### Walter J. Stachon

10345 Z Street Omaha, NE 68127 July 7, 2015 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Reguest Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. § 11.61, Walter J. Stachon hereby petitions for an exemption from the listed Federal Aviation Regulations ("FARs") listed below and detailed in Appendix A for commercial operation of the eBee Ag Unmanned Aircraft System (UAS) manufactured by SenseFly, Ltd of Switzerland. • 14 C.F.R. § 61.113(a) • 14 C. F. R§ 91.7 (a)
• 14 C. F. R. § 91.119 (c)
• 14 C.F.R. § 91.121
• 14 C.F.R. § 91.151 (a) (1) • 14 C. F. R. § 91.405 (a) • 14 C.F.R § 91.407 (a) (1) • 14 C.F.R. § 91.409(a) (1) and (2) • 14 C. F. R§ 91.417 (a) and (b)

The requested exemption would authorize the eBee Ag UAS to be used for aerial imaging of agriculture crop improvement research and development experiments and monitoring farm production fields. The requester has 36 years' experience as a field scientist conducting crop improvement trials. Use of the eBee Ag will provide a unique low and slow perspective for collection of field data and reduce the need to collect data by manual methods, ground equipment or conventional aircraft. The public benefit in using a UAS compared to conventional aircraft is equivalent or greater safety to the public and/or operators of airborne equipment. Additional benefits are the reduced cost of acquiring aerial imagery making data collection more practical and contributing to the reduction in time to bring improved crop varieties and treatments to market. Also a significant public benefit is the low carbon foot print of UAS compared to conventionally fueled equipment.

Page 11UAS flight operations will be subject to FAA conditions and limitations as required by Section

333. AII of the UA flight operations will be flown in accordance with the specific UAS manufacturer User Manual (SenseFly, Extended User Manual eBee document, appendix B). Maintenance will be in accordance with the specific UAS manufacturer Maintenance Procedures Document (SenseFly, eBee maintenance procedures document, appendix C). It is requested the FAA treat the SenseFly documents as proprietary and not include them in the public docket. 1. Unmanned Aircraft System (UAS) — SenseFly, eBee Ag

Characteristics The eBee Ag is a small (37.8-inch wingspan) and ultra-light (maximum take-off weight of 1.7 pounds) platform made of flexible EPP foam that performs precision aerial mapping missions with an on-board GPS and related flight management software (eMotion2) that allows the operator to safely and efficiently plan a mission in 3D and monitor it in real-time. Because of theembedded camera protected by a foam envelope, the eBee Ag can take a collection of highdefinition, still images that can later be used to generate maps and contour lines of the surveyed area. SenseFly manufactures a variant of the eBee Ag simply referred to as the eBee. The only difference between these two models is the camera suite that they carry. The airframe, ground control station, data link, and flight profile is identical between the eBee and eBee Ag. AII referenced SenseFly documents in this petition will simply say eBee and will not specify eBee or eBee Ag. The four main characteristics of the eBee Ag include:

a. Very light weight The eBee Ag 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 Ag are detachable and made of flexible foam with no hard or sharp edges and almost no internal strengthening structure.

b. Electric-powered The eBee Ag is electric powered. 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 Ag autopilot system continuously analyzes data from the Inertial Measurement Unit and the onboard GPS and takes care of all the aspects of the flight under the supervision of the operator.
d. Option for Manual control Page 12

### Additionally, the eBee Ag provides an override capability that allows the operator to 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 of the aircraft with the provided remote controller should it become necessary to respond to emergent circumstances. Airworthiness & Safety The SenseFly eBee Ag is an inherently airworthy and safe UAS, see UAS manufacturer Justification of Airworthiness and Safety Assessment (SenseFly Justification of airworthiness eBee, document, Appendix D). The FAA has approved grants of exemption (exemption No. 11167, 11170 and 111263) for eBee UAS operations in the NAS for commercial operations in the agriculture and survey industry. Throughout the world the SenseFly eBee UAS has obtained flight approvals in nine countries besides the U.S. for VLOS operations; Switzerland, Australia, France, Norway, Sweden, United Kingdom, Canada, Germany and Denmark. 2. Operation of the Unmanned Aircraft System (UAS) - SenseFly eBee Ag 

