4/8/15

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Filed with www.regulations.gov

Re: Re: Request for Summary Grant of Exemption Under Section 333 of the FAA Reform 

Act and Part 11 of the Federal Aviation Regulations

Dear Madam, Sir,

Through a partnership with New Mexico State University’s Flight Test Center, NewFields has 

been successfully operating under a COA since September 2014; conducting surveys of a 

Colorado mine site with the eBee UAS. The research conducted under this COA has yielded 

valuable information regarding the safe operations of the eBee at industrial facilities, which 

NewFields will leverage to ensure a high level of safety during future UAS operations. The 

Summary Grant Exemption under Section 333 requested here would permit NewFields to provide 

valuable services to its clients through UAS operations that, because of their remote locations, 

secure facilities and the operators’ experience with unmanned aviation safety, pose a minimal 

level of risk to others in the air and on the ground.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”)

and 14 C.F.R. Part 11, NewFields Knowledge Management (“NewFields”), an operator of the

eBee Unmanned Aircraft System (“eBee”) seeks a summary grant of exemption from the Federal

Aviation Regulations (“FARs”) listed below based on exemption No. 11263 previously issued by 

the Federal Aviation Administration on April 1, 2015:

• 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 commercial operations using the eBee for mapping 

and survey applications. These operations will be subject to strict operating requirements defined 

in the eBee user manual (NewFields 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) in

order to ensure at least an equivalent level of safety to currently authorized operations using

manned aircrafts.

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 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 embedded 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 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 sharp or hard edges and 

almost no internal strengthening structure. 

b. 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. 

c. 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 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 should it become necessary to 

respond to emergent circumstances, thanks to the remote controller provided with the system.
2. APPLICATIONS

The eBee will be used to perform aerial surveys of industrial facilities, agricultural facilities and

energy infrastructure, including mining operations, smelting operations, Superfund sites, 

pipelines, solar energy plants and electrical utilities. The targeted survey sites are typically located 

in very remote locations with access often strictly controlled through security checkpoints.

The data collected during the survey will be used to create aerial imagery, elevation models and 

vegetation index maps for the survey sites. These datasets will be used to provide high resolution 

and high accuracy data for volumetric measurements; mapping vegetation health; engineering 

and design work; monitoring environmental compliance; facilitating construction management; 

and marketing.

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333

a. Airworthiness assessment of the eBee

NewFields 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-flighttest-center-conducts-ebee-airworthiness-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).

Moreover, SenseFly obtained flight approvals for the eBee (delivered by national civil aviation 

authorities) in many countries, including:

• 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

In this summary grant of exemption request, NewFields is hereafter referred to as the operator.

A summary grant of exemption to NewFields for the eBee will be subject to the same operating 

conditions issued by the Federal Aviation Administration, without deviation or alteration, in 

exemption No. 11263 on April 1, 2015. The operating restrictions are summarized below:

1. Operations authorized by this grant of exemption are limited to the eBee when weighing less 

than 55 pounds including payload. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 
3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UA be operated at 7 airspeeds greater than 

the maximum UA operating airspeed recommended by the aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be 

able to communicate verbally at all times. Electronic messaging or texting is not permitted 

during flight operations. The PIC must be designated before the flight and cannot transfer his or 

her designation for the duration of the flight. The PIC must ensure that the VO can perform the 

duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists between 

the conditions and limitations in this exemption and the procedures outlined in the operating 

documents, the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the operator’s responsibility to track 

such revisions and present updated and revised documents to the Administrator or any law 

enforcement official upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to this grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA granted this 

exemption, then the operator must petition for an amendment to its grant of exemption. The 

FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates 

or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional 

test flight prior to conducting further operations under this exemption. Functional test flights may 

only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The 

functional test flight must be conducted in such a manner so as to not pose an undue hazard to 

persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects 

the safe operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe flight. 
11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must have completed the FAA Airman Knowledge 

Exam. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s 

license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the 

Federal government.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must 

be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building) and determining the 

PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on the current FAA published aeronautical 

chart, unless a letter of agreement with that airport’s management is obtained or otherwise 

permitted by a COA issued to the exemption holder. The letter of agreement with the airport 

management must be made available to the Administrator or any law enforcement official upon 

request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The exemption holder 

may apply for a new or amended COA if it intends to conduct operations that cannot be 
conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and activities at 

all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects 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. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.
3. CONCLUSION

This request is designed to follow up on previous efforts by the Federal Aviation Administration 

to determine equivalent levels of safety for UAS operations. By requesting a summary grant of 

exemption we hope to achieve expedited approval for UAS operations to the public’s benefit.

Yours sincerely,

McCain McMurray

Remote Sensing Specialist

1730 17th St. Suite #925

Denver, CO 80202
ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 

NewFields requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the eBee: 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural 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 populated 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. SenseFly requests the 

FAA treat the eBee risk assessment as proprietary under 14 C.F.R. 11.35(b) and not include this 

document in the public docket. 

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size of marks 

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. Given the size of the eBee (wingspan of 37.8 inches), this requirement is impossible 

to match. The equivalent level of safety will be achieved by having the upper part of the eBee 

stick with a copy of the AMA membership of the operator in charge. The AMA agrees to provide 

2 original copies of the AMA license to every eBee operator. 

