SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 1

September 18th, 2014

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Filed with www.regulations.gov

Re: Petition for Exemption 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, SenseFly Ltd. (“SenseFly”), the manufacturer of the eBee Unmanned Aircraft

System (“eBee”), on behalf of itself and future commercial operators of its eBee, seeks an

exemption from the Federal Aviation Regulations (“FARs”) listed below:

• 14 C.F.R. Part 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)

• 14 C.F.R. 91.7(a)

• 14 C.F.R. 91.9

• 14 C.F.R. 91.109(a)

• 14 C.F.R. 91.119

• 14 C.F.R. 91.121

• 14 C.F.R. 91.151(a)

• 14 C.F.R. 91.203

• 14 CFR Subpart E (91.401 - 91.417)

The requested exemption would authorize commercial operations using the eBee for mapping and 

precision agriculture applications. These operations will be subject to strict operating requirements
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 2

and conditions defined by the Safety Program of the Academy of Model Aeronautics (“AMA”) (see 

Annex B), in order to ensure at least an equivalent level of safety to currently authorized operations

using manned aircrafts.

Given the technical specifications of the eBee (especially its very light weight), SenseFly and the 

AMA think it is relevant to use the AMA rules to meet the required level of safety of operations with 

the eBee. Indeed, the AMA has a proven track record in supervising operations conducted by 

operators using Remote Control Aircrafts and provides the most relevant expertise in terms of 

providing safety guidelines for operators using ultra-light remote control aircrafts. Hobbyists and 

modelers have been safely operating unmanned aircrafts (model aircrafts) for years in compliance 

with AMA standards.

By this petition, SenseFly seeks an exemption that will also authorize a commercial operator to use 

the eBee for commercial purposes provided the operator complies with any terms and conditions of 

SenseFly’s exemption, including the procedures and requirements set forth in the eBee user 

manual and the AMA Safety Program, once the operator commits to do so in a letter filed with the 

FAA in this docket and available in Annex C; SenseFly requests the FAA treat the eBee user 

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

Similar to the practice of other agencies, which allow non-parties to a special permit or exemption 

to obtain the same special permit or exemption authority by submitting a letter to the agency 

committing itself to comply with the terms and conditions of such permit or exemption, SenseFly 

requests the FAA agree to grant such authority to operators upon receipt of a written commitment 

filed in this docket to comply with the terms and conditions of the exemption granted to SenseFly.

Under this exemption, the operator would agree, if requested, to contact the FAA in order to 

provide the FAA with the details of the related missions and provide assurance that training and 

maintenance requirements are met.

In the alternative, SenseFly requests the FAA to agree to process expeditiously and in an 

abbreviated manner petitions for an exemption filed under section 333 by an operator that intends 

to operate the eBee and commits to comply with the terms and conditions contained in the grant of 

exemption as well as in SenseFly and AMA requirements and procedures. Such petitions would not 

be subject to the summary publication requirement or opportunity for comment, unless the 

petitioner seeks additional or different exemption relief.

Under the requested exemption, SenseFly and other operators of the eBee will ensure that the 

aircraft will be operated by an individual who meets all of the following requirements:

• Is a registered member of the AMA;

• Has passed SenseFly’s training program for the eBee; SenseFly 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.

• Has completed an AMA-affiliated small unmanned aircraft systems (UAS) education and 

training program and has achieved an AMA UAS endorsement, or has successfully

completed a small UAS education and training program provided by any FAA qualified 

entity.

1. CHARACTERISTICS OF THE AIRCRAFT

The eBee is a small (38 inches wingspan) and ultra-light (maximum take-off weight of 1.7 pounds)

platform made of flexible foam that performs precision aerial mapping missions thanks to the onboard 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 
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 3

that are used later to generate maps and contour lines of the surveyed area. 

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 kinetic energy (60 Joules (“J”) at 

cruise speed) 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 two rubber bands 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 AND ADDED VALUE OF THE EBEE

Mapping applications with the eBee may include agricultural applications, mining, construction and 

survey/GIS operations. The reason why the eBee solution has been very successful worldwide 

(thousands of operations in more than 50 countries) is that there are many operational benefits 

related to the use of this solution:

a. First, the eBee brings safety to daily survey operations: there is no need for the humans to 

access dangerous working areas anymore (mines, quarries, or polluted sites). The missions can be 

programmed and reproduced reliably as often as needed for regularly updated maps.

b. Second, the eBee is a cost-effective solution. It is cheaper to operate a UAS rather than an 

aircraft or other ground systems for the same results. Moreover, small UAS like the eBee can help

