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 ofthe 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 Regul a tions ("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 ai rcrafts

. The eBee will be operated by an individual who fulfills the following requirements:
• Has successfully passed a manufacturer's tra ining 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, th e eBee takes a collection of high-definition s till images that are used later to generate maps and contour lines of the surveyed area . The fo ur 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 withou t 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 ri s k of hazardous situation s. Finally, the wings ofthe 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 propell er 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 ofthe flight under the supervision ofthe ope rator
. 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 industri es by providing high quality and actionable information to users. Indeed, use of the eBee would contribute to various so cial goods, from environmental protection to improved crop yields, safety inspection s, property damage assessment and sea rch and rescue. 3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 a. Airworthiness Assessm ent of the eBee: ENDEAVOR UNMANNED SOLUT IONS, LLC notes t hat the airworthiness of the eBee has already been demonstrated for different projects in the United States, invo lving state/fede ral agencies or universities (among othe rs the New Mexico State Un iversity: https:lfnewscenter
. nmsu. edu/Articles/vi ew/10208/nmsu
- uas-flight-test
-center-conducts-ebee
airworthin ess-assessment, and the US Army Corps of Engin ee rs (USACE) New Orleans, who coordinated with the Department of the Army and the FAA to obtain all authorizations requ ired in order to operate the eBee UAS). M oreove r, Sense Fi y obtained flight approvals for the eBee (delivered by national civil aviation authorities) in ma ny countries, among others: • Australia (flig ht approval for VLOS operations} • Can ada (flight approval for VLOS operations) • Denm ark (flight approval for VLOS operations) • France ( fli ght approval for Extended
-VLOS operat ion s) • Germany (flight approval for VLOS operations) • Norway (flight approval fo r VLOS operations) • Sweden (flight approval for VLOS operations) • Switzerland (flight approval for VLOS operations) • United Kingdom (flight approva l for VLOS o perations) b

. Operating Requirements: Grant of the exemption to ENDEAVOR UNMANNED SOLUTIONS, LLC for th e eBee will be subject to the following operating con ditions, based on the operating requirements set forth by the Academy of Model Aeronautics (see Annex B). The main restrict ions are su mmarized below : 

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# • Operations to be conducted over private, controlled-access, or public property where approved; Permission from the land owner/authority required before co mmencing 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 mile s from an airport shall only be initiated after verbal coordination with the airport authority, or ai r traffic control when a control tower is present at the airport; • All operations shall co mply 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 co mpl eted the written test of t he Private Pilot licen se. 3. CONCLUSION ENDEAVOR UNMANNED SOLUTIONS, LLC is a survey operator. We are a service provider engaged in high precision mapping products. Our se rvices 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 proj ects, 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 ofthis request to satisfy the need for an equivalent level of safety. We look forward to working with your office

. Please contact u s at any time ifyou require additional information or clarification. Yours sincerely,



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. Coolidge FAA Certificate 3610935