# Exemption Request

Under Section 333 of the FAA Reform

Act & Part 11 of the Federal Aviation Regulations

April 201 5

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

- 140 1200 New Jersey Ave., SE

Washington, DC 20590

Prepared by :

EMC, Inc. (EMC) 2472 Sunset Drive, Grenada, MS 38901 (662) 226

- 5166

Mark Mattox mattox@emcsurvey.com



## * Documents were submitted confidentially for proprietary reason **s & will not be available to the public** Boundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

1 | Page EM C, Inc.

2472 Sunset Drive Grenada, MS 38901 Telephone: 662.226.5166

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Table of Contents

Petition Summary...............................................................................................

. ........ ...2

Characteristics of the eBee.............................................................................

. ..............4

Applic ations

................................................................................................. . ............. .....4

Applicable Legal Standard under Section 333............

.. .................. . ...... ...... ...... ...5

Basis for Petition..........................................................

. ................................................6

Annex A – Exemption Request..............................

.. ..........................................7

Annex B – AMA’s Safety Requirements........................

.. ... ................. .......... ....11

SenseFly - eBee User Manual*..............................................

.. ......................Appendix A

SenseFly - eBee Maintenance Procedures*..........................

.. ..... . .................Appendix B

SenseFly - eBee Training Documentation*............................

.. ......................Appendix C

SenseFly - eBee Justification of Airw orthiness and Safety Assessment*..

.. ..Appendix D



### * Documents were submitted confidentially for pr oprietary reasons and will not be available to the publicBoundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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April 8, 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 Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Madam or Sir,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, EMC, Inc. (“EMC”), a small business located in Grenada, Mississippi, seeks an exemption for the eBee Unmanned Aircraft System manufactured by Sens eFly SA of Switzerland (“eBee”) from the Federal Aviation Regulations (“FARs”) listed below:

 14C.F.R. 21

 14C.F.R. 45.23

 14C.F.R. 45.29

 14C.F.R. 61.133(a)

 14C.F.R. 91.7(b)

 14C.F.R. 91.9(b)(2)

 14C.F.R. 91.109(a)

 14C.F.R. 91.119

 14 C.F.R. 91.121

 14C.F.R. 91.151(a)

 14 C.F.R. 91.203 (a) & (b)

 14 CFR Subpart E (91.401 - 91.417)

The requested exemption would authorize unmanned aircraft operations for the purpose of precision aerial surveys using the eBee for applications by EMC. These operations will be subject to strict operating requirements and conditions defined by the safety c ode of the Academy of Model Aeronautics (see Annex B), in order to ensure at least an equivalent level of safety to currently authorized operations using manned

aircrafts.

Over the last 30 years, EMC performed thousands of land and hydrographic surveys for federal, state and local government entities, as well as various private and public companies in over forty-five (45) states. EMC is a multi-disciplined surveying company offering turn-key solutions for both routine and complex surveying challenges serving clients in multiple industries, includ ing, but not limited to transportation (highways, railroad, ports, harbors and waterways), construction, telecommunication, oil and gas, power suppliers, and the state and federal governments. The requested exemption would authorize commercial operations using the eBee for the efficient production of precision, valuable, high-reso lution, still photos; which would be of significant value with the accurate data in providing precision mapping and survey applications.Boundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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The electric-powered, unmanned aspect of aerial technology of the eBee provides a much safer solution to aerial surveying in that: a. The flight crews’ lives will not be put at risk of an accident. b. The low and slow flight of an extremely light weight product with safety measures programmed into the eBee’s operating system drastically reduces the chance of the general public being harmed. c. Since the eBee is electric-powered, there is absolutely none of the risks associated with fuel igniting. d. The eBee will eliminate the possibility of injuries of EMC’s surveyor crew that would require accessing hard to reach areas and maneuvering on terrain that poses potential safety hazards.

The following appendices are included in this document for reference purposes. EMC requests that the FAA treat these documents as proprietary under 14 C.F.R. 11.35(b) and not include these appendices in the public docket:

Appendix A: SenseFly – eBee User Manual Ver.15 Appendix B: SenseFly - eBee Maintenance Procedures Appendix C: SenseFly - eBee Training Documentation Appendix D: SenseFly – eBee Justification of Airworthiness and Safety Assessment

These operations will be subject to strict operating requirements defined in the eBee user manual (EMC requests the FAA treat the eBee training program as proprietary under 14 CFR 11.35(b) and not include this document in the public docket) and conditions defined by the Safety Code of the Academy of Model Aeronautics (see Annex B), in order to ensure at least an equivalent level of safety to currently authorized operations using manned aircrafts.

