Shawnee Professional Setvices 

Engineers, Survryors, Acquisition & Energy 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, District of Columbia 20590 

21 January 2016 

SliawneePSI.com 

RE: EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM ACT AND PART 11 OF THE FEDERAL AVIATION 

REGULATIONS 

To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. 

Part 11, Shawnee Professional Services ("Shawnee"), an operator of the eBee Unmanned Aircraft System 

("eBee") seeks an exemption from the Federal Aviation Regulations ("FARs") listed below: 

• 14 C.F.R. 21 

• 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 commercial operations using the eBee for mapping and survey 

applications. These operations will be subject to strict operating requirements defined in the eBee user 

manual (Shawnee requests the FAA treat the eBee user manual as proprietary under 14 C.F.R. 11.35(b) and 

does not include this document in the public docket) and conditions defined in the paragraph 3. 

1. CHARACTERISTICS OF THE AIRCRAFT 

The eBee is a small (37.8 inches wingspan) and ultra-light (maximum take-off weight of 1.7 pounds) 

platform made of flexible foam that performs 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: 

401 Washington Street 

PO Box 1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 4th Street 

PO Box 125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447 
' Shawnee Professional Services ,. Engineers, Surveyors, Acquisition & Energy 

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a. Very lightweight 

The eBee is so light that the operator can launch it 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 reduces the risk of hazardous situations. Finally, the 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 is electric powered. A brushless engine technology makes it silent and reliable. The propeller is 

attached with a rubber band to the body 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 the 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 capability that allows the operator to take manual actions 

during the flight (Go to Home, Go Land, Hold 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 remote controller provided with the system. 

2. APPLICATIONS 

For our company, applications for the eBee include aerial mapping, surveying, and agricultural activities. 

There are several benefits to using the eBee for these applications - benefits for our company and the 

public: 

• Economic benefits: The processing of the collected data brings high-tech jobs to our region, a rural 

area with high unemployment and low educational attainment rates. The low cost of the UAV 

technology brings its use into the realm of possibility for farmers, local coal mines, and 

organizations/local governments with tight budgets. These entities are not typically able to afford 

to hire a full-sized aircraft for any reason. 

• Safety: The eBee is very lightweight; any possible accidents or mishaps will likely cause little to no 

401 Washington Street 

PO Box1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 4th Street 

POBox125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447 
Shawnee Professional Services 

Engineers, Surveyors, Acquisition & Energy 

ShawneePSI.com 

damage or injuries -the potential of death or serious injuries for the operator or other bystanders 

is negligible. In normal operation, it flies on carefully predetermined paths programmed into the 

software, allowing the operator to enhance safety even further by determining when it where it 

will fly. It also has the option for manual control during emergencies, so the operator can deal with 

exigencies that occur after the flight path is established. 

• Environmental benefits: The battery-powered eBee negates the need for full-size aircraft on small, 

localized projects, reducing fuel use and pollutant/greenhouse gas emissions. The UAV is nearly 

silent, further reducing the noise pollution from full-size aircraft. 

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

a. Airworthiness assessment of the eBee 

Shawnee notes that the airworthiness of the eBee has already been demonstrated for different projects in 

the United States, involving state/federal agencies or universities (among others the New Mexico State 

University: https:/ /newscenter. n msu .edu/ Artie les/view I 1 0208/nmsu-uas-flight-test-center-cond ucts-ebeeairworthiness-assessment, and the 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). Moreover the eBee 

already received 15 Exemptions from the FAA. 

SenseFiy also obtained flight approvals for the 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 operations) 

• 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 

Grant of the exemption to Shawnee for the eBee will be subject to the following operating conditions: 

• 1. Operations authorized by this grant of exemption are limited to the SenseFiy eBee when 

401 Washington Street 

PO Box1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 4th Street 

PO Box125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447 
Shawnee Professional Services 

Engineers, Survryors, Acquisition & EnergJJ 

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weighing less than 55 pounds including payload. 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 restriction. 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 PIC 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 permitted 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 ensure 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 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 or any law 

enforcement official upon request. The operator must also present updated and revised 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 

401 Washington Street 

PO Box1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 4<h Street 

PO Box125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447 
Shawnee Professional Services 

Engineers, Survryors, Acquisition & Energy 

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Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to 

the operating documents. 

