Jon Tull, CEO Ag Tech Enterprises, Inc. 4580 E. Thousand Oaks Blvd. Su ite 300 Wes tlake Village, CA 91362
Ju ne 11, 2015

Unmanned Ai rcraft S ystems Integration Office AFS-80 800 Independence Ave

., S.W. Washington, D

.C. 20591
To Whom It May Concern : Enclosed please find an exemption application filed on behalfof Ag Tech Enterprises, Inc. underSection 333 ofthe FAA Modernization and Reform Act of201 2 and 14C.F.R

. Part 11to allow commercial operations of unmanned aircraft for precision aerial survey. We here atAg Tech request that you consider t his request for summary grant based up on the company's existing 333 exemption (Exemption No. 11573; Regulatory Docket No. FAA-2015-0351) for use ofa similar aircraft, and also based upon the exemptionsthat have already been granted regarding the make and model ofai rcraft present ly at issue. Should you or yourstaff have any questions, please contact the undersigned

. Thank you for yourtime and considerat ion.

Jon Tull, CEO EnclosuresJune 11,2015 U.S. Department ofTransportation DocketManagement System 1200 NewJersey Ave., 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 "ReformAct") and 14 C.F.R. Part 11 , Ag TechEnterprises, Inc. ("Ag Tech") an operator ofthe 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 • 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. 91.109(a) • 14 C.F.R. 91.121 • 14C.F.R. 91.319(a)(l) • 14 C.F
.R. 91.7(b) • 14C.F.R.91.119 • 14 C.F.R. 91.151(a) • 14 C.F.R. 91.203(a)&(b) • 14 CFRSubpart E (91.401

- 91.417) Therequested 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 (Ag Tech requests the FAAtrea t 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 inthe paragraph 3. 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 offlexible foam that performs pre-programmed precision aerial mapping missions thanks to the on-board GPS and the related flight management software (eMotion) that allows the operator to plan safely and efficiently a mission in 3D, and then monitor itinreal-time. Thanks to the embedded camera, protected by a foam envelope, the eBee takes a collection of high-definition still images that are used la ter to generate maps and contour lines ofthe surveyed area.The four main characteristics ofthe 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 (38 J in case ofa controlled emergency landing) also significantly reduces the risk ofhazardous situations. Finally, the wings ofthe eBee are detachable and made offlexible 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 bandto the body ofthe plane so that it can easily flex away in case ofcontact 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 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 Horne, 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 Ag Tech intends to use the eBee to collect aerial data for use in precision agriculture, allowing Ag Tech to assist customers with crop yield optimization, resource allocation and management, pest control, and risk management. Ag Tech proposes to use a small, lightweight UAV- the eBeeand proprietary cloud-based software to collect, process, and analyze aerial data. In doing so, Ag Tech would occupy a brand new space in a transformative industry by providing high quality and actionable information to users. Ag Tech's use ofthe eBee would contribute to various social goods, from environmental protection to improved crop yields. In providing this service, Ag Tech would empower researchers and farmers to make better management decisions through software that identifies disease and insects, nutrient deficiencies, and materials for increasing yields with fewer resources.

• Annex B describes applications and reasoning in more detail. Ag Tech requests the FAA treat the eBee training program and Annex B as proprietary under 14 C.F.R. 11.35(b) and not include this document in the public docket. Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333.

### 3. APPLICABLE LEGAL STANDARD UNDER SECTION 333

a. Airworthiness assessment ofthe eBee Ag Tech 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.nrnsu
.edu/ Articles/view/10208/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 order to operate the eBee UAS). Moreover the eBee already received 15 Exemptions from the FAA. Sense Fly also obtained flight approvals for the eBee (delivered by national civil aviation authorities) inmany countries, among others:
• Switzerland (flightapproval 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)
b. Operating requirements Grant of the exemption to Ag Tech for the eBee will be subject to the following operating conditions:
• 1
. Operations authorized bythis grant ofexemption are limited to the SenseFlyeBee when weighing less than 55 pounds including payload. Proposed operations ofany other aircraft will require a new petition ora petitionto amend this exemption

. • 2. Operations for the purpose ofclosed-set motion picture and television filming are not permitted.
• 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. 

### In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.
• 4
. The UA must be operated at an altitude ofno more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.
• 5

. The UA must be operated within visual line ofsight (VLOS) ofthe 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 onthe PIC's FAA-issued airman medical certificate orU
.S. driver's license.

