1



## Pravia, LLC’s Petition for Exemption for the SenseFly eBee Ag

Unmanned Aerial System

FAA Rules Docket : _

__________

Submitted on 30 Sep 2014

Tim Ray, Managing Partner Scott Brink , Managing Partner

Pravia, LLC 555 Falcon Trail Niceville, FL 32578 Phone: 970

- 443

- 5475, 970

- 310

- 1712 Email: tim@pr aviallc.com, scott@praviallc.com2 

## Table of Contents

Petition Summary

................................ ................................ ................................ .... 3 Background

................................ ................................ ................................ ............. 3 Statutory Authority

................................ ................................ ................................ . 5 Basis for Petition

................................ ................................ ................................ ..... 11

Site s ................................ ................................ ................................ ......... Appendix A eBee User Manual*

................................ ................................ ................. Appendix B eBee Inspection and Maintenance Requirements *

................................ Appendix C eBee Training *

................................ ................................ ........................ Appendix D eBee Jus tification of Airworthiness and Safety Assessment *

................ Appendix E

* Documents were submitted confidentially for proprietary reason s and will not be available to the pu blic3

A. Petition Summary
Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Pravia,
LLC (Pravia) request s exemption from the following Federal Aviation Re gulations that are found under Title 14 of the Code of Federal Regulations (CFR) : Part 21 Subpart H , 45.23 (b), 91.7 (a), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) (b), Part 91 Subpart E (91.401

- 91.417)

. Pravia seeks expedited approv al an d exemption from the CFRs listed above in order to operate the eBee Ag Unmanned Aircraft System (UAS) for the purpose of providing high resolution aerial imagery to a domestic agricultural seed company

. Operation of the eBee Ag by Pravia will follow strict operational limitations as outlined in this documen t and all recommendations by the FAA.
B. Background 1. Pravia , LLC Pravia is a s cientific and technological services company located in Niceville, FL that provides research, analysis, monitoring , and reporting of geographic data captured via remote sensing payloads aboard manned , fixed wing aircraft. Pravia’s two managing partners have bee n in the aviation industry for 17 plus years and have more than 8 years of combined Military UAS experience. P r avia’s UAS background make s it an ideal candidate t o t ackle the unique challenges associate d w ith commercial UAS operations for precision agriculture. 2. eBee Ag The eBee Ag UAS is manufactured by SenseFly SA of Switzerland , and it includes a lightwei ght battery operated aircraft, ground control station, and associated data link equipment. The e Bee Ag airframe is constructed of EPP foam and weighs only4

1.5 lbs. with a wingspan of 3.2 ft. The eBee Ag is powered by a lithium polymer battery that drives an el ectric pusher propeller. It is hand launched, has maximum flight time of 45 minutes , and operates at a cruising speed of 22 mph

– 35 mph. The aircraft is linked to the ground control station via a 2.4 GHz USB radio modem with a maximum data link range of 1.6 NM . If onboard sensor s detect a critical situation at any time (low battery, close proximity to the ground, weak data link signal , etc. ) the eBee Ag will automatically initiate a preprogrammed safety procedure.

Sen seFly manufactures a variant of the eBee Ag simply referred to as the eBee. The only difference between these two models is the camera suite that they carry . The airfr ame, ground control station, data link, and flight profile i s identical between the eBee and eBee Ag. All referenced SenseFly documents in this petition will simply say eBee and will not specify eBee or eBee Ag. The eBee Ag has extensive flight experience and a history of operational success

o verseas. It has been approved for Visual Line of Sight (VLOS) operations in the UK, Switzerland, Australia, Canada, and Ireland and Extended VLOS operations in France. In the United States , the eBee Ag is being used for research by New Mexico State5

University ’s Physical Scien ce Laboratory UAS Test Center. N MSU is currently operating an eBee Ag under a Certificate of Authorization (COA) to develop safety of flight procedures for mapping industry projects such as open

- pit mining and oil and gas operations. For additional information on the eBee Ag , reference Appendix B (eBee User Manual), Appendix C (eBee Inspection and Maintenance Requirements ) and Appendix E (eBee Justification for Airworthiness and Safety Assess ment) which specify manufacturing information, aircraft per formance, operating limits, normal and emergency procedures, fail

