Rural Tech Center

November 9, 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 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, Rural Tech Center, LLC seeks an exemption from the Federal Aviation Regulations 

(“FARs”) listed below: 

 14 C.F.R. Part 21

 14 C.F.R. 45.23

 14 C.F.R. 45.29

 14 C.F.R. 61.23

 14 C.F.R. 61.3 

 14 C.F.R. 61.113(a) & (b)

 14 C.F.R. 61.133(a)

 14 C.F.R. 91.7(a)

 14 C.F.R. 91.9 

 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 

 14 CFR Subpart E (91.401 - 91.417) 

The requested exemption would authorize unmanned aircraft operations using the eBee for agriculture 

mapping and high resolution aerial imagery applications by Rural Tech Center, LLC in the United States. 

These operations will be subject to strict operating requirements 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. 

Rural Tech Center, LLC provides precision agriculture mapping services and high resolution aerial 

imagery to clients throughout South Dakota, Nebraska, and Iowa. Rural Tech Center, LLC. 

Unmanned aerial technology is becoming a desirable tool in the agricultural industry. As growers are 

caring for more and more acres, field scouting by foot is becoming less efficient. It is nearly impossible, 

nor practical, for a person to scout an entire field by walking. Aerial scouting technology allows an 
agronomist to see a large field all at once and allows for more efficient and effective recommendations 

and decision-making. The unmanned aspect of aerial technology eliminates the endangerment of 

human life by low and slow flight and allows a safe and cost-effective acquisition of close-up aerial 

images. 

Given the technical specifications of the eBee, especially its very light weight, and the type of 

operations, including flights above crops, Rural Tech Center, LLC believes it is relevant to use the 

Academy of Model Aeronautics (AMA) rules to meet the required level of safety of future operations 

with the eBee. 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 guidelines for operators using ultra-light remote controlled aircrafts. The eBee will be 

operated by an individual who fulfills the following requirements: 

 Is a registered member of the AMA;

 Has passed SenseFly’s training program for the eBee; Rural Tech Center, LLC 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.

 Have completed an aviation fundamentals course. 

 Has a valid driver’s license 

Under this exemption, the operator would agree, if requested, to contact the FAA in order to provide 

the FAA with the details of the related missions and provide assurance that training and maintenance 

requirements are met. 

1. CHARACTERISTICS OF THE AIRCRAFT 

The eBee is a small (37.8-inch wingspan) and ultra-light (maximum take-off weight of 1.7 pounds) 

platform made of flexible foam that performs precision aerial mapping missions with an on-board GPS 

and related flight management software (eMotion) 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 can take a collection of high-definition, still images that can later be used to 

generate maps and contour lines of the surveyed area. 

The four main characteristics of the eBee include: 

a. 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 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 are detachable and made of flexible foam with no hard or sharp edges and almost no internal 

strengthening structure. 

b. Electric-powered 

The eBee 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 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 

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 with the remote controller provided with the system, 

should it become necessary to respond emergent circumstances. 

2. APPLICATIONS AND ADDED VALUE OF THE EBEE 

Rural Tech Center, LLC intends to plan and implement an aerial agricultural program using precision 

agricultural mapping services and high resolution aerial imagery and SenseFly’s eBee in order to assist its 

clients in management decision-making to increase production and crop-scouting efficiency. 

Using the eBee’s sensor technology, Rural Tech Center, LLC staff will be able to collect near infrared 

(NIR) and/or multispectral images. Once the entire field is flown, collected images can be “stitched” 

together in a software program to make a complete infrared or multispectral map of a field. Using 

specific mathematical equations within the Pix4D program, different crop stresses and production 

factors can be discovered. 

The eBee will be used to determine several factors, including but not limited to: 

 Nutrient deficiencies

 Vegetation stress 

 Weed pressure and type

 Presence and onset of disease

 Weather damage (hail/wind)

 Soil erosion 

Often times, diseases or insects begin deteriorating plant health within one part of a field and spread 

over time. If an agronomist is only able to see a few areas of a field, the chances of overlooking a major 

problem are incredibly high, but if the entire field can be depicted from the eBee, plant health issues can 

be fixed before they expand, reducing yield loss. 

Every stressful situation that a plant encounters reduces crop yield. The work product provided by Rural 

Tech Center, LLC will assist agronomists strive to eliminate and reduce plant stress by implementing crop 

protection programs to make their customers more profitable. By using real-time aerial imagery to see 

the onset and occurrence of plant stresses, Rural Tech Center, LLC can better help their customers 

maintain a high yield (more production), and in turn, high profitability, in a safe and efficient manner. 

The end goal at Rural Tech Center, LLC is to be able to provide the maps produced by the eBee to 

qualified personnel to create variable- rate prescriptions using an agronomic mapping program. The 

prescriptions can then be loaded into one of the cooperative’s fertilizer spreaders so that fertilizer is 

applied to the correct areas at the proper rate. 
Overall, UAV technology offers a substantial economic benefit to the agricultural industry. The eBee 

would save clients and agronomists a great deal of time scouting fields. Furthermore, due to the fact the 

eBee images are geo-referenced, agronomists can pinpoint a problem area on a map and then walk or 

drive directly to that area to see what issues are happening and potentially correct them. 