### SenseFly eBee Ag flight operations will be flown in accordance with the specific UAS manufacturer User Manual (SenseFly, Extended User Manual eBee document, appendix B). Maintenance will be in accordance with the specific UAS manufacturer Maintenance Procedures (SenseFly, eBee maintenance procedures document, appendix C). The UA will be operated with both a Pilot-in-Command (PIC) and a ground based Visual Observer (VO). Operating Conditions • UAS flight operations will be conducted over rural, uncongested private farm lands with permission from the land owner or manager. • UAS flight operations will be during the day and under visual meteorological conditions; • UAS will be flown within Visual Line-of-Sight (VLOS) of both the PIC and VO at all times; • Visual contact with the UA will be required at all times • PIC and VO will be in voice communication at all times; • The UA will be flown in Class G airspace at no higher an altitude of 400 ft. Above Ground Level (AGL); • UA flight operations will not be conducted over congested areas or open air assemblies of people; • PIC will give way to manned aircraft operations and operate the UA to avoid and remain well clear of manned aircraft; • UA flight operations will be conducted outside of 5 nautical miles (NM) of an airport or helipad unless a letter of agreement with the airport's management is obtained; • AII flights will obtain an Air Traffic Organization (ATO) issued Certificate of Authorization (COA) prior to conducting flight operations. Included in the COA request will be a request for a Notice to Airman (NOTAM). Operator Requirements

Page 13The eBee Ag is an ultra-light UA made of flexible EPP foam with no sharp or hard edges

characterized by a high level of pre-programmed controls and various built-in technical capabilities (programming of a geofence, automatic wind detection) that prevent the operator from doing a mission outside of the operating limits. AII flights are pre-programmed with GPS guidance and do not require human intervention; nevertheless human override is possible by clicking on one of the multiple "action" buttons or by using the remote controller provided with each eBee Ag UAS. In the case of unplanned events, either the autopilot reacts immediately or the operator can choose between different pre-programmed or manual actions. Those procedures include a Flight Termination System (emergency landing procedure, triggered by the autopilot or the operator in charge: given its very light weight, the eBee will initiate a gliding approach to the ground at very low speed around the current location). Moreover, the kinetic energy of the aircraft is 60 J in-flight at cruise speed. In comparison, the kinetic energy of a football is about 110 J when thrown by hand. Given the inherent safe operation of the eBee Ag UAS the following operator's requirements are proposed. • PIC will hold an FAA private pilot certificate and current third class airman medical certificate; • The PIC and VO will have completed the UAS manufactures Training Program (senseFly eBee training documentation, Appendix E); • The PIC and VO will have read and acknowledged understanding of the Conditions and Limitations of the Grant of Exemptions and pertinent COA. The name and address of the applicant:
Walter J. Stachon 10345 Z Street Omaha, NE 68127 Ph: 507-649-1625 Email: wstachon(c),outlook.com

Thank you for your consideration of this matter.

Walter J. Stachon

Page 14

### Appendices:

A. EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION Appendices: B— E senseFly, eBee documentation, proprietary documents. See email attachment referencing confidential documents associated with this petition filing.
B. senseFly, eBee Extended User Manual C. senseFly Maintenance procedures D. senseFly Justification of airworthiness eBee E. senseFly eBee training documentation

Appendix A. EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations; Pilot in Command; The regulation prescribes, in pertinent part, that; (a) No person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, 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; and (2) The aircraft does not carry passengers or property for compensation or hire. Relief request with explanation: Allow flight operations with a pilot holding only a private pilot certificate. Given the safety features of the eBee Ag UAS and the fact that the missions are pre-programmed and monitored in real-time with a specific flight management software (eMotion2) and that the eBee UA cannot carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current manned flight operations by requiring the PIC operating the UA to have a private pilot's license rather than a commercial pilot's license. This equivalent level of safety is achievable with the aeronautical knowledge required of a private pilot certificate and specific UAS manufacturer platform training (senseFly eBee training documentation, Appendix E).

