July 22, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of Coleman Engineering Company for an Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012

Dear Madam/Sir,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“Reform Act”) and 14

C.P.R. Part 11, Coleman Engineering hereby applies for an exemption from the Federal Aviation

Regulations identified below, to allow commercial operations of small unmanned aerial vehicles.

This exemption is made based on information outlined in this petition, as well as the accompanying senseFly 

eBee RTK Operators Manual (Appendix B) and the Coleman Engineering Operational Limitations

(Appendix C). The eBee RTK UAS was selected because it has a proven capability for controlled flight.

These devices are offered for general sale around the world and have often been used as Model Aircraft in 

the USA.

The Requested exemption would authorize commercial operations using the eBee RTK for mapping and 

surveying applications. These operations will be subject to strict operating requirements defined in the user 

manual 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.

Coleman Engineering Company has already been granted an FAA exemption for the use of the DJI Phantom 

2, in a letter dated June 16, 2015. Exemption No. 11833, Regulatory Docket No. FAA-2015-1121. The 

intended use of the eBee RTK UAV would be very similar. Since the eBee RTK is a winged aircraft instead 

of a multi-rotor aircraft, this will assist Coleman Engineering Co. in covering different needs and tasks that 

are not as efficient or possible with the DJI phantom 2 quad copter. 

Specifically, the UAS is:

A lightweight (approximately 1.61 lb gross weight with all on-board equipment), battery operated 38” 

wingspan aircraft manufactured by SenseFly, Model eBee RTK, with the following equipment:

- An on-board flight computer with GPS navigation (utilizing L1/L2 GPS and Glonass GPS band 

frequencies) and location ability that receives signals for flight controls from a ground-based 

transmitter/controller

- Onboard RTK corrections at 20 Hz;

- Upstream corrections at 1 Hz;
- An on-board camera capable of capturing imagery in the form of full color, high definition still photos

and video;

- Controlled by eBee RTK’s autopilot;

- Captures images automatically;

- Pilot tube that measures dynamic and static pressure, and can precisely calculate the drones air speed;

- Brushless electric motor;

- Low noise, low pollution;

- Researchable lithium-polymer battery.

The Ground Station Includes:

- A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who 

controls the UAS while in the air;

- A 2.4GHz USB radio transmitter/controller operated by the PIC to control the UAS while in flight;

- A radio receiver receiving live video and flight data from the on-board camera and computer projects it 

all together onto a screen for the PIC to view during flight;

- A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UAS while 

in flight.

Proposed Operations

Coleman Engineering intends to use UAS in two general areas. First, Coleman Engineering seeks an 

exemption to perform video filming and photographing by air for public and private use. The purpose of this

photography will be to aid in topographic mapping of ground based features on the earth. Second, it will

employ UAS’s to inspect land, residential, commercial, industrial structures and property.

Specifically, Coleman Engineering will use UAS’s that are equipped with cameras and sensors in order to 

engage in the following commercial activities:

(a) Taking photographs to support professional operations in engineering, land surveying, architecture, real 

estate and other related professional activities.

(b) Inspections by air of agricultural areas.

(c) Inspections by air of infrastructure such as bridges, highways, electrical installations, dams, aqueducts,

photovoltaic power stations, wind farms and pipes. These inspections will only be done under contract 

with the owners or with any local government authority.

(d) Inspections by air of land and residential, commercial and industrial structures, only under contract with

the owners or with any local government authority.

(e) Inspections by air to detect sources of pollution and gas emissions, under contract with the owners in the 

area or with any local government authority.

(f) Support provided to search and rescue operations and reconnaissance in cases of need, emergency or 

natural disasters and only when government authorities have requested it by contract or donation.

Relevant Statutory Authority

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA Modernization 

and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely accelerate the integration

of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform 

Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the National Air Space

("NAS") where it is safe to do so based on the following considerations:
- The UAS’s size, weight, speed and operational capability;

- Operation of the UAS in close proximity to airports and populated areas; and

- Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's safety 

regulations and minimum standards when the Administrator decides a requested exemption is in

the public interest. See 49 U.S.C. §106(f) (defining the authority of the Administrator); 49 U.S.C.