Along with efficiency, UAV technology offers the potential for maintaining high yields. This is not only 

important from a financial standpoint for growers, but from a production standpoint. With the world 

population continuously increasing, it is essential that farmers be able to maintain higher yields in order 

to continue to feed a hungry planet and to keep up with the world demand for high quality food and fuel 

products. 

The use of the eBee technology will allow clients a significant advantage to maintain crop health and 

maintain high yields in order to meet consumer demand and make a living. Several countries around 

the world are offering this technology to farmers. UAVs have successfully and safely scouted fields in 

Europe and China and even applied aerial application. 

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

a. Airworthiness assessment of the eBee 

Rural Tech Center, 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 (including New 

Mexico State University: 

https://newscenter.nmsu.edu/Articles/view/10208/nmsu-uas-flight-test-center-conductsebeeairworthiness-assessment, and the USACE New Orleans, who coordinated with the Department of 

Army and the FAA to obtain all authorizations required in order to operate the eBee UAS for levee 

system monitoring, documentation of construction progress, and extensive oblique photography of 

USACE structures & activities, and others). 

Moreover, Rural Tech Center, LLC notes that SenseFly obtained flight approvals for the eBee (delivered 

by national civil aviation authorities) in many countries, among others: 

 Switzerland (flight approval for Visual Line of Sight operations) 

 Canada (flight approval for Visual Line of Sight operations) 

 Australia (flight approval for Visual Line of Sight operations)

 France (flight approval for Extended Visual Line of Sight operations)

 Germany (flight approval for Visual Line of Sight operations)

 United Kingdom (flight approval for Visual Line of Sight operations)

 Norway (flight approval for Visual Line of Sight operations) 

 Sweden (flight approval for Visual Line of Sight operations)

 Denmark (flight approval for Visual Line of Sight operations) 

b. Operating Conditions 

Grant of the exemption to Rural Tech Center, LLC for use of the eBee will be subject to the following 

operating conditions, based on the operating conditions set forth by the Academy of Model Aeronautics. 

The main restrictions 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; 

 Operations 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 Meteorological Conditions (VMC) and daylight hours 

 Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually monitored 

at all times; 

 Flight ceiling pre-programed at 400 feet; 

 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 shall 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 procedures inherent to the activities 

of the related company. 

A large percentage of the property serviced by Rural Tech Center, LLC is located within isolated, rural 

areas. Before a property is flown, Rural Tech Center, LLC will request permission from each owner. With 

the geo-fence incorporated within the software, Rural Tech Center, LLC will avoid flying over houses and 

house-yards as much as reasonably possible. The flight ceiling will be pre-programmed at 400 feet so as 

to ensure the aircraft will not fly over the height specified by the AMA. By staying below this level, the 

eBee should not interfere with manned aircraft operations 

Rural Tech Center, LLC takes pride in providing a safe working environment for its clients and staff and 

currently has excellent safety procedures in place. 

c. Operator Requirements 

The eBee is an ultra-light UAV platform made of flexible 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 

geo-fence, automatic wind detection) that prevent the operator from doing a mission outside of the 

operating limits. All 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 system. 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 these safety features recognized by the U.S. Army Corps of Engineers and the national aviation 

authority of several countries, Rural Tech Center, LLC requests an exemption from the airworthiness 
certification requirements in Part 21 and the concomitant requirements in 14 C.F.R. 91.7(a)) and 91.203 

to operate an airworthy aircraft. Instead, operators of the eBee will: 

 Have completed an aviation fundamentals course, and; 

 Have passed SenseFly’s training program for operation of the UAS. The manufacturer’s training 

program for operators has been already satisfactorily reviewed through the Application for 

Airworthiness Qualification Level (AQL) 3 Airworthiness Release (AWR). 

Rural Tech Center, LLC also seeks an exemption from certain requirements in Parts 45 and 91 that are 

impractical as well as unnecessary for UAS operations. 

4. CONCLUSION 

Rural Tech Center, LLC, in association with SenseFly and the Academy of Model Aeronautics 

organization, who has a deep and well-known experience in terms of safe integration of remote 

controlled aircrafts in the National airspace for low-level operations, provides here adequate 

justification for the grant of the requested exemption allowing safe precision agriculture mapping 

services, high resolution aerial imagery and operations of the eBee in the National Airspace System. 

The value that the eBee could bring to the agricultural industry is invaluable. It would bring several 

efficiency and production benefits to agricultural operations and allow Rural Tech Center, LLC to provide 

the owner-members of the cooperative with outstanding service in order to help them exceed their 

potential. If the population is expected to continually increase, then it is essential for agricultural 

production to escalate as well. Allowing Rural Tech Center, LLC to utilize the eBee in their operations in 

a safe manner in accordance with AMA guidelines would not only make sense economically, but would 

also in a matter of sustainability. 

Rural Tech Center, LLC offers in this Exemption a pragmatic approach to allow the efficient operation of 

ultra-light UAVs pursuant to FAA, AMA, and SenseFly safety requirements and conditions. 

Sincerely yours, 

Michael Hoffman, Owner Email: admin@ruraltechcenter.com