United States Department of Transportation 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 Washington, DC 20590 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 

2012 

Dear Sir or Madam: EnviroMINE, Inc. seeks exemption from the requirements of 14 C.F.R. §§ 91.9(b), 

91.203(a), 91.203(b), 45.23(b) and 21.185. This exemption will permit EnviroMINE, 

Inc. to operate an unmanned aerial system ("UAS") over areas of the States of 

Califomia and westem Arizona suitable for, or in use by, surface mining while keeping 

the documents required immediately accessible to the pilot at the ground control 

station. 

The exemption will relieve EnviroMINE, Inc. from the airworthiness certificate 

standards and the requirement to have a certificate of airworthiness issued for its 

UAS. This exemption will also permit any required markings concerning the 

operational status of the UAS to be displayed on a banner or flag displayed at the 

ground control station during operation 

EnviroMINE is also seeking relief from the requirements of having a private or 

commercial pilot's certification to operate the UAS for the purposes identified. The UAS 

is very lightweight and the operating parameters will be very similar, if not the same, 

as a remote control model UAS used by hobbyists. Individuals controlling the eBee 

will be experienced in safe operations of the remotely controlled UAS and will complete 

training by the manufacturer prior to UAS use for commercial purposes. 

EnviroMINE will implement safety procedures and flight restrictions to prevent ground 

or airbome accidents involving the UAS. Information on flight parameters and conditions for all missions will be maintained by EnviroMINE and will be available to 

the FAA upon request. Operations will be completed under the guidance provided by the Academy of Model Aeronautics (AMA) National Model Aircraft Safety Code, FAA 

safety standards for remote control model aircraft and/ or UAS standards otherwise 

established by the FAA. 

3511 Camino Del Rio South, Suite 403 - San Diego, CA 92108 

(619) 284-8515/(800) 755-3995 - Fax: (619) 284-0115 
software. Often times, the aerial imaging available to EnviroMINE is from public 

sources and can be relatively inaccurate and/ or outdated. As presented in this 

Petition, EnviroMINE seeks to operate its UAS for the special purpose of collecting 

aerial photographs to create surface maps and updated imagery in the support of and 

use by biologists, archaeologists, mine operators and the agencies that regulate these 

operations. 

Characteristics of the Aircraft 

EnviroMINE seeks an exemption to operate an eBee senseFly UAS for commercial 

purposes within the national airspace system ("NAS"). Built in Switzerland, the eBee 

consists of a flexible foam wing, a digital camera and a ground control station (Figure 

1). The eBee system has a gross system weight of approximately 1. 7 pounds and a 

wingspan of 38 inches. This vehicle has a single, rear mounted plastic propeller and 

an electric motor powered by a lithium polymer battery. 

Figure 1: The eBee 

{eBee 

sensefly 

The four main characteristics of the eBee are: 

1. Very light weight 

The eBee is so light that the operator can launch it by hand and land it on 

almost any surface without requiring a parachute or landing net. Its low impact 

energy of 38 Joules (in the case of a controlled emergency landing) also 

significantly reduces the risk of hazardous situations. The wings of the eBee are 

detachable and made of flexible foam with no sharp or hard edges and almost 

no internal strengthening structure. 
3. 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. Ground station software allows the operator to 

produce a 3-D flight plan prior to the mission, simulate the flight, monitor the 

drone's parameters during flight and allow the pilot to control the trajectory of 

the eBee during flight. 

4. Option for Manual control 

Additionally, the eBee provides an override capability that allows the operator to 

take manual actions during the flight such as Go to Home, Go Land, Hold and 

Resume the Mission. suspend automated operations can also be suspended by 

the operator and take manual control of the aircraft should it become necessary to respond emergent circumstances, thanks to the remote controller provided 

with the system. 

The eBee does not create a hazard to users of the NAS or the public, or otherwise 

create a threat considering its size, weight, speed or operational capability. The 

specifications of the eBee are listed in the table below: 

T a e bl 1 . e B ee S ;peel ·o 1ea t· 1ons 

Weight (inc. camera) 1.7lb Wingspan 38 in 

EPP foam, carbon structure & 

Material composite parts 

electric pusher propeller, 160W 

Propulsion brushless DC motor 

Battery 11.1 v, 2100 mAh 

Camera (default) 16 Megapixel IXUS/ELPH 

Operational Characteristics 

Maximum flight time 50 minutes 

Cruising speed 22-35 miles/hour 

Radio link range up to 1.86 miles 

Maximum coverage (single flight)_ 6.2 square miles 

Ground sampling distance (GSD) down to 0.39 in. 