§44701(f) (permitting exemptions from §§44701(a), (b) and §§44702-44716,et seq.). A party requesting an 

exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2)

would not adversely affect safety (or how it would provide a level of safety at least equal to the existing

rules). See 14 C.F.R. §11.81 (petitions for exemption).

Coleman Engineering’s Proposed UAS Operations Meet the Requirements of Section 333 of the

Reform Act

Coleman Engineering’s proposed operations in this Petition for Exemption qualify for expedited approval 

pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are

satisfied.

Approval is Warranted Based on the UAS Size, Weight, Speed, and Operational Capability

Coleman Engineering will employ the eBee RTK for the operations specified in this Petition for

exemption. The eBee RTK UASs have a take-off weight of less than 1.61 pounds, the flight speed of 28

miles per hour, and it will not be flown in controlled airspace or at an altitude that exceeds 400 feet AGL.

All flights will be flown in such a way that they can be safely terminated with a reserve battery power of

25% of the battery's maximum charge. The eBee RTK UAS do not carry any flammable propellant or fuel.

The eBee RTK UAS also has an integrated GPS system that calculates the UAS’s position and height

and relays that information via a secure connection to the operator. 

Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations Manual

Colman Engineering’s Operations Limitations and the eBee RTK’s operators manual contain all of the 

procedures and limitations necessary to successfully perform the operations specified in this Petition for

Exemption (Appendices B & C).

Public Interest

The public interest will be served by granting Coleman Engineering’s Petition for Exemption. Congress has 

established a national policy that favors early integration of UAS’s into the NAS in controlled, safe working

environments such as those proposed in this Petition. In addition, the public also has an interest in reducing

the hazards associated with alternate methods of conducting similar operations. Currently operations are

conducted using teams that physically climb onto structures using ladders, using low flying helicopters or

aircraft, or simply not available by traditional means. By using UAS, exposure to physical hazards will be 

reduced of conducting the operation while remaining safely on the ground.

Additionally, Coleman Engineering’s intended uses for the UAS’s have identifiable safety benefits that 

include reducing the danger and emissions associated with full size helicopters. UAS have no fuel to ignite or

explode, no crew, adds a greater degree of flexibility which supplements the current capabilities offered by

manned aircraft, and public interest for a ground impact of a small lightweight UAS is further minimized 

from an ecological and safety standpoint.
Federal Register Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: Coleman Engineering seeks an exemption from the

following rules:

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c),

91.121,91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b)

The exemption will enhance safety by reducing risk to the general public and property owners from the

substantial hazards associated with performing equivalent work with conventional aircraft, rotorcraft, or

other methods.

Conclusion

Coleman Engineering’s Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform 

Act of 2012 including weight speed, operating capabilities, proximity to airports and populated areas, 

operation within visual line of sight and national security. Additionally, the Petition provides more than 

adequate justification for the grant of the requested exemptions to permit Coleman Engineering to operate the 

selected UAS for the operations specified herein.

Granting the exemption will benefit the public interest as a whole in several ways, including (1) significantly

improving safety and reducing risk by alleviating human exposure to danger, and (2) improving the quality

of services and decreasing operating costs compared with conventional flight operations.

With the advent and availability of this technology surveying and mapping functions are changing from a 

traditional ground based operations to the aerial platform. Coleman Engineering will have the ability to 

collect a tremendous amount of data in a small fraction of the time that would be needed for ground based 

efforts. As project sizes increase, the savings to both Coleman Engineering and our Clients will increase

greatly. The cost of purchasing our eBee RTK is minimum in comparison to that of a traditional manned 

aircraft. A major advantage of the low operational expenses is that Coleman Engineering can provide these

aerial acquisition services at a much lower cost to the consumer while remaining competitive and profitable. 

This will in turn lead to economic growth and stability at a local, state and federal lever.

Coleman realizes that other survey and engineering firms have already been granted an exemption to use

there UAS for commercial purposes, as shown in FAA exemption No. 11585, Docket No. FAA–2015–0442 

and FAA exemption No. 11426A, Docket No. FAA–2015–0173

With the eBee RTK’s small and lightweight design it can be assembled and deployed in a manner of only a

few minutes once the survey crews arrive on site. It will perform its mission effectively and efficiently and 

land directly at our feet. The data we collect will be able to be processed immediately. All of these factors

prove to be a huge benefit to the consumer, and help advance the land surveying profession to a whole new 

level.

