725 W TOWN & COUNTRY RD., SUITE 300 · ORANGE, CA 92868 · TEL (714) 835-6355 · FAX (714) 835-6671 May 21, 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 Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, J.L. Patterson & Associates, Inc. (“JLP” ), an operator of the eBee Unmanned Aircraft System (“eBee”) manufactured by SenseFly SA of Switzer land, seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below:

 14 C.F.R. 21, Subpart H

 14 C.F.R. 45.23

 14 C.F.R. 45.29

 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) & 91.319 (a) (1)

 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(a) & (b)

 14 CFR Subpart E (91.401 - 91.417)

The requested exemption would authorize commercial operations using the eBee for mapping and survey support applications of railroad corridors. These operat ions will be subject to strict operating requirements defined in the eBee user manual (JLP requests the FAA treat the eBee training program, user manual, maintenance manual & risk assessment as p roprietary under 14 C.F.R. 11.35(b) and does not include this document in the public docke t) 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.

The aircraft carries an onboard geo-referenced still camera tha t allows it to conduct precision photogrammetry at the resolution necessary for highly accurate topographic mapping. The resulting data is used to improve efficiencies in engineering efforts related to accurately planning, designing and constructing railroad infrastructure for both private railr oads and rail transit agencies and port
authorities alike.

Our firm also serves as first responders involving railroad inc idents for several private and public railroad owners and agencies. As such it is common for our orga nization to be called upon to survey, record and analyze the aftermath when railroad incidents occur, deployment of the eBee for emergency response documentation and analysis of accident sites greatly enhances the speed and safety of personnel performing the field recon work in addition to protecting the integrity of the accident site during the early stages of the investigation.725 W TOWN & COUNTRY RD., SUITE 300 · ORANGE, CA 92868 · TEL (714) 835-6355 · FAX (714) 835-6671 In the examples above, use of an airborne survey vehicle specif ically prevents the need of personnel to enter dangerous areas of an operating railroad which is subj ect to strict FRA rules under 49 CFR Part 214, Subpart C - Roadway Worker Protection. By approving t hese exemptions, the FAA will create benefits to both public agencies and private railroads which are ultimately in the public
interest.

The eBee will be operated in the field with both a Pilot in Com mand (PIC) and a ground-based Visual Observer (VO) in accordance with FAA Policy N 8900.227 S ection 14 "Operational Requirements for UAS" with the following additional restriction s:

 All operations will occur in Class G airspace at no more than 4 00 ft. above ground level (AGL).

 Operations will occur over railroad properties with the permiss ion of the owner.

 All required permits will be obtained from state and local government prior to operation.

 The aircraft will not be operated at air shows or over an open-air assembly of people.

 Operations will be limited to daytime and visual meteorological conditions (VFR flight rules) by an individual who fulfill the following requirements:

o Aircraft will remain within Visual Line of Sight (VLOS) at no g reater than 1/2NM
from the PIC at all times

o While the aircraft is airborne, the VO will be positioned withi n voice and/or radio
distance from the PIC.

o Has successfully passed a manufacturer’s training program, for the eBee; JLP 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 docke t;

o Has a Private Pilot license.

 The PIC and VO will meet the re quirements outlined in FAA Policy N 8900.227 Section 16 Personnel Qualifications. Additionally, the PIC and VO will per form maintenance on the system and will complete a course of maintenance instruction as part of their initial training from the manufacturer. Due to the simplicity of the system, we do not anticipate the need for a supplemental pilot.

When performing UAS mapping operations on active railroad right s-of-way, the PIC and VO will be under the jurisdiction of the Federal Railroad Administratio n (FRA). In compliance with 49 CFR Part 214, Subpart C - Roadway Worker Protection, any personnel whose duties require that they enter an active/operating railroad property, must obtain an ini tial 40 hours of owner approved safety training and an 8 hour annual refresher course. It is JLP polic y that the operator of our UAS must carry evidence of compliance with 49 CFR Part 214, Subpart C - Roadway Worker Protection whether entering railroad right-of-way or not, in the form of a n approved ID detailing the time and date of the conforming training. While FRA regulations do not a pply to the National Airspace System (NAS), we feel these added safety regulations further en hance our awareness and intent to operate a UAS with the utmost care, attention to safety both under FRA and FAA regulations and enhance the safety of our UAS operation overall. Furthermore, t he use of a UAS will help reduce and in many cases eliminate the need for personnel to enter hazardous and dangerous operating railroad right-of-way to measure and collect topographic data. Use of a UAS can help prevent injuryand the loss of life where personnel duties require them to otherwise enter operating railroad rightsof-way.725 W TOWN & COUNTRY RD., SUITE 300 · ORANGE, CA 92868 · TEL (714) 835-6355 · FAX (714) 835-6671 1. CHARACTERISTICS OF THE AIRCRAFT

The eBee is a small (37.8 inches wingspan) and ultra-light (max imum take-off weight of 1.7 pounds) platform made of flexible foam that performs pre-progra mmed precision aerial mapping missions thanks to the on-board GPS and the related flight mana gement 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, th e eBee takes a collection of highdefinition still images that are used later to generate maps an d 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) als o significantly reduces the ri sk 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 mak es 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 all ows 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 emergent circumstances, thanks to the remote controller provide d with the system.