Given the technical specifications of the very light we ight, eBee, and the type of operations; EMC believes it is relevant to use the Academy of Model Aeronautics (AMA) rules and guidelines to meet the required level of safety of future operations with the eBee. (See A nnex B) Indeed, the AMA has a proven track record in supervising operations conducted by operators using remote controlled aircrafts and provides the most relevant expertise in terms of providing safety guide lines for operators using ultra-light remote controlled

aircrafts.

The eBee will be operated by an individual who fulfills the following requirements:

 The pilot in charge, (“PIC”), will maintain a current private pilot’s license, a current driver’s license issued by the state and a valid third-class airman medical certificate

 The PIC will be accompanied by a safety/visual observer, (“VO”), as he compliments the PIC’s capabilities to see and avoid other aircraft (per 91.113) and provides an additional level of operational safety; and thus the UA must never be operated beyond the actual visual capabilities

 The VO’s responsibilities will be as follows:

 initially launch the vehicle before turning it over to the PIC

 monitor the authorized airspace to identify errant aircraft or unsafe conditions that might exist during the flight

 maintain constant verbal communication with the PIC to alert him to changing conditions

 in the event of an emergency, calling the appropriate agency overseeing the airspace

EMC takes pride in providing a safe working envir onment for our employees, crew members and the general public at all times. We currently have excellent safety procedures in place, as well as an outstanding safety director within our company.Boundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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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 precision aer ial mapping missions thanks to the on- board 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. (See Appendix A)

The four main characteristics of the eBee are:

1. Very light weight The 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 im pact energy (38 J in case of a controlled emergency landing) also significantly reduces the risk of haz ardous situations. Finally, the wings of the eBee are

detachable and made of flexible foam with no shar p or hard edges, and almost no internal strengthening structure. The limited weight and construction material s used, reduce the potential for harm to person(s) or damage to property in the event of an incident or accident.

2. Electric-powered The eBee is electric powered. 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. The unmanned aircraft (UA) carries no fuel and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated.

3. 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 take s care of all the aspects of the flight under the supervision of the operator. The pilot and crew will be remotely located from the aircraft. The risk to an onboard pilot and crew during an incident or accident is eliminated with the use of a UAS for the proposed operation.

4. Option for Manual control 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 nec essary to respond emergent circumstances, thanks to the remote controller provided with the system. The eBee has the capability to perform an emergency landing and land safely after experiencing certain in-flight contingencies or failures with undue hazard to persons or property on the surface if the power unit should fail. The eBee is also capable of responding to a loss of global positioning system(GPS) or a lost-link event with pre-coordinated automated landing maneuvers. These safety features provide an equivalent level of safety compared to a manned aircraft holding a restricted airworthiness certificate performing a similar operation.

All maintenance and upkeep required to ensure the safe operation of the eBee will be based upon completion of appropriate inspections(s) such as pre-flight.

2. APPLICATIONS EMC has purchased the SenseFly eBee and respectively r equests exemption to operate the eBee for precision aerial surveying using the onboard camera. The value that the eBee could bring to the surveying and mapping industry is invaluable. EMC intends to perform aerial acquisition and research nationwide to meet the surveying and mapping demands of our clients in a more timely, accurately, efficient and most importantly, safer manner. In support of our state and federal government agencies with an excellent, work history withBoundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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the U. S. Army Corps of Engineers, the capabilities and time saved using the eBee are much more feasible when compared to the limited access to areas that arise from time to time. With the safety of our nation’s citizens in mind, and in the event of a natural disaster, such as Hurricane Katrina and the limited to access to areas for an extended period of time, the eBee could literally save lives by allowing it to take to the skies to quickly and safely meet the area’s immediate/urgent surveying needs.

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 a. Airworthiness assessment of the eBee (See Appendix D) EMC 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-airworthinessassessment , and the USACE District, New Orleans, who coordinated with the Department of 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 civil aviation authorities) in many countries:

Switzerland (flight approval for VLOS operations) Canada (flight approval for VLOS operations) Australia (flight approval for VLOS operations) France (flight approval for Extended-VLOS operations) Germany (flight approval for VLOS operations) United Kingdom (flight approval for VLOS operations) Norway (flight approval for VLOS operations) Sweden (flight approval for VLOS operations) Denmark (flight approval for VLOS operations)

b. Operating requirements Grant of the exemption to EMC for the eBee will be subject to the following operating conditions, based on the operating conditions set forth by the Academ y of Model Aeronautics (see Annex B).

The main restrictions are summarized below:

 Operations to be conducted over private, cont rolled-access, or public property where approved

 Permission from the land owner/authority required before commencing any flight

 Operations over congested or densely populated areas will be avoided and stand-off distances imposed of at least 500’ from all nonparticipating per sons, vessels, vehicles and structures, unless:

 barriers or structures are present that would sufficiently protect non-participating persons in the event of an accident; and/or

 the owner/controller of such structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard; and

 Operations, nearer to the PIC, VO, operator trainees or essential persons, do not present an undue hazard to those persons.