Very Respectfully, 

James D. Blondheim

635 Circle Drive

Iron Mountain, MI 49801

jblondheim@coleman-engineering.com

(906) 774-3440
Appendix A
Appendix A

The regulations from which the exemption is requested are listed below. Beside each regulation number is 

the page of the attached Appendix A upon which each may be found together with our proposed equivalent 

level of safety for each regulation:

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121,

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

Exemptions Requested

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

including UASs, from its safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest.

Coleman Engineering seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 27, 45, 

61 and 91 for purposes of conducting the requested operations using a UAS. Listed below are the specific

sections of 14 C.F.R. for which exemption is sought:

14 C.F.R. Part 21, Subpart H - Airworthiness Certificates

The FAA has stated that no exemption is needed from this section if a finding is made under the Reform

Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used

for the same application. (Regulatory Docket No. FAA-2014-0352). These criteria are met, and therefore

no exemption is needed.

Equivalent Level of Safety

The UAS selected by Coleman Engineering is safe when taking into account their size, weight, speed, and

operational capability. The UAS weighs less than 1.61 pounds and will be flown at less than 35 miles per

hour and completely outside controlled airspace. Additionally, the UAS carry neither pilots nor

passengers, carry no explosive materials and or flammable liquid fuels, and operate exclusively within the

parameters stated in the Operator’s Manual and Operations Limitations.

Operations under this exemption will be closely controlled and monitored by the operator and will be 

conducted in compliance with local public safety requirements to provide security for the area of 

operation. Coleman Engineering will also, if necessary, provide the FAA with advance notice of all 

operations via NOTAMS and in coordination with the local FSDO. In all cases, the UAS operated under

the proposed conditions will be at least as safe as, or safer than, conventional rotorcraft operating with an 

airworthiness certificate without the restrictions and conditions of the proposed UAS operations.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.P.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category

rotorcraft. To the extent that Coleman Engineering UAS would otherwise require certification under Part

27, we seek an exemption from Part 27's airworthiness standards for the same reasons identified in the

request for exemption from 14 C.F.R. Part 21, Subpart H.

14 C.F.R. §§45.23(b), Display of marks; general

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

at least 2 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. The UAS does not have an entrance in 

which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by

the FAA.

Coleman Engineering proposes to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" as large as practicable on the top of the aircraft, where the PIC, VO and others in the 

vicinity of the aircraft while it is preparing for launch will be able to see the designation. Finally, the ground 

station will display a high contrast flag or banner that contains the words "Unmanned Aircraft Ground 

Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground

station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point

of origin.

In a previous Grant of Exemption, Regulatory Docket No. FAA-2014-0352, the FAA determined that 

exemption from these requirements was warranted provided that the aircraft "have identification (N-Number)

markings in accordance with 14 C.F.R part 45, Subpart C if the markings are as large as practicable."

14 CFR § 61.113 (a) and (b); 61.3 (c,2-v): Private Pilot Privileges and Limitations, Medical Certificate

In addition, Coleman Engineering seeks exemption from 14 C.F.R §61.113, which restricts private pilot 

certificate holders from flying aircraft for compensation or hire, and which would also require a second class 

medical certificate. The purpose of this section is to ensure the skill and competency of any PIC where the

aircraft is carrying passengers or cargo for hire. In this case, while the UAS will be operated as part of a

commercial operation, it carries neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. 

FAA-2014-0352, the FAA determined that the unique characteristics of UAS operation outside of controlled 

airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a

commercial pilot certificate and class II medical certificate. Additionally, instead of having a second or third

class medical, we suggest that the PIC exercise the privileges similar to that of a sport pilot, requiring only a

valid US driver’s license.

Safety Mitigation

Coleman Engineering seeks to ensure safe operation by ensuring that any PIC is thoroughly versed in 

airspace and communication issues pertaining to all aircraft operators but also in the unique aspects of UAS 

flight.

