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 Request 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, Aerial Scout Ag. Ops. Support, LLC. (ASAOS), a remote sensing 

company, and 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 ASAOS in the United States. These operations will be subject 

to strict operating requirements defined in the eBee user manual. ASAOS requests the FAA treat 

the eBee training program as proprietary under 14 C.F.R. 11.35(b) and does not include this 

document in the public docket 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 operations using manned aircrafts. 

ASAOS, LLC is a precision agriculture and remote sensing company with operations in 

California and Arizona. ASAOS was founded to enhance crop management and food safety 

verification capabilities of agricultural producers by providing on-demand advanced imagery and 

data analytics using unmanned aircraft systems (UAS). ASAOS is committed to providing 
innovative products and dependable service to help its clients excel in their agricultural 

production and food safety operations.

Unmanned Aerial 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 models lack the resolution and 

accuracy necessary for elite crop planning, crop management, food safety, quality, and plant 

health identification.

UAV collected data allows a consultant to review the ranch area(s) of interest with greater 

accuracy, resolution and efficiency to better aid clients with production design, 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 populated environments of 

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

rules 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 guidelines for operators using 

ultra-light remote controlled aircraft.

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

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

ASAOS requests the FAA treat the eBee training program as proprietary under 14 C.F.R. 

11.35(b) and does not include this document in the public docket.

 Is a registered member of the AMA.

 Has a valid driver’s license.

 In addition to the eBee operator, ASAOS will have a second person on site to act as a 

spotter in order identify other aircraft 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 

pounds) 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 monitor the mission in realtime. 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 weight
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 to emergency circumstances, thanks to the remote controller provided with the system.

2. APPLICATIONS

ASAOS intends to plan and implement an aerial data collection program using precision 

agriculture and remote 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, ASAOS 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 information to include, but not be limited to:

 Vegetation stress management

 Leaf area index

 Terrain modeling

 Growth monitoring

 Weed detection

 Tree classification

 Drainage planning

 Water use reduction
Presently, agricultural advisors provide their clients with information based on a limited 

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

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

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

yields.

 Annex C describes applications and reasoning in more detail. ASAOS requests 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 permits ASAOS

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

the human eye. The terrain data will allow clients to tailor irrigation designs to field conditions,

and mitigate potential areas of risk to productivity. This technology is cost effective and provides 

a platform for greater efficiency by properly irrigating crops, reducing water use, electrical 

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

ranch employees to be creative with 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 crop areas and possible risk of food safety contamination

 Food safety risk assessments 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.

 Increasing quality of crops through the better management of nutritional inputs

 Increasing 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 preventing over and under watering of crops 
At 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 technology will improve services

presently being offered to agricultural clients, increase efficiencies, and add another dimension to 

the role of quality and food safety on the farm.

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333

a. Airworthiness assessment of the eBee

ASAOS notes that the airworthiness of the eBee has already been demonstrated for different 

projects in the United States. These involved state/federal agencies or universities (among others,

New Mexico State University): https://newscenter.nmsu.edu/Articles/view/10208/nmsu-uasflight-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 in 

order to operate the eBee UAS).

Moreover, ASAOS notes that senseFly 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 ASAOS 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 permission from the land owner/authority required before commencing any 

flight;

 Operations over congested areas shall be avoided;

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

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

times;

 Operations limited 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 around operator of 0.5 
miles;

 Flight ceiling pre-programed at or below 400 feet;

 All 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 tower 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 operations will be compliant with existing safety procedures inherent to the 

activities of the related company.

A large percentage of project locations serviced by ASAOS are in isolated, rural, nonresidential 

areas. Before an area is flown, ASAOS will request 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, 

ASAOS will avoid flying 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 interfere with 

manned aircraft operations.

ASAOS takes pride in providing a safe working environment for its members and currently has 

excellent safety procedures in place, as well as an outstanding safety director within the company.

c. Operator Requirements

The eBee is an ultra-light UAV platform made of flexible foam with no sharp 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 prevents the operator 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 System (emergency landing procedure, triggered by the autopilot or 

the operator in charge. Given 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 countries, 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 operation of the UAS. The manufacturer’s 

training program for operators has already been satisfactorily reviewed through the 

Application for Airworthiness Qualification Level (AQL) 3 Airworthiness Release 
(AWR).

 In addition to the eBee operator, ASAOS will also have another person on site to spot and 

identify other aircraft and objects in the nearby airspace.

ASAOS also seeks an exemption from certain requirements in Parts 45 and 91 that are impractical 

as well as unnecessary for UAS operations. Please see Annex A for a detailed explanation of 

each regulation from which an exemption is sought and the equivalent level of safety showing. 

3. CONCLUSION

ASAOS, in association with senseFly and the Academy of Model Aeronautics organization, who

have a deep and well-known level of experience in terms of safe integration of remote controlled 

aircrafts in the National Airspace 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 ASAOS to provide their

clients with outstanding 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 and 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 professionally.

ASAOS offers in this Exemption a pragmatic approach to allow the efficient operation of ultralight UAVs pursuant to FAA, AMA, and senseFly safety requirements and conditions.

Sincerely,

H Walt Armijo

Aerial Scout Ag Ops Support, LLC

President
ANNEX 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 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. ASAOS 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. § 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 (wingspan 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 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 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), SenseFly proposes 

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

operators should 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 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/nmsuuas-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 levee system 

monitoring, documentation of construction progress, and extensive oblique photography 

of USACE structures & activities

An equivalent level of safety will be achieved by insuring compliance with the SenseFly manuals 

prior to each flight. 

14 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 

manual is in the aircraft. ASAOS assumes that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. ASAOS 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 software eMotion. The equivalent level of safety 

during the training will be achieved by the manufacturer or authorized distributor providing the 
training 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 cannot 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 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 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 current 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 available 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 reference 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 variations 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 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, ASAOS 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, 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 certificate.

 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 aircraft.

To obtain an equivalent level of safety and meet the intent of 91.203, ASAOS 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 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.

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 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.

ANNEX B: ACADEMY OF MODEL AERONAUTICS SAFETY REQUIREMENTS

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

http://www.modelaircraft.org/files/540-D.pdf
http://www.modelaircraft.org/files/560.pdf

ANNEX C: eBee AND SENSEFLY DOCUMENTATION, PROPRIETARY DOCUMENT

See confidential email attachment referencing this petition filing and comment number.