 Operations must not interfere with manned aircraft operations, must remain a safe distance from, yield the right of way to manned aircraft, and operators must “sense and avoid capability” regarding other

airborne aircraft and obstacles at all times

 Operations will be limited to Visual Flight Ru les 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 guaranteed with a GPS geo-fence around operator of 0.5 milesBoundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER

APPLICABLE RULES SUBJECT TO EXEMPTION

EMC requests an exemption from the following regulat ions, as well as any additional regulations that may technically apply to the operation of the eBee:

14 CFR 21 –CERTIFICATION PROCEDURES FOR PR ODUCTS AND PART Subpart H – Airworthiness Certificates (Appendix D) 14 CFR 91.203(a)(1) Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedur al requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a). Given the size of the eBee, its very light weight (the maximum take-off weight is 1.7 pounds) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H in order to achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populat ed areas of the UAS involved. An analysis of these different criteria demonstrates that the eBee operated without an airworthiness certificate, under the conditions proposed in that exemption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness certificate. A proprietary risk assessment for operations with the eBee, which demonstrates that assertion, is also being submitted to the FAA as part of this application. EMC requests the FAA treat the eBee risk assessment as proprietary under 14 CFR 11.35(b) and not include this document in the public docket.

14 CFR 45.23 Display of marks and 45.29 Size of Marks Under these regulations an aircraft must display the Roman capital letter "N" and the aircraft's registration number in letters at least 3 inches high. Additionally , an aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station.

Due to the size of our eBee having a wing-span of 96 cm (37.8 in.) and a wing-area of 0.25m 2 (387.50 in 2 ), this requirement is impossible to achieve. Furthermore , our eBee does not have an entrance in which the word "Experimental" could be placed, and we may not be provided an FAA registration number for our eBee. To achieve an equivalent level of safety, EMC proposes setting a ground station where all of the aircraft's registrations (if applicable) and manuals will be centraliz ed in the eBee’s storage/carrying case which will be with the operator at all times when in use. Since our eBee will operate in Visual Line of Sight (VLOS), this station will be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

14 CFR 61.113 Private Pilot Privileges and limitations: Pilot In Command (PIC) Under these current regulations, civil operation for compensation or hire required a PIC holding a commercial pilot certificate per 14 CFR 61. Based on the private pilot limitations in accordance with pertinent parts 14 CFR 61.113 (a) and (b), a pilot holding a private certificate cannot act as a PIC of an aircraft for compensation or hire, unless the flight is only incidental to a business or employment.

Given the safety features of the eBee, and the fact that the missions are pre-programmed and monitored in real-time with the flight management software, EMC propose s that the PIC hold a private pilot certificate and a

third-class airman medical certificate. The PIC will obt ain the necessary airmanship skills to operate the eBee via training program(s). This will enable the PIC to sa fely operate the eBee in all conditions including evasive and emergency maneuvers, and maintaining appropriate distances from structures, vehicles, person, etc.Boundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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14 CFR 91.7 Civil aircraft airworthiness (See Appendix D) This regulation requires that no person may operate a civil ai rcraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the eBee without an airworthiness certificate, no

standard will exist for airworthiness of the eBee.

Given the previous airworthiness asse ssments given to the eBee, among others: New Mexico State University: https://newscenter.nmsu.edu/Articles/view/10208/nmsu- uas-flight-test-center-conducts-ebee-airworthinessassessment and the USACE New Orleans, who coordinated with the Department of Army and the FAA to obtain all authorizations required in order to oper ate the eBee UAS for levee system monitoring, documentation of construction progress, and extensive oblique photography of USACE structures & activities In addition, EMC will strictly follow all of the guidelines for all pre-flight inspections, safety precautions and product maintenance procedures, as stated in Appendix A and Appendix B, which will include a method for determining the airworthiness of the aircraft; and therefore request relief from 14 CFR 91.7(a). Our PIC will be responsible for and capable of determining whether the aircraft is in a condition for safe flight; so we are not requesting relief from 14 CFR 91.7(b).

14 CFR 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements This regulation provides that no person may operate an ai rcraft unless a current, approved, flight manual is in the aircraft. EMC assumes that the intent of this require ment is to ensure that flight manual information is available to the aircrew while operating the aircraft. EMC requests an exemption to this requirement since, the aircraft is not only too small to carry documentation; the documentation would not be available to the crew.

The equivalent level of safety will be achieved by keepi ng a hard copy of the flight manual in the eBee’s storage/transportation case. This case will be located at the proposed ground station in the PIC’s possession during the operation of the eBee.

14 CFR 91.109(a) and 14 CFR 91.319(a)(1) - Flight instruction; Simulated instrument flight and certain flight tests. The regulation provides that "No person may operate a civ il aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls."