We believe the combination of aeronautical knowledge, UAS airmanship skills, and verification through 

remaining current is a sufficient method to evaluate a pilot’s qualifications, given that operations will be

conducted within the limitations outlined in this petition. Like with any required skill, the more flight time

the PIC gains, the more proficient the PIC becomes.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Coleman Engineering seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in 

airworthy condition to be operated. The FAA has stated (Regulatory Docket No. FAA-2014-0352) that no

exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft

Given its size, configuration, and load capacity, the eBee RTK has no ability to carry such a manual on the

aircraft, not only because there is no pilot on board, but because there is simply no room or capacity to carry

such an item on the aircraft.
Safety Mitigation

The safety related purpose of this manual requirement can be equally satisfied by maintaining the eBee RTK

Manual at the ground control point where the pilot flying the eBee RTK will have immediate access to it. 

Accordingly, we request an exemption from § 91.9(b) (2)'s flight manual requirements, on the condition that 

the eBee RTK flight manual be available at the point of control during each operation.

14 C.F.R. § 91.103: Preflight Action

Coleman Engineering seeks an exemption from 14 C.P.R.§ 91.103, which requires a PIC to become familiar

with specific information before each flight, including information contained in the FAA-approved Flight 

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely conduct

the flight, an exemption is requested to the extent that an FAA-approved Flight manual is required.

Safety Mitigation

An equivalent level of safety will be provided by following the Aircraft Operations Manual and flight manual 

provided by the manufacturer. The PIC will take all required preflight actions, including performing all

required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance,

aircraft performance data, and contingency landing areas before initiation of flight. The Operators Manual 

and Operational Limitations will be kept at the ground station with the operator at all times.

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

Coleman Engineering seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "no person may

operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that

aircraft has fully functioning dual controls." UAS and remotely piloted aircraft, by their design, do not have

functional dual controls. Instead, flight control is accomplished through the use of a device that 

communicates with the aircraft via radio communications.

Safety Mitigation

Given the size and speed of the UAS employed by Coleman Engineering, an equivalent level of safe training

can still be performed without dual controls because no pilot or passengers are aboard the UAS, and all 

persons will be a safe distance away in the event that the UAS encounters any difficulties during flight 

instruction. In addition, we will conduct flight training at our Research and Development test sites, which 

are located on our own property. These training flights will be conducted in a sterile area and will otherwise

comply with the provisions in the Operator’s Manual for flights at the R&D facility. The FAA has stated 

(Regulatory Docket No. FAA-2014-0352) that no exemption is required.

14 C.F.R. § 91.119: Minimum Safe Altitudes

Coleman Engineering requests an exemption from the minimum safe altitude requirements of 14 C.F.R. 

§91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in noncongested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than 

those minimum altitudes when it can be operated "without hazard to persons or property on the surface,"

provided that "each person operating the helicopter complies with any routes or altitudes specifically

prescribed for helicopter by the FAA.”

Safety Mitigation

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, 

and given the lack of flammable fuel, any risk associated with these operations is far less than those that 

presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, 

weight, and speed of the UAS, as well as the location where it is operated. In order to avoid any risk to 
aircraft, flight operations will be restricted to 400' AGL or below.

14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to 

maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure. An exemption is required to the extent that the UAS does not have 

a barometric altimeter, but rather a GPS altitude read out.

Safety Mitigation

The FAA has stated that an equivalent level of safety can be achieved if the UAS will be operated at 400'

AGL or below and within visual line-of-sight in addition to GPS based altitude information relayed in real 

time to the operator. See Grant of Exemption to Astraeus Aerial, Docket No. FAA-2014-0352. As the 

attached Operations Manual indicates, the chosen UAS meets these requirements, and a zero altitude

initiation point will be obtained prior to flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Coleman Engineering requests an exemption from 14 C.F.R. § 91.15l(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast

weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal 

cruising speed;

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight operations can be

conducted while still maintaining a 30 minute reserve. Coleman Engineering proposes that all flights comply

with this requirement by mandating that the aircraft be safely landed with no less than 25% of battery life

remaining.

Safety Mitigation

The FAA has stated that an equivalent level of safety is provided if the UAS flight is terminated with at least

25% reserve battery power still available. See Grant of Exemption to Astraeus Aerial, Docket No. PAA2014-0352. The Operations Manual conforms to this limit, providing an equivalent level of safety.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft 

and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the

airworthiness certificate be "displayed at the cabin or cockpit entrance so it is legible to passengers or crew."