2. APPLICATIONS

The intended applications are specifically for aerial mapping of railroad corridors that are heavily industrial in nature and away from the general public to suppor t:

 Emergency Response Documentation and or Analysis

 Planning, designing and constructing railroad infrastructure.725 W TOWN & COUNTRY RD., SUITE 300 · ORANGE, CA 92868 · TEL (714) 835-6355 · FAX (714) 835-6671 3. APPLICABLE LEGAL STA NDARD UNDER SECTION 333

a. Airworthiness assessment of the eBee

JLP notes that the airworthiness of the eBee has already been d emonstrated for different projects in the United States, involving state/federal agencies or universi ties (among others the New Mexico State University: https://newscenter.nmsu.edu/Articles/view/10208/nmsu-uas-flight -test-centerconducts-ebee-airworthiness-assessment , and the USACE New Orleans, who coordinated with the Department of Army and the FAA to obtain all authorizations req uired in order to operate the eBee UAS).

Moreover, SenseFly obtained flight approvals for the eBee (deli vered by national civil aviation authorities) in many countries, among others:

 Switzerland (flight approval for VLOS operations)

 Canada (flight approval for VLOS operations)

 Australia (flight approva l for VLOS operations)

 France (flight approval for Extended-VLOS operations)

 Germany (flight approval for VLOS operations)

 United Kingdom (flight appr oval for VLOS operations)

 Norway (flight approval for VLOS operations)

 Sweden (flight approval for VLOS operations)

 Denmark (flight approval for VLOS operations)

b. Operating requirements

Grant of the exemption to JLP for the eBee will be subject to t he following operating conditions, based on the operating conditions set forth by the Academy of M odel Aeronautics (see Annex B).
The main restrictions are summarized below:

 Operations to be conducted over private, controlled-access, or public property where approved;

 Permission from the land owner/a uthority required before commen cing any flight;

 Operations over congested areas shall be avoided;

 Operations must not interfere with manned aircraft operations, must yield the right of way to manned aircraft, and operators must See & Avoid other aircra ft and obstacles at all times

 Operations limited to Visual Flight Rules Meteorological Condit ions (VMC) and daylight
hours

 Aircraft operations must remain within Visual Line of Sight (VL OS) and will be visually monitored at all times;

 VLOS guaranteed with a GPS geo-f ence around operator of 0.5 mil es

 Flight ceiling pre-programed at 400 feet;

 All operations conducted within 5 miles from an airport shall o nly be initiated after verbal coordination with the airport authority, or air traffic control when a control tower is present at the airport;725 W TOWN & COUNTRY RD., SUITE 300 · ORANGE, CA 92868 · TEL (714) 835-6355 · FAX (714) 835-6671  All operations shall comply with required permissions and permits established by territorial, state, county or city jurisdictions; including local law enforc ement, fire, or other appropriate governmental agencies.

 The eBee operations will be comp liant with existing safety proc edures inherent to the activities of the related company.

c. Operator Requirements

The eBee operator will have a Private Pilot license and will su ccessfully have passed a manufacturer’s training program for the eBee.

3. CONCLUSION

We submit that the combination of the aircraft's light weight, historically demonstrated flight performance, qualified flight crew and strict operation under the guidelines established in 8900.227, the FAA can have confidence that the operation will have an equ ivalent or greater level of safety to manned aircraft performing the same mission.

The name and contact information of the applicant are:

J.L. Patterson & Associates, Inc.

Attn: Marc Cañas Vice President, GIS Professional Phone: (714) 835-6355 ext: 217 Fax: (714) 835-6671
Email: macanas@jlpatterson.com J.L. Patterson & Associates, Inc. Jacqueline L. Patterson, PE President, Principal Engineer Phone: (714) 835-6355 ext: 219

Fax: (714) 835-6671
Email: jlpatterson@jlpatterson.com

Sincerely, J.L. Patterson & Associates, Inc.

