MARK R PAULSON – ADDENDUM TO EXEMPTION RULEMAKING REQUEST

July 8, 

2015U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE.,

Washington, DC 20590

Submitted Electronically via the Federal Docket Management System (FDMS) 

Re: Addendum to Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations

Dear Sir or Madam:

I, Mark R. Paulson. RPLS, have prepared the following addendum to my Exemption Request filed on May 

14th 2015. This Addendum allows for the inclusion of a Fixed Wing UA to the original request

 Sensefly eBee

THE UNMANNED AIRCRAFT (UA):

 The UA is a lightweight (under 1.5 lb. gross weight), battery operated delta wing aircraft capable 

of manual and fully automated flight.

THE UA INCLUDES:

 An on-board flight computer with GPS navigation and location ability that receives signals for 

flight controls from a ground-based transmitter/controller;

 An on-board camera capable of capturing imagery in the form of full color, high definition still 

photos and video

 An on-board telemetry system that delivers flight data from the on-board flight computer to the 

on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass 

direction of flight and direction back to its launch site

 An on-board radio transmitter that transmits the flight data from the telemetry system 

described above to the ground station

THE GROUND STATION PART OF THE SYSTEM:

 A Pilot in Command (PIC) In operational control of a mission from beginning to end, and who 

controls the UA while in the air

 A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight

 Ground Station (computer/tablet) which receives and displays system telemetry real time from 

the UA

 A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UA 

while in flight.

o Appendix A is part of the original request and pertains to flight operations

o Appendix B is part of the original request and includes the DJI Phantom 2 Vision’s User’s Manual

o Appendix C is part of the original request and includes the DJI Inspire 1’s Users’ Manuals. 
MARK R PAULSON – ADDENDUM TO EXEMPTION RULEMAKING REQUEST

 Appendix D (Attached here) pertains to the flight procedures for the eBee

 Appendix E (Attached here) and includes a link to the eBee user’s manual

This Addendum makes no other changes to the original request including exemptions sought, reasons 

for exemption request, and/or operating parameters.

The name and contact information of the applicant remains the same: 

Sincerely,

Mark R. Paulson, RPLS

Phone: 210.896.3384

Email: markp@proseals.com
MARK R PAULSON – APPENDIX D FLIGHT PROCEDURES FOR THE eBee

APPENDIX D – FLIGHT PROCEDURES FOR THE EBEE

Fixed Wing aircraft differ from Multi Rotors (Rotorcraft) in their takeoff and landing procedures. For this 

reason the pre-flight checklist and operating/flight procedures below are provided. 

PRE-FLIGHT CHECKLIST

Prior to operation preflight checklists provided by the manufacturer of the UA’s will be followed. Below 

is such an example.

 Remote Controller, Batteries, and Ground Station Computer/tablet are fully charged.

 Propeller is mounted correctly.

 Camera lens cap has been removed.

 Camera Micro-SD card has been inserted.

 Attach wings.

 Connect battery.

 Confirm motor can start and are functioning as normal.

 Ground Station Computer/Tablet can connect to the camera.

 Pre Programmed Mission is queued.

TAKE OFF/LANDING PROCEDURES

Manufacturer recommended Takeoff and Landing procedures will be followed.

TAKE OFF

 Power on the Remote Controller.

 Power on the Camera.

 Power on the aircraft.

 Connect the Ground Station Computer/Tablet to the UA.

 Wait for GPS Signal to lock and the aircraft to initialize entering the “Ready to Fly’ mode.

 Initiate Launch.

LANDING

 Aircraft will loiter upon completion of mission.

 Confirm landing site is clear of any obstructions or personnel.

 Initiate landing.
MARK R PAULSON – APPENDIX D FLIGHT PROCEDURES FOR THE eBee

FAILSAFE FUNCTION

The UA will enter Failsafe mode when the connection from the remote controller is lost. The flight 

control system will automatically control the aircraft to return to home and land to reduce injuries or 

damage. The following situations would make the aircraft fail to receive a signal from the remote 

controller and enter Failsafe mode:

 The remote controller is powered off.

 The aircraft has flown out of the effective communication range of the remote controller.

 There is an obstacle obstructing the signal between the remote controller and the aircraft, 

essentially reducing the distance the signal can travel.

 There is interference causing a signal problem with the remote controller.
MARK R PAULSON – APPENDIX E USERS MANUAL FOR THE eBee

APPENDIX E USERS MANUAL FOR THE SENSEFLY eBee

The SenseFly eBee user’s manual is over 25mb. 

A link to the document can be found here

https://www.sensefly.com/fileadmin/user_upload/sensefly/documents/brochures/eBee_en.pdf