### April 22, 2015

Exemption No. 11407 Regulatory Docket No. FAA–2015–0130

Mr. Andreas Neuman

Chief Executive Officer UAV-IQ LLC

11734 Wilshire Boulevard #C805 Los Angeles, CA 90025

Dear Mr. Neuman:

This letter is to inform you that we have gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated January 15, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of UAV-IQ LLC (herei nafter petitioner or operato r) for an exemption. The exemption would allow the petitioner to opera te an unmanned aircraft system (UAS) to conduct precision photogrammetry and crop sc outing at the resolutions necessary for precision agriculture.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is an eBee Ag.

### 2

In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consider ation of the size, weight, speed, and limited operating area associated with the aircraft a nd its operation, the Secret ary of Transportation

has determined that this airc raft meets the conditions of Section 333. Therefore, the FAA finds that the relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial da ta collection. The FAA has issued grants of exemption in circumstances similar in all materi al respects to those pr esented in your petition. In Grants of Exemption No s. 11062 to Astraeus Aerial ( see Docket No. FAA

− 2014

− 0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA

− 2014

− 0382), and 11213 to Aeryon Labs, Inc. ( see Docket No.

FAA

− 2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifica tions described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gi ves the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a gr ant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, UAV-IQ LLC is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5 ), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) a nd (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to opera te a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, UAV-IQ LLC is hereafter refe rred to as the operator.

### 3

Failure to comply with any of the conditions an d limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the eBee Ag when weighing less than 55 pounds including pa yload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restricti on. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. 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 or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C and VO at all times. 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; electronic messaging or texting is not perm itted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must en sure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepa ncy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents,

the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised documents to the Administrator or any la w enforcement official upon request. The

### 4

operator must also present updated and revise d 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 an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questi ons arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e .g. replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functi onal test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. Th e pre-flight inspection must account for all potential discrepancies, e .g. inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exempti on must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the f light review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs

### 5

(training, proficiency, and e xperience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditi ons (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the ai rport management must be made available to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the pr ivate or controlled-access property.

19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that fo r at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Author ization (COA). All operations shall be conducted in accorda nce with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.

22. All aircraft operated in accord ance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

### 6

23. Documents used by the operator to ensure th e safe operation and flight of the UAS and any 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 th e Administrator or any law enforcement official upon request.

24. The UA must remain clear and give wa y to all manned aviation operations and

activities at all times.

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

26. All 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 pr otect 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 in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or struct ures has granted permission for operating closer to those objects 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.

The PIC, VO, operator trainees or es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/cont roller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. 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 Sa fety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for th e purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)

as documented in this grant of exemption.

### 7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction ove r the area of proposed filming. The 3-day notification may be waived w ith the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person res ponsible for the on-s cene operation of the UAS;

d. Make, model, and serial or N

− Number of UAS to be used;

e. Name and certificate number of UAS PI Cs involved in the aerial filming;

f. A statement that the operator has obtain ed permission from property owners

and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;

g. Signature of exemption holde r or representative; and

h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from pa rticipating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on April, 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards ServiceUAV

- 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 2 012 (the “Reform Act”) and 14 CFR Part 11, UAV

- I Q 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.

Th e aviation experience of the applicants and the type of agricultural ope rations 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 e xemption 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 associate d 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 vari able 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 benefi ts to both agriculture and the environment which are ultimately in the public interest.

Unless otherwise specified in this grant of exemption, th e UAS, the UAS PIC, and the UAS operations will comply with all applicable parts of 14 C F R including, but not limited to, parts 45, 47, 61, and 91. These operations will also be subject to strict operating requirements d efined in the eBe e 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 air c raft performing the

same mission.

In regards to privacy concerns, a ll flig hts 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 exempti on 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 g rant.

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

3. The UA must be operated at an altitude of no more t han 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 le nses, as specified on t he

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 opera ting 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 exe mption. 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 conta cted 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 a lterations 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 w ho 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 t he 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 ra ted 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 ope rations 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 o r 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 (cons idering 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 Certif icate 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 th e 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 mu st 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 requirement s.

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 co ngested 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 s tructures where the land owner/controller has granted permission and the PIC has made a safety assessment of the risk of operating closer to those

ob jects 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 priv ate 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 Tran sportation 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 the s e document s 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 ManualUAV

- 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 A g:

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 f or 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 ca rry 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 condu ct 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 require ment.

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 pers ons 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 bel ow 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 barome tric 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 baromet ric

pressur e will have limited e ffect 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 t o 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 o f 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)

- Maintena nce, 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 th e 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 at tached Maintenance Procedures (A ppendix 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 the s e document s in the public docket

.

Maintenance performed by the PIC is li mited 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, constr uction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.