### • 6. All operations must utilize a visual observer (VO). The UA 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 or her 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. Ifa 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 if 

### it petitions for extension or amendment to this grant of exemption. If the operator determines 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 docwnents.
• 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.
• 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in acondition for 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. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for 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. Under this grant ofexemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAAainnan medical certificate or a valid U.S. driver's license issued by 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 aircraft in which the PIC is rated on his or her pilot 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 must be logged in a manner consistent with 14 

### CFR § 

### 61.5l(b). Flights for the purposes of training the operator's P!Cs 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 ofthis 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 UA with appropriate distance from nonparticipants in accordance 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) are not authorized.
• 16. The UA may not 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 an ARP, the center ofthe airport symbol as denoted on the current FAA- published aeronautical chart, unless a letter ofagreement 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 to the Administrator or any law enforcement official upon request.
• 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC.
• 18. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.
• 19. The PIC must abort the flight inthe event ofunpredictedobstacles or emergencies.
• 20. The PIC is prohibited from begiiUling a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer ifgreater.
• 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 cannot be conducted under the 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 CFR part 45, Subpart C. Markings must be aslarge as practicable

. 

## • • 23. Documents used by the operator to ensure the safe operation andflight ofthe UAS and any documents required under 14 CFR §§ 91.9 and 91.203 mustbe available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
• 24. The UA must remain clear and give way to all manned aviation operations and activities at all times.
• 25. TheUAS may not be operated by the PIC from any moving device 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 UA and/or debris in the event of an 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 ofthe UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; 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 of operating closer to those objects and determined that itdoes not present anundue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this 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 obtained for each flight to be conducted.
• 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined 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 on the NTSB Web site: www.ntsb.gov. 3. CONCLUSION Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas, and operation within visual line ofsight and national security

- provide more than adequatejustification for the grant of the requested exemptions allowing commercial operation of applicant's UAS for the Purposes outlined herein and are consistent withexemptions already granted. Ag Tech respectfully submits that because this small, unmanned aerial vehicle**~** the eBee- will be used in lieu ofcomparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft, the FAA can have confidence that the operations will achieve at least an equivalent level or greater level of safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilitiesunder Section 333(c) ofthe Reform Act to "esta blish requirement for the safe operation ofsuch aircraft systems in the national airspace system."

Jon Tull, CEO Ag TechEnterprises, Inc.

ANNEXA: EXEMPTION REQUESTAND EQUIVALENTLEVEL OFSAFETY SHOWINGS UNDER APPLICABLERULESSUBJECTTOEXEMPTION Ag Tech requests an exempt ion from the following regulations as well as any additional regulations that maytechnically apply to the operation ofthe eBee: 14 C.F.R. Part21, SubpartH: Airworthiness Certificates 14 C
.F.R 

### § 91.203(a)(1) Section 9 1.203 requires all civil aircraft to have a certificate ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedura l 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 currentsafety levels. Such an exemption meets the requirements of an equiva lent level of safety under Part 11 and Section 333 ofthe Reform Act. TheFederal Aviation Act and Section 333 ofthe 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 ofthe UAS involved

. Ananalysis ofthese different criteria demonstra tes 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 ofthis application. Ag Tech 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 ofmarks; size ofmarks These regulations provide that each aircraft must display "N" and the aircraft's regist ration number in letters at least 3 inches high. Additiona lly, 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 ofthe eBee (wingspan of37.8 inches), this requirement is impossible to match. 14 C.F.R. 

### §61.3: Requirements for certificates, ratings and authorizations14 C.F.R. § 61.113(a) & (b); 61.133(a): PrivatePilot Privileges and Limitations; Pilotin Command; CommercialPilot Privileges and Limitations The regulation provides that no person may serve as a required pilot flight crewmem ber ofa civil aircraft ofthe United States, unless thatperson: (1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession orreadily accessible in the aircraft whenexercising theprivileges of that pilot certificate or authorizat ion. However, when the aircraft is operated within a foreign country, a pilot license issued by that country may beused. Theregulation provides also that no person that holds a private pilot certificate may act as pilot in command ofan aircraft for compensation orhire. Subparagraph (b) allows a privatepilotto act as pilot incommand ofan aircraft in connection with any business or employmentif: (1) Theflight is only incidenta l to thatbusiness or employment; (2) Theaircraft does not carrypassengers orproperty for compensation orhire. 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), Sensef ly proposes that operators ofthe eBee should not

### be required to hold a commercial pilot certification. Instead, operators should be required to: Have a sport or recreational pilot license (at least) and have successfully passed a manufacturer's training programfor the eBee. 14 C.F.R. § 91.7(a): Civil aircraft ainvorthiness 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 ofthe eBee without anairworthiness certificate, no standard will exist for airworthiness ofthe eBee. Given the size of the aircraft and the previous airworthiness assessments give n to the eBee, among others:

• New Mexico State University: https://newscenter.nmsu.edu/Articles/view /10208/nmsuuas-flight-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, documentation ofconstruction progress, and extensive oblique photography ofUSACE structures & activities An equivalent level ofsafety will be achieved by insuring compliance with the SenseFly manuals prior to eachflight. 14 C.F.R. 

