### February 25, 2016
U.S. Department ofTransportation Do cket Management Sy stem 1200NewJer s ey Ave., SE W as hington, DC 20590 Re; ReQUest for Summary Grant of Exemption under Section 333 of the FAA Reform Act and Part llof the Federal Ayjation Regulations Dear Madam or Sir, Pursuant to Section 333 of the FAA Moderni zati o n an d Refonn Act of 2012 (the "Refon n Act") an d 14 C
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. Part 11 ,The Lane Construction Corp. , a n engineering a nd constru cti on company, an op erato r of the eB ee ( "eBee ») Small Unmanned Airc r aft System ('sUAS') seeks a summary gra nt of exemp tio n from the Federal Aviation Regulation s ("FARs") li sted below ba sed on exemption 11136 pr eviously is sued by the Fede r al Aviation Administration on Ja nuary 5, 2015:

• 14 C
.F.R. 61.133(a) (b) • 14 C
. F.R. 91.7(b) • 14C.F. R.91. 119 • 14C.F.R.91.15l(a) • 14 C FRSubpart E(91.401-91.417) The requested exemption would authorize com m ercia l op erations using the eBee for aerial imaging and survey m appi n g for safety and monitoring of secured and controlled construction s ite
. The sU AS o perati ons will be subje c t to strict operating requireme n ts d e fin ed in the eBee u ser manual ( The Lane Construction Corp
. re q ues ts the FAA treat the eB ee training pr ogram as proprietar y under 14 C
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. II JS(b) a nd does n ot include this d ocument in t he public docket) in order to ensure at le ast an equivalent level of safe ty to currently authorized operations usin g manned aircrafts. Th e eBee will be operated by an individual who fulfill the following requirements:
• Has successf ully pa ssed a manuf a ctur er's trainin g program for the eBee ; The Lane Constru c tion Corp. requests the FAA treat the eBee training pro gam as proprietar y under 14 C.F
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. 11.35(b) and does not include this document in the public docket.
1. 

### CHARACTERISTICS OF THE AI RCRAFT The eBee i s a small (37.8 inches wings p an) and ultra-light (maximum take-off weig ht of I. 

### 7 (pounds) platform made of flexible foam th at performs pre-pro gramm e d preci sion aerial mappin g mi ssi ons thanks to the on-board G PS and the related flight management software (eMotion) that a llo ws the operator to plan saf ely and effi ci ently a mission i n 30, and then monitor it in real-time T hanks to the embedded camera, protected by a foam envelope, the eBee take s a collection of hi g h-definition still imag es that are used later to generate maps and contour line s of the surveyed area.The four main characteristic s of the eBee are:
a. Very light weight The eBee i s so li ght that the operator can launch it by hand and let it lan d on almost an y s urface without requiring a para chu te or lan ding net {belly land) .Its low impact energy (38 J in case of a contro lled emergency lan din g) also significantly reduces the ri sk of hazardous s ituati o n s. Finally, th e 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 i s e lectric po wered . A brushless engine technology make s it s ilent and reliable. The propeller is attached wi th a rubber band to the bod y of the plane so that it ca n easily fle x away in case of contact with any object.
c. Semi-automatic fli g ht The artificial intelligen ce in co rporated within th e eBee autop ilot syste m continuously anal yzes data from t he Inertial Mea s ure ment Unit and from the onboard GPS and takes care of all th e aspects of the flight under th e supervision ofthe o perator . d
. Option for Manual control Addition a ll y , the eBee provides an o v erride capability th at allow s the operator to take m a nual action s during the flight (Go to Home, Go L and , Hold and Re s um e th e mi ssi on) and also s u spend au tomated operations and take manual co ntrol of the aircraft s hould it become ne cessary to respond emergent c ircum s tances, thanks to the remote contro ller provid e d with the system. 

