April 15, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Request for Summary Grant of Exemption Under Se ction 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Madam or Sir,

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11 Skanska USA Civil, an enginee ring and construction company, an operator of the eBee (“eBee”) Small Unmanned Aircraft System (‘sUAS ’) seeks a summary grant of exemption from the Fede ral Aviation Regulations (“FARs”) listed below based on exemption 11136 previously issued by the Federal Aviation Administration on January 5, 2015:

• 14 C.F.R. 61.133(a) (b)

• 14 C.F.R. 91.7(b)

• 14 C.F.R. 91.119

• 14 C.F.R. 91.151(a)

• 14 CFR Subpart E (91.401 - 91.417)

The requested exemption would authorize comm ercial operations using the eBee for aerial imaging and survey mapping for safety and monitoring of secured and controlled construction site . The sUAS opera tions will be subject to strict operating requirements defined in the eBee user manual (Skanska USA Civil request s the FAA treat the eBee training program as proprietary unde r 14 C.F.R. 11.35(b) and does not include this docu ment in the public docket) in order to ensure at least an equiv alent level of safety to currently authorized opera tions using
manned aircrafts.

The eBee will be operated by an individual who fulf ill the following requirements:

• Has successfully passed a manufacturer’s training p rogram for the eBee; Skanska USA Civil requests the FAA treat the eBee training program as proprietary under 14 C.F.R. 11.35(b) and does not include this document in the public docket.

• Has, at a minimum, a Private Pilot license and a th ird class medical certificate or US Driver’s Licens e.

1. CHARACTERISTICS OF THE AIRCRAFT

The eBee is a small (37.8 inches wingspan) and ultr a-light (maximum take-off weight of 1.7 (pounds) platform made of flexible foam that perfor ms 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 i t 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 re duces the risk of hazardous situations. Finally, the wings of the eBee are detachable and made of fl exible foam with no sharp or hard edges and almost no internal strengthening structure.

b. Electric-powered

The eBee is electric powered. A brushless engine te chnology makes it silent and reliable. The propeller is attached with a rubber band to the bod y of the plane so that it can easily flex away in case of contact with any object.

c. Semi-automatic flight

The artificial intelligence incorporated within the eBee autopilot system continuously analyzes
data from the Inertial Measurement Unit and from th e 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 capabil ity that allows the operator to take manual actions during the flight (Go to Home, Go Land, Hol d 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 remot e controller provided with the system.

2. APPLICATIONS

Skanska USA Civil intends to use the eBee to conduc t imaging flights for the purpose of safety and sur vey mapping. The aircraft will be used over controlled access pr operty and only be used to image property for which we have been contracted by the land owner to do so. Images will be used to increase production, identify envir onmental land issues and allow for land use planning.

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333

a. Airworthiness assessment of the eBee

Skanska USA Civil notes that the Federal Aviation A dministration has already issued anexemption specific to the eBee to the previously li sted regulations for the same purpose in which

Skanska USA Civil intends to use the sUAS.

Moreover, SenseFly obtained flight approvals for th e 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 operation s)

• 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

A summary grant of exemption to Skanska USA Civil f or the eBee will be subject to the same operating conditions issued by the Federal Aviation Administration, without deviation or alteration, in exemption No. 11136 on January 5, 20 15. The main restrictions are summarized
below:

1. Operations authorized by this grant of exempti on are limited to the following aircraft described in the operating documents which is a fixed-wing aircraft weighing approximately 1.5 pounds: senseFly eBee (eBee ). Proposed operations of any other aircraft will require a new petition or a pet ition to amend this grant.

2. The UA may not be flown at an indicated airsp eed 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 spec ified in the operating documents. All altitudes reported to ATC must be in feet AGL.

4. The UA must be operated within visual line o f sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human v ision 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 observ er (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 a t 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 fu nctions prescribed in the operating documents.

