Aerial Scout Ag Ops Support, LLC

379 West Market Street, Suite A

Salinas, California 93903

831

- 205

- 1806

March 12th

, 2015

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

Re: Exemption Reque st Under Section 333 of the FAA Reform Act and Part 11 of the Federal
Aviation Regulations

Dear Madam, Sir,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”)

and 14 C.F.R. Part 11

, Ae rial Scout Ag . Ops. Support, L LC. (ASA O S ), a remote sensing

company , an d 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. 45.23

 14 C.F.R

. 45.29

 14 C.F.R. 61.3

 14 C.F.R. 61.113( a)&(b)

 14 C.F.R. 61.133(a)

 14 C.F.R. 91.7(b)

 14 C.F.R. 91.9(b)(2)

 14 C.F.R. 91.109(a)

 14 C.F.R. 91.119

 14 C.F.R. 91.151(a)

 14 C.F.R. 91.203(a) & (b)

 14 CFR Subpart E (91.401

- 91.417)

The requested exemption would authorize commercial operations using the eBee for precision agriculture and remote sensing by AS A OS in the United States. These operations will be subject to strict operating requirements defined in the eBee user manual

. ASA O S requests the FAA treat the eBee training program as proprietary unde r 14 C.F.R. 11.35(b) and does not include this document in the public docket and conditions defined by the Safety Code of the Academy of Model Aeronautics (see Annex B), in order to ensure at least an equivalent level of safety to currently authorized oper ations using manned aircrafts.

A S A O S, LLC is a precision agriculture and remote sensing company with operations in

California and Arizona

. ASA O S was founded to enhance crop management and food safety
verification capabilities of agricultur al producers by providing on

- demand advanced imagery and
data analytics using unmanned aircraft systems (UAS)

. ASA O S is committed to providinginnovative products and dependable service to help its clients excel in their agricultural

production and food safety operation s

.

Unmanned A erial Vehicle (UAV) technology

, and its associated data

, is becoming a desirable

deliverable within the agriculture industry

. As client requirements continue to evolve, traditional
crop management techniques , available imagery, and field mod els lack the resolution and

accu racy necessary for elite crop planning, crop management, food safety

, quality , a nd plant

health identification

.

UAV collected data allows a consultant to review the ranch area (s) of interest with greater
accuracy, resolut ion and efficiency to better aid client s with production d esign , predictive crop
yields, overall water use reduction, pest control and nutritional inputs, and food safety hazard
analysis and risk assessments

. Of more importance

, is that the unmanned aspect reduces the risk
of placing employees in perilous environments.

Given the technical specifications of the eBee and the rural, sparsely populate d environments of

the workspace, ASA O S believes it is relevant to use the Academy of Model Aeronautics (AMA)

ru les to meet the required level of safety of future eBee operations. The AMA has a proven track
record in supervising operations conducted by operators using remote controlled aircrafts and
provides the most relevant expertise in terms of providing safety g uidelines for operators using

ultra

- light remote controlled aircraft.

The eBee will be operated by an individual who fulfill s the following requirements:

 Has successfully passed a manufacturer’s (senseFly) training program for the eBee

. ASAOS requests th e 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.

 Is a registered member of the AMA.

 Has a valid driver’s license

.

 In addition to the eBee operator, ASAOS will have a s econd person on site to act as a spotter in order identify other aircraf t and objects in the airspace during the flight.

1. CHARACTERISTICS OF THE AIRCRAFT

The eBee is a small (37.8 inches wingspan) and ultra

- light (maximum take

- off weight of 1.7

po und s) platform made of flexible

- foam that performs pre

- programmed aerial mapping missions

with an on

- board GPS , and a related flight

- management software (eMotion)

. eMotion allows the operator to safely and efficiently plan a flight in 2D or 3D , and then monit or the mission in real

time. Thanks to the embedded camera, protected by a foam envelope, the eBee takes a collection of high

- definition still images used to generate dynamic maps and contour lines of the targeted

terrain.

The four main characteristics of the eBee are:

a. Very light weightThe eBee is so light that the operator can launch it by hand and let it land on almost any surface

without requiring a parach ute or landing net (belly land). Its low impact energy ( 38 J in case of a controlled emerge ncy 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 i s 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 artifi cial 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 Man ual 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 ai rcraft should it become necessary to respond to emergen cy circumstances, thanks to the remote controller provided with the system.

