# §TONJE**OAK~** LJUC

March23,2016

U.S. DepartmentofTransportation DocketManagement System 1200 NewJerseyAve., SE Washington, DC 20590 Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations DearMadam, Sir, Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act"), P.L. 112-95, 'Special Rules for Certain Unmanned Aircraft Systems" and 14 C.F.R. Part 11, Stone Oak LLC. ("Stone Oak"), seeks an exemption from the Federal Aviation Regulations ("FARs") as listedbelow:

• 14 C.F.R. 21 • 14 C.F.R. 45.23 • 14 C.F.R. 45.29 • 14 C.F.R. 61.23 • 14 C.F.R. 61.3 • 14 C.F.R. 61.113(a) (b) • 14 C.F.R. 61.133(a) (b) • 14 C.F.R. 91.7(a) (b) • 14 C.F.R.91.9 • 14 C.F.R. 91.109 • 14C.F.R.91.119 • 14 C.F.R. 91.121 • 14 C.F.R. 91.151(a) • 14 C.F.R. 91.119 • 14 C.F.R. 91.203 • 14CFRSubpartE(91.401-91.417) The name and contactinformationfor this application is: RichardA. Korgan Stone OakLLC 19400Redbud Drive Catoosa, Oklahoma74015 Tel: 918-691-8448 e-mail: rkorgan@gmail.com

### The requested exemption would authorize Stone Oak to perform commercial operations that would enhance their existing services to perform mapping services, including but not limited to imaging for Precision Agricultural applications, Digital Terrain Modeling, Accident Reconstruction, Infrastructure reconnaissance and inventory with GIS applications for Private, Local, State and Federal entities, land surveys that would include Riparian Boundaries of State andFederal ownedlands associatedwithnavigablerivers. These services will be augmented byuse ofeitherorbothofthe following:

• The eBee, a fixed wing UnmannedAircraft System (UAS) manufacturedby SenseFly, A Parrot Company ("SenseFly").

• The UXS and UXS HP ("UXSIHP"), fixed wing UAS's manufactured by Trimble NavigationLimited ("Trimble"). These operations will be subject to strict operating requirements and conditions defmed in the eBee and UXSIHP user manuals (while the documents are included with this request, Stone Oak hereby requests that the FAA treat the eBee and UXS/HP user manuals as proprietary under 14 C.P.R. 11.35(b) and does notincludetheir documents in

### thepublic docket). WithRegardto the SenseFlyeBee UAS: 1. CHARACTERISTICS OF THEAIRCRAFT 

### The eBee is a small fixed wing (37.8 inchwingspan) andultra-light (maximumtake-offweight of 1.7 pounds) platform made of flexible foam that performs pre-programmed precision aerial mapping missions using the on-board GPS and the related flight management software (eMotion) that allows the operatorto plan safely and efficiently a mission in 3D, andthenmonitor it in

### realtime. Using an embedded camera, protected by the airframe foam envelope, the eBee takes a collection ofhigh-definition still images that are used later to generate maps and contour lines of the surveyed area. The four maincharacteristics ofthe eBee are:

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 lowimpact energy (38 J 

### in case ofa controlled emergency landing) also significantlyreduces the risk ofhazardous situations. Finally, the wings ofthe eBee are detachable and made offlexible foam with no sharp orhard edges and almostno 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 ofthe plane so that it can easily flex away in case ofcontactwith 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 theStoillle Oak 13 

### aspects ofthe flight under the supervision ofthe 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 emergent circumstances, thanks to theremote controllerprovided with the system. 2. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

### Airworthiness assessment ofthe eBee Stone Oak notes that the airworthiness ofthe 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.nmsu.edu/ Articles/view II0208/nmsu-uas-flighttest-center-conducts-ebee-airworthiness-assessment, and the USACE New Orleans, who coordinated with the Department ofArmy and the FAA to obtain all authorizations required in orderto operate the eBee UAS). Moreoverthe eBee has alreadyreceived 15 Exemptions from the FAA. SenseFly also obtained flight approvals for the eBee (delivered by national civil aviation authorities) inmany 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) With Regardto the Trimble UX5/HP UAS: 1. CHARACTERISTICS OF THE AIRCRAFT 

### The UX5/HP is a small fixed wing (39.9 inch wingspan) and ultra-light (maximum take-off weight of 11 pounds) platform with a 5.1 pay load capacity. The aircraft is composed of a combination ofcarbon structure and EPP foam that will performpre-programmed precision aerial mapping missions using the on-board GPS and the related flight management software that allows the operator to plan safely and efficiently a mission in 3D, while monitoring the mission in realtime. Using an embedded down-looking hi-resolution camera the UX5/HP takes a collection of high-definition still images that are used later to generate maps and contour lines ofthe surveyed area. The four main characteristics ofthe UX5/HP are:

a. Very light weight The aircraft system includes a ground launching mechanism that enables the operator to launch

### the UX5/HP hands free. Its low impact energy also significantly reduces the risk ofhazardous situations. Finally, the wings ofthe UX5/HP are detachable and made offlexible foam with no sharp orhard edges and almost no internal strengthening structure. b. Electric-powered The UX5/HP is electric powered. A brushless engine technology makes it silent and reliable. The propeller is attached to the electric motor in such a way that it can easily flex away in case of contact with any object.

c. Semi-automatic flight The artificial intelligence incorporated withinthe UX5/HP autopilot system continuously analyzes data from the Inertial Measurement Unit and from the onboard GPS and takes care of all the aspects ofthe flight under the supervision ofthe operator. The UX5 HP in particular utilizes additional electronics to record its known position relative to another station with known coordinates. d. Option for Manual Control Automated operations can be suspended during the flight to take manual control ofthe aircraft should it become necessary to respond to emergent circumstances. The UX5/HP provides an override capabilitythat allows the operatorto take manual actions. 2. APPLICABLELEGAL STANDARD UNDER SECTION333 Airworthiness assessment ofthe UX5/HP On December 10, 2014 Exemption 11110 was issued to Trimble Navigation Limited, and later amended onMay 7, 2015 with issuance ofExemption 1111OA inFAADocket2014-0367. Exemption 11110 and 1111OA allowed an Applicant to operate the UX5 and the UX5 HP aircraft manufactured by Trimble or other Trimble aircraft approved for commercial operations under Exemptions 11110 and 1111OA, as they may be amended in the future. Applicant notes that, in Exemption 11257, the FAA also recently authorized use ofthe Trimble UX5 by a third party under conditions like those inExemption 1111OA. 1 

### Stone Oakhereby confirms that itwill accept the conditions in Exemptions 11110A as well as those set forth in Exemption No. 1257, Regulatory DocketNo. FAA-2014-0889 and will operate the aircraftin strict compliance withthe conditions inexisting exemptions previously grantedbythe FAA, oras they maybe amended. With Regardto the SenseFlyeBeeUAS andthe TrimbleUX5/HP UAS: 3. CONDITIONSAND LIMITATIONS Grant of the exemption to Stone Oak for the eBee and the UX5/HP will be subject to the following operating conditions: 1. Operations authorized by this grant ofexemption are limited to the aircraft weighing less than 55 pounds including payload. Proposed operations ofany other aircraft will require a newpetitionorapetitionto amendthis exemption.

Exemption No. 11257to Montana Land Surveys (see Docket No. FAA-2014-0889).Stone Oalk /5 2. Operations for the purpose ofclosed-set motion picture and television filming are not permitted. 3. The UAS may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemptionholder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UAS be operated at airspeeds greater than the maximum UAS operating airspeed recommended by the aircraftmanufacturer. 4. The UAS must be operated at an altitude ofno more than 400 feet above ground level (AGL). Altitudemustbereported in feet AGL. 5. The UAS must be operated within visual line of sight (VLOS) of the Pilot-InCommand (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 FAAissued airmanmedical certificate orU.S. driver's license. 6. All operations must utilize a visual observer (VO). The UAS must be operated within the visual line ofsight VLOS ofthe 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 orher designation for the duration ofthe flight. The PIC must ensure that the VO canperform the duties required ofthe 

## 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 ifit petitions for extension or amendmentto this grant ofexemption. Ifthe operatordetermines 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 ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance oralterations that affectthe UAS operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conductedby a PIC with a VO and mustremain at least 500 feet from otherpeople. The functional test flight mustbe conducted in such a manner so as to notpose anundue hazardtopersons andproperty. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it isS:toltlle Oak 16 ina conditionfor 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 inspectionreveals a conditionthat affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessarymaintenance has beenperformed andthe UAS is found to beina conditionfor 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. Underthis grantofexemption, a PIC musthold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airmanmedical certificate ora validU.S. driver's license issuedby 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 aircraftinwhichthe PIC is rated onhis orherpilot 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 mustbe 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 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 experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS withappropriate distance from nonparticipants inaccordance 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) arenot authorized. 16. The UAS maynot operate within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with anARP, the center ofthe airport symbol as denoted onthe current FAApublished 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 ofagreement with the airport management must be made available totheAdministratororanylawenforcementofficial uponrequest. 17. The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhenvisibilityis lessthan 3 statutemiles from the PIC.Stol!1le Oak 17 18. Ifthe UAS loses communications or loses its GPS signal, the UAS must return to a pre- determinedlocationwithintheprivate orcontrolled-accessproperty. 19. The PIC mustabort the flight inthe eventofunpredictedobstacles oremergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UAS to conduct the intended operation andto operate after that for atleast five minutes orwiththe reserve powerrecommendedbythe manufacturerifgreater. 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 cannotbe conductedunderthe terms ofthe 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 (NNumber) markings in accordance with 14 CFRpart 45, Subpart C. Markings must be as large as practicable. 23. Documentsusedbythe operatorto ensurethe safe operationand flight ofthe UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC atthe Ground Control Stationofthe UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official uponrequest. 24. The UAS must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS maynotbeoperatedbythePIC from anymovingdevice orvehicle. 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 UAS and/or debris in the event ofan 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 UAS, flight operations must cease immediately in a manner ensuringthe safety ofnonparticipatingpersons; 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 ofthe risk ofoperating closer to those objects and determined that itdoes notpresent anunduehazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons underthis 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 obtainedfor each flight to be conducted.

### 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defmed 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 onthe NTSB Web site: www.ntsb.gov

. 4. CONCLUSION 

### Stone Oak hopes thatthis Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of2012 including weight, speed, operating capabilities, proximity to airports and populated areas, operation within VLOS and national security. The proposed UAS operations will 

### benefit the public as a whole by improving safety and reducing risk by alleviating human exposure to danger

. In consideration ofthe foregoing, Stone Oak further hopes that since the UAS will 

### be operated in strict compliance with the conditions in existing exemptions previously granted by the FAA, or as they may be amended, notice need not be provided in the Federal Register norpublic comment solicited.

# rgan**~** Manager Stone Oak, LLC