At a maximum gross weight of less than 1.61 pounds, the UAS is too small to carry documentation, does not 

have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety

and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA

will be co-located with the crew at the ground control station and available for inspection upon request. The

FAA has stated (Regulatory Docket No. FAA-2014-0352) that no exemption is required.
14 C.F.R. 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) Maintenance Required

Coleman Engineering seeks an exemption from the maintenance inspection requirements contained in 14 

C.P.R.§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and 

inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.P.R. §91.405(a) (stating that each 

owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). 

An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with 

an airworthiness certificate, which the UAS’s will not have.

Safety Mitigation

An equivalent level of safety will be achieved because maintenance and inspections will be performed in

accordance with the Operators Manual. As provided in the Operators Manual, flights will not be conducted 

unless a flight operations checklist is performed that includes all of the aircraft's components.
Appendix B
The survey-grade 

mapping drone

3 reasons to 

choose 

the eBee RTK

01. Survey-grade accuracy

Absolute orthomosaic / Digital Elevation Model accuracy of down to 3 cm 

(1.2 in) without the need for GCPs – meaning less time spent in the field 

and high precision in even the most inaccessible areas.

02. Fully integrated workflow

The eBee RTK’s supplied flight planning & control software (eMotion) 

connects to the base station and broadcasts correction data to the rover 

(eBee RTK) – no additional logger or third-party software required.

03. Compatible with existing base stations

The eBee RTK is compatible with most leading brands of base station, 

working seamlessly alongside your existing portfolio of instruments.
Out of the box and ready to fly

The eBee RTK is supplied in its own carryon sized case, which contains all the 

components you need to take to the skies. 

This includes download keys for our eMotion 

flight planning software and Postflight Terra 

3D photogrammetry software.

To launch the eBee RTK, simply attach 

its wings, shake it three times to start its 

motor, and throw it into the air! The artificial 

intelligence built into the senseFly autopilot 

continuously analyzes data from the Inertial 

Measurement Unit and the onboard GPS to 

control every aspect of its flight.
Super lightweight

• Durable EPP foam body & wings

• Take-off weight: 0.73 kg (1.61 lbs)

16 MP still camera

• Controlled by eBee RTK’s autopilot

• Captures images autonomously

• GSD of down to 1.5 cm per pixel

Built-in GNSS/RTK receiver

• L1/L2, GPS & GLONASS

• Onboard RTK corrections at 20 Hz

• Upstream corrections at 1 Hz

GNSS antenna

• Receives corrections from most leading

 brands of base station

• Absolute X,Y/Z accuracy down to 3 cm / 5 cm

• No Ground Control Points necessary

Pitot tube

• Measures dynamic & static pressure

• Precisely calculates the drone’s air speed

Inherently safe

• Shock absorbent foam + low weight 

 = low impact energy

• Minimal danger to people & property

Green technology

• Brushless electric motor

• Low noise, low pollution

• Re-chargeable lithium-polymer 

battery 
3 ways of working with the eBee RTK

The eBee RTK is a highly flexible system. It can 

be used in either of three ways, depending on 

how you prefer to work and your access to incountry correction data networks.

Whichever method you choose, no additional 

base station purchase is necessary since the 

eBee RTK is compatible with most leading 

brands of survey-focused base station.
· Place your base station on a known position

· Enter the base station’s coordinates and 

characteristics into eMotion

· eMotion streams correction data to the 

drone via the ground modem

· Position your base station in a convenient 

location

· eMotion calculates your base’s approximate 

position

· eMotion streams correction data to the 

drone via the ground modem

· Correct your base’s position in postprocessing to achieve a high level of 

absolute accuracy

· Configure your drone’s eMotion software to 

receive VRS/NTRIP correction data (internet 

connection and VRS/NTRIP subscription 

required)

· eMotion streams correction data to the 

drone via the ground modem

01 Local base, known position

02 Local base, unknown position

03 Virtual reference station

GNSS/RTK base station 

on known position

Operator

Laptop/tablet

with USB

ground modem

eBee RTK

GNSS/RTK base station 

on unknown position

Operator

Laptop/tablet

with USB

ground modem

eBee RTK

www

Operator

Laptop/tablet

with USB

ground modem

eBee RTK
Plan & control your flight

senseFly’s intuitive eMotion software makes 

it easy to plan and simulate your mapping 

mission.