2. APPLICATIONS

ASA O S intends to plan and implement an aerial data collection program using precision agriculture and remo te sensing techniques

, and senseFly’s eBee in order to assist clients with production design, predictive crop yields, overall water use reduction, pest control and nutritional inputs management , and food safety hazard analysis and risk assessments.

Using the eBee’s sensor technology, ASA O S will collect time

- specific imagery and elevation information. Once the entire terrain of interest is flown, images collected during the flight will be merged together in a software program to make a complete photographic and terrain project map. Using specific algorithms within the Post

- flight Terra 3D software, project field conditions, terrain characteristics and potential vegetation deficiencies can be easily identified.

The eBee will be used to evaluate generated inf ormation to includ e, but not be limited to:

 Vegetation stress management

 Leaf area index

 Terrain modeling

 Growth monitoring

 Weed detection

 Tree clas s ification

 Drainage planning

 Water use reductionPresent ly

, agricultural advisors provide their clients wit h information based on a limited

perspective and their recommendations subsequently become limited by the lack of high

resolution information available. The most readily available information either lacks the required

detail, or was captured during a time period that is not relevant to the expected field operation

schedule. The objective of this technology is to help growers eliminate guesswork and create

efficiencies by using real

- time, aerial imagery to study time

- specific field conditions and

utiliz ing terrain models to evaluate and assess field resources , and develop mitigation measures

for the over use of water and agricultural inputs, t he improvement of plant health, and crop

yields.

 Annex C describes applications and reasoning in more detail. ASAOS r equests the FAA treat the eBee training program and Annex C as proprietary under 14 C.F.R. 11.35(b) and not include this document in the public docket.

UAV technology offers a substantial economic benefit to agriculture

. The eBee permit s ASA O S

the abilit y to proactively identify areas of concern within a crop before becoming detectable by

the human eye . The ter

rain data w ill allow clients to tailor irrigation design s to field conditions

, and mitigate potential areas of risk to productivity. This technolog y is cost effective and provides

a platform for greater efficienc y by properly irrigating crops , reduc ing water use, electrical

energy consumption, less vehicle use and gasoline consumption, and permits the opportunity for

ranch employee s to be creative wi th other operational activities

.

UAV technology will immediately enhance food safety and quality of agricultural crops and in

the future will provide additional opportunities for greater refinement of information as visual

technology and data collection programs improve. Present UAV technology will improve food

safety and quality as follows:

 Food Safety hazard analysis completed prior to purchasing or leasing a ranch for

agricultural production

 Food safety risk assessments completed prior to planting a crop to determine potential

routes of contamination

 Determine if animal intrusion into crop areas and possible risk of food safety

contamination

 Determine if animal feeding in c rop areas and possible risk of food safety contamination

 Food safety risk asses sments completed prior to the anticipated harvest of crops to

determine any new source(s) of possible contamination

 Determine density of nearby animal populations and their possible food safety risk to

crop areas.

 Increas ing quality of crops through the be tter management of nutritional inputs

 Increas ing quality of crops through the better management of pesticide applications

 Increasing quality of crops by determining soil differences and levels prior to planting

crops

 Increasing quality of crops by preve nting over and under watering of cropsAt least two companies have received approval from the FAA to perform similar operations.

Advanced Aviation Solutions and Viafield are currently approved in the United States to perform

similar operations with UAV equipment. ASAOS wishes to remain competitive and current

within the agricultural service arena. Implementing UAV tec hnology will improve services

presently being offered to agricultural clients, increase efficienc ies

, and add another dimension to

the ro le of quality and food safety on the farm

.

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333

a. Airworthiness assessment of the eBee

ASA O S notes that the airworthiness of the eBee has already been demonstrated for different projects in the United States

. T hese involved state/federal agencies or universities (among others

, New Mexico State University ) : https://newscenter.nmsu.edu/ Articles/view/10208/nmsu

- uas

flight

- test

- center

- conducts

- ebee

- airworthiness

- assessment , and the USACE New Orleans, who coordinated with the Department of Army and the FAA to obtain all authorizations required i n order to operate the eBee UAS).