Orthomosaic accuracy down to 1.18 in. 

Digital Elevation Model (DEM) accuracy down to 1. 96 in. 

3D flight planning yes 
system monitoring, documentation of construction progress, and extensive oblique 

photography of USACE structures & activities. 

Flight approvals for the eBee have been obtained from the national civil aviation 

authorities in a number of countries including: 

• 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) 

Mandatory Operating Conditions 

The grant of the exemption to EnviroMINE for the eBee will be subject to the following 

operating conditions, based on the operating conditions set forth by the Academy of 

Model Aeronautics. The main restrictions are summarized below: 

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

where approved; 

• Permission from the land owner j 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 nautical mile • Flight ceiling pre-programmed at 400 feet or less; • 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 
Inspection and Maintenance Requirements have been provided to the FAA under 

separate, confidential cover. 

EnviroMINE provides the following information in support of its petition for exemption: 

A. Name and Address of the Petitioner. 

The name, address and contact information of the Petitioner is: 

EnviroMINE, Inc. 

Attn: Mr. Dennis Fransway 

3511 Camino Del Rio South 

Suite 403 

San Diego, CA 92108 

Phone: 619-284-8515 

e-mail: dennis@enviromineinc.com 

B. The Specific Sections of 14 C.F.R. From Which EnviroMINE Seeks Exemption. 

EnviroMINE, Inc., the Petitioner, pursuant to the provisions of the Federal Aviation 

Regulations and the FAA Modemization and Reform Act of 2012, Section 333, 

seeks relief from the following specific sections of Title 14 of the Code of Federal 

Regulations: 

---------------------------------------------------------------

• 14 CFR 21.185; 

• 14 C.F.R. 45.23(b) &45.29; 

• 14 CFR 61; 

• 14 C.F.R. 91, et seq.; 

• 14 CFR 121; 

• 14 CFR 407 (a) (1); 

• 14 CFR 409 (a) (2); and 

• 14 CFR 417 (a) & (b). 

C. The Extent of Relief EnviroMINE Seeks And The Reasons It Seeks The Relief. 

1. Relief from 14 C.F.R. § 21.185. 

EnviroMINE seeks to exempt the eBee UAS from 14 C.F.R. § 21.185: Issue of 

ainuorthiness certificates for restricted category aircraft. 
single, defined, special purpose operation such as aerial mapping. 

EnviroMINE seeks relief from the airworthiness certificate requirements of the FAR 

because operation of the eBee will not create a hazard to users of the NAS, the public 

or present a threat to national security. 

The proven safe operational history of the eBee in the NAS demonstrates that the eBee 

has operated safely in the NAS without creating a hazard to aircraft or people on the 

ground. In addition, EnviroMINE has specified parameters for the eBee's intended 

operation pursuant to this exemption. As a result, the FAA may approve operation of 

the eBee, without an airworthiness certificate, by setting specific operating limitations to ensure a level of safety equivalent to that provided by airworthiness certification. 

2. Relief from 14 C.F.R. § 45.23(b) & 45.29. 

EnviroMINE seeks an exemption from 14 C.F.R. § 45.23(b) and § 45.29: Display of 

marks; general. 

EnviroMINE requests relief from the requirement of Section 45.23(b) that the word 

"Experimental" be displayed on the eBee near each entrance to the cabin, cockpit, or pilot point. Additionally, these regulations provide that each aircraft must display "N" 

and the aircraft's registration number in letters at least 2 inches high. 

Given the size of the unmanned eBee (wingspan of 37.8 inches), the vehicle has no 

ability to carry passengers since it has no cabin, cockpit, door entrances or pilot point on the UAS. The equivalent level of safety will be achieved by placing a sticker with a copy of the AMA membership of the operator in charge on the upper part of the eBee. 

In addition, each operator will display at the ground station a high contrast flag or 

banner that with the words "Unmanned Aircraft System Ground Station" in letters 3 

inches high or greater. Since the aircraft will operate within 1/2 nautical mile of the 

ground station, the banner should be visible to anyone that observes the aircraft and 

chooses to investigate its point of origin. 

3. ReliefFrom 14 C.F.R. § 61. 

EnviroMINE seeks an exemption from 14 C.F.R. § 61: Certification: Pilots, Flight 

Instructors, And Ground Instructors. 

Pursuant to 14 C.F.R. § 61 no person may serve as a required pilot flight crewmember 

of a civil aircraft of the United States, unless that person has on their person or in the aircraft the authorization or certificates as listed in 14 C.F.R. § 61.3. EnviroMINE can achieve an equivalent level of safety as achieved by current Regulations because 
EnviroMINE seeks an exemption from 14 C.F.R. § 91.9: Civil Aircraft flight manual, 

marking, and placard requirements. 

