ASSOCIATION FOR UNMANNED 

VEHICLE SYSTEMS INTERNATIONAL 

22 September 2014 

Docket Management Facility 

2700 South Quincy Street, Suite 400 • Arlington, VA 22206 • 703.845.9671 • 703.845.9679 fax 

U.S. Department of Transportation 

1200 New Jersey Avenue SE 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

Subject: Comments to FAA Docket Number FAA-2014-0727, SenseFiy Petition for Exemption 

To whom it may concern, 

The Association for Unmanned Vehicle Systems International {AUVSI), the world's largest non-profit 

organization representing the unmanned systems industry, with more than 7,000 members worldwide, 

including 600 corporate members~· supports Sense Fly's 'exemption petition ·that would authorize 

commercial operations'usirigthe eBee for mapping applications that may include agriculture applications, 

mining, construction and survey/GIS operations and urges the FAA to grant their request immediately. 

Furthermore, the 'eBee is an ultra-light UAV platform made of flexible foam. with no sharp edge 

characterized by a high level of pre-programmed control and various built-in technical capabilities 

(pr'ogramliling of a geocfence, automatic wind detection) that limit the potential for operation outside of 

the operatihg conditions. Moreover, the kinetic energy of the aircraft in-flight is 38 Joules ("J") in case of 

a controlled emergency landing. In comparison, the kinetic energy of a football is about 110 J when thrown 

by hand. ..l 

Unmariried Aircraft Sysfems have been successfully and safely operated in Japan, Australia, and South 

Korea for more than 20 years, which have logged more than 2 million flight hours, without anyone being 

injured. In Japan alone, UAS treats more than 2.4 million acres of farmland each year. Because manned 

"agriculture pilots are at increased risk for fatal injury compared with pilots in all other industries"\ the 

use of an unmanned aircraft systems {UAS) for agriculture will save time, money, and most importantly; 

lives, by not jeopardizing a human in an aircraft. 

Unmanned aircraft systems hold tremendous potential to create jobs, boost local economies, and keep 

people safe. In a report issued last year2

, AUVSI found that the UAS industry is poised to create more than 

100,000 new jobs and over $80 billion in· economic impact within the first 10 years following the 

integration of UAS into the national airspace system. Eighty percent ofthe future commercial UAS market 

will be in precision agriculture, including remote sensing. Therefore, there is a compelling need for the 

FAA to expedite the commercial use of UAS. 

In recognition ofthe growth potential ofthis new industry, in Feb. 2012, Congress mandated the FAA 

write the rules to safely integrate UAS into the national airspace by20153

, a deadline the U.S. Department 

1 http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5315a4.htm 

2 www.auvsi.org/econreport 

3 https://www.faa.gov/regulations_policies/reauthorization/media/PLAW-112publ95[1].pdf 
of Transportation Inspector General4 and Government Accountability Office5 have regrettably said will not 

be met. Luckily, Congress had the foresight to include section 333 in the FAA Modernization and Reform 

Act (Public Law 112-956) which allows the Secretary of Transportation to determine if certain UAS may 

operate safely in the airspace before the FAA finalizes rules for widespread commercial use of small UAS. 

In the opinion of AUVSI, SenseFiy has a deep and well-known experience in terms of safe integration of 

remote controlled aircrafts in the national airspace system for low-altitude operations and their 

exemption outlines at least an equivalent level of safety over the use of a manned aircraft and they have 

adequately addressed the safety requirements in a number of federal aviation regulations7. 

Although AUVSI applauds the FAA's efforts to consider UAS exemption requests8, AUVSI remains 

concerned the FAA is more than three years late in issuing safety regulations for the wide-spread 

commercial use of small UAS9

. On 8 April 2014, AUVSI and 32 other association representing the manned 

aviation community, air traffic controllers, and future users of UAS, including agriculture groups, realtors, 

media organizations, and public safety organizations, sent a letter to the FAA strongly encouraging them 

to grant exemptions but to also expedite the public notice and comment for small UAS rulemaking10. The 

FAA expects to release its notice of proposed rulemaking for small UAS in November11• 

The commercial UAS industry will not be allowed to fully take off until regulations, not just exemptions, 

are finalized. Troublingly, FAA officials have publically said the regulations will take at least 16 months 

after the public comment period ends before it is finalized. That is simply unacceptable. 

Accelerating commercial UAS use will not only help businesses harness the tremendous potential of UAS, 

they will also help unlock the economic impact and job creation potential ofthe technology. AUVSIIooks 

forward to continuing to work with the FAA and other stakeholders to ensure UAS are integrated safely 

and responsibly as quickly as possible. The FAA should promptly grant this exemption request, look for 

ways to allow for more commercial use of UAS immediately, and get on with rulemaking. 

Respectfully submitted, 

Michael Toscano 

President & CEO 

AUVSI 

4 http://www .o ig.dot.gov I sites/ dot/fi les/FAA%200ve rs ight%20of%20U n rna n ned%20Ai rcraft%20Syste rns%5 E6-26-14 _ 0. pdf 

5 http:/ /www.gao.gov/assets/670/660683.pdf 

6 https :/ /www. faa .gov I regulations _policies/ rea utho rizatio n/ rned ia/PLA W -112 pu bl95 [ 1]. pdf 

7 49 U.S.C. §44704, 14 CFR Parts 21, 27, 137, 45.23(b), 61.113(a)(b), 91.7(b), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 

91.151(b), 91.203(a)(b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a)(b), and 91.1501 

8 http:/ /www.auvsi.org/auvsinews/associationnews 

9 http://www. dot.gov I regulations/ report-on-significant-rule rna kings 

10 http:/ /higherlogicdownload.s3.a rnazonaws.corn/ AUVSI/958c920a-7f9b-4ad2-9807-

f9a4e95d1ef1/UploadedFiles/Joint%20Letter%20to%20FAA%20on%20Expediting%20UAS%20rulernaking%20Final.pdf 

11 http://www .dot.gov /regu lations/report-on-significant-rulerna kings