February 15, 2016 U.S. DepartmentofTransportation DocketManagement System 1200New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Under Section 333 ofthe FAA Reform Act andPart 11 ofthe Federal Aviation Regulations DearMadam, Sir, Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "ReformAct") and 14 C.F.R. Part II, Napton Aerial Surveying an operator ofthe eBeeUnmanned Aircraft System ("eBee") seeks an exemptionfrom the Federal Aviation Regulations ("FARs") listed below:


### • 14C.P.R.21 • 14 C.P.R. 61.133(a) (b) 

### • 14 C.P.R. 91.7(b) 

### • 14C.F.R.91.119 • 14 C.P.R. 91.151(a) • 14 CFRSubpart E (91.401

- 91.417) Thefollowing appendices are included in this documentforreference purposes. NaptonAerial Surveying requests thatthe FAAtreatthese documents as proprietary under 14 C.F.R. 11.35(b) and not include these appendices in thepublicdocket: AppendixA: SenseFly -Justification ofairworthiness eBee AppendixB: SenseFly- eBee UserManual Vl7 AppendixC: SenseFiy

- eBeetraining documentation AppendixD: SenseFly

- eBeemaintenance procedures Therequested exemption would authorize commercial operations using the eBee formapping and survey applications. Theseoperations will be subjectto strict operatingrequirements defined in the eBee user manual (SES requests the FAAtreat the UserManual as proprietaryunder 14 C.P.R. 11.35(b) and not include this documentin the public docket) and conditions defined bythe Safety Code ofthe Academy ofModel Aeronautics , in orderto ensure at least an equivalent level ofsafetyto currently authorized operationsusing manned aircrafts. The eBeewill beoperated by an individual who fulfills thefollowing requirements: Has successfullypassed a manufacturer'straining program for the eBee Has a Private Pilot license 1. CHARACTERISTICS OF THEAIRCRAFT The eBee is a small (37.8 inches wingspan) and ultra-light (maximum take-offweight of 1.7 pounds) platform made offlexible foam thatperforms precision aerial mapping missions thanks tothe onboard GPS andtherelated flight management software (eMotion)that allows the operatorto plan safely and efficiently a mission in 3D, andthen monitor it in real-time. Thankstothe embeddedcamera, protectedby a foam envelope, the eBee takes a collection ofhigh-definition still images that are used laterto generate maps and contour lines ofthe surveyed area. The four main characteristics ofthe eBee are:
a. Very light weight The eBee is so lightthat the operator can launch it by hand and let it land on almost any surface without requiring a parachute orlandingnet (belly land). Its low impact energy 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 arubber band to 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 ofall the aspects of the flight underthe supervision ofthe operator. d. Option for Manual control Additionally. the eBee provides an override capabilitythat allows the operatorto take manual actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend automated operations and take manual control ofthe aircraft should it become necessary to respond emergent circumstances. thanks to the remote controUer provided with the system. 2. APPLICATIONS Napton Aerial Surveyinghas plans to purchase the SenseFiy eBee and respectively requests exemption to operate the eBee for aerial surveying ofconstruction sites, mines, fann operations, landfills and mapping purposes.
3. APPLICABLELEGAL STANDARD UNDER SECTION333

a. Airworthiness assessment ofthe eBee SES notes that the airworthiness ofthe eBee has already been demonstrated for differentprojects in the United States, involving state/federal agencies or universities (among others the New Mexico State University: https://ncwscenter.nmsu.edulArticles/view/I0208/nmsu-uas-flight-testcenter-conductsMehee-ainvorthincss-asscs.sment, and the USACE New Orleans, who coordinated with the Department of Army and the FAA to obtain all authorizations required in order to operatethe eBee UAS). Moreoverthe eBee alreadyreceived 15 Exemptions from the FAA. Sensefly also obtained flight approvals for the eBee (delivered by national civil aviation authorities) inmanycountries, among others:• Switzerland (flightapproval for VLOS operations) • Canada (flightapproval for VLOS operations) • Australia (flightapproval for VLOS operations) • France (flight approval for Extended-VLOS operations) • Germany (flightapproval for VLOS operations) • United Kingdom (flight approval for VLOS operations) • NoiVIay (flight approval for VLOS operations) • Sweden (flightapproval for VLOS operations) • Demnark (flightapproval for VLOS operations)
b. Operatingrequirements Grant ofthe exemption to Napton Aerial Surveying for the eBee will be subject to the following operating conditions:
• 1. Operations authorized