- safe features, and maintenance and inspection procedures. C. Statutory Authority 1. FAA Modernization and Reform Act of 2012, Sec tion 333 Section 333 (a) states that the FAA “ shall determine if certain unmanned aircraft systems may operate safety in the national airspace system before completion of the plan and rul ema king required by Section 332”

. Section 333 (b) then lists several factors that should be considered in determining which UAS ’ woul d be eligible for expedited integration into the National Airspace System (NAS)

. Specifically UAS ’ that “ as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to the users of the national airspace system or the public, or pose a threat to national security”. If a UAS
meets the criteria laid forth in Sec tion 333 (b), Sec tion 333 (c) then gives the FAA the authority to decide if an airworthi ness certification as specified by Title 49 U nited States Code , S ection 44704 is even required for operation . Section 333 (c) specifically states that the FAA can determine “w hether a certificate of waiver, certificate of authorization,6

or airworthiness certification under section 44704 of T itle 49, United States Code, is required for the operation of unmanned aircraft systems ” . Thus , the FAA has the ability to allow a UAS that meets the criteria put forth in Sec tion 333 (b) to operate wi thin the NAS without an airworthiness certification as long as the UAS does not pose any hazar d or threat to the NAS, public, and national security. 2. How Pravia meets the criteria laid forth in Section 333 Below are the criteria laid forth in Section 333 (b ) and a detailed description of how Pravia meets ea ch of these criteria.

a. Size, Weight, and Speed The eBee Ag’s foam airframe weighs 1.5 lbs

. , has a 3.2 ft

. wingspan and operates at cruising speeds of 22 mph

– 35 mph. This small, lightweight aircraft that operates at relatively slow speeds will poses little to no hazard to people or
structures on the ground , t hus making it an exponentially safer alternative to manned, fixed wing aircraft for aerial imaging.
b. Operational Capability The primary function of the eBee Ag is to provide aerial imagery using one of four interchangeable geo

- reference still cameras. H igh resolution data generated from these cameras offer a wide range of applications through analysis, such as biomass estimation, yield monit oring, leaf area indexing , and overall crop health. This inform ation then helps companies maximize crop yields , which is of great benefit to the economy and the p ublic. The eBee Ag is hand launched on

- site, requiring no runway for take

- off and landing and no transit to and from the site . Once airborne , the eBee Ag will7 fly at an altitude of 400 ft

. AGL or less over th e designated agricultural plot

. Prior to flight, the Pi lot in Command (PIC) set s a designated flight area and flight parameters to ensure that the eBee Ag will remain within the confines of the approved site and not exceed a maximum altitude 400 ft

. AGL. If onboard sensors detect a critical issue at any time, such as a low battery state or loss of GPS signal , the eBee Ag will immediately execute preprogrammed safety procedures (Reference Appendix E)

. The eBee Ag’s small operational footprint and built

- in safety protocol provide a much sa fer alternative for aeri al imaging and would
pose a minimal ha zard to the NAS or public.

c. Proximity to Airports/Populated Areas The eBee Ag will only operate over agricultural plots for the purpos e of collecting aerial imagery. There are 10 sites over which the eBee Ag will be flown ( Reference C. 3.b. )

. All sites are o wned and operated by a domestic agricultural seed company , which has already granted approval to Pravia to conduct eBee Ag flights

. T here are a few small o ffice and mainte nance buildings located amongst the agricultural plots and Pravia will ensure all eBee Ag operations avoid overflight of these structures . In addition there are no

c ommercial airports within 5 NM and no general aviation airports within 3 NM of any of the sites

. The eBee Ag will also operate at an altitude of 400 ft

. AGL or less , and as a result will be laterally de

- conflicted from manned aircraft operations. By operating at low altitudes over agricultural plots the eBee Ag will pose no threat to individuals or structures on the ground and will remain well clear of any and all air traffic.8

d. Visual Line of Sight (VLOS) The eBee Ag will be flown in accordance with day Visual Flight Rules (VFR) and only in Visual Meteorological Conditions (V MC) during day