### 2. APP L ICATIONS The Lane Co nstru c ti o n Corp. intends to use the eBee to conduct imaging fli ght s for the purpose of safe ty and s urvey mappin g. The aircraft will be u sed over co ntrolled access property an d only be used to imag e pro pert y for which we h ave been co ntra cted b y the land owner to do so. Im ages will be u se d to incre ase production , identify environmenta l land iss u es and allow for lan d u se p lann ing. 

### 3. APPLICABLE LEGAL STANDARD UNDER SECTION 333
a . Airworthine ss assessment of the eBee The Lane Co ns truction Corp. no tes that the Federal Aviation Administration ha s already i ssued an exemption specific to the eB ee to the previously listed regulations for the s ame purpose in w hi c h The Lan e Co n struc tion Co rp . intends to u s e the sUAS Moreover , SenseFly obtained fli ght approvals for the eBee {deli vered by n ational civil aviation authorities) in many countrie s, amon g others :
• Switzerland (flight approval for VLOS operation s) • Canada (flight approval for V LOS operation s) • Australia (flight approva l for VLOS op e rati o n s) • Fra nc e (flight approval for Extended- VLOS operations) • Germany (flight approval for V LOS op e r ation s) • Uni te d Kingdom (flight appro va l for VLOS operations) • Norway (flight approval fo r VLOS operations)b. Operating requirements A summary grant of exemption to The Lane Construction Corp. for the eBee will be subject to the same operating conditions issued by the Federal Aviation Administration, without deviation or alteration , in exemption No.lll36 on January 5, 2015.The main restr iction s are summarized below: 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 weighin g approximate l y 1.5 pounds: senseF ly eBee (eBee ). Proposed operations of any other aircraft wi ll 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 ind icated by the procedures specified in the operating documents. All altitudes reported to A TC 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 vi sion unaided by any device other than corrective lenses , as specified on the PIC's FAA-issued ainnan 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 thi s grant of exemption must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitati ons in this exemption and the procedures outlined in the operating documents, the co nditions and limitations herein take precedence and must be fo ll owed. 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 respons ibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must al so present updated and revised documents if it petitions for extension or amendment to this gra nt of exemptio n . 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 amendmen t to its grant of exemption
. The FAA's sUAS 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 sUAS to ensure it i s in a co ndition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft is prohibited from operating until the necessary maintenance has b een performed and the sUAS is found to be in a condition for safe flight. The Ground Contro l Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 8. Any sUAS maintenance or alterations that affect the sUAS operation or flight characteri stics , e.g. replacement of a flight critical component, must undergo a functional test flig ht. The PIC who conducts the fu nctional test flight must make an entry in the aircraft records.9. The pre-flight in spection section in the operating document s mu s t account for a ll di s crepancies , i.e. inoperable components , items , or equipment, not already covered in the relevant sections of the operating documents. I 0. The operator must follow the sUAS aircraft/component, maintenance , overhaul , replacement, in spection , and life limit requirements. 11. The operator must cany out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, in specti on, 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 sUAS to service
. 12. Each s UAS operated under thi s exemption mu st comply with all manufacturer System a nd Safety Bulletins. 13
. The PIC must make an entry in the aircraft record of the corrective ac tion taken again s t di s crepancie s discovered between inspections
. 14
. The Pilot in Command (PIC) will be trained in flight , operations and safety procedures as detailed in the Flight Manual. 15. The operator may not permit any PIC to opera te unless that PIC has demonstrated through the opera tor's training that the PIC is able to safe ly operate the sUAS in a manner consistent with how the sUAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons , ve s sel s, vehicles and structures . A record of training mu s t be documented and made available upon reques t by the Administrator. Flights for the purposes of training the operator's PICs and V Os (training & proficiency , and experience-building) , are permitted under the terms of thi s exemption. However , said training operations may on l y be conducted during dedicated training session s . 16
. s UAS operation s may not be conducted during night, as defined in 14 

### CFR 1.1. All operations mu st be conducted under vi sual meteorological conditions (VMC). Flights under special vi sual flight rules (SVFR) are not authorized
. 17
. All operations shall be conducted in Cl as s G air space. 18. The UA ma y not operate within 5 nautical mi le s of the airport reference point as denoted on a cunent FAA-publi shed aeronautical chart. 19. The UA may not be operated less than 500 feet below or le ss 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 lo se s its GPS signal , 