Ag businesses and farmers face the growing needs of the population while reducing operational 

costs. The eBee also enables the ability to take up new challenges - like water or environmental 

management through analysis of vegetation index maps.

c. Third, users can save time and work more efficiently by using the eBee. A mission does not need 

a long preparation time or long deployment constraints, or long waiting time for perfect weather 

conditions unlike, for example, the use of satellites. Initial results are accessible directly on-site, 

which is impossible with images provided by satellites or manned aircrafts.

d. The eBee has social benefits too: it is eco-friendly (electric-powered), and its affordability allows 

many high-valued applications like data gathering for sustainability projects (agribusiness, 
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 4

reforestation) or post-disaster management missions.

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333

a. Airworthiness assessment of the eBee

SenseFly 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.nmsu.edu/Articles/view/10208/nmsu-uas-flighttest-center-conducts-ebee-airworthiness-assessment, and the US Army Corps of Engineers 

(“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, SenseFly has obtained flight approvals for the eBee from the national civil aviation 

authority in many countries, including:

• Switzerland (flight approval for Visual Line of Sight “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 Conditions

Grant of the exemption to SenseFly for the eBee, and for the benefit of operators of the eBee, will 

be subject to the following operating conditions, based on the operating conditions set forth by the 

AMA (see Annex B), and the factors the FAA is to consider under section 333. The main 

restrictions are summarized below:

• Operations to be conducted over private, controlled-access, or public property where 

approved;

• 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;

• VLOS guaranteed with a GPS geo-fence around operator of 0.5 miles;

• Flight ceiling pre-programed at 400 feet AGL;

• All operations conducted within 5 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.
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 5

c. Operating Requirements

The eBee is an ultra-light UAV platform made of flexible foam with no sharp or hard edge

characterized by a high level of pre-programmed control and various built-in technical capabilities

(programming of a geo-fence, automatic wind detection) that prevent the operator doing a mission

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 those safety features, recognized by the U.S. Army Corps of Engineers and the national 

aviation authority of several countries, SenseFly 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. 

SenseFly also proposes that operators of the eBee should not be required to hold a commercial or

private pilot certification, and hereby requests an exemption from the pilot certification requirements 

in the Federal Aviation Act and Part 61. Pilot certification requirements for manned aircraft are 

neither necessary nor appropriate in many respects for operators of small, ultra lightweight UAVs. 

There are undoubtedly ATP-certificated pilots who nonetheless would need training to operate a 

UAV safely; conversely, the UAV training regimen includes instruction for non-certificated 

operators in those aspects of safe operation in the National Airspace System (“NAS”) that are 

relevant to the UAV and the UAS operation. The FAA has authority under both section 333 and its 

general waiver and exemption authority in 49 U.S.C. 44701(f) to waive the statutory pilot 

certification requirement upon a showing that the required UAS training achieves an equivalent 

level of safety.

To achieve as well as exceed an equivalent level of safety, operators will be required to:

• 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 been already satisfactorily reviewed through the 

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

SenseFly 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. 
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 6

4. CONCLUSION

SenseFly, in association with the Academy of Model Aeronautics who has a deep and well-known 

experience in terms of safe integration of remote controlled aircrafts in the National airspace for 

low-altitude operations, provides here adequate justification for the granting of the requested

exemption allowing safe commercial operations of the eBee in the NAS.

SenseFly offers in this petition a pragmatic approach to allow the efficient operation of ultra-light 

UAVs pursuant to FAA, AMA, and SenseFly safety requirements and conditions.

Yours sincerely,

Jean-Christophe Zufferey, SenseFly CEO
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 1

ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS 

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

SenseFly 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

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. SenseFly 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.

The equivalent level of safety will be achieved by having the upper part of the eBee stick with a 

copy of the AMA membership of the operator in charge. The AMA agrees to provide 2 original 

copies of the AMA license to every eBee operator.

14. CFR §61.23: Medical certificates: Requirement and duration

Regulations provide that a person:

(1) Must hold a first-class medical certificate:

• When exercising the pilot-in-command privileges of an airline transport pilot certificate;

• When exercising the second-in-command privileges of an airline transport pilot certificate in 

a flag or supplemental operation in part 121 of this chapter that requires three or more 

pilots; or

• When serving as a required pilot flight crewmember in an operation conducted under part 

121 of this chapter if the pilot has reached his or her 60th birthday.