6. The operating documents and this grant of e xemption must be maintained and made available to the Administrator upon reques t. 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 operatin g documents. It is the operator’s responsibility to track such revisions and present updated a nd revised documents to the Administrator uponrequest. The operator must also present up dated and revised documents if it petitions for

extension or amendment to this grant of ex emption. 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 amendm ent to its grant of exemption. The FAA’s sUAS Integration Office (AFS-80) may be contact ed if questions arise regarding updates or revisions to the operating documents.

7. Prior to each flight the PIC must inspect th e sUAS to ensure it is in a condition for safe flight. If the inspection reveals a conditi on that affects the safe operation of the sUAS, the aircraft is prohibited from operating until the necessary maintenance has been performed
and the sUAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. Al l maintenance and alterations must be properly
documented in the aircraft records.

8. Any sUAS maintenance or alterations that aff ect the sUAS operation or flight characteristics, e.g. replacement of a flig ht critical component, must undergo a functional test flight. The PIC who conducts the funct ional test flight must make an entry in the
aircraft records.

9. The pre-flight inspection section in the ope rating documents must account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating document s.

10. The operator must follow the sUAS aircraft/c omponent, maintenance, overhaul, replacement, inspection, and life limit r equirements. 11. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the oper ating documents. Maintenance, inspection, and
alterations must be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of th e PIC returning the sUAS to service.

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

13. The PIC must make an entry in the aircraft r ecord of the corrective action taken against discrepancies discovered between inspectio ns.

14. The Pilot in Command (PIC) will be trained i n flight, operations and safety procedures as detai led in the Flight
Manual.

15. The operator may not permit any PIC to opera te unless that PIC has demonstrated through the operator’s training that the PIC is ab le to safely operate the sUAS in a manner consistent with how the sUAS will be opera ted under this exemption, including evasive and emergency maneuvers and maintaining approp riate distances from persons, vessels,
vehicles and structures. A record of train ing 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 operatio ns may only be conducted during dedicated training sessions.

16. sUAS operations may not be conducted during night, as defined in 14 CFR 1.1. Alloperations must be conducted under visual meteorological conditions (VMC). Flights

under special visual flight rules (SVFR) a re not authorized. 17. All operations shall be conducted in Class G airspace.

18. The UA may not operate within 5 nautical mil es of the airport reference point as denoted on a current FAA-published aeronautical ch art.

19. The UA may not be operated less than 500 fee t below or less than 2,000 feet horizontally from a cloud or when visibility is less t han 3 statute miles from the PIC.

20. If the UA loses communications or loses 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 o f unpredicted obstacles or emergencies in accordance with the operating documents.

22. The PIC is prohibited from beginning a fligh t 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% bat tery power remaining.

23. The operator must obtain an Air Traffic Orga nization (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 les s than 48 hours prior to the operation.

24. All aircraft operated in accordance with thi s exemption must be identified by serial number, registered in accordance with 14 C FR 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 freq uency spectrum used for operation and control of the UA must comply with the Federal Com munications Commission (FCC) or other appropriate government oversight agency re quirements.

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 sUAS any tim e the aircraft is operating. These documents
must be made available to the Administrato r 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.

28. The sUAS 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 leas t 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 re main under such protection. If a situation ariseswhere nonparticipating persons le ave such protection and are within 500 feet of the

UA, flight operations must cease immediately and/or;

b. the aircraft is operated near ves sels, vehicles or structures where the land owner/controller has granted pe rmission 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 priva te or controlled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized repre sentative 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 defi ned by the applicable COA must be reported to the FAA's sUAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Boar d (NTSB) per instructions contained on the
NTSB Web site: www.ntsb.gov.

3. CONCLUSION

This request is designed to follow up on previous e fforts by the Federal Aviation Administration to determine equivalent levels of safety for sUAS o perations. By requesting a summary grant of exemption we hope to achieve expedited approval for sUAS operations to the public’s benefit.