- light hours. The eBee Ag will operate within 1 NM and VLOS of the PIC (and the Safety Observer positioned next to the PIC) at an altitude 400 ft

. AGL or less

. Th e Safety Observer will be responsible for ensuring that the eBee Ag remains within
V LOS at all times and will also assist in spotting potential hazards. 3. Other Relevant Factors

a. Operational Limitations Pravia has established the following operational limitations for eBee Ag flights over designated s ites.

o eBee Ag f

lights are only p ermitted over designated sites

o The eBee Ag will operate at or below 400 ft

. AGL

o The eBee Ag will operate within 1 NM and within VLOS of the PIC and Safety Observer

o The Safety Observer will be located next to the PIC and will ensure the aircraft remains within VLOS and assist in spotting potential hazards

o The eBee Ag will operate in accordance with Day V isual Fl ight R ules and only in V isual M eteorological C onditions during daylight hours

o The d uration o f each eB ee Ag Flight shall not exceed 45 minutes9

o All take

- off and landings will occur on

- site in accordance with the SenseFly eBee User Manual ( Reference Appendix B )

o eBee Ag flights will avoid direct overflight of any office or maintenance buildings located on

- site

o All employees working on

- site will be thor oughly briefed on eBee Ag operations prior to operations commencing

o eBee Ag operations will be conducted by commercially certified pilo ts who have completed SenseFly’s eBee Training ( Reference Appendix D )

o eBee Ag flights will be c ancelled in th e event that any aircraft or ground control station equipment is inoperative or not fully functional

o If the PIC or Safety Observer spot a potential hazard, such as a manned aircraft within close proximity to the designated flight area, the PIC will immedi ately land the eBee Ag and operations will only resume after the hazard is clear of the area

o All eBee Ag maintenance will be accomplishe d in accordance with the SenseFly eBee Inspection and Maintenance Requirements ( Reference Appendix C )

o Only one eBee Ag will be airborne at any given time for each designated site s

o The PIC wil l file a NOTAM for eBee Ag f light s at each s ite, providing at a minimum radial/DM E , radius, and a date/time group10 Pravia will be bound by these limitations for commercial flights afte r FAA approval of the exemptions laid forth in this petition. Pravia will also follow any guidance from the FAA in accordance with Sec 333 (c) which states that after determining if UAS meets the criteria for safe operation that the FAA “shall [also]
estab lish requirements for the safe operation of the” UAS in the NAS.
b. Sites

There are 10 current sites that are owned and operated by a domestic agricultural seed company where eBee Ag operations would be conducted. This
company has already granted approval to Pravia to conduct UAS operations at these locations. These sites are agricultural plots where crops are grown and monitored by scientist in an effort to increase crop efficiency and yield. A few small office and maintenance buildings can be found at several of these sites and Pravia will ensure all eBee Ag operations avoid overflight of these structures . In addition to this there are no commercial airports within 5 NM and no general aviation airports within 3 NM of the se sit es (Reference Appendix A for additional site information)11

As precision agricultural continues to grow there is the po tential for additional sites that would require eBee Ag operations for aerial imagery collection . In addition to seeking approval to operate the eBee Ag at these 10
current s i tes, Pravia seeks approval to operate at future sites that meet the following criteria: 1) s ite is owned and operated by the domestic seed company , 2) s ite consists of agricultural plots, 3) n o commercial airports are within 5 NM of the site, and 4) n o general aviation airports are wit hin 3 NM of the site. Pravia will also comply with any additional requirements or restrictions the FAA may have for eBee Ag operations at these future sites.
D. Basis for Petition 1. Name a nd Address of the Petitioner Pravia, LLC 555 Falcon Trail Niceville, FL 32578 Phone: 970

- 443

- 5475, 970

- 310

- 1712 Email: tim@praviallc.com , scott@praviallc.com 2. Specific Sections of 14 CFR from which Pravia Seeks Exemption Below are the sections from which P ravia seek s exemption, with specifics on the

e xtent of relief sought, reason for relief, and why exemption would not adversely affect safety.

a. Part 21 Subpart H

– Airworthiness Certificatio n

Part 21 Subpart H establishes the requirements for the issuance of an airwor thiness certificate

. Pravia seeks complete exemption from Part 21 Subpart12 H pursuant with Section 333 , which authorizes the FAA to exempt a UAS from the requirements o f an airworth iness certificate base d on consideration of the following: size, weigh, speed, operation al capability, proximi ty to airports and populated areas , and operation within VLOS

. An equal level of safety will be achieved with the o perational l imitations establi shed in this document ( Reference B.3.a) for all Pravia eBee Ag f lights. Specifically that all flights will occur within VLOS of the PIC and Safety Observe, at an altitude of 400 ft

. AGL or less , and only over designated agricultural plots . As a result the eBee Ag can safely operate without creating a hazard to any other aircraft, people , or structures on the ground. The combination of the eBee Ag’s safe operational history in Europe and the United States and small, lightweight airframe , in conjunction with Pravia’s pilot requirement s and

o perating limitations result in a safer alternative for aerial imagery collection.
b. 45.23 (b)

– Marking Requirements 45.23 (b) requires aircraft to display the r oman capital letter “N” with registration number and the words “restricted”, “light

- sport”, “experimental” , or “provisional”, as applicable , on the entrance to the ca bin, cockpit, or pilot station in lettering that is between 2 in

. and 6 in

. in height. The eBee Ag is unmanned and thus has no cabin, cockpit, pilot st ation, or entrance on which these required markings could be displaye d. In addition Pravia may not have a registration number assigned by the FAA . As a result Pravia seeks full exemption from thi s regulation. Pravia will to the max imum extent possible comply with the location requirements of 45.27 (a) and the size requirements of 45.29 (f). Pravia13 specifically proposes to put the word “ EXPERIMENTAL ” in the largest lettering possible on top of the aircraft in accordance with 45.29 (f) “i f no surf ace authorized to be marked by 45.27 is large enough for full

- size marks, marks as large as practicable must be placed on the la rgest of the authorized surfaces”

. Pravia also proposes placing a flag at the g round c ontrol s tation with the words
“EXPE RIMENTAL UAS” in 3 in

. lettering. An equal level of safety would be maintained by displaying the word

“ EXPERIMENTAL ” on top of the aircraft and by placing a flag at the g round

c ontrol s tation with the words “EXPERIMENTAL UAS”

. Since the eBee Ag will always be within VLOS of the P IC (positioned at the g round c ontrol s tation) and flown at a low altitude (400 ft

. AGL or less) the markings on airframe and the flag located at the g round c ontrol s tation would allow all parties to v isually be informed of the UAS’ operating status.

c. 91.7 (a)

– Civil A ircraft A irworthiness 91.7 (a) states that “n o person may operate a civil aircraft unless it is in an airworthy condition”. Pravia is already seeking exemption for airworthiness Certification (R eference D. 2

. a . ) and thus no FAA standard will exist for determining airworthiness. As a result Pravia seek s full exemption from this regulation. Pravia will achieve an equal level of safety by using SenseFly’ s eBee User Manual and Inspection and Maintenance Requirements ( Reference Appendix B and C ) which contain pre

- flight protocol for each flight, safety checks, and comprehensive maintenance procedures. In addition the eBee Ag has already14 demonstrated the ability to fly safely in the NAS under th e current NMSU FAA

approved COA, and thus is airworthy.
d. 91.9 (b)

– Civil A ircraft F light M anual in the A ircraft 91.9 (b) states that no person may operate an aircraft unless there is a
current approved flight manual for the aircraft onboard. The eBee Ag’s small and lightweight airf

rame is not physically capable of carrying an a ircraft f light m anual onboard. In addition to this the eBee Ag is unmanned , and the PIC is located at the g round c ontrol s tation. Pravia thus seeks exemption from the requirement to carry the a ircraft f

light m anual o nboa rd. Pravia instead proposes that the Sense Fly eBee User Manual (Reference Appendix B) and Justification of Airworthiness
Document (Reference Appendix E) , which contain information normally found in an aircraft flight manual, be kept at the g round c ontrol s tation where it is readily assessable to the PIC and Safety Observer for reference. If it were physically possible for these required documents to be place d onboard the aircraft , the PIC and Safety Observer would have no means of accessing the information due to the fac t that eBee Ag is unmanned with no aircrew onboard. Therefore an equal level of safety will be meet by keeping the
eBee User M anual and Justification of Airworthiness Document at the g round

c ontrol s tation where it will be readily accessible (within arm’s reach ) to the PIC who is operating the aircraft, thus meeting the intent of the regulation.

