May 8, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

Filed at www.regulations.gov

SUBJECT: Petition for Exemption under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

C.F.R. Part 11, Coastal Science & Engineering Inc. (CSE), seeks an exemption from Federal Aviation Regulations (FARs) detailed below for the eBee Unmanned Aircraft System (“eBee”) manufactured by SenseFly 

SA of Switzerland:

 14 CFR 61.113(a) and (b)

 14 CFR 91.7(a)

 14 CFR 91.119(c)

 14 CFR 91.121

 14 CFR 91.151(a)(1)

 14 CFR 91.405(a)

 14 CFR 91.407(a)(1)

 14 CFR 91.409(a)(1) and (2)

 14 CFR 91.417(a) and (b)

CSE provides consulting, engineering, and surveying services to clients in ocean and coastal resource management, preservation, and restoration. CSE’s clients are typically government entitys including local municipalities, state agencies, and federal agencies. The surveying services provided to these clients routinely 

include topographic and feature (habitat) mapping that is acquired through aerial photogrammetry. Use of 

the eBee UAS to produce high resolution, accurate mapping solutions creates benefits to the coastal surveying/mapping industry and to the environment which serve the public interest. Specifically, use of the eBee 

UAS provides the following advantages:

 Environmental Impact: The eBee UAS is constructed of flexible foam and weighs less than two 

pounds. The eBee operates on a sealed lithium-polymer battery and does not use combustible fuel. 

The eBee can be launched and recovered with very little, if any, environmental impact. Use of the 

eBee UAS in the coastal zone allows acquisition of topographic and feature data that is otherwise 

unobtainable due to the sensitive organisms and vegetation that inhabit the coastal zone, particularly 

on and landward of the sand dunes. Use of the eBee UAS will allow data acquisition in critical habitat areas of the coast that are restricted to human access or areas occupied by endangered species 

without disturbance. The data produced by the eBee exceeds standards suggested by resource managers for project and impact monitoring, and will increase knowledge of project performance, impacts, and endangered species habitat utilization.

 Shoal Mapping: Mapping and surveying “shoals” or sand bars is extremely difficult both by conventional and hydrographic surveying. At higher tides there is enough water to cover the shoal but 
Petition for Exemption under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

[Page 2]

not enough depth to operate a survey vessel. At low tides, the shoals are exposed and become 

subaerial allowing data acquisition. The eBee UAS will allow data acquisition of the shoals without 

risking the safety of personnel or equipment, and will allow for more accurate and comprehensive 

data coverage of these dynamic areas.

 Cost: Use of the eBee provides a competitive advantage to our clients because they are able to acquire survey data in difficult areas in a matter of hours. Conventional surveying techniques would 

require days, if not weeks, to obtain the same quantity of data.

 Schedule: The workflow for conventional manned aerial photography is such that the client receives 

deliverables from several days to weeks after flight date. The eBee UAS includes post-processing 

software that will allow CSE to deliver the final mapping product to the client within several hours 

to a few working days after flight date.

 Quantity and Quality: The eBee UAS, at normal flight heights, acquires imagery at a resolution of 

less than one inch per pixel. This resolution provides excellent clarity in the resulting ortho-photos, 

and also results in very accurate survey deliverables. The workflow of the eBee will allow quick acquisition of multiple datasets (imagery and elevation). This will give CSE’s scientists and engineers 

the capability to collect and analyze coastal dynamic data at rates and levels never possible within 

the limited budgets of coastal municipalities.

The requested exemption would authorize commercial operations using the eBee for mapping and survey 

applications. These operations will be subject to strict operating requirements defined in the eBee user 

manual (CSE requests that 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) in order to ensure at least an equivalent level of safety to 

currently authorized operations using manned aircrafts. Additionally, CSE will only employ the eBee during 

times where the coverage area is least utilized by the public, typically early morning hours or during the 

winter season, and limit the altitude of the UAS to no more than 400 ft. 

UAS Characteristics

The eBee is a small (37.8 inches wingspan) and ultra-light (maximum take-off weight of 1.7 pounds) 

platform made of flexible foam that performs pre-programmed precision aerial mapping missions thanks to 

the on-board GPS and the related flight management software (eMotion) that allows the operator to plan 

safely and efficiently a mission in 3D, and then monitor it in real-time. Thanks to the embedded camera, 

protected by a foam envelope, the eBee takes a collection of high-definition still images that are used later 

to generate maps and contour lines of the surveyed area. 

The four main characteristics of the eBee are:

a. Very light weight

The eBee is so light that the operator can launch it by hand and let it land on almost any surface without 

requiring a parachute or landing net (belly land). Its low impact energy (38 J in case of a controlled emergency landing) also significantly reduces the risk of hazardous situations. Finally, the wings of the eBee 

are detachable and made of flexible foam with no sharp or hard edges and almost no internal strengthening 

structure. 

b. Electric-powered

The eBee is electric powered. A brushless engine technology makes it silent and reliable. The propeller is 

attached with a rubber band to the body of the plane so that it can easily flex away in case of contact with 

any object. 
Petition for Exemption under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

[Page 3]

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.

Applicable Legal Standard Under Section 333

a. Airworthiness assessment of the eBee

CSE 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-flight-test-center-conducts-ebeeairworthiness-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)

 Denmark (flight approval for VLOS operations)

b. Operating requirements

Grant of the exemption to CSE for the eBee will be subject to the following operating conditions, based on 

the operating conditions set forth by the Academy of Model Aeronautics. 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;
Petition for Exemption under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

[Page 4]

 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 operator will have a Sport Pilot license and a FAA airman medical certificate.

Conclusion

Coastal Science & Engineering Inc. is a consulting, coastal surveying and engineering firm. The use of the 

eBee’s technology will make our work more profitable and efficient. The eBee will enable us to deliver 

accurate results in near real time to our clients. It also allows zero impact data collection through sensitive 

habitats occupied by endangered species. The eBee is safer than having CSE’s employees out in the field 

for specific projects, and also very safe for other aircrafts because of the mission specifications (below 400 

ft.) and eBee integrated safety features. 

Very respectfully,

Captain Andrew Giles

50 GRT USCG Master Near Coastal #272015

Senior Technical Associate