### by this grant ofexemption are limited to the SenseFlyeBee when weighing lessthan 55 pounds including payload. Proposed operations ofany other aircraft will require a newpetition ora petitionto amendthis 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 mustbe reported in feet AGL.


### • 5. The UA must be operated within visual line of sight (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 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 mustbe operated within the visual line ofsight (VLOS) ofthe PIC and VO atalltimes. The VO may be usedto satisfy the VLOS requirement as longas 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 thatthe VO canperformthe 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 limitationsin 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 

### ifit petitions for extension or amendment to this grant of exemption. Ifthe operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operatormustpetitionfor anamendment to its grant ofexemption. The FAA'sUAS Integration Office (AFS-80) may 

### be contacted ifquestions ariseregarding updates orrevisions to the operating documents.
• 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 notpose anundue hazard to persons and property.
• 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a conditionfor safe operation.
• 10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

### VAS 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 conditionfor 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. Underthis grant ofexemption, a PIC musthold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Colombia, Puerto Rico, aterritory, a possession, orthe Federal government. The PIC must also meet the flight review requirements specified in 14 CPR § 61.56 in an aircraft in whichthe PIC is rated onhis orherpilotcertificate.
• 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 § 

### 61.51(b). Flights for the purposes of training the operator's P!Cs and VOs (training, proficiency, and experience-building) and determiningthe PIC's ability to safely operate the UAS in a manner consistent with how the UAS will be operated under thisexemption 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.! 19.
• 15. VAS operations may not be conducted during nigbt, as defmed in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are notauthorized.
• 16. The UA may not operatewithin 5 nautical miles ofan airportreference 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 onthe current FAA- published aeronautical chart, unless a letter ofagreement with 

### that airport's managementis 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 enforcementofficial 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 orloses its GPS signal, the UAmust return to a predetermined locationwithinthe private orcontrolled-accessproperty.
• 19. The PIC must abortthe flight inthe event ofunpredicted obstacles oremergencies.
• 20. The PIC is prohibited from beginning 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 bythe manufacturerifgreater.
• 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 cannotbe conductedunderthe 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 as large as practicable.
• 23. Documents usedbytheoperatorto ensurethe safe operation and flight ofthe UAS and any documents requiredunder 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 atall times.
• 25. The UAS may not be operatedby 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 

### structuresunless: • 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 ofany 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 closerto those objects and detenninedthatitdoes not present anundue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons underthis 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.ntsh.gov.3. CONCLUSION By utilizingthe UAV for aerial surveyingfunctions, Napton Aerial Surveying will have the ability to collectdata in a fraction ofthe time and costthatwould be associated with a ground based survey. The aerial survey can be completed in a matter ofminutes instead ofdays. Costsaving will be passed along to clients due to the reduction in manpower required to completethe survey. Datafrom the aerial survey canbeprocess in within minutes ofcompletingtheflight, thus allowingthe clients to make nearreal-time decisions and increase work flow at their sites. The costtopurchase and maintain the SenseFiyeBee is nominal in comparisontothat ofa traditional manned aircraft. Dueto its unique, lightweight and compact design, the SenseFly eBeecan be assembled and deployed in less than five (5) minutes after arriving onsite. It can perform its mission effuctively and efficiently and literally land atyour feet. Thedatafrom the mission can begin being processed immediately atthe survey site orin the office.

Yours sincerely,

Clint Napton Owner Napton Aerial Surveying 16944 132"d St. Bloomer, WI 54724