14 C.F.R. § 91.7 (a): Civil aircraft airworthiness

Page 15The regulation prescribes that;

(a) No person may operate a civil aircraft unless it is in airworthy condition. Relief request with explanation 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 Ag 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: Grant of Exemption Nos. 11167, 11170, and 11263, an equivalent level of safety will be achieved by insuring compliance with the SenseFly manuals (senseFly, eBee Extended User Manual, Appendix B and senseFly Maintenance procedures Appendices C) prior to each flight and the PIC can determine the UAS is in a condition for safe flight. 14 C.F.R. § 91.119 (c): Minimum Safe Altitudes The regulation prescribes that; (c) Over other than congested areas, an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. Relief request with explanation: 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 eBee Ag will be operating at a maximum of 400 feet AGL, it will not be possible to comply with this requirement. The equivalent level of safety will be achieved because the eBee Ag will only fly over private property with the permission of the landowner or manager. The operator will define before every flight a working area radius and a flight area ceiling, preventing the eBee Ag 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 Ag, the material with which the eBee Ag is built and its specific safety procedures (among others ground detection), 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 or over any open-air assembly of persons.

14 C.F.R. § 91.121 Altimeter Settings The regulation prescribes that; (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating— (1) Below 18,000 feet MSL, to— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; Page 16(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the

current reported altimeter setting of an appropriate available station; or (iii) 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. Relief request with explanation: To provide an equivalent level of safety, the eBee Ag autopilot calculates the reference altitude (ground level) with the on-board GPS during the pre-flight tests. The GPS and barometer data are then used to calculate the altitude in-flight. 14 C.F.R. § 91.151(a)(1): Fuel Requirements for Flight in VFR Conditions The regulation prescribes that; (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there 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; Relief request with explanation: Allow for replacement of the required 30 minutes of flight time reserves with a reserve of 30% battery power remaining. Given the area of operation for the eBee Ag the equivalent level ofsafety is already achieved with the specific procedure preventing the eBee Ag to accept a takeoff order if the battery level is below a given value. Moreover, the eBee Ag UAS has integrated "low" and "criticaP' battery level warnings and implemented a"return to Home" (and "Go Land") actions in these situations. 14 C.F.R. Subpart E§§ 91.405(a) Maintenance required, 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 91.409(a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records. 14 C.F.R Subpart E in totality prescribes that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with Parts 39 and 43. Specifically § 91.405(a) requires that aircraft discrepancies are repaired between required inspections, §§ 91.407 and 91.409 requires the aircraft to be approved for return to service by a person authorized under § 43.7 after maintenance and inspection, § 91.409 requires an annual inspection for the issuance of an airworthiness certificate, and §91.417 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. Relief request with explanation: To allow for all inspections, maintenance and approvals for return to service by the PIC or owner. SenseFly proposes that the maintenance of the eBee will be accomplished by the owner Page 17or the operator according to the User Manual (SenseFly, Extended User Manual eBee

document, appendix B) and Maintenance Procedures Document (senseFly Maintenance procedures, appendix C). An equivalent level of safety will be achieved because the eBee is small in size; it is not a complex mechanical device and does carry any external payload. 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 Ag automatically runs a sequence of pre-flight tests to make sure that every sensor and every critical part is operating properly. If a problem is detected, the eBee Ag will not be able to be switched-on and a message error is displayed on the main screen of eMotion2 flight management software. The owner or the operator can then refer to the eBee user manual to troubleshoot this issue. Several parts of the eBee Ag 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. Appendices: B— E senseFly, eBee documentation, proprietary documents. See email attachment referencing confidential documents associated with this petition filing.

B. senseFly, eBee Extended User Manual C. senseFly Maintenance procedures D. senseFly Justification of airworthiness eBee E. senseFly eBee training documentation

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