397 Spruce Glen Road Lexington, SC 29072 (703) 599
- 3277 August 15, 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 of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, ENDEAVOR UNMANNED SOLUTIONS , LLC, an operator of the SenseFly 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  FAA Order 8900.1 Volume 1 6 -4-4- 1(a)  14 C.F.R. 61.101(e)(4) & (5)  14 C.F.R. 61.113(a) & (b)  14 C.F.R. 61.133(a)  14 C.F.R. 61. 3 1 5 ( c )  14 C.F.R. 91.7(a)  14 C.F.R. 91.9(b)(2)  14 C.F.R. 91.103  14 C.F.R. 91.109(a)  14 C.F.R. 91.119  14 C.F.R. 91.121  14 C.F.R. 91.151(a)  14 C.F.R. 91.203(a) & (b)  14 C.F.R. 91.319(a)(1)  14 CFR Subpart E (91.401
- 91.417) 

# E **ndeavor Unmanned Solutions, LLC** 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 m anual (ENDEAVOR UNMANNED SOLUTIONS, LLC 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 by the Safety Code of the Academy of Model Aero nautics (see Annex B), in order to ensure at least an equivalent level of safety to currently authorized ope rations using manned aircraft. The eBee will be operated by an individual who fulfill s the following requirements:
 Has successfully passed a manufacturer’s training program for the eBee. **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 G lobal P ositioning System (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 em bedded 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 W eight . T he 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 ( only 38 joules 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- P owered . The eBee is electric powere d. 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 F light . The artificial intellige nce incorporated within the eBee autopilot system continuously analyzes data from the Inertial Measurement Unit (IMU) and from the onboard G PS and takes care of all the aspects of the flight under the supervision of the operator. d. Option for Manual C ont rol . Additionally, the eBee 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 should it become necessary to respond to emergent circumstances, thanks to the remote controller provided with the system.**2. APPLICATIONS**

The primary role of the eBee is to collect, process, and analyze aerial data principally for purposes of the following: 1) precision agriculture, 2) precision surveying, 3) monitoring natural resources, endangered species and plant life , 4) conducting flight demonstrations , 5) inspection of roofs, towers, dams and levees, telecommunications and utility struct ures, railroad track, pipeline, power line and bridges, 6) surface mining, 7) construction, 8) maintenance services, 9) special events, and 10) assisting first responders. In doing so, ENDEAVOR UNMANNED SOLUTIONS, LLC would occupy a brand new space in tra nsformative industr ies by providing high quality and actionable information to users. Indeed, use of the eBee would contribute to various social goods, from environmental protection to improved crop yields, safety inspections, property damage assessment a nd search and rescue. **3. APPLICABLE LEGAL**  **STANDARD UNDER**  **SECTION 333**  a. Airworthiness Assessment of the eBee: ENDEAVOR UNMANNED SOLUTIONS, LLC 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.nmsu.edu/Articles/view/10208/nmsu
- uas-flight
-test - center- conducts - ebee airworthiness- assessment, and the US A rmy C orps of E ngineers (USACE) New Orleans, who coordinated with the Department of the Army and the FAA to obtain all authorizations required in order to operate the eBee UAS). Moreover, SenseFly obtained flight approvals for the eBee (delivered by national ci vil aviation authorities) in many countries, among others:
 Australia (flight approval for VLOS operations)  Canada (flight approval for VLOS operations)  Denmark (flight approval for VLOS operations)  France (flight approval for Extended
-VLOS operations)  Ger many (flight approval for VLOS operations)  Norway (flight approval for VLOS operations)  Sweden (flight approval for VLOS operations)  Switzerland (flight approval for VLOS operations)  United Kingdom (flight approval for VLOS operations) b. Opera ting R equirements: Grant of the exemption to ENDEAVOR UNMANNED SOLUTIONS, LLC for the eBee will be subject to the following operating conditions, based on the operating requirements set forth by the Academy of Model Aeronautics (see Annex B). The main restrict ions are summarized below:
 Operations to be conducted over private, controlled - access, or public property where approved;  Permission from the land owner/authority required before commencing any flight;  Operations over congested areas shall be avoided;  Ope rations must not interfere with manned aircraft operations, must yield the right of way to manned aircraft, and operators must See & Avoid other aircraft and obstacles at all times; Operations limited to Visual Flight Rules (VFR) and Visual Meteorological Conditions (VMC)

and daylight hours;  Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually monitored at all times;  VLOS is guaranteed with a GPS geo -fence around the operator of 0.5 miles;  Flight ceiling pre - programed no higher than 400 feet AGL;  All operations conducted within 5 miles from an airport shall only be initiated after verbal coordination with the airport authority, or air traffic control when a control tower is present at the airport;  All operations sha ll comply with required permissions and permits established by territorial, state, county or city jurisdictions; including local law enforcement, fire, or other appropriate governmental agencies;  The eBee operations will be compliant with existing safety p rocedures inherent to the activities of the related company. c. Operator Requirements : The eBee operator will have successfully completed the written test of the Private Pilot license **. 3. CONCLUSION**  ENDEAVOR UNMANNED SOLUTIONS, LLC is a survey operator . We are a service provider engaged in high precision mapping products . Our services and products save our clients time giving the ability for them to make better decisions. The eBee is safer than having ENDEAVOR UNMANNED SOLUTIONS, LLC’s employees out in the field for specific projects, and also very safe for other aircraft because of the mission specifications (below 400 ft.) and eBee integrated safety features. ENDEAVOR UNMANNED SOLUTIONS, LLC is prepared to modify or amend any part of this request t o satisfy the need for an equivalent level of safety. We look forward to working with your office. Please contact us at any time if you require additional information or clarification. Yours sincerely, 

# Timothy E. Coolidge Timothy E. Coolidge FAA Certificate 3610935