Plan: Import your preferred base map and 

define the area you want to cover. Then 

specify your required ground resolution (with 

a GSD of down to 1.5 cm), and image overlap. 

eMotion automatically generates a full flight 

plan, calculating the eBee RTK’s required 

altitude and displaying its projec ted 

trajectory.

Configure: If you know your base station’s 

coordinates, enter these into eMotion. 

If not, eMotion will calculate your base’s 

approximate position. Or you can configure 

eMotion to receive VRS/NTRIP corrections.

eMotion then streams correction data to 

the eBee RTK via the senseFly USB ground 

modem.

Simulate: To ensure your mission’s success, 

run a virtual flight that simulates wind 

strength and direction. Then make any flight 

plan updates required and prepare to launch.
Create geo-referenced maps & models 

Process: Use Postflight Terra 3D professional 

photogrammetry software, supplied with 

every eBee RTK, to process your flight’s 

photos into geo-referenced 2D orthomosaics, 

3D point clouds, triangle models and Digital 

Elevation Models (DEMs), in just a few clicks.

Trust: With the eBee RTK’s GSD of down to 1.5 

cm, relative orthomosaic/3D model accuracy 

of 1-3x GSD, and absolute horizontal/vertical 

accuracy of down to 3/5 cm (without GCPs), 

you can have full confidence in the accuracy 

of the outputs you produce.
Technical specifications

Weight (inc. supplied camera)

Wingspan

Material

Propulsion

GNSS/RTK receiver

Battery

Camera (supplied)

Carry case dimensions

Hardware

Operation

Approx. 0.73 kg (1.61 lb) 

96 cm (38 in)

EPP foam, carbon structure & composite parts

Electric pusher propeller, 160 W brushless DC motor

L1/L2, GPS & GLONASS

11.1 V, 2150 mAh

16 MP IXUS/ELPH

55 x 45 x 25 cm (21.6 x 17.7 x 9.8 in)

40 minutes 

40-90 km/h (11-25 m/s or 25-56 mph) 

Up to 3 km (1.86 miles) 

8 km2

 / 3 mi2 (at 974 m / 3,195 ft altitude AGL)

Up to 45 km/h (12m/s or 28 mph)

Down to 1.5 cm (0.6 in) per pixel

1-3x GSD

Down to 3 cm (1.2 in) / 5 cm (2 in)

Yes (inc. mid-air collision avoidance) 

Yes

Approx. 5 m (16.4 ft)

Maximum flight time

Nominal cruise speed

Radio link range

Maximum coverage (single flight)

Wind resistance

Ground Sampling Distance (GSD)

Relative orthomosaic/3D model accuracy

Absolute horizontal/vertical accuracy (no GCPs)

Multi-drone operation

Automatic 3D flight planning

Linear landing accuracy

Package contents

• eBee RTK foam body (inc. all electronics & built-in autopilot) 

• Pair of detachable wings 

• 16 MP IXUS/ELPH still camera (inc. 16 GB SD card, battery, USB 

cable & charger) 

• GNSS antenna

• 2.4 GHz USB radio modem for data link (inc. USB cable) 

• Two Lithium-Polymer battery packs & charger

• Spare propeller

• Carry case with foam protection 

• Remote control & accessories (for safety pilots)

• User manual 

• Software included: eMotion (flight planning & control) & 

Postflight Terra 3D (professional photogrammetry)
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Content and images non contractual © 2014 senseFly Ltd

Where can you buy your eBee RTK? Visit www.sensefly.com/about/where-to-buy to locate 

your nearest distributor.

senseFly Ltd

Route de Genève 38

1033 Cheseaux-Lausanne

Switzerland 

Swiss made

About senseFly: senseFly designs, assembles and markets autonomous mini-drones and 

related software solutions for civil professional applications such as precision agriculture, land 

surveying, GIS, construction, environmental conservation and more. 
EN

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www.sensefly.com
ANNEX B
Academy of Model Aeronautics National Model Aircraft Safety Code

Effective January 1, 2014 

A. GENERAL: A model aircraft is a non-human-carrying aircraft capable of sustained flight in the atmosphere. It may not exceed limitations of this code and is 

intended exclusively for sport, recreation, education and/or competition. All model flights must be conducted in accordance with this safety code and any 

additional rules specific to the flying site. 