Yours sincerely,

Andrew Deveney GPS systems Manager
Skanska USA CivilANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAF ETY

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

Skanska USA Civil requests an exemption from the fo llowing regulations as well as any additional regulations that may technically apply t o the operation of the eBee:

14 CFR 61.133: Commercial pilot privileges and limi tations.

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. Su bparagraph (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 candidat e must demonstrate a level of aeronautical knowledge and aircraft handling beyond what is requ ired to operate a sUAS. Our proposed operations would require that a Pilot-In-Command ha ve the aeronautical knowledge and aircraft handling skills currently required obtaining a priv ate pilot certificate. Given the lack of passengers or cargo on board the sUAS, controlled access opera tions area we operate in and the simplicity of the sUAS we believe that an equivalent level of saf ety can be achieved by requiring the pilot in command hold, at a minimum, a private pilot certifi cate and a third class medical certificate or U.S. Driver license.

14 CFR 91.7(a): Civil aircraft airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowin g commercial operation of the eBee without an airworthiness certificate, no standard will exis t for airworthiness of the eBee. Given the size of the aircraft and the previous airworthiness assessm ents given to the eBee, among others:

• New Mexico State University: https://newscenter.nmsu.edu/Articles/view/10208/nms uuas-flight-testcenter-conducts-ebee-airworthiness-assessment

• USACE New Orleans, who coordinated with the Departm ent of Army and the FAA to obtain all authorizations required in order to operate the eBeeUAS for levee system monitoring, documentation of constr uction progress, and extensive oblique photography
of USACE structures & activities

An equivalent level of safety will be achieved by i nsuring compliance with the SenseFly manuals prior to each flight.

14 CFR 91.119: Minimum Safe Altitudes

The regulation provides that over sparsely populate d areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or st ructure. Since the aircraft will be operating at a maximum of 400 feet AGL, the eBee cannot comply wit h this requirement.

The equivalent level of safety will be achieved bec ause the eBee will only fly over private property with the permission of the landowner. The operator will define before every flight a working area radius and a flight area ceiling, prev enting the eBee to go beyond the flight area. The landowner and the persons who may be on the gro und in the flight area will be briefed of theexpected route of flight and the associated risks t o persons and property on the ground. Due to the

small size of the eBee and the material with which the eBee is built, the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in granting the exemption.

Moreover, the aircraft will not be operated over co ngested areas nor over any open-air assembly of persons. The aircraft will be operated at an alt itude allowing, if a power unit fails, an emergency landing without undue hazard to persons o r property on the surface.

14 CFR 91.151(a): Fuel Requirements for Flight in V FR 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 th e first point of intended landing and to fly after
that for at least 30 minutes.

Given the area of operation for the eBee, Skanska U SA Civil believes that an equivalent level of safety is already achieved with the specific proced ure preventing the eBee to accept a take-off order is the battery level is below a given value. Moreover, SenseFly has integrated “low” and “critical” battery level warnings and implemented a “return to Home” (and “Go Land”) actions in
these situations.

14 CFR Subpart E (91.401 - 91.417) - Maintenance, P reventive Maintenance, and
Alterations

The regulation provides that the operator is primar ily responsible for maintaining the aircraft in an airworthy condition, including compliance with Part s 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return t o service by a person authorized under 43.7" after maintenance and inspection. Section 91.409(a)(2) re quires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been acco mplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.

Skanska USA Civil proposes that the maintenance of the eBee will be accomplished by the owner/operator according to the maintenance manual, provided by SenseFly. Skanska USA Civil requests the FAA treat the eBee training program as proprietary under 14 C.F.R. 11.35(b) and not include this document in the publi c docket.

An equivalent level of safety will be achieved beca use the eBee is small in size, it is not a complex mechanical device, it will carry no externa l payload, and it will operate only in restricted predetermined areas. Moreover, the operator is the person most familiar with the aircraft and is
best suited to maintain the aircraft in an airworth y condition and to ensure an equivalent level of safety. Finally, before every flight, the eBee runs automatically a sequence of pre-flight tests to make sure that every sensor and every critical part is running properly. If a problem is detected,
the eBee will not be able to be switched-on and a m essage error is displayed on the main screen of the flight management software. The operator can th en refer to the maintenance manual to troubleshoot this issue. Several parts of the eBee are easily interchangeable (propellers, wings), which allows the operator to make sure the wings an d propulsion system are always airworthy
when a mission is initiated.