UAV-IQ LLC Ph: 310-497-9389 Email: info@uav-iq.com

15 January 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam: 

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

11, UAV-IQ LLC (“UAV-IQ”), seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below 

for the eBee Ag Unmanned Aircraft System manufactured by SenseFly SA of Switzerland. 

The aviation experience of the applicants and the type of agricultural operations requested for consideration closely 

match those granted to Advanced Aviation Solutions LLC in Exemption No. 11136, and the model UAS requested 

is identical. The operations would be subject to the same conditions and limitations.

This requested exemption would support an application for a commercial Certificate of Authorization to use the 

system to support agriculture. The eBee Ag system consists of a lightweight (1.5 lb) battery operated aircraft, a 

PC-based ground control station, and associated communications equipment. The aircraft carries an onboard 

geo-referenced still camera that allows it to conduct precision photogrammetry and crop scouting at the resolutions 

necessary for precision agriculture. This high-resolution data can direct variable seeding rates as well as the 

precise application of fertilizer and chemicals reducing their use. This data helps farmers to maximize yields while 

reducing costs and impacts to the environment. By approving these exemptions, the FAA will create benefits to 

both agriculture and the environment which are ultimately in the public interest.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations will comply 

with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. These operations will also 

be subject to strict operating requirements defined in the eBee user manual.

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel 

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of 

maintenance instruction as part of their initial training. 

We submit that the combination of the aircraft's light weight, historically demonstrated flight performance, fully 

qualified flight crew and strict operation under the guidelines established in 8900.227, the FAA can have 

confidence that the operation will have an equivalent or greater level of safety of manned aircraft performing the 

same mission. 

In regards to privacy concerns, all flights will occur over private or controlled access property with the property

owner’s prior consent and knowledge. Inspection will be in areas where the owners will have consented to the 

inspections or otherwise have agreed to allow the UAS and the operator to be in the area where inspection will take 

place.

The regulations from which the exemption is requested are as follows: 14 CFR 61.113(a) and (b), 91.7(a), 

91.119(c), 91.121; 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to the extent 

necessary to allow UAV-IQ to operate UAS for the purpose of aerial imagery to support agriculture. This 

exemption is subject to the conditions and limitations listed below.
UAV-IQ LLC Ph: 310-497-9389 Email: info@uav-iq.com

1. Operations authorized by this grant of exemption are limited to the following aircraft described in the 

operating documents which is a fixed-wing aircraft weighing approximately 1.5 pounds: senseFly eBee 

Ag (eBee Ag). Proposed operations of any other aircraft will require a new petition or a petition to amend 

this grant.

2. The UA may not be flown at an indicated airspeed exceeding 70 knots.

3. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be 

in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the 

PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the 

PIC’s FAA-issued airman medical certificate.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to 

communicate verbally at all times. The PIC must be designated before the flight and cannot transfer his or 

her designation for the duration of the flight. The PIC must ensure that the VO can perform the functions 

prescribed in the operating documents.

6. The operating documents and this grant of exemption must be maintained and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and limitations in this 

exemption and the procedures outlined in the operating documents, the conditions and limitations herein 

take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in 

its operating documents. The operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update or revision would 

affect the basis upon which the FAA granted this exemption, then the operator must petition for

amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents.

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the UAS is found to be in a condition 

for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance 

and alterations must be properly documented in the aircraft records.

8. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. 

replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts 

the functional test flight must make an entry in the aircraft records.

9. The pre-flight inspection section in the operating documents must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not already covered in the relevant sections of the operating 

documents.

10. The operator must follow the UAS aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements.

11. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, and alterations must be noted in the 

aircraft records, including total flight hours, description of work accomplished, and the signature of the 

PIC returning the UAS to service.

12. Each UAS operated under this exemption must comply with all manufacturer System and Safety 

Bulletins.
UAV-IQ LLC Ph: 310-497-9389 Email: info@uav-iq.com

13. The PIC must make an entry in the aircraft record of the corrective action taken against discrepancies 

discovered between inspections.

14. The Pilot in Command (PIC) must possess at least a private pilot certificate and at least a current 

third-class medical certificate. The PIC must also meet the flight review requirements specified in 14 CFR 

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

15. The operator may not permit any PIC to operate unless that PIC has demonstrated through the 

operator’s training that the PIC is able to safely operate the UAS in a manner consistent with how the 

UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. A record of training must be 

documented and made available upon request by the Administrator. Flights for the purposes of training 

the operator’s PICs and VOs (training, proficiency, and experience-building), are permitted under the

terms of this exemption. However, said training operations may only be conducted during dedicated 

training sessions.

16. UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations must be 

conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) 

are not authorized.

17. All operations shall be conducted in Class G airspace.

18. The UA may not operate within 5 nautical miles of the airport reference point as denoted on a current 

FAA-published aeronautical chart.

19. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud 

or when visibility is less than 3 statute miles from the PIC.

20. If the UA loses communications or loses its GPS signal, it must return to a predetermined location 

within the planned operating area and land or be recovered in accordance with the operating documents. 

21. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with 

the operating documents.

22. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point and land 

the UA with 30% battery power remaining.

23. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will 

also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but 

not less than 48 hours prior to the operation.

24. All aircraft operated in accordance with this exemption must be identified by serial number, registered 

in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 

CFR part 45, Subpart C. Markings must be as large as practicable.

25. Before conducting operations, the radio frequency spectrum used for operation and control of the UA 

must comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

26. The documents required under 14 CFR 91.9 and 91.203 must be available to the PIC at the Ground 

Control Station of the UAS any time the aircraft is operating. These documents must be made available to 

the Administrator or any law enforcement official upon request.

27. The UA must remain clear and yield the right of way to all other manned aviation operations and 

activities at all times.
UAV-IQ LLC Ph: 310-497-9389 Email: info@uav-iq.com

28. The UAS may not be operated by the PIC from any moving device or vehicle.

29. The UA may not be operated over congested or densely populated areas.

30. Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain 

under such protection. If a situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flight operations must cease immediately and/or; 

b. the aircraft is operated near vessels, vehicles or structures where the land owner/controller has 

granted permission and the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and

c. operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue 

hazard to those persons per § 91.119(a).

31. All operations shall be conducted over private or controlled-access property with permission from the 

land owner/controller or authorized representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.

32. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office 

(AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. 

We look forward to working with your office. Please contact us at any time if you require additional information 

or clarification. 

UAV-IQ requests the FAA treat Appendices B, C, D and E as proprietary under 14 C.F.R. 11.35(b) and does 

not include these documents in the public docket.

The name and contact information of the applicant are: 

UAV-IQ LLC 

Attn: Andreas Neuman 

Ph: 310-497-9389 

Email: aneuman@uav-iq.com 

 Sincerely, 

 

 Andreas Neuman

 Chief Executive Officer

Appendices: 

A. Exemption Request and Equivalent Level of Safety 

B. Maintenance Procedures 

C. Training Program 

D. Aviation Experience

E. User Manual
UAV-IQ LLC Ph: 310-497-9389 Email: info@uav-iq.com

APPENDIX A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

UAV-IQ requests an exemption from the following regulations as well as any additional regulations that may 

technically apply to the operation of the SenseFly eBee Ag: 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot 

privileges and limitations. 

The regulation provides 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; 

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

Since there are currently no means available for the pilot of a UAS to gain the experience in an equivalent category 

and class in order to apply for a commercial pilot's license, we propose to generate an equivalent level of safety by 

requiring our pilots to hold a private pilot certificate. Since the aircraft cannot carry passengers or property, we 

feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a 

business. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to 

any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we 

cannot comply with this requirement. 

To provide an equivalent level of safety we will only fly over private property with the permission of the land 

owner. The land owner will be briefed of the expected route of flight and the associated risks to persons and 

property on the ground. We maintain that due to the small size of the eBee Ag, the hazard to persons, vessels, 

vehicles, and structures is not comparable to manned aircraft and should be considered in granting the exemption. 

(See appendix C section 6.4.1 Consideration about risks related to ground impacts) 

The aircraft will not be operated over congested areas nor over any open air assembly of persons. The aircraft will 

be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or 

property on the surface. 

14 CFR 91.121 Altimeter settings. 

The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting available 

within 100 nautical miles of the aircraft. The aircraft will fly below 400 feet AGL and will not need to maintain 

hemispherical cruising altitudes in order to de-conflict with other aircraft. As such, an appropriate altimeter 

measurement presented to the pilot should be Above Ground Level and should be based on the barometric pressure 

at the point of launch. To provide an equivalent level of safety, the UAS's AGL altimeter will be set to zero on the 

ground prior to every flight. Since the aircraft will fly no more than 50 minutes, even rapid changes in barometric 

pressure will have limited effect on the safety of the flight. 

14 CFR 91.151 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. We feel the 

intention of this paragraph is to provide a reserve of energy as a safety buffer for go-arounds and other delays to 

landing. 

The eBee Ag is battery operated and the maximum duration of flight from a single battery charge is 50 minutes. 

Since the aircraft will never fly more than 1/2 nm from the point of intended landing, a full battery charge at launch 

will ensure that we meet the reserve energy requirement of this paragraph. 
UAV-IQ LLC Ph: 310-497-9389 Email: info@uav-iq.com

The PIC will not initiate flight unless there is enough power to fly to the first point of intended landing and, 

assuming normal cruising speed, land the UA with 30% battery power remaining.

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 part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be 

"approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our 

intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft 

for return to service." 

As provided in the attached Maintenance Procedures (Appendix D) and User’s Manual (Appendix E), the PIC will 

ensure that the aircraft is in an airworthy condition prior to flight and conduct detailed inspections after every 10 

hours. UAV-IQ requests the FAA treat these two documents as proprietary under 14 C.F.R. 11.35(b) and does 

not include these documents in the public docket.

Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, and updating software 

and firmware. All other maintenance will be performed by the manufacturer. The PIC will document work 

performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the 

PIC can ensure an equivalent level of safety.