### it must return to a pre-determined 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 m accordance with the operating documents. 22
. The PIC is prohibited from beginning a flight unless (cons iderin g wind and foreca s t weather conditions) there is enough power to fly at nonnal 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 ) i ss ued Certificate of Waiver or Authori zation (COA) prior to conducting any opera tions under thi s grant of exemption
. Thi s COA wi ll also require the operator to request a Noti ce to Airman (NOTAM) n ot more th an 72 hours in advance, but not less than 4 8 hours prior to the operation
. 24
. All a ircra ft operated in accordance with this exemption must be identified by seria l number , regi stered in accordance with 14 CFR part 47 , and ha ve identification (NNumber) markings in accordance with 14 CFR part 45,Subpart C
. Marking s must be a s large as practicable
. 25. Before conducting operations , the radio frequency spectrum u sed for operation and control of the UA must comply with the Federal Communication s Commission (FCC) or other ap p rop riate government oversight age ncy requirements. 26. The documents requir ed under 14 C FR 91.9 and 91.203 mu s t b e available to the PIC at the Ground Control Station of the sUAS any tim e the aircraft is operating. The s e documents must b e made av ailable 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 time s. 28. The sUAS may not be operated by the PI C f r om any moving de vice or vehicle. 29. The UA may not be operated over congested or densely populated areas . 30. Fl ight operations must be conducted at leas t 500 feet from all nonparticipating pe rso ns , vessels, vehicles , and structure s unles s :
a. Barriers or structures a r e present that sufficiently protect nonparticipating persons from the UA and / or deb ris in the event of an accident. The operator mu st ensure that nonparticipating person s remain under su ch protection
. If a s itu ation arises where nonparticipating pers ons leave such protection and are within 500 feet of the U A , fli g ht operations must cease immediately and / or; b
. the aircraf t i s operated near vessel s, veh icle s or structures where the land owner/controller ha s granted permission an d the PIC has made a safety assessment of the risk of operating closer to tho se obj ects and determined that 

### it doe s not pre sent an undue hazard , and
c. operations nearer to the PIC, VO, operator trainees or e ss ential persons do not present an undue haz ard to those persons per§ 91.119(a). 31. All operations sha ll be condu cted over private or c ontrolled-access property with pennission from the l and owner/controller or authorized representative. Perm ission from land owner/controller or authori zed rep resentative will be obtained for each flight to be conducted. 32. Any inciden t, accident , or flight operation th at transgresses the lateral or vertica l boundarie s of the operational area as defined by the a ppli ca ble COA must be reported to the FAA's sUAS Integration Offi ce (AF5-80) within 24 hours . Accidents must b e reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web si te: www . nt sb
. gov .

### 3. CONCLUSION This reque st is designed to foll o w up on previou s efforts by the Federal Aviation Admini stration to determine equiva l ent levels of safety for sUAS operations. By reque sting a summary grant of exemption we hope to achi eve expedited approval for 

### sUAS operations to the public's benefit.

Yours sincerely , / Anthon y Todd Corporate Survey Manager The Lane Construction Corp
.ANNEX A : EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULESSUBJECTTO EXEMPTION The Lane Construction Corp. requests an exemption from the following regulations as well as any additio n al regulations that may technically apply to the operation of the eBee: 14 CFR 61.133: Commercial pilot privileges and limitations. The regulation provides that no person that hold s 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. To obtain a commercial pilot certificate a candidate must demonstrate a level of aeronautical knowledge and aircraft handling beyond what i s required to operate a sUAS. Our proposed operations would require that a Pilot-In-Command have the aeronautical knowledge and aircraft handling ski ll s currently required obtaining a private pilot certificate. Given the lack of passengers or cargo on board the sUAS, controlled access operations area we operate in and the simplicity of the sUAS we believe that an equivalent level of safety can be achieved by requiring the Pilot in Command hold , at a minimum, a private pilot certificate and a third clas s medical certificate or U.S. Driver's license. 14 CFR 91.7(a): Civil aircraft airworthiness This regulation requires that no person may operate a civi l aircraft unless 