Moreover, ASA O S notes that s enseFly 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 approv al for VLOS operations)

 Denmark (flight approval for VLOS operations)

b. Operating requirements

Grant of the exemption to ASA O S for the eBee will be subject to the following operating conditions, based on the operating conditions set forth by the Academy of Model Aeronautics (see Annex B). The main restrictions are summarized below:

 Operations to be conducted over private, controlled

- access, or public property where approved with p ermission from the land owner/authority required before commencing any

fli ght ;

 Operations over congested areas shall be avoided;

 Operations must not interfere with manned aircraft operations, must yield the right of way

to manned a ircraft, and operators must See & Avoid other aircraft and obstacles at all

times ;

 Operations limit ed to Visual Flight Rules Meteorological Conditions (VMC) and daylight

hours ;

 Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually
monitored at all times;

 Visual Line of Sight operations guaranteed with a GPS geo

- fence ar ound operator of 0. 5miles ;

 Flight ceiling pre

- programed at or below 400 feet;

 A ll operations conducted within five miles from an airport shall only be initiated after verbal coordination with the airport authority, or air traffic control when a control t ower is present at the airport;

 All operations shall comply with required permissions and permits established by territorial, state, county or city jurisdictions; including local law enforcement, fire, or other appropriate governmental agencies.

 The eBee o perations will be compliant with existing safety procedures inherent to the activities of the related company.

A large percentage of project locations serviced by ASA O S are in isolated, rural, nonresidential

areas. Before an area is flown, ASA O S will req uest written permission from each property owner. Residents within the vicinity of each project area will also be notified and educated on the purpose of the flight. With the geo

- fence incorporated within the flight management software,

ASA O S will avoid fl ying over houses and yards as much as reasonably possible. The flight ceiling will be pre

- programmed no higher than 400 feet to ensure the aircraft will not fly over the height specified by the AMA. By staying below this level, the eBee should not interfer e with manned aircraft operations.

ASA O S takes pride in providing a safe workin g environment for its members and currently has excellent safety procedures in plac e, as well as an outstanding safety director within the company.

c. Operator Requirements

T he eBee is an ultra

- light UAV platform made of flexible foam with no sh arp or hard edges characterized by a high level of pre

- programmed controls and various technical capabilities (programming of a geo

- fence, automatic wind detection) that prevent s the op erator from beginning a flight outside of the operating limits. All flights are pre

- programmed with GPS guidance and do not require human intervention; nevertheless human override is possible by clicking on one of the multiple “action” buttons or by using the remote controller provided with each eBee system. In the case of unplanned events, either the autopilot reacts immediately or the operator can choose between different pre

- programmed or manual actions. Those procedures include a Flight Termination Syst em (emergency landing procedure, triggered by the autopilot or the operator in charge

. G iven its very light weight, the eBee will initiate a gliding approach to the ground at very low speed around the current location. Moreover, the kinetic energy of the aircraft

is 60 J in

- flight at cruise speed . In comparison, the kinetic energy of a football is about 110 J when thrown by hand

.

Given these safety features recognized by the U.S. Army Corps of Engineers and the national
aviation authority of several coun tries, ASAOS requests an exemption from the airworthiness
certification requirements in Part 21 and the concomitant requirements in 14 C.F.R. 91.7(a) and
91.203 to operate an airworthy aircraft. Instead, operators of the eBee will:

 Have completed an AMA affiliated small UAS education and training program and achieved an AMA UAS endorsement, or have successfully completed a small UAS education and training program provided by any FAA qualified entity, and;

 Have passed SenseFly’s training program for opera tion of the UAS. The manufacturer’s training program for operators has a lready been satisfactorily reviewed through the Application for Airworthiness Qualification Level (AQL) 3 Airworthiness Release(AWR).

 In addition to the eBee operator, ASAOS will als o have another person on site to spot and identify other aircraft and objects in the nearby airspace.

ASA O S also seeks an exemption from certain requirements in Parts 45 and 91 that are impractical
as well as unnecessary for UAS operations. Please see An nex A for a detailed explanation of
each regulation from which an exemption is sought and the equivalent level of safety showing.

3. CONCLUSION

ASA O S , in association with senseFly and the Academy of Model Aeronautics organization, who

ha ve a deep and well

- known level of experience in terms of safe integration of remote controlled

aircrafts in the National A irspace for low

- level operations, provides here adequate justification for the grant of the requested exemption allowing safe precision agriculture operations of the eBee in the National Airspace System.

The eBee will bring an added dimension of data accuracy to agriculture . It would produce
several efficiency and production benefits to farming operations

, allow ASA O S to provide the ir

clients with o utstanding service value, and whose ultimate objective is to help them manage their
operations with a higher degree of information. The demand for improved accurate data that

creates opportunities for efficiencies, reductions in the consumption of water a nd energy, while
reducing food safety risks and improving quality will continue to increase as the benefits of this
technology become known to agriculture. The safe integration of the eBee system will greatly

benefit agriculture economically and profession ally.

