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 2 1  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 entir e field by walking. Aerial scouting technology allows anagronomist 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 operat ors 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 requir ements:
 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 do cket.  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 assura nce 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 m apping 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 ca n 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. Th e 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 ana lyzes 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 necess ary 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 multispe ctral 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 st resses 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 wi ll 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 person nel 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 fin ancial 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 d emand 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 wo rld 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 Tec h 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/Articl es/view/10208/nmsu
- uas -flight -test - center-conducts ebeeairworthiness - 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 moni toring, 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 avia tion 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 (fl ight 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)  Swe den (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 operat ing 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 & Avoi d 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 ope rations 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 exist ing 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 permis sion 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 airc raft 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 c urrently 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 tech nical 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 h uman 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 g round 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 recognize d 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 airworthinesscertification 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 a s 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 a ircrafts 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 ut ilize 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