14. CFR §61.23: Medical certificates: Requirement and duration 

Regulations provide that a person: 

(1) Must hold a first-class medical certificate: 

• When exercising the pilot-in-command privileges of an airline transport pilot certificate; 

• When exercising the second-in-command privileges of an airline transport pilot 

certificate in a flag or supplemental operation in part 121 of this chapter that requires 

three or more pilots; or 

• When serving as a required pilot flight crewmember in an operation conducted under 
part 121 of this chapter if the pilot has reached his or her 60th birthday. (2) Must hold at 

least a second class medical certificate when exercising:

• Second-in-command privileges of an airline transport pilot certificate in part 121 of this 

chapter (other than operations specified in paragraph (a)(1)(ii) of this section); or 

• Privileges of a commercial pilot certificate 

Given the size of the eBee, its structure, the limited flight area, and the safety features integrated 

in the autopilot (among others the Flight Termination System), SenseFly believes that an 

Equivalent Level of Safety can be reached if the operator has a valid driver’s license.

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 14 C.F.R. § 

61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; 

Commercial Pilot Privileges and Limitations 

The regulation provides that no person may serve as a required pilot flight crewmember of a civil 

aircraft of the United States, unless that person: 

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in that 

person's physical possession or readily accessible in the aircraft when exercising the privileges of 

that pilot certificate or authorization. However, when the aircraft is operated within a foreign 

country, a pilot license issued by that country may be used. The regulation provides also that no 

person that holds a private pilot certificate may act as pilot in command of an aircraft for 

compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an 

aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Given the safety features of the eBee and the fact that the missions are pre-programmed and 

monitored in real-time with a specific flight management software (eMotion), SenseFly proposes 

that operators of the eBee should not be required to hold a commercial or private pilot 

certification. Instead, operators should be required to: 

• Have completed an AMA affiliated small unmanned aircraft systems education and 

training program and achieved an AMA UAS endorsement, or have successfully 

completed a small UAS education and training program provided by any FAA qualified 

entity, 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). 

The equivalent level of safety will be achieved by having an operator trained by the AMA (or 

any FAA qualified entity) and SenseFly, and using the integrated features of the aircraft to 

maintain a high level of safety during the different missions.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness 
This regulation requires that no person may operate a civil aircraft 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 size 

of the aircraft and the previous airworthiness assessments given to the eBee, among others: 

• New Mexico State University: https://newscenter.nmsu.edu/Articles/view/10208/nmsuuasflight-test-center-conducts-ebee-airworthiness-assessment

• 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. 

An equivalent level of safety will be achieved by insuring compliance with the eBee user manual 

prior to each flight. 

14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements 

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. SenseFly assumes that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. SenseFly 

requests an exemption to this requirement since the aircraft is not only too small to carry 

documentation, but the documentation would not be available to the crew. 

The equivalent level of safety will be achieved by keeping a hard copy of the eBee user manual 

in the eBee transport box. 

14 C.F.R. § 91.109(a): Flight Instruction

The regulation provides that "No person may operate a civil 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. The equivalent level of safety 

during the in-flight training will be achieved by the manufacturer or affiliate providing the 

training as described in the eBee training program and through the use of experienced and 

qualified instructors familiar with the eBee and also members of the AMA. 

14 CFR § 91.119: Minimum Safe Altitudes 

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the eBee will be operating at a 

maximum of 400 feet AGL, SenseFly cannot comply with this requirement. 

The equivalent level of safety will be achieved because the eBee will only fly 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 landowner and 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, the material with which the eBee is built and its specific safety 

procedures (among others ground detection), 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 over congested areas or over any open-air 

assembly of persons.

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 then used to calculate the altitude in-flight. 

14 C.F.R. § 91.151(a): 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. As the eBee is electric-powered, this requirement is inapplicable. 

In any event, given the area of operation for the eBee, SenseFly believes that an equivalent level 

of safety is already achieved with the specific procedure preventing the eBee to accept a take-off 

order is the battery level is below a given value. Moreover, SenseFly has integrated “low” and 

“critical” battery level warnings and implemented a “return to Home” (and “Go Land”) actions 

in these situations. 

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

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.

To obtain an equivalent level of safety and meet the intent of 91.203, SenseFly proposes that 

documents deemed appropriate for this aircraft by the FAA will be co-located with the operator 

at the ground control station in the eBee transport box and available for inspection upon request. 

In order to identify the aircraft, SenseFly proposes that a copy of the AMA membership of the 

operator will be permanently affixed to the eBee on the upper side of the body. 
14 CFR Subpart E (91.401 - 91.417): Maintenance, Preventive Maintenance, and 

Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 

91.409 require the aircraft to be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. Section 91.409 requires an annual inspection for the 

issuance of an airworthiness certificate. Section 91.417 requires the owner or operator to keep 

records showing certain maintenance work that has been accomplished by certificated 

mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to 

service. 

SenseFly proposes that the maintenance of the eBee will be accomplished by the owner or the 

operator according to the eBee user manual. An equivalent level of safety will be achieved 

because the eBee is small in size, it is not a complex mechanical device and does carry any 

external payload. Moreover, the operator is the person most familiar with the aircraft and is best 

suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of 

safety. Finally, before every flight, the eBee automatically runs a sequence of pre-flight tests to 

make sure that every sensor and every critical part is operating 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 owner or the operator can then refer to the eBee user manual to troubleshoot this 

issue. Several 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.
ANNEX B: ACADEMY OF MODEL AERONAUTICS SAFETY REQUIREMENTS

http://www.modelaircraft.org/files/105.pdf

http://www.modelaircraft.org/files/540-D.pdf

http://www.modelaircraft.org/files/560.pdf