### it is in airworthy condition. Should the exemption be granted allowing co mmercial operation ofthe eBee without an airworthiness certificate, no standard will exi st for airworthiness of the eBee. Given the size of the aircraft and the previou s airworthiness assessments given to the eBee , among others:

• New Mexico State University: https : //

newscenter.nmsu.edu/Articles/view / 10208/nm su-uas-flighttest-center -conducts-ebee-airworthiness-as sessment
• 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 SenseFly manuals prior to each flight. 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 s tructure. Since the aircraft will be operating at a maximum of 400 feet AGL, the eBee cannot comply with this requirement.The equiva lent level of safety will be achieved becau se the eBee will only fly over private property with th e pennission of the landowner. The o perato r will define before every flight a w o rkin g area radiu s and a flight area ceiling, preventin g the eBee to go beyond the flight area. The land owner and the p er sons who m ay be on the ground in the fli ght area will be briefed of the expected route of fl ight and the associated risk s to perso ns and property on the ground. Due to the sm all s ize of the eBee and the material with which the eBee i s built, the hazard to persons , vessels, vehicles , and s tructure s i s not comparable to manned aircraft and should be considered in granting the exemption. M o r eover , 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 fail s, an emergency landing without undue hazard to perso ns or property on the surface. 

### 14 

### CFR 91.151(a) : Fuel Requirements for Flight in VFR Conditions The regulation provi de s that no p erson may begin a fl ight in an airplane under day- VFR co ndi tio n s unle ss th ere is enough fuel to fly to the first poi nt of intended landing and to fly after that for at lea st 30 minute s . Given the area of operation for the eBee , believes that an equivalent level of saf ety i s a lre ad y achieved with the specific procedure preventin g th e eBee to accept a take-off order is the battery level i s below a given value. Moreover, SenseFiy ha s integrated "low" and un critic al battery level warnings and implemented a "return to Home" (and 

### '·Go Land ") actions in the se s ituation s. 

### 14 

### CFR Subpart E (91.40191.417) ·Maintenance, Preventive Maintenance, and Alterations The regulation pro v ide s that the operator i s primarily res pons ible for maintaining the aircraft in an airworthy condition, including compliance with Parts 39 and 43
. Paragraph s 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. Section 91.409(a)(2) require s an annual in s pection for th e is s uance of an airworthiness certificate. Section 91.417(a) require s the owner or operator to keep records s howing certai n maintenance work that ha s been acco mpli sh e d b y certificated me c hani cs, under Part 43, or licen sed pilots and records of approva l of the a ircraft for return to service
. The Lane Co ns tru ction Corp. propo ses that the mainten ance of the eBee will be accomplished by the ow ner / op erator according to th e mainte n ance manual, prov ided by SenseFiy
. The Lane Co nstru ctio n Corp. requests the FAA treat the eBee trainin g program as proprietary under 14 C.F .R. 11 .35(b) and not include this document in the public doc ket. An equivalent level of safety will be achieved because the eBee i s small in s ize , it i s not a co mplex mechanical device, it will carry no external paylo ad , and it will operate only in restricted pred et e rmined areas. Moreover, the operator i s the pers on most familiar with t he a ircraf t and i s be s t s uited to maintain the aircr aft in an airworthy cond iti on and to ensure an equ iva lent level of safety. Finall y, before every flight , the eBee run s automatically a sequence of pre-flight tests to make sure that every s en so r and every critical part is running properly. If a problem is dete c t e d , the eBee will not be able to be sw itched-on and a message error i s di splayed on the main sc reen of the flight mana ge ment so ftware
. The operator can then refer to the maintenance manu a l to trouble s ho o t this issue. Several parts of the eBee are easily interchang eable (propellers , wings), which allows the operator t o make sure the wings and propul s ion system are always airworth y when a mission is initiated
.