### § 91.9: Civilaircraft flight manual, marking, and placard requirements. This regulation provides thatnopersonmay operate an aircraft unless a current, approved flight manual is inthe aircraft. Ag Tech assumes thattheintent ofthis requirement is to ensure that flight manual information is availableto the aircrew while operating the aircraft. AgTech requests an exemptionto this requirement since the aircraft is not onlytoo small to carry documentation, the documentation would not be availableto the crew.The equivalent level ofsafety will be achieved bykeeping a hard copy ofthe flight manual in the eBeetransportation box. 

### 14 C.F.R. 

### § 91.109(a) & 

### 91.319(a): Flight Instruction The regulation provides that "No person may operate a civil aircraftthat 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 ofthe flight management software eMotion. The equivalentlevel ofsafety during the training will be achieved by the manufacturer orauthorized distributor providingthe training and through the use ofexperienced and qualified operators familiar withthe eBee. 

### 14 C.F.R. 

### § 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 aircraft will be operating at a maximum of400 feet AGL, the eBee cannot comply with this requirement. The equivalent level of safety will be achieved because the eBee will only fly over private property with the pennission of the landowner. The operator will define before every flight a working arearadius 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 ofthe expected route offlight and the associated risks to persons and property onthe ground. Due to the small size of the eBee and the material with which the eBee is built, 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 nor over any open-air assembly of persons. The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons orproperty onthe surface. 

### 14 C.F.R. 91.121- Altimeter settings This sectionrequires that eachperson operating an aircraft shall maintain the cruising altitude or flight level ofthe 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 ofa station along the route and within 100 nautical miles ofthe aircraft; • Ifthere is no station within the area prescribed inparagraph (a)(l)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; • Inthe case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. To provide an equivalent level ofsafety, the eBee autopilot calculates thereference altitude (ground level) with the

**on~board** GPS during the preflight tests. The GPS andbarometer data are merged with respect to their respective precisions. The GPS provides reliable infonnationto correct potential barometricbias, while rapid variations in altitude are detected through thebarometer. Hence, barometric bias induced by environmental factors is rejected. 

### 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 ofintended landing and to fly after that for at least 30 minutes. Given the area of operation for the eBee, Ag Tech believes that an equivalent level of safety is already achieved with the specific procedure preventing the eBee to accept a take-offorder is the battery level is below a given value. Moreover, Sensefly has integrated "low" and "critical" battery level warnings and implemented a "retlll11 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 ooperate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section ora special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that itis legible to passengers or crew. The eBee weighs only 1.7 pounds (max take-offweight). As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. In addition, there is no pilot and there are no passengers onboard the aircraft. To obtain an equivalent level ofsafety and meet the intent of§91.2036, Ag Techproposes that documents deemed appropriate for this aircraft by the FAAwill be co-located with the operator at the ground control station in the eBee box and available for inspection upon request. 14 C.F.R. 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 that the aircraft be "approved for return to service by a person authorized under 43.T' after maintenance and inspection. Section 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) 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 ofapproval ofthe aircraft for return to service. Ag Tech proposes that the maintenance ofthe eBee will be accomplished by the owner/operator according to the maintenance manual, provided by SenseFly. Ag Tech 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. An equivalent level of safety will be achieved because the eBee is small in size, it is not a complex mechanical device, it will carry no external payload, and it will operate only in restricted predetermined areas. Moreover, the operator is the person most familiar with the aircraft and isbest suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety. Finally, before every flight, the eBee runs automatically a sequence ofpre-flight tests to make sure that every sensor and every critical part is running 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 the flight management software. The operator can then refer to the maintenance manual to troubleshoot this issue. Several parts ofthe 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.
ANNEX B: eBee AND SENSEFLY DOCUMENTATION, PROPRIETARY DOCUMENT See confidential email attachment referencing this petition filing and commencementnumber.