1. Model aircraft will not be flown: 

(a) In a careless or reckless manner. 

(b) At a location where model aircraft activities are prohibited. 

2. Model aircraft pilots will: 

(a) Yield the right of way to all human-carrying aircraft. 

(b) See and avoid all aircraft and a spotter must be used when appropriate. (AMA Document #540-D.) 

(c) Not fly higher than approximately 400 feet above ground level within three (3) miles of an airport without notifying the airport operator. 

(d) Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed use agreement. 

(e) Not exceed a takeoff weight, including fuel, of 55 pounds unless in compliance with the AMA Large Model Airplane program. (AMA Document 520-A.) 

(f) Ensure the aircraft is identified with the name and address or AMA number of the owner on the inside or affixed to the outside of the model aircraft. (This 

does not apply to model aircraft flown indoors.) 

(g) Not operate aircraft with metal-blade propellers or with gaseous boosts except for helicopters operated under the provisions of AMA Document #555. 

(h) Not operate model aircraft while under the influence of alcohol or while using any drug that could adversely affect the pilot’s ability to safely control the 

model. 

(i) Not operate model aircraft carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a 

hazard to persons or property. 

Exceptions: 

 Free Flight fuses or devices that burn producing smoke and are securely attached to the model aircraft during flight. 

 Rocket motors (using solid propellant) up to a G-series size may be used provided they remain attached to the model during flight. Model rockets may 

be flown in accordance with the National Model Rocketry Safety Code but may not be launched from model aircraft. 

 Officially designated AMA Air Show Teams (AST) are authorized to use devices and practices as defined within the Team AMA Program Document. 

(AMA Document #718.) 

(j) Not operate a turbine-powered aircraft, unless in compliance with the AMA turbine regulations. (AMA Document #510-A.) 

3. Model aircraft will not be flown in AMA sanctioned events, air shows or model demonstrations unless: 

(a) The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event. 

(b) An inexperienced pilot is assisted by an experienced pilot. 

4. When and where required by rule, helmets must be properly worn and fastened. They must be OSHA, DOT, ANSI, SNELL or NOCSAE approved or comply 

with comparable standards. 

B. RADIO CONTROL (RC)

1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others. 

2. A successful radio equipment ground-range check in accordance with manufacturer’s recommendations will be completed before the first flight of a new or 

repaired model aircraft. 

3. At all flying sites a safety line(s) must be established in front of which all flying takes place. (AMA Document #706.) 

(a) Only personnel associated with flying the model aircraft are allowed at or in front of the safety line. 

(b) At air shows or demonstrations, a straight safety line must be established. 

(c) An area away from the safety line must be maintained for spectators. 

(d) Intentional flying behind the safety line is prohibited. 

4. RC model aircraft must use the radio-control frequencies currently allowed by the Federal Communications Commission (FCC). Only individuals properly 

licensed by the FCC are authorized to operate equipment on Amateur Band frequencies. 

5. RC model aircraft will not knowingly operate within three (3) miles of any pre-existing flying site without a frequency-management agreement. (AMA 

Documents #922 and #923.) 

6. With the exception of events flown under official AMA Competition Regulations, excluding takeoff and landing, no powered model may be flown outdoors 

closer than 25 feet to any individual, except for the pilot and the pilot's helper(s) located at the flightline. 

7. Under no circumstances may a pilot or other person touch an outdoor model aircraft in flight while it is still under power, except to divert it from striking an 

individual. 

8. RC night flying requires a lighting system providing the pilot with a clear view of the model’s attitude and orientation at all times. Hand-held illumination 

systems are inadequate for night flying operations. 

9. The pilot of an RC model aircraft shall: 

(a) Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot. 

(b) Fly using the assistance of a camera or First-Person View (FPV) only in accordance with the procedures outlined in AMA Document #550. 

(c) Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document #560. 

C. FREE FLIGHT 

1. Must be at least 100 feet downwind of spectators and automobile parking when the model aircraft is launched. 

2. Launch area must be clear of all individuals except mechanics, officials, and other fliers. 

3. An effective device will be used to extinguish any fuse on the model aircraft after the fuse has completed its function. 

D. CONTROL LINE 

1. The complete control system (including the safety thong where applicable) must have an inspection and pull test prior to flying. 