ASA O S offers in this Exemption a pragmatic approach to allow the efficient operation of ultra

light UAVs pursuant to FAA, AMA, and senseFly safety requirements and conditions.

S incerely,

H Walt Armijo Aerial Scout Ag Ops Support, LLC

PresidentANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

ASAS 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 proced ural 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, i t 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 o f 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 proximi ty 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, t han 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. ASAOS requests the FAA

treat the e Bee 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. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station.

Given the size of the eBee (w ingspan of 37.8 inches), this requirement is impossible to match.

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 P ilot 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 issued b y that country may be used.

The regulation provides also that no person that holds a private pilot certificate may act as pilot incommand of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as

pilot in command of an a ircraft 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 f act that the missions are pre

- programmed and

monitored in real

- time with a specific flight management software (eMotion), SenseFly proposes that operators of the eBee should not be required to hold a commercial pilot certification. Instead, operators shou ld be required to:

Have successfully passed a manufacturer’s training program for the eBee , and also has a spotter on site to identify objects in the airspace.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness

This regulation requires that no person ma y 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 air craft and the previous airworthiness assessments given to the eBee, among others:

 New Mexico State University: https://newsce nter.nmsu.edu/Articles/view/10208/nmsu

uas

- flight

- test

- center

- conducts

- ebee

- airworthiness

- 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 lev ee 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 C. F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight

m anual is in the aircraft

. ASA O S assumes that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. ASA O S requests an exemption to this requirement since the aircraft is not only too small to carry documentation,

the documentation would not be available to the crew.

The equivalent level of safety will be achieved by keeping a hard copy of the flight manual in the eBee transportation box.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

The regulation provides that "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls."

Flight instruction will be accomplished through an elaborated training program, using first the simulation mode of the flight management softwar e eMotion. The equivalent level of safety during the training will be achieved by the manufacturer or authorized distributor providing thetraining and through the use of experienced and qualified operators familiar with the eBee.

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 canno t comply with this requirement.

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 no t comparable to manned aircraft and should be considered in granting the exemption.

Moreover, the aircraft will not be op erated 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 CFR 91.121

– Altimeter settings

This section requires that each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating below 18,000 feet MSL to:

 The curre nt reported altimeter setting of a station along the route and within 100 nautical
miles of the aircraft;

 If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate ava ilable station;

 In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

To provide an equivalent level of safety, the eBee autopilot calculates the refere nce altitude (ground level) with the on

- board GPS during the pre

- flight tests. The GPS and barometer data are merged with respect to their respective precisions. The GPS provides reliable information to correct potential barometric bias, while rapid variat ions in altitude are detected through the barometer. Hence, barometric bias induced by environmental factors is rejected.

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 a n 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, ASA O S believes that an equivalent level of safety is

alr eady achieved with the specific procedure 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 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

 No person may operate a civil aircraft unless it has an appropriate and current

airworthiness c ertificate.

 No person may operate a civil aircraft unless the airworthiness certificate required by
paragraph (a) of this section or a special flight authorization issued under §91.715 is
displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The eBee weighs only 1.7 pounds (max take

- off weight). As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. In addition, there is no pilot or passengers on board the air craft.

To obtain an equivalent level of safety and meet the intent of 91.203, ASA O S propose that documents deemed appropriate for this aircraft by the FAA will be co

- located with the operator at the ground control station in the eBee box and available for inspection upon request

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 compli ance 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

o f 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 aircraf t for return to service.

ASAS proposes that the maintenance of the eBee will be accomplished by the owner/operator according to the maintenance manual, provided by SenseFly. ASAOS 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 public docket.

An equivalent level of safety will be achieved because the eBee is small in size, it is not a complex mechanical device, it will carry no external payload, and it will operate only in rest ricted 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 fligh t 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 al ways airworthy

when a mission is initiated.

ANNEX B: ACADEMY OF MODEL AERONAUTICS SAFETY REQUIREMENTS

http://www.modelaircraft.org/files/105.pdf

http://www.modelaircraft.org/files/540

- D.pdfhttp://www.modelaircraft.org/files/560.pdf

ANNE X C: eBee AND SENSEFLY DOCUMENTATION, PROPRIETARY DOCUMENT

See confidential emai l attachment referencing this petition filing and comment number.