August 15, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

397 Spruce Glen Road 

Lexington, SC 29072 

(703} 599-3277 

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, ENDEAVOR UNMANNED SOLUTIONS, LLC, an operator of the SenseFiy 

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 

• FAA Order 8900.1 Volume 16-4-4-l(a) 

• 14 C.F.R. 61.101(e)(4) & (5) 

• 14 C.F.R. 61.113(a) & (b) 

• 14 C.F.R. 61.133{a) 

• 14 C.F.R. 61.315{c) 

• 14 C.F.R. 91.7(a) 

• 14 C.F.R. 91.9(b)(2) 

• 14 C.F.R. 91.103 

• 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(a) & (b) 

• 14 C.F.R. 91.319(a}{1) 

• 14 CFR Subpart E (91.401- 91.417) 
' 

> . 

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

and survey applications. These operations will be subject to strict operating requirements 

defined in the eBee user manual (ENDEAVOR UNMANNED SOLUTIONS, LLC 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. 

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

• Has successfully passed a manufacturer's training program for the eBee. 

1. CHARACTERISTICS OF THE AIRCRAFT 

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

pounds) platform made of flexible foam that performs pre-programmed precision aerial 

mapping missions thanks to the on-board Global Positioning System (GPS) and the related flight 

management software (eMotion) that allows the operator to plan safely and efficiently a mission 

in 3D, and then monitor it in real-time. Thanks to the embedded camera, protected by a foam 

envelope, the eBee takes a collection of high-definition still images that are used later to 

generate maps and contour lines of the surveyed area. 

The four main characteristics of the eBee are: 

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 (only 38 joules 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 (IMU) 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 emergent circumstances, thanks to the remote controller provided with the system. 
2. APPLICATIONS 

The primary role of the eBee is to collect, process, and analyze aerial data principally for 

purposes of the following: 1) precision agriculture, 2) precision surveying, 3) monitoring natural 

resources, endangered species and plant life, 4) conducting flight demonstrations, 5) inspection 

of roofs, towers, dams and levees, telecommunications and utility structures, railroad track, 

pipeline, power line and bridges, 6) surface mining, 7) construction, 8) maintenance services, 9) 

special events, and 10) assisting first responders. In doing so, ENDEAVOR UNMANNED 

SOLUTIONS, LLC would occupy a brand new space in transformative industries by providing high 

quality and actionable information to users. Indeed, use of the eBee would contribute to 

various social goods, from environmental protection to improved crop yields, safety 

inspections, property damage assessment and search and rescue. 

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

a. Airworthiness Assessment of the eBee: 

ENDEAVOR UNMANNED SOLUTIONS, LLC 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:lfnewscenter.nmsu.edu/Articles/view/10208/nmsu-uas-flight-test-center-conducts-ebeeairworthiness-assessment, and the US Army Corps of Engineers (USACE) New Orleans, who 

coordinated with the Department of the Army and the FAA to obtain all authorizations required 

in order to operate the eBee UAS). M oreover, SenseFiy obtained flight approvals for the eBee 

(delivered by national civil aviation authorities) in many countries, among others: 

• Australia (flight approval for VLOS operations} 

• Canada (flight approval for VLOS operations) 

• Denmark (flight approval for VLOS operations) 

• France (flight approval for Extended-VLOS operations) 

• Germany (flight approval for VLOS operations) 

• Norway (flight approval for VLOS operations) 

• Sweden (flight approval for VLOS operations) 

• Switzerland (flight approval for VLOS operations) 

• United Kingdom (flight approval for VLOS operations) 

b. Operating Requirements: 

Grant of the exemption to ENDEAVOR UNMANNED SOLUTIONS, LLC for the eBee will be subject 

to the following operating conditions, based on the operating requirements 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; 

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; 

J 
• Operations limited to Visual Flight Rules (VFR) and Visual 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 is guaranteed with a GPS geo-fence around the operator of 0.5 miles; 

• Flight ceiling pre-programed no higher than 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 w ith 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. 

c. Operator Requirements: 

The eBee operator will have successfully completed the written test of t he Private Pilot license. 

3. CONCLUSION 

ENDEAVOR UNMANNED SOLUTIONS, LLC is a survey operator. We are a service provider 

engaged in high precision mapping products. Our services and products save our clients time 

giving the ability for them to make better decisions. The eBee is safer than having ENDEAVOR 

UNMANNED SOLUTIONS, LLC's employees out in the field for specific projects, and also very 

safe for other aircraft because of the mission specifications (below 400ft.) and eBee integrated 

safety features. 

ENDEAVOR UNMANNED SOLUTIONS, LLC is prepared to modify or amend any part of this request 

to satisfy the need for an equivalent level of safety. We look forward to working with your office. 

Please contact us at any time if you require additional information or clarification. 

Yours sincerely, 

"'1~1_ [ 6"£dr-~ Timothy E. Coolidge 

FAA Certificate 3610935