e. 91.103

– Preflight A ction 91.103 requir es that the PIC be familiar with specific information before each flight such as weather , forecast, and fuel requirements. In addition to this the15

PIC must be familiar with information found within the approved f light m anual relating to aircraft performance and take

- off and landing distances. Due to the fact that the eBee Ag has no FAA

- approved f light m anual Pravia seeks exemption from this regulation. Pravia proposes to use the SenseFly eBee User Manual ( Reference Appen dix B) and Justification of Airworthiness Document (Reference Appendix E) in lieu of an FAA

- approved f light m anual. T hese two SenseFly publications have extensive pre - flight checklist s that include reviewing weather, battery requirements, take

- off and land ing distances , and aircraft performance data. The information found in the SenseFly eBee User Manual and Justification for Airworthiness Document is comparable to the information found in a FAA

- approved f

light m anual, to include a comprehensive step

- by

- step pre

flight checklist. As a result an equal level of safety will be maintained by the PIC using these two SenseFly publications , which addresses the items listed in 91.103. f. 91.109

– Flight Instruction 91.109 states that “no pers on may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls”. The eBee Ag is operated by the PIC through a ground control station that

comm unicates with the aircraft via line of s ight ( LOS) transmissions. The eBee Ag by design does not have fully functioning dual controls and as a result Pravia seeks exemption from this regulation. Exemption from this regulation requiring dual controls will not create a safety hazard, because the eBee Ag is unmanned and does not carry a pilot or16

p assenge rs on board. In addition the eBee Ag’s small size and foam air frame is significantly less hazard ous to persons and structures on the ground than a manned , fixed

- wing aircraft

. Because the e Bee Ag ground control station is computer based it will be accessible to both the Instructor and Student at all times. The “controls” can in essence be passed back and forth between the Instructor and Student, achieving an equivalent level of safety as ha ving two sets of controls.
g. 91.119

– Minimum Safe Altitude 91.119 establishes the minimum altitude that civil aircraft may safely operate at. 91.119 (c) specifically states that over “ other than congested areas ” a civil aircraft cannot operate below an “altitude of 500 feet above the surface, except over open wat er or sparsely populated areas (and) i n those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or
structure ”

. The sole function of the eBee Ag is to fly at low altitudes over agricultural plots , which can be categorized as “other than congested areas”. Small UAS ’ , like the eBee Ag, by design are typically flown at altitudes of less than 500 ft

. AGL and in close proximity to the PIC and Safety Observer to maintain VLOS. Pravia has established operating l imitations to achieve the highest level of safety, specifically that the eBee Ag will not operate above 400 ft

. AGL and that the eBee Ag will remain within VLOS of the PIC and Safety Observer. For these reason s Pravia seeks exemption from this regulation. An equivalent level of safety will be maintained by only operating the eBee Ag over designated s ites ( Reference 3.C.b) . In addition the eBee Ag’s small
size and foam airf

rame is significantly less hazard ous to persons and structures on17

t he ground than a manned, fixed

- wing aircraft providing the same service. Also by ope rating at an altitude of 400 ft. AGL or less the eBee Ag will be laterally de

conflicted from manned aircraft that are subject to this minimum s afe altitude regulation and thus an equal if not greater level of safety will be maintained.
h. 91.121

– Altimeter Settings 91.121 requires aircraft to maintain a cruising level or flight level in reference to a current reported altimeter setting. The eBee Ag is not equipped with a programmable altimeter but rather determines location and altitude via an onboard GPS and barometer

. Also since the eBee Ag will be operating at or below 400 ft. AGL , there is no need to maintain hemispherical cruising altitudes for de

- confliction with manned aircraft. For these reason s Pravia seeks exemption from this regulation. An equal level of safety will be achieved through the eBee Ag’s GPS and barometer, which provide altitude and location data to the PIC via the ground control station . An automatic pre