Flight instruction will be accomplished through an elaborated training program, using first the simulation mode of the flight management software eMotion as set forth in Exhibit 2. The equivalent level of safety during the training will be achieved by the manufacturer providing the training as outlined in Exhibit 2 and through the use of experienced and qualified operators familiar with the eBee. (See Appendix C)

14 CFR 91.119: Minimum Safe Altitudes The regulation provides that over sp arsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, the eBee cannot comply with this requirement.

To acquire an equivalent level of safety, we will only fl y over private property with the permission of the landowner. The operator will define before every flight a working area radius and a flight area ceiling, preventing the eBee to go beyond the flight area. 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 and the material with which the eBee is built, 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 ov er congested areas or over any open- air assembly of persons. The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.Boundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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14 CFR 91.121 – Altimeter settings This section requires that 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 below 18,000 feet

MSL to:

 The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

 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;

 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.

To provide an equivalent level of safety, the eBee autopilot calculates the reference altitude (ground level) with the on-board GPS during the pre-flight tests. The GPS and barometer data are merged with respect to their respective precisions. The GPS provides reliable information to correct potential barometric bias, while rapid variations in altitude are detected through the barometer. Given the limited altitude of the proposed missions, we feel that an equivalent level of safety is achieved; and we request relief from 91.121.

14 CFR 91.151: Fuel Requirements for Flight in VFR Conditions The regulation provides that no person may begin a flight in an airplane under day VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes.

The eBee is a battery-operated aircraft with a maximum duration of flight from a single battery charge of 50 minutes. Furthermore, the area of operation for the eBee will never fly over 1/2 nm from the point of intended landing. A full battery charge allows us to meet the reserve energy requirements. We also believe that an equivalent level of safety is already achieved with the specific procedure preventing the eBee to accept a “take-off” order if the battery level is below a giv en value. Additionally, the eBee has integrated “low” and “critical” battery-level warnings; and has implem ented a “return to Home” and “Go Land” command actions, should these non-anticipated situations ever arise.

14 CFR 91.203 (a) & (b) Civil aircraft: Certifications required This regulation provides as follows: No person may operate a civil aircraft unless it has an appropriate and current airworthiness certificate. No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The eBee weighs only 1.7 pounds (max take-off weight). As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. In addition, there is no pilot or passengers on board the aircraft. To obtain an equivalent level of safety and meet the intent of 91.203, EMC propose that documents deemed appropriate for this aircraft by the FAA will be located with the operator at the proposed ground control station in the eBee’s carrying case and available for inspection upon request.

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance and Alterations (See Appendix B) The eBee is not the type of equipment that would require a certified mechanic’s skills or knowledge. EMC proposes that the maintenance of the eBee be accomplished by the owner/operator according to the maintenance manual, provided by SenseFly. EMC requests the FAA treat the eBee training program as proprietary under 14 C.F.R. 11.35(b) and not include this document in the public docket.

An equivalent level of safety will be achieved because the eBee is small in size, it is not a complex mechanical device, it will carry no external payload, and it will operate only in restricted predetermined areas. Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in anBoundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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airworthy condition and to ensure an equivalent level of safety. Finally, before every flight, the eBee runs automatically a sequence of pre-flight tests to make su re that every sensor and every critical part is running properly. If a problem is detected, the eBee will not be able to be switched “on” and a message error is displayed on the main screen of eMotion. The operator can then refer to the maintenance manual to troubleshoot this issue. Most parts of the eBee 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.Boundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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ANNEX B: ACADEMY OF MODEL AERONAUTICS SAFETY REQUIREMENTS

Academy of Model Aeronautics National Model Aircraft Safety Code http://www.modelaircraft.org/files/105.pdf

“See and Avoid” Guidance http://www.modelaircraft.org/files/540-D.pdf

Radio Controlled Model Aircraft Operation Utilizing Failsafe, St abilization and Autopilot Systems http://www.modelaircraft.org/files/560.pdfBoundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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Appendix A

SenseFly - eBee User Manual Rev.15 Confidential (A thru D will be mailed)

* Documents were submitted confidentially for proprietary reasons & will not be available to the publicBoundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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Appendix B

SenseFly - eBee Maintenance Procedures Confidential (A thru D will be mailed)

* Documents were submitted confidentially for proprietary reasons & will not be available to the publicBoundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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Appendix C

SenseFly – eBee Training Documentation Confidential (A thru D will be mailed)

* Documents were submitted confidentially for proprietary reasons & will not be available to the publicBoundary | Topographic | Hydrographic | Geophysical | Laser Scanning | Mobile LiDAR | GPS Data Development

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2472 Sunset Drive Grenada, MS 38901 Telephone: 662.226.5166

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Appendix D

SenseFly – eBee Justification of Airworthiness and Safety Assessment Confidential (A thru D will be mailed)

* Documents were submitted confidentially for proprietary reasons & will not be available to the public