Relief from§ 91.9(b) is requested because the eBee weighs approximately 1.7 pounds 

at its maximum gross weight and cannot carry the approved Airplane Flight manual 

on the vehicle. Since the eBee is unmanned, the aircrew member is located at a 

ground control station. At all times the UAS is operating, EnviroMINE will maintain 

the approved Airplane Flight Manual at the ground control station for immediate 

accessibility by the operating aircrew member. 

5. Relief from§ 91.121 

EnviroMINE seeks an exemption from 14 C.F.R. § 91.121: Altimeter settings. 

Relief from § 91.121 is requested because the eBee UAS continuously analyzes data 

from the Inertial Measurement Unit and the onboard GPS to determine elevation. 

Once the flight area has been designated, the planning system downloads a base 

Digital Elevation Model (DEM) for the specific area into the UAS which allows the unit 

to continuously monitor the elevation above ground level (AGL). This information is 

monitored at the ground control station during the entire flight. 

6. Relief from § 91.203(a) and (b). 

EnviroMINE seeks an exemption from 14 C.F.R. § 91.203(a) and (b). Section 91.203: 

Civil aircraft: Certifications required, 

EnviroMINE requests relief from the requirement of Section 91.203(a) that an 

appropriate and current airworthiness certificate and an effective U.S. registration 

certificate be carried within the aircraft. Also, EnviroMINE requests relief from the 

requirement of Section 91.203(b) that the airworthiness certificate be displayed at the 

cabin or cockpit entrance so that it is legible to passengers or crew. The eBee is 

incapable of carrying passengers or crew and has no cabin, cockpit, or door entrances. 

The UAS operator is located at the ground control station and no passengers are 

carried at any time. EnviroMINE will keep the documents required by Sections 

91.203(a) and (b) at the ground control station, where it will be immediately available 

to the operator of the UAS at all times the unmanned aerial vehicle is operating. 

7. Relief from § 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b). 

EnviroMINE seeks an exemption from 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 

417(a) & (b): Maintenance Inspections. 
will conduct a routine, manufacturer recommended, inspection and maintenance 

program that involves regular software updates and repair /replacement procedures 

for any damaged hardware. As a result, an equivalent level of safety will be achieved 

as required by the intent of the regulations. 

D. The Reasons Why Granting EnviroMINE's Request would be In the Public 

Interest. 

Granting the EnviroMINE Petition will further the public interest by allowing 

EnviroMINE the ability to safely and economically collect aerial photographs in an 

efficient manner over areas of the States of California and western Arizona which are 

suitable, or being used, for mining. Imagery collected will be utilized for developing 

. topographic maps and surface models in support of surface mine operations and 

regulatory agencies. The eBee will provide safe, efficient, and economical aerial 

photography and mapping operations to further each of these fields, all of which are 

critical to the well-being of the general public. 

The specific operations that EnviroMINE will perform with the eBee demonstrate how 

the requested exemption will directly benefit the above-referenced industries and the 

public. In the mining industry, the eBee will be used to aid in site inspections, 

topographic surveying, biological monitoring, evaluating geology and planning 

proposed mines. Construction aggregate (sand & gravel) is the second most utilized 

natural resource in the world and is necessary for building roads, bridges and all 

other infrastructure necessary for a modern society. Use of the eBee will allow mine operators to manage this resource to provide the materials to build and maintain the 

infrastructure systems used by the public on a daily basis. Monitoring biological 

conditions (vegetation & wildlife) on, and in, the vicinity of the mine is also beneficial 

to the public since it is a strong indication of potential environmental consequences 

developing. In addition agencies responsible for regulating this industry will be able to 

monitor permit compliance by these operations using the aerial photos, maps and 

surface models developed. 

The eBee is a battery powered UAS that serves as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount of manned aircraft needed to perform aerial photographs, an 

exemption allowing the use of an eBee UAS to collect these photographs would reduce 

the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 

increase the safety of life and property both in the air and on the ground. 
This exemption would maintain the level of safety established by Section 91. 9(b) 

because EnviroMINE will keep the approved Airplane Flight Manual at the ground 

control station where the pilot in command flying the eBee will have immediate access 

to the document. 

Previous exemptions granted by the FAA concerning Section 91.9(b) establish that 

safety is not adversely affected when the approved Aircraft Flight Manual is 

maintained at the ground control station of a UAS, where it can be immediately 

accessed by the pilot in command. Section 91.9(b) "requires aircraft to carry the flight 

manual so the pilot would have ready access to the aircraft limitations while in flight." 