- flight test is done to check the GPS and barometer and if any error is found the eBee Ag is prevented from taking

- off. Also if at any time during flight there i s a failure of the GPS or barometer , the eBee Ag will initiat e an emergency landing. This , combined with the fact that the aircraft’s altitude will be visually monitored by the PIC and Safety Observer,

ensure s an equal level of safety is attained in lieu o f referencing an altimeter setting. Furthermore by operating at or below 400 ft

. AGL the eBee Ag will not create a hazard to any manned aircraft maintaining hemispheric crui sing altitudes based on a current altimeter setting.18

i. 91.151 (a)

– Fuel Requirements for Flight in VFR Conditions 91.151 (a) states that no person may begin a flight in Day VFR conditions unless there is enough fuel to fly to the intended landing point and fly for 30 minutes after that point is reached. The eBee Ag is battery operated and does not carry fuel. It has a maximum flight time of 45 minutes on a fully charged battery. Compliance with the regulation woul d leave the eBee Ag less than 15 minutes of flight time. Pravia seeks full exemption from this regulation due to the fact that the risk or danger associated with failing to reach a safe landing point with 30 minutes of extra “fuel” does not exist with the eBee Ag. The eBee Ag does not have to return to a “landing point” but rather can be safely put down anywh ere over th e agricultural plot

. An equal level of safety will be ma intained simply by the fact that the eBee Ag is designed to safely land anywhere over the agricultural plot in the event that the battery is exhausted. Any risk associated with battery duration (fuel) in relationship to flight time is mitigated by the fact that eBee Ag has the ability to land anywhere and at any given time. j. 91.203 (a) & (b)

– Civil A ircraft: Certifications R equirements 91.203 requires all civil aircraft to have “within it...an appropriate and current airworthiness certificate” that must be “displayed at the cabin or cockpit entrance so that is legible to passengers or crew”. Pravia is already seeking exemption from the airworthiness certificate reg ulation and thus requires an exemption from this regulation. In addition t he eBee Ag due to its size and design has no cabin or cockpit , and therefore does not have the ability to affix or carry19 certification or registration documents. Furthermore the eBee Ag does not carry any passengers or crew for whom the certificate is required to be displayed

. Pravia proposes that a ny FAA

- req uired documents be kept at the g round c ontrol

s tation and that a small placard be affixed to the eBee Ag airframe with manufactu re, registration, and contact information. An equal level of safety wil l be achieved by having any FAA

- required documents located at the g round c ontrol s tation where it will be readily accessible to the PIC and any other agencies th at may require the information. Having a placard attached to the eBee Ag airframe will also allow any person or age ncies to be informed of the UAS’ origin and status.
k. Part 91 Subpart E (91.401
- 91.417)

– Maintenance, Preventative Maintenance, and Alteration s These regulations provided the maintenance and inspections requirements in reference to Part 39 and Part 43. 91.405 (a) specifically states that “no person may perform maintenance, preventive maintenance, and alterations on an aircraft other than as pres cribed in this subpart and other applicable regulations, in cluding part 43 of this chapter”. Pravia seeks full exemption from these regulations due to
the fact that these sections apply to an aircraft with an airworthiness certificate for which Pravia is a lready seeking exemption. An equal level of safety will be achieved by using the SenseFly eBee Inspection and Maintenance Requirements ( Reference Appendix C ) which provide step

- by

- step instructions on Regular Maintenance, Preventive Maintenance , and Corrective Maintenance . The PIC will be responsible for20 conducting maintenance in accordance with the se procedures . Any eBee Ag maintenance that is not covered in these procedures will be performed by the manufacture r . Pravia will ensure that all maintenan ce perfo rmed on the eBee Ag by the PIC and manufacture r is documented in accordance with 91.407 (a) (1). Specificall y that the records will include “a description of the work perf ormed; and the date of completion of the work performed; and the signature...of the person approving the aircraft for return to service”. T he PIC will authorize the eBee Ag for return to service for all maintenance covered in the eBee Inspection and Maintenance Requirements and the manufacture r will authorize the eBee Ag for return t o service for all maintenance that is outside the scope of the eBee Inspection and Maintenance Requirements . Pravia will also ensure that no modifications or alterations are made to the airframe that affect the flight operating characteristics of the eBee Ag. 3. How request benefits public as a whole The eBee Ag is a safe, efficient, and an e conomical alternative to manned, fixed

wing aircraft that are currently being used to conduct aeri al imaging of agricultural plots