• 8. Any UAS that has undergone 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 

prior to conducting further operations under this exemption. Functional test flights may only be 

conducted by a PIC with aVO and must remain at least 500 feet from other people. The functional 

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. The 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 manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

• 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 

• 13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, 

recreational, or sport pilot 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 Colombia, Puerto Rico, a 

territory, a possession, or the Federal government. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate. 

• 14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability 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. 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 (training, proficiency, and experience-building) and determining the PIC's 

ability to safely operate the UAS in a manner consistent with how the UAS will be operated under 

401 Washington Street 

POBox1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 4th Street 

PO Box125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447 
Shawnee Professional Services 

Engineers, Survryors, Acquisition & Energy 

ShawneePSI.com 

this exemption are permitted under the terms of this exemption. However, training operations may 

only be conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered nonparticipants, and 

the PIC must operate the UA with appropriate distance from nonparticipants 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 conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized. 

• 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center ofthe 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 airport 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 predetermined location within the private or controlled-access property. 

• 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

• 20. The PIC is prohibited from beginning a flight 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 for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

• 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations 

shall be conducted in accordance 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 under the 

terms of the attached COA. 

• 22. 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 (N- Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

401 Washington Street 

PO Box1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 41h Street 

POBox125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447 
Shawnee Professional Services 

Engineers, Survryors, Acquisition & Energy 

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• 23. Documents used by the operator to ensure the 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 the Administrator or any law enforcement official upon request. 

• 24. The UA must remain clear and give way 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 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 in a manner 

ensuring the safety of nonparticipating persons; and 

• b. The owner/controller of any vessels, vehicles or structures 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 essential persons are not considered nonparticipating persons 

under this exemption. 

• 27. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller 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 Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

401 Washington Street 

POBox1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 41h Street 

POBox125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447 
Shawnee Professional Services 

Engineers, Surveyors, Acquisition & Energy 

ShawneePSI.com 

3. CONCLUSION 

Given these conditions, we respectfully request an exemption from the aforementioned regulations and 

further request authorization to perform commercial survey & mapping operations with the eBee UAV. 

Yours sincerely, 

Zachary Garrett 

Corporate Secretary 

Contact Information: Zachary Garrett 

Tell (618) 658-6065 • Fax 1 (618) 658-9190 

Email: zgarrett@shawneepsi.com 

Mailing Address: PO Box 125 

Enclosures: 

Sensejly eBee: justification of Airworthiness and Safety Assessment 

**Please maintain confidentiality** 

Sensejly eBee: Maintenance Procedures 

**Please maintain confidentiality** 

Sensejly eBee: Training Documentation 

**Please maintain confidentiality** 

Sensejly eBee: Extended User Manual 

**Please maintain confidentiality** 

401 Washington Street 

PO Box1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 4th Street 

POBox125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

Vienna, Illinois 62995-0125 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447 
Shawnee Professional Services 

Engineers, S urvryors, Acquisition & Ener;gy 

ShawneePSI.com 

ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION 

Shawnee requests an exemption from the following regulations as well as any additional regulations that 

may technically apply to the operation of the eBee: 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

14 CFR § 91.203(a)(1) 

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled 

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR§ 91.203(a). Given the size of the eBee, its very light weight (the maximum 

take-off weight is 1.7 pounds) and the limited operating area associated with its utilization, it is 

unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H in order to 

achieve or exceed current safety levels. 

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 

of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the UAS involved. 