2. The pull test will be in accordance with the current Competition Regulations for the applicable model aircraft category. 

3. Model aircraft not fitting a specific category shall use those pull-test requirements as indicated for Control Line Precision Aerobatics. 

4. The flying area must be clear of all utility wires or poles and a model aircraft will not be flown closer than 50 feet to any above-ground electric utility lines. 

5. The flying area must be clear of all nonessential participants and spectators before the engine is started.
Appendix C
Appendix C

Operational Limitations

1. The unmanned aircraft system (UAS) will weigh 1.61 pounds, including energy source(s) and equipment.

2. The UAS will fly at around 28 MPH.

3. Flights will be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the

procedures specified in the operator’s manual. All altitudes reported to ATC must be in feet AGL.

4. The UAS will 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.

5. All operations will utilize a visual observer (VO). 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.

6. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. 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. The

Ground Control Station, if utilized, will be included in the preflight inspection. All maintenance and alterations 

will be properly documented in the aircraft records.

7. If the UAS has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. 

replacement of a flight critical component, the UAS will undergo a functional test flight in accordance with the

operator’s manual. The PIC who conducts the functional test flight will make an entry in the UAS aircraft 

records of the flight. The requirements and procedures for a functional test flight and aircraft record entry will be

added to the operator’s manual.

8. The operator will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, 

replacement, and inspection/maintenance requirements will be established and identified in the operator’s

manual. At a minimum, requirements for the following will be included in the operator’s manual:

a. Actuators / Servos;

b. Transmission (single rotor);

c. Powerplant (motors);

d. Propellers;

e. Electronic speed controller;

f. Batteries;

g. Mechanical dynamic components (single rotor);

h. Remote command and control;

i. Ground control station (if used); and

j. Any other components as determined by the operator.

9. The Pilot In Command (PIC) will possess at least a valid U.S. driver’s license.

10. Prior to operations the PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a

minimum of five hours as UAS pilot operating of the make and model of UAS to be utilized for operations and 

three take-offs and three landings in the preceding 90 days. Training, proficiency, experience-building, and takeoff and landing currency flights can be conducted to accomplish the required flight cycles and flight time.

11. The UAS may not be operated directly over any person, except authorized and consenting personnel,

below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or
emergency.

12. The operator will ensure that no persons are allowed within 500 feet of the area except those consenting. This

provision may be reduced to no less than 200 feet if it would not adversely affect safety.

13. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the

Operator’s Manual.

14. Each UAS operation will be completed within 30 minutes flight time or with 25% battery power remaining, 

whichever occurs first.

15. The operator will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization 

(COA) prior to conducting any operations. This COA will also require the operator to request a Notice to 

Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

16. All aircraft operated in accordance will be identified by serial number, registered in accordance with 14 CFR

part 47, and have identification (N- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings 

must be as large as practicable.

17. Each UAS operated will comply with all manufacturer Safety Bulletins.

18. The radio frequency spectrum used for operation and control of the UA will comply with the Federal 

Communications Commission (FCC) or other appropriate government oversight agency requirements.

19. At least three days before scheduled flight, the operator will submit a written Plan of Activities to the local 

FSDO with jurisdiction over the area of proposed flight area. The 3- day notification may be waived with the

concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator

c. Make, model, and serial or N-number of UAS to be used;

d. Name and certificate number of UAS PIC involved

e. A statement that the operator has obtained permission from property owners and/or local officials to conduct

the flight operations; the list of those who gave permission must be made available to the inspector upon 

request;

f. Signature of exemption-holder or representative; and

g. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state

over which flights will be conducted and the altitudes essential to accomplish the operation.

20. The documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control 

Station of the UAS any time the aircraft is operating.

21. The UA will remain clear and yield the right of way to all other manned operations and activities at all times 

(including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

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

under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not

authorized.

23. The UAS will not be operated by the PIC from any moving device or vehicle.

24. The UAS will 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.
25. The UAS will not operate in Class A, B, C, or D airspace without written approval from the FAA. The UAS

may not operate within 5 nautical miles of the geographic center of a non-towered airport as denoted on a

current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The

letter of agreement with the airport management must be made available to the Administrator upon request.

26. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational 

area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office (AFS-80) within 

24 hours.