. There are a four major reasons why the p ublic would benefit from granting Pravia

exem ptions from these regulations. Authorizing eBee Ag flights over designated sites would 1) reduce the number of manned aircraft in the NAS, 2) reduc e air and noise pollution, 3) reduce the risk to life and property on the ground, and 4) increase agricultural economic growth. Util izing the eBee Ag in lieu of a traditional manned, fixed wing aircraft will result in the overall reduction of manned aircraft in the NAS. Thus there will be less21

aircraft that require control and coordination with Air Traffic Controllers (ATC)

. Because the e Bee Ag can take

- off and land on

- site and operate at an altitude of 400 ft

. AGL (or less) within VLOS of the PIC the re is no need for ATC to provide coordination during ground, take

- off, departure, transit, arrival, and landing phases of flight. As the skies over the United States get busier and busier , any small effort to lighten the load of the Air Traffic Controllers would be of great benefit to the public. At 1.5 lbs

. the battery operated eBee Ag with an electric motor provides a much quieter alternative to manned, fixed

- wing aircraft. Traditionally a manned aircraft would have to transit from the departure airport to the desired site and fly at low altitudes to achieve high

- resolution imagery. The eBee Ag will require no transit time , and the electric motor will be ex ponentially quieter than a twin

- engine combustion motor on passenger aircraft that is typically used to conduct aeri al imaging. In addition the eBee Ag requires no fuel since it is battery operated. A manned aircraft on the other hand typically burn s 20

- 30 gallons

. of aviation fuel per hour which is polluting the air not only over the site but over the p ath of transit and around the airport. Con ducting aerial imaging with the eBee Ag in lieu of a manned aircraft would thus greatly reduce both air pollution and noise pollution which is of great benefit to the public. Using the eBee Ag would also greatly r educe if not completely eliminate the risk to life and property on the ground. The eBee Ag’s incredibly small size, reduced weight, and foam airframe pose no hazard to people or structures on the ground as opposed to a manned twin engine passenger aircraft , which has a much greater potential for collate ral damage. In addition the eBee Ag is unmanned and as a result the risk associated with piloting this aircraft is non

- existent. Overall the eBee Ag provides a much safer22

alternative to manned, fixed

- wing air craft operations for the purpose of collecting aerial imagery. Lastly using the eBee Ag to provide aerial imagery would result in agricultural economic growth. High

- resolution data generated from eBee Ag flights would provide scientist s with invaluable in formation on biomass estimation, yield monitoring, leaf area indexing, and overall crop health. By analyzing this data sci entist s can make modifications to a wide range of variables that will maximize crop yields

. More efficient crops would allow the U

. S

. to generate more food for stateside consumption but also increase the amount of crops that can be exported to foreign countries. The major increase in economic growth in the agricultural industry would energize the U

. S

. economy , which in turn would be of great benefit to the public. 4. Additional information, views, and arguments The following documents have been included as Appendices to this Petition. Appendix B, C, D , and E have been submitted confidentially for proprietary reasons and will not be available to the public.

o Sites (Appendix A)

o eBee User Manual (Appendix B)

o eBee Inspection and Maintenance Requirements (Appendix C)

o eBee Training (Appendix D)

o eBee Justification o f Airworthiness and Safety Assessment (Appendix E) 5. Summary for Federal Register
Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Pravia, LLC requests exemption from the following Federal Aviation Regulations that are23

found under Title 14 of the Code of Federal Regulations: Part 21 Subpart H , 45.23 (b), 91.7 (a), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) (b), Part 91 Subpart E (91.401

- 91.417) . Exemption from these regulations would allow Pravia, LLC
to operate the SenseFly eBee Ag Unmanned Aerial System over a domestic agricultural seed company’s s ites for the purpose of providing high

- resolution aerial imagery of agricultural plots.