Zee.Aero Inc. 2700 Broderick Way, Mountain View, CA 94043 (650) 964

- 4570

October 20 , 2014

U.S. Department of Transportation Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Av enue, SE. Washington, DC 20590

Dear Sir or Madam:

Zee.Aero was founded in 2010 to develop environmentally friendly airplanes for practical personal transportation. The company is exploiting technology advances in electric energy storage and motor systems, augmented flight controls, and composite structure s.

We request an exemption to 14 CFR 91.151(a)(1) to allow our manned aircraft using electric propulsion to fly with a reduced “fuel” reserve during our FAA

- approved research and development flight test program . The specific sections of 14 CFR from which Zee.Aero seeks an exemption are as follows:

§91.151 Fuel requirements for flight in VFR conditions. (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) the re is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

— (1) During the day, to fly after that for at least 30 minutes.

Rationale for request The aircraft under development incor porate unique design and system features that provide an equivalent or higher level of safety compared to liquid

- fuele d spark ignition propulsion systems. During all test flights, the aircraft will be flown under a tightly co ntrolled set of conditions, and a test team will monitor airport traffic conditions, weather conditions and the health of aircraft systems. These procedures will mitigate local air traffic conflicts and protect persons and propertyZee.Aero 14	CFR	91.151(a)(1)	exemption	request 

### 2 on the ground. Relevant aircraft and operational parameters and safety features include:

Aircraft Safety Characteristics

• The Zee.Aero electric propulsion system (EPS) utilizes solid

- state electronics and
redundancies with few moving parts. This is in contrast with a carburet or/fuel inje ctor system , fuel lines and associated metering systems with the inaccuracies inherent in a traditional liquid fueled propulsion system

.

• A b attery and energy flow management system provides precise real

- time s tate of energy remaining and time

- remaining warnings to the pilot

.

• An independent health monitoring system and proprietary battery architecture assures a high level of protection from thermal runaway or other electrical system failure

.

• A ballistic recovery parachute is available to recover pilot and vehicle in an emergency.

Operational Safety Plans

• Detailed failure scenario fight planning enable the pilot and flight test team to ensure that the planned reserve is always available and that communication of planned landing will be accurate and complet e. This type of planning includes, but is not limited to;

o A safe cone of operations established for each flight that enables an engine out glide to a runway for either an upwind or downwind landing.

o Ground station and cockpit monitoring to keep flight operations within the safe cone of operations at all times.

o Takeoff, departure, and landing profiles that prescribe landing options as a function of altitude and aircraft position.

• The EPS is continuously monitored both in the cockpit and via a ground test station. Hardware redundancy and operational restrictions have been established to mitigate the
effects of EPS failures.

• All test flights will be conducted outside controlled airspace, within sight of the base airport and only when sustained w inds are 10 knots or less.

• The aircraft will only be flown by highly qualified test pilots listed in the approved flight test program.

With these aircraft safety features and operational controls , Zee.Aero is confident that its airplane

can be operate d as safely as traditional gas

- powered airplanes operatin g under §91.151

.Zee.Aero 14	CFR	91.151(a)(1) exemption	request 

### 3 The request for a lower fuel reserve is also based on endurance restrictions due to the significant weight penalty of currently available battery systems. State of the art batteries for this type of application have , at best , nine times less energy density by weight than aviation gasoline. Therefore, to stay within safe design limits, the energy storage system in the initial Z ee.Aero test airplane s will only allow a maximum 25

- minute flight at cr uise power with a 5

- minute reserve. Adding more batteries to extend flight time will not be feasible during the test phase

.

Based on the above information , Zee.Aero requests a minimum 5

- minute fuel reserve . This would
allow time for contingencies such as loitering for traffic and at least one go around.

Public Interest
Zee.Aero is leading the development of new technologies to ad vance the safety, capability , user
friendliness and public acceptance of personal aircraft. Grant of the exemption to CFR 91.151(a)(1) will allow Zee.Aero to conduct flight

- testing in controlled conditions to demonstrate the viability of these new technologies. The result s of this work will confirm that the technologies are viable and can benefit the public. This will lead to a higher level of safety and increased accessibility to the benefits of personal flight than is currently available with traditional General
Aviation aircraft.

For the Federal Register Zee.Aero requests an exemption to 14 CFR 91.151(a) (1) to allow its manned aircraft using electric propulsion to fly with a reduced “fuel” reserve during its FAA

- approved research and development flight test program.

We look forwa rd to a positive response . Please feel free to contact me at tom.gunnarson@zee.aero or 301

- 471

- 1923 with any questions concerning this request.

Sincerely,

Tom Gunnarson Lead of Certification and Regulatory Affairs