(2) Must hold at least a second class medical certificate when exercising:
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 2

• Second-in-command privileges of an airline transport pilot certificate in part 121 of this 

chapter (other than operations specified in paragraph (a)(1)(ii) of this section); or

• Privileges of a commercial pilot certificate

Given the size of the eBee, its structure, the limited flight area, and the safety features integrated in

the autopilot (among others the Flight Termination System), SenseFly believes that an Equivalent 

Level of Safety can be reached if the operator has a valid driver’s license.

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 or private pilot certification. 

Instead, operators should be required to:

• Have completed an AMA affiliated small unmanned aircraft systems 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 been already satisfactorily reviewed through the 

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

The equivalent level of safety will be achieved by having an operator trained by the AMA (or any 

FAA qualified entity) and SenseFly, and using the integrated features of the aircraft to maintain a 

high level of safety during the different missions.

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-uasflight-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, 
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 3

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 eBee user manual

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. SenseFly assumes that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. SenseFly requests

an exemption to this requirement since the aircraft is not only too small to carry documentation, but 

the documentation would not be available to the crew.

The equivalent level of safety will be achieved by keeping a hard copy of the eBee user manual in 

the eBee transport box.

14 C.F.R. § 91.109(a): 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 in-flight training will be achieved by the manufacturer or affiliate providing the training as 

described in the eBee training program and through the use of experienced and qualified 

instructors familiar with the eBee and also members of the AMA.

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 eBee will be operating at a 

maximum of 400 feet AGL, SenseFly 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, the material with which the eBee is built and its specific safety procedures (among others

ground detection), 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 or over any open-air assembly of persons. 

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;
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 4

• 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 

then used to calculate the altitude in-flight.

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. As the eBee is electric-powered, this requirement is inapplicable.

In any event, given the area of operation for the eBee, SenseFly 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.

To obtain an equivalent level of safety and meet the intent of 91.203, SenseFly proposes 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 transport box and available for inspection upon request. In 

order to identify the aircraft, SenseFly proposes that a copy of the AMA membership of the operator 

will be permanently affixed to the eBee on the upper side of the body.

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 the aircraft to be "approved for return to service by a person authorized under 43.7" after 

maintenance and inspection. Section 91.409 requires an annual inspection for the issuance of an 

airworthiness certificate. Section 91.417 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.

SenseFly proposes that the maintenance of the eBee will be accomplished by the owner or the 

operator according to the eBee user manual. An equivalent level of safety will be achieved because

the eBee is small in size, it is not a complex mechanical device and does carry any external

payload. 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 automatically runs a sequence of pre-flight tests to make sure that 

every sensor and every critical part is operating 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 eMotion. The 

owner or the operator can then refer to the eBee user manual to troubleshoot this issue. Several 
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 5

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.
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 1

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
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 1

ANNEX C: PROPOSITION OF DOCUMENT TO BE FILLED OUT BY EVERY OPERATOR

Section 1: Organization Contact Details

• Organization:

• Organization Address:

• Organization Phone Number:

• Website of the Company:

• Organization Contact Full Name:

• Contact Phone number:

• Contact email address:

Section 2: Operator(s) Contact Details

• Operator First Name:

• Operator Middle Name (optional):

• Operator Last Name:

• Primary Phone Number:

• Email address:

• Secondary Phone Number:

• AMA Membership Number:

Note: Add the above-requested information for each operator.

Section 3: Operator’s Certifications 

1.a. The operator(s) has (have) successfully accomplished AMA’s training regimen and received an 

AMA endorsement (please provide a copy of the certificate(s)); or has (have) successfully 

accomplished a training program performed by a FAA qualified entity:

Yes: ! / No: !

1.b. The operator(s) has (have) successfully accomplished SenseFly specific training program for 

the related UAV (please provide a copy of the certificate(s)):

Yes: ! / No: !

2. The operator(s) has (have) reviewed the operating requirements described in the Petition for 

Exemption filled out by SenseFly and agrees to comply with those operating requirements:
SenseFly’s Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations - Page 2

Yes: ! / No: !

Section 4: Description of Operations

• Enter the number of UAVs you are registering:

• Enter the serial numbers, if possible, for the UAVs you are registering:

• Briefly describe the purpose of your proposed operation(s):

• Describe the times of day in which you plan to operate:

• Enter how many observers will be present for each UAV type of operation:

Section 5: Description of Additional Operating Procedures

• Describe how you will maintain communication with operators on the ground:

• Describe the additional safety procedures you propose to use:

• Describe any other factors you deem important:

Date:

Full name:

Signature: