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. 

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UAS 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 the 

embedded 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 

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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 

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The 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 

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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 

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The 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; 

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(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 of 

safety 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 

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or 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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