Jon Tull, CEO 

Ag Tech Enterprises, Inc. 

4580 E. Thousand Oaks Blvd. 

Su ite 300 

Westlake Village, CA 91362 

June 11, 2015 

Unmanned Aircraft Systems 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 behalf of Ag Tech Enterprises, Inc. under Section 

333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11 to allow commercial 

operations of unmanned aircraft for precision aerial survey. 

We here at Ag 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 of a similar aircraft, and also based upon the exemptions that have already been granted regarding 

the make and model of aircraft present ly at issue. 

Should you or your staff have any questions, please contact the undersigned. Thank you for your time 

and considerat ion. 

Jon Tull, CEO 

Enclosures 
June 11,2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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 of2012 (the "Reform Act") 

and 14 C.F.R. Part 11 , Ag Tech Enterprises, Inc. ("Ag Tech") an operator of the 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 

• 14 C.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 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 (Ag Tech 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 in the 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 of flexible 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 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 (38 J 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 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 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 UA V- 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 of the 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 of the 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/1 0208/nmsu-uas-flighttest-center-conducts-ebee-airworthiness-assessment, and the 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 the eBee already received 15 Exemptions from the 

FAA. 

Sense Fly also obtained flight approvals for the eBee (delivered by national civil aviation 

authorities) in many countries, among others: 

• 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) 

b. Operating requirements 

Grant of the exemption to Ag Tech for the eBee will be subject to the following operating 

conditions: 

• 1. Operations authorized by this grant of exemption are limited to the SenseFly eBee when 

weighing less than 55 pounds including payload. Proposed operations of any other aircraft 

will require a new petition or a petition to amend this exemption. 

• 2. Operations for the purpose of closed-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 of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

• 5. The UA must be operated within visual line of sight (VLOS) of the 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 on the PIC's FAA-issued airman medical certificate or U.S. 

driver's license. 
• 6. All operations must utilize a visual observer (VO). The UA must be operated within the 

visual line of sight (VLOS) of the 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 of the flight. The PIC must ensure 

that the VO can perform the duties required of the 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. If a 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 

of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions 

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 U AS to ensure that it is 

in a condition 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. If the inspection 

reveals a condition that affects the safe operation of the 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 of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA 
ainnan 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 of this 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 of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA- published 

aeronautical chart, unless a letter of agreement with that airport's management is obtained 

or otherwise permitted by a COA issued to the exemption holder. The letter of agreement 

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 or when visibility is less than 3 statute miles from the PIC. 

• 18. If the 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 in the event ofunpredicted obstacles 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 if greater. 

• 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an A TO-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 of the 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 as 
large as practicable . 

• 

• 23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be 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. The UAS may not be operated by the PIC from any moving device or vehicle. 

• 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 of the 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 of the risk of 

operating closer to those objects and determined that it does not present an undue 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 of the 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 of sight and national security - provide more than adequate justification for the grant of 

the requested exemptions allowing commercial operation of applicant's UAS for the Purposes 

outlined herein and are consistent with exemptions already granted. 

Ag Tech respectfully submits that because this small, unmanned aerial vehicle ~ the eBee- will 

be used in lieu of comparatively 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) responsibilities 
under Section 333(c) of the Reform Act to "establish requirement for the safe operation of such 

aircraft systems in the national airspace system." 

Jon Tull, CEO 

Ag Tech Enterprises, Inc. 

ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 

Ag Tech 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 C.F.R § 91.203(a)(1) 

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. 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 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 of37.8 inches), this requirement is impossible to match. 

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 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 program for 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 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/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 of construction progress, and extensive oblique photography 

of USACE structures & activities 

An equivalent level of safety will be achieved by insuring compliance with the SenseFly manuals 

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. Ag Tech assumes that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. Ag Tech 

requests an exemption to this requirement since the aircraft is not only too small to carry 

documentation, the documentation would not be available to the crew. 
The equivalent level of safety will be achieved by keeping a hard copy of the flight manual in the 

eBee transportation box. 

14 C.F.R. § 91.109(a) & 91.319(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 training will be achieved by the manufacturer or authorized distributor providing the 

training and through the use of experienced and qualified operators familiar with the 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 of 400 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 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 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 or property on the surface. 

14 C.F.R. 91.121- Altimeter settings 

This section requires that each person operating an aircraft shall maintain the cruising altitude or 

flight level of the 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)(l)(i) of this section, the 

current reported altimeter setting of an appropriate available station; 

• 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 preflight tests. The GPS and barometer data are 

merged with respect to their respective precisions. The GPS provides reliable infonnation to 

correct potential barometric bias, while rapid variations in altitude are detected through the 
barometer. 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 of intended 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-off order 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) 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. 

The eBee weighs only 1.7 pounds (max take-off weight). 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 on board the aircraft. 

To obtain an equivalent level of safety and meet the intent of §91.2036, Ag Tech 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 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 of approval of the aircraft for return to service. 

Ag Tech proposes that the maintenance of the 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 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 runs automatically a sequence of pre-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 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. 

ANNEX B: eBee AND SENSEFLY DOCUMENTATION, PROPRIETARY DOCUMENT 

See confidential email attachment referencing this petition filing and commencement number.