An analysis of these different criteria demonstrates that the eBee operated without an airworthiness 

certificate, under the conditions proposed in that exemption, will be at least as safe, or safer, than a 

conventional aircraft with an airworthiness certificate. A proprietary risk assessment for operations with 

the eBee, which demonstrates that assertion, is also being submitted to the FAA as part of this application. 

Shawnee requests the FAA treat the eBee risk assessment as proprietary under 14 C.F.R. 11.35(b) and not 

include this document in the public docket. 

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations 

The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft 

of the United States, unless that person: 

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's 

physical possession or readily accessible in the aircraft when exercising the privileges of that pilot 

certificate or authorization. However, when the aircraft is operated within a foreign country, a pilot license 

401 Washington Street 

PO Box 1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 4<h Street 

PO Box 125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447 
Shawnee Professional Services 

Engineers, S urvryors, Acquisition & Energy 

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issued by that country may be used. 

The regulation provides also that no person that holds 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; 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Given the safety features of the eBee and the fact that the missions are pre-programmed and monitored 

in real-time with a specific flight management software (eMotion), SenseFiy proposes that operators of 

the eBee should not be required to hold a commercial pilot certification. Instead, operators should be 

required to: 

Have a sport or recreational pilot license (at least) and have successfully passed a manufacturer's training 

program for the eBee. 

14 C.F.R. § 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 allowing commercial operation of the eBee without an airworthiness 

certificate, no standard will exist for airworthiness of the eBee. Given the size of the aircraft and the 

previous airworthiness assessments given to the eBee, among others: 

• New Mexico State University: https://newscenter.nmsu.edu/Articles/view/10208/nmsu-uas-flighttest-center-cond ucts-ebee-ai rwo rt hi ness-assessment 

• 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 SenseFiy 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 structure. Since the aircraft will be operating at a maximum of 400 

feet AGL, the eBee cannot comply with this requirement. 

401 Washington Street 

PO Box 1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 4•h Street 

PO Box 125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447 
Shawnee Professional Services 

Engineers, Survryors, Acquisition & Energy 

ShawneePSI.com 

The equivalent level of safety will be achieved because 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, preventing the eBee to go beyond the flight area. 

The landowner and the persons who may be on the ground in the flight area will be briefed of the expected 

route of flight and the associated risks to 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 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 persons or property on the surface. 

14 C.F.R. § 91.151(a): 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 to the first point of intended landing and to fly after that for at least 30 minutes. 

Given the area of operation for the eBee, Shawnee believes that an equivalent level of safety is already 

achieved with the specific procedure preventing the eBee to accept a take-off order is the battery level is 

below a given value. Moreover, SenseFiy 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, Preventive Maintenance, and Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with Parts 39 and 43. Paragraphs 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) requires 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 accomplished by certificated mechanics, under Part 43, or licensed pilots and records 

of approval of the aircraft for return to service. 

Shawnee proposes that the maintenance of the eBee will be accomplished by the owner/operator according 

to the maintenance manual, provided by SenseFiy. Shawnee requests the FAA treat the eBee maintenance 

manual as proprietary under 14 C.F.R. 11.35(b) and not include this document in the public docket. 

An equivalent level of safety will be achieved because the eBee is small in size, it is not a complex 

401 Washington Street 

PO Box 1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 4<h Street 

PO Box 125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447 
Shawnee Professional Services 

Engineers, Suroryors, Acquisition & Energy 

ShawneePSI.com 

mechanical device, it will carry no external 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 airworthy 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 message error is displayed on the main screen of the flight management software. The operator can then 

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 and propulsion 

system are always airworthy when a mission is initiated. 

401 Washington Street 

POBox1836 

Paducah, Kentucky 42002-1836 

(270) 443-7600 

104 South 4"' Street 

POBox125 

Vienna, Illinois 62995-0125 

(618) 658-6065 

Fax (618) 658-9190 

901 North DuQuoin Street 

PO Drawer 130 

Benton, Illinois 62812-0130 

(618) 439-9447