the privileges of that pilot certificate or authorization. 

However, when the aircraft is operated within a foreign country, a pilot license issued by that 

country may be used. The regulation provides also that no person that holds a private pilot 

certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) 

allows a private pilot to act as pilot in command of an aircraft in connection with any business or 

employment if:

(1) The flight is only incidental to that business or employment;

(2) The aircraft does not carry passengers or property for compensation or hire.

Given the safety features of the eBee and the fact that the missions are pre-programmed and 

monitored in real-time with a specific flight management software (eMotion), Quiet Creek

proposes that operators of the eBee should not be required to hold a commercial or private pilot 

certification. Instead, operators should be required to:

• Have completed an AMA affiliated small unmanned aircraft systems education and 

training program and achieved an AMA UAS endorsement, or have successfully 

completed a small UAS education and training program provided by any FAA qualified 

entity, or, hold a private pilots certificate and;

• Have passed SenseFly’s training program for operation of the UAS. The manufacturer’s 

training program for operators has been already satisfactorily reviewed through the 

Application for Airworthiness Qualification Level (AQL) 3 Airworthiness Release (AWR). 

The equivalent level of safety will be achieved by having an operator trained by the AMA 

(or any FAA qualified entity) and SenseFly, and using the integrated features of the 

aircraft to maintain a high level of safety during the different missions.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. Should the exemption be granted allowing commercial operation of the eBee without 

an airworthiness certificate, no standard will exist for airworthiness of the eBee. Given the size 

of the aircraft and the previous airworthiness assessments given to the eBee, among others:

Quiet Creek’s petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Annex (A) p. 2
• New Mexico State University: https://newscenter.nmsu.edu/Articles/view/10208/nmsuuasflight-test-center-conducts-ebee-airworthiness-assessment

• USACE New Orleans, who coordinated with the Department of Army and the FAA to 

obtain all authorizations required in order to operate the eBee UAS for levee system 

monitoring, documentation of construction progress, and extensive oblique photography 

of USACE structures & activities.

An equivalent level of safety will be achieved by insuring compliance with the eBee user manual

prior to each flight.

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

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

manual is in the aircraft. Quiet Creek assumes that the intent of this requirement is to ensure 

that flight manual information is available to the aircrew while operating the aircraft. Quiet Creek 

requests an exemption to this requirement since the aircraft is not only too small to carry 

documentation, but the documentation would not be available to the crew. The equivalent level 

of safety will be achieved by keeping a hard copy of the eBee user manual in the eBee transport 

box.

14 C.F.R. § 91.109(a): Flight Instruction

The regulation provides that "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls." Flight instruction will be 

accomplished through an elaborated training program, using first the simulation mode of the 

flight management software eMotion. The equivalent level of safety during the in-flight training 

will be achieved by the manufacturer or affiliate providing the training as described in the eBee 

training program and through the use of experienced and qualified instructors familiar with the 

eBee and also members of the AMA.

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 eBee will be 

operating at a maximum of 400 feet AGL, Quiet Creek cannot comply with this requirement. The 

equivalent level of safety will be achieved because the eBee will only fly over private or 

government property with the permission of the landowner or governmental entity. The operator 

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

to go beyond the flight area. The landowner and the persons who may be on the ground in the 

flight area will be briefed of the expected route of flight and the associated risks to persons and 

property on the ground. Due to the small size of the eBee, the material with which the eBee is 

built and its specific safety procedures (among others ground detection), 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 or over any open-air assembly of persons.

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:

Quiet Creek’s petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Annex (A) p. 3
• 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. The GPS and barometer data 

are then used to calculate the altitude in-flight.

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 day-VFR 

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. As the eBee is electric-powered, this requirement is inapplicable. In 

any event, given the area of operation for the eBee, Quiet Creek believes that an equivalent 

level of safety is already achieved with the specific procedure preventing the eBee to accept a 

take-off order is the battery level is below a given value. Moreover, SenseFly has integrated 

“low” and “critical” battery level warnings and implemented a “return to Home” (and “Go Land”) 

actions in these situations.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

• No person may operate a civil aircraft unless it has an appropriate and current 

airworthiness certificate.

• No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

To obtain an equivalent level of safety and meet the intent of 91.203, Quiet Creek 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 transport box and available for inspection upon 

request. In order to identify the aircraft, Quiet Creek proposes that a copy of the AMA 

membership of the operator will be permanently affixed to the eBee on the upper side of the 

body.

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 the aircraft to be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. Section 91.409 requires an annual inspection for the 

issuance of an airworthiness certificate. Section 91.417 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. Quiet Creek proposes that the maintenance of the eBee will be accomplished by the 

owner or the operator according to the eBee user manual. An equivalent level of safety will be 

Quiet Creek’s petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Annex (A) p. 4
achieved because the eBee is small in size, it is not a complex mechanical device and does 

carry any external payload. Moreover, the operator is the person most familiar with the aircraft 

and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent 

level of safety. Finally, before every flight, the eBee automatically runs a sequence of pre-flight 

tests to make sure that every sensor and every critical part is operating properly. If a problem is 

detected, the eBee will not be able to be switched-on and a message error is displayed on the 

main screen of eMotion. The owner or the operator can then refer to the eBee user manual to 

troubleshoot this issue. Several parts of the eBee are easily interchangeable (propellers, wings), 

which allows the operator to make sure the wings and propulsion system are always airworthy 

when a mission is initiated. Proprietary maintenance procedures (enclosure (4)) (authored by 

Sensefly and used here with permission) for the eBee is also being submitted to the FAA as part 

of this application. Quiet Creek and Sensefly requests the FAA treat these maintenance

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

docket.

Quiet Creek’s petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Annex (A) p. 5
ANNEX B: ACADEMY OF MODEL AERONAUTICS SAFETY REQUIREMENTS

http://www.modelaircraft.org/files/105.pdf

http://www.modelaircraft.org/files/540-D.pdf

http://www.modelaircraft.org/files/560.pdf

Quiet Creek’s petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Annex (C) p.1