The eBee UAS will always be operated without any passengers or crew onboard and is 

incapable of carrying flight manuals or additional documents. If attempted, the UAS 

would most likely be unable to fly. 

The FAA has previously granted similar exemptions through Exemption Nos. 8607, 

8737, 8738, 9299, 9430, 9554, 9564, 9565, 10167, 10602, 10673, 10835, 10869 and 

10968. 

This exemption would maintain the level of safety established by Sections 91.203(a) 

arid (b) because EnviroMINE will keep the required documents at the ground control 

station where the pilot in command flying the eBee will have immediate access. 

Previous exemptions granted by the FAA concerning Sections 91.203(a) and (b) 

establish that safety is not adversely affected when the Airworthiness Certificate and 

U.S. registration certificate are kept at the ground control station of the UAS, where it 

can be immediately accessed by the operator in command. Specifically, the FAA has 

held that the intent of Sections 91.203(a) and (b) is better served by having the 

required documents in the control of the operator. 

The original intent of the subject regulation was to display the airworthiness and 

registration documents so they would be easily available to FAA inspectors and 

passengers for inspection and verification of the airworthiness and registration of the 

aircraft. In this case, the aircraft is incapable of carrying passengers or crew. 

The missions for which eBee is intended will prevent the UAS from being available for 

the inspections normally prescribed for civil aircraft. Further, it will be operated from a 

known departure and arrival point, under the constant control of a pilot-in-command. 

The intent of the regulation is best served by having the required documents in the 

control of the UAS operator and available for inspection if requested. 
In seeking this exemption, EnviroMINE submits that the eBee can operate safely in the 

NAS above the State of California and western Arizona without creating a hazard to 

aircraft or people on the ground. Accordingly, the FAA may approve its use without an airworthiness certificate as demonstrated by: (i) the safe operational history and 

current use of the eBee in the NAS; (ii) the characteristics of the eBee; and (iii) the 

specific operating limitations. In support of this position and exemption request, 

EnviroMINE has submitted to the FAA, under separate, confidential cover, a 

Justification of Airworthiness and Safety Assessment for the eBee; eBee Operators 

Training Documentation; and eBee's Inspection and Maintenance Requirements. 

The eBee is currently operating safely in the NAS pursuant to Certificates of 

Authorization ("COA'') granted by the FAA. These include New Mexico State University 

and the U.S. Army Corps of Engineers, New Orleans District. 

EnviroMINE proposes to only conduct aerial photography flight operations over areas 

of the States of California and western Arizona that are not near airports or helipads or over residential areas. 

Specifically, EnviroMINE's proposed area of flight operations includes areas suitable 

for mining that are: 

1. On active mining operations in or near urban areas, EnviroMINE will maintain 

a 100 yard, horizontal buffer between the eBee and congested properties. Flight 

paths shall not cross over residences. 

2. Not within 5 miles of any airport or helipad without proper notification. If an 

airport is located within 5 miles of a proposed VAS flight the airport operator, 

the control tower (if an air traffic facility is located at the airport) or the flight 

service station will be notified of the proposed flight. 

3. Not more than 400 feet above ground level. 

In summary, EnviroMINE seeks to operate its eBee areas of California and western 

Arizona suitable for, or in use by, mining operations while maintaining safe distances 

from any populated areas, airports or helipads. 

In seeking this exemption, EnviroMINE proposes to commercially operate the eBee 

without satisfying the restricted category airworthiness certification process specified 

in 14 C.F.R. § 21.185 as well as other regulations as discussed above. EnviroMINE 

proposes to operate the eBee, for the special purpose of conducting aerial photography 
3. The eBee shall be operated pursuant to Visual Flight Rules (VFR) and only 

during daylight hours. 

4. The duration of each flight shall not exceed 40 minutes or 25% battery power 

whichever is lower. 

5. The eBee shall operate from on-site takeoff/landing locations directly next to 

the pilot in command. 

6. EnviroMINE's UAS has a GPS flight mode where it will return to the takeoff 

location and land if communication with the remote control pilot is lost. 

7. Operation of the eBee with any inoperative instruments or equipment shall be 

prohibited. 

8. The eBee shall be maintained m accordance with the Manufacturer's 

Maintenance Manual. 

EnviroMINE understands that the Administrator may stipulate special conditions for 

the intended operation of the eBee in accordance with Section 333 of the FAA 

Modernization and Reform Act of 2012. 

F. Can Be Published In The Federal Register, stating: The 

nviroMINE Seeks Exemption: 

EnviroMINE's Petition is made pursuant to the FAA Modernization and Reform Act of 

2012, Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, EnviroMINE's request for 

exemption may be granted pursuant to the authority of Section 333 and 14 C.F.R. 

Part 11. Specifically, EnviroMINE, Inc. seeks exemption from the requirements of 14 

CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 

121; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and 14 CFR 417 (a) & (b). 

This exemption will permit EnviroMINE, Inc. to operate an unmanned aerial vehicle 

system over areas of the State of California and western Arizona while keeping the 

documents required by the regulations at the ground control station and immediately 

accessible to the pilot. Furthermore, the exemption will relieve EnviroMINE, Inc. from 

the airworthiness certificate standards and the requirement to have a certificate of 

airworthiness for its unmanned aerial vehicle system. This exemption will also permit 
for procurement of necessary airworthiness certificates in relation to FAR § 

91.203(a)(1). The size, weight and enclosed operational area of EnviroMINE's UASs 

permits exemption from Part 21 because EnviroMINE's UASs meet an equivalent level 

of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. 

§ 44 701 (f)) and Section 333 of the Reform Act in consideration of the weight, size, 

speed, maneuverability and proximity to areas such as airports and dense 

populations. EnviroMINE's eBee UAS meets or exceeds each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are 

no pilots or passengers, and given the size of the UAS, this Regulation is inapplicable. 

An equivalent level of safety will be achieved by maintaining a manual at the flight 

operations center. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10167A, 10602, 10700 and 32827. 

14 C;F.R. § 91.121 regarding altimeter settings is inapplicable insofar as EnviroMINE's 

UASs utilizes an electronic global positioning system and downloaded Digital Elevation 

Models to provide elevation and altitude that is continuously monitored at the ground 

control station. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications 

and registrations. They are inapplicable for the same reasons described in the above 

discussions. The equivalent level of safety will be achieved by maintaining such certifications and registrations at the EnviroMINE's flight operations center. 

2. 14 C.F.R. § 45.23: Marking of the Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to 

certain specifications. EnviroMINE's UASs are, by definition, unmanned. They 

therefore do not have a cabin, cockpit or pilot station on which to mark certain words 

or phrases. Further, two-inch lettering is difficult to place on such small aircraft. In 

lieu of aircraft markings, EnviroMINE will display at the ground station a high 

contrast flag or banner that with the words "Unmanned Aircraft System Ground 

Station" in letters 3 inches high or greater. Since the aircraft will operate within 1/2 

nautical mile of the ground station, the banner should be visible to anyone that 

observes the aircraft and chooses to investigate its point of origin. 
the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. 

Thus, allowing EnviroMINE to operate its UAS will exceed current safety levels in 

relation to 14 C.F.R. §61.113 (a) & (b). 

4. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. 

EnviroMINE's eBee UAS will never operate at an altitude greater than 400 AGL. Given 

the areas the eBee will be operated over plus the size, weight, maneuverability and 

speed of EnviroMINE's UAS, an equivalent level of safety will be achieved. 

5. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections. 

The cited Regulations require aircraft owners and operators to have an aircraft 

inspected at certain times and to have discrepancies repaired if discrepancies are 

detected between inspections. 

These Regulations only apply to aircraft with an airworthiness certificate. They will 

_not apply to EnviroMINE should its requested exemption be granted. EnviroMINE 

- conducts a routine maintenance program that involves regular software updates and 

repair /replacement measures for any damaged hardware. Therefore, an equivalent 

level of safety will be achieved. 

6. Conclusion 

EnviroMINE seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the 

FAA Modemization and Reform Act of 2012, which will permit safe operation of the 

eBee commercially for the special purpose of conducting aerial photographs over areas 

in California and westem Arizona that are suitable, or in use, for mining. This 

photography will be used to develop maps and surface models for use by mine 

operators, regulatory agencies and advancing the interests of the public. 

Granting EnviroMINE's request for exemption will reduce current risk levels and 

thereby enhance safety when compared to conventional aircraft. Conducting aerial 

photography has relied on the use of large, conventional aircraft powered by 

flammable, liquid fuel. EnviroMINE's UAS is significantly smaller, lighter and more 

maneuverable than a conventional aircraft. Also, the UAS is does not carry any 

flammable fuel, rather it relies on an electric motor and lithium battery for 

propulsion. 

EnviroMINE's eBee is not capable of carrying people and as a result the likelihood of 
respectfully requests that the FAA grant its exemption request without delay. 

Sincerely, 

EnviroMINE, Inc. 

Warren R. Coalson 

President