Jacqueline L. Patterson, P.E.
President

Appendices:

A. Exemption Request and Equivalent Level of Safety B. Academy of Model Aeronautics Safety Requirements C. Privacy Issues D. Safety CaseAPPENDIX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

JLP requests an exemption from the following regulations as wel l as any additional regulations that may technically apply to the operation of the eBee:

14 C.F.R. Part 21, Subpart H: Air worthiness Certificates 14 CFR § 91.203(a)(1)

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 limi ted operating area associated with its utilization, it is unnecessary to go through the certificat e 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, ope rational capability, and proximity to airports and populated areas of the UAS involved. An analysis of t hese different criteria demon strates that the eBee operated without an airworthiness certificate, under the conditions prop osed in that exemption, will be at least as safe, or safer, than a conventional aircraft with an a irworthiness certificate. A proprietary risk assessment for operations with the eBee, which demonstrate s that assertion, is also being submitted to the FAA as part of this application. JLP requests the FAA treat the eBee risk assessment as proprietary under 14 C.F.R. 11.35(b) and not incl ude this document in the public
docket.

14 C.F.R. § 45.23 & 14 C.F.R. § 45. 29: Display of marks; size o f marks

These regulations provide that each aircraft must display "N" a nd 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 entra nce to the cabin, cockpit, or pilot
station.

Given the size of the eBee (wingspan of 37.8 inches), this requ irement is impossible to match.

14 C.F.R. § 61.3: Requirements for certificates, ratings and au thorizations 14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileg es 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 authorizat ion 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 ope rated 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 incommand of an aircraft for co mpensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraf t in connection with any business or employment if:

(1) The flight is only incidental to that business or employmen t; (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 mis sions are pre-programmed and monitored in real-time with a specific flight management softwa re (eMotion), SenseFly proposes that operators of the eBee should not be required to hold a com mercial pilot certification. Instead, operators should be required to:

Have a private pilot license and have successfully passed a manufacturer’s training program for the

eBee.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness

This regulation requires that no person may operate a civil air craft 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 airwor thiness of the eBee. Given the size of the aircraft and the previous airworthiness assessments given t o the eBee, among others:

 New Mexico State University: https://newscenter.nmsu.edu/Articles/view/10208/nmsuuas-flight-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 constr uction progress, and extensive oblique photography of
USACE structures & activities

An equivalent level of safety will be achieved by insuring compliance with the SenseFly manuals prior to each flight.

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

This regulation provides that no person may operate an aircraft unless a current, approved flight
manual is in the aircraft. JLP assumes that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. JLP requests an exemption to this requirement since the aircraft is not only to o small to carry documentation, the
documentation would not be available to the crew.

The equivalent level of safety will be achieved by keeping a ha rd copy of the flight manual in the eBee transportation box.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

The regulation provides that "No person may operate a civil air craft that is being used for flight
instruction unless that aircraf t has fully functioning dual con trols."

Flight instruction will be accomplished through an elaborated t raining program, using first the simulation mode of the flight management software eMotion. The equivalent level of safety during the training will be achieved by the manufacturer or authorized distributor providing the trainingand through the use of experienced and qualified operators familiar with the eBee. 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. Sin ce the aircraft will be operating at a maximum of 400 feet AGL, the eBe e cannot comply with this requi rement.

The equivalent level of safety will be achieved because the eBe e 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 f light area will be briefed of the expected route of flight and the associated risks to persons an d property on the ground. Due to the
small size of the eBee and the material with which the eBee is built, the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft a nd should be considered in granting the exemption.

Moreover, the aircraft will not be operated over congested area s nor over any open-air assembly of persons. The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surf ace.

14 CFR 91.121 – Altimeter settings

This section requires that each person operating an aircraft sh all 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 r oute 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 eleva tion of the departure airport or an appropriate altimeter setting available before departure.

To provide an equivalent level of safety, the eBee autopilot ca lculates the reference altitude (ground level) with the on-board GPS during the pre-flight tests. The G PS and barometer data are merged with respect to their respective precisions. The GPS provides r eliable information to correct potential barometric bias, while rapid variations in altitude a re detected through the barometer. Hence, barometric bias induced by environmental factors is reje cted.

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

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 intend ed landing and to fly after that for at least
30 minutes.

Given the area of operation for the eBee, JLP believes that an equivalent level of safety is already achieved with the specific procedure preventing the eBee to acc ept 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): Car rying Civil Aircraft Certific ation and Registration

This regulation provides as follows:

 No person may operate a civil aircraft unless it has an appropr iate 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 cockp it entrance so that it is legibl e to passengers or crew.

The eBee weighs only 1.7 pounds (max take-off weight). As such, there is no ability or place to carry certification and registration documents or to display th em on the UAS. In addition, there is no pilot or passengers on board the aircraft.

To obtain an equivalent level of safety and meet the intent of 91.203, JLP propose that documents deemed appropriate for this aircraft by the FAA will be co-loca ted with the operator at the ground control station in the eBee box and available for inspection upon request

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Ma intenance, and

Alterations

The regulation provides that the operator is primarily responsi ble for maintaining the aircraft in an airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. Section 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the ow ner 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 airc raft for return to service.

JLP proposes that the maintenance of the eBee will be accomplis hed by the owner/operator according to the maintenance manual, provided by SenseFly. JLP requests the FAA treat the eBee training program as proprieta ry under 14 C.F.R. 11.35(b) and no t include this document in the public docket.

An equivalent level of safety will be achieved because the eBee is small in size, it is not a complex mechanical device, it will carry no external payload, and it wi ll operate only in restricted predetermined areas. 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, th e eBee runs automatically a seq uence of pre-flight tests to make sure that every sensor and every c ritical part is running 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 the flight management software. The operator can then refer to the maintenance manual to troubleshoot this issue. Several parts of the eBee are easily i nterchangeable (propellers, wings), which allows the operator to make sure the wings and propulsion system are always airworthy when
a mission is initiated.APPENDIX B: ACADEMY OF MODEL AE RONAUTICS SAFETY REQUIREMENTS

### Academy of Model Aeronautics Na tional Model Airc raft 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 limitation s 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 ai rport 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 outs ide 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 provision s 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 pi lot’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 d rops 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 flig ht. 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 Progr am 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 app roved 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 Compet ition 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, exc ept 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 presc ribed for the pilot. (b) Fly using the assistance of a camera or First-Person View (F PV) 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 fly ing. 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 Precisio n 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 a ny above-ground electric utility lines. 5. The flying area must be clear of all nonessential participants and spectators before the engine is started.Academy of Model Aeronautics 5161 East Memorial Drive Muncie, Indiana 47302 (800) 435- 9262 | Membership Services | www. modelaircraft.org 

## Academy of Model Aeronautics

5161 East Memorial Drive Muncie, Indiana 47302 (800) 435

- 9262
– Membership Services

www. modelaircraft.org



# “SEE	AND	AVOID”	GUIDANCE

A.	General:

1.	The	primary	means	to	avoid	collisions	between	all	aircraft	flying	within	our	National	Airspace	System
(NAS)	is	“See	and	Avoid.”

2. Vigilance	must	be	maintained	by	each	person	operating	an	aircraft	(whether	model	or	manned)	so	as	to

“see	and	avoid”	other	aircraft.

3.	Model	aircraft	must	avoid	manned	aircraft.	Our	privilege	to	fly	model	aircraft	in	the	NAS	depends	on	our

commitment	to	remain	“well	clear”	of	manned	aircraft.

4.	Simply	avoiding	an	actual	collision	is	not	enough.	A	“near	miss”	is	not	acceptable.

5.	Unless	flying	at	a	mixed-use	site	where	manned	and	model	aircraft	routinely	share	airspace	through

their	own	site- specific rules,	model	aircraft	must	fly	sufficiently	far	away	from	manned	aircraft	so	as	not	to

create	a	collision	hazard.

6.	Model	aircraft	flying	must	not	only	be	safe,	it	must	be	perceived	to	be	safe	by	the	greater	manned
aviation	community.	Modelers	must	continually	demonstrate	their	respect	for	the	safety	of	manned
aircraft	by	remaining	vigilant	and	well	clear.

7.	Whenever	a	potential	conflict	arises	between	model	aircraft	and	manned	aircraft,	the	pilot	of	the	model
aircraft	must	always	give	way	to	the	manned	aircraft.

8.	The	pilot	of	a	model	aircraft	must	never	assume	the	pilot	of	a	manned	aircraft	can	see	the=	model	or	will
perform	any	maneuver	to	avoid	the	model’s	flight	path.

9.	Visual	Line	of	Sight	is	required	by	the	Safety	Code.	It	means	that	visual	contact	with	the	aircraft	must	be
maintained	without	enhancement	other	than	by	corrective	lenses	prescribed	for	the	model	aircraft	pilot.
All	RC	flying	must	remain	clear	of	clouds	smoke	or	any	other	obstruction	to	the	line	of	sight.

10. “ Blue	Sky ” is	a	term	used	to	explain	the	method	used	to	increase	separation	between	a	model	and	a
manned	aircraft	in	the	same	vicinity.	The	modeler	should	maneuver	the	aircraft	in	such	a	way	as	to
increase	the	amount	of	blue	sky	perceived	between	the	model	and	the	manned	aircraft.	By	increasing	the
blue	sky	separation,	the	question	about	depth	perception	is	taken	out	of	the	equation	and	the	modeler
need	not	worry	whether	the	model	is	closer	to	him	than	the	manned	aircraft	or	further	away.	Increasing
the	blue	sky	between	the	model	and	the	manned	aircraft	automatically	increases	separation	between

them.Academy of Model Aeronautics 5161 East Memorial Drive Muncie, Indiana 47302 (800) 435- 9262 | Membership Services | www. modelaircraft.org 

## Academy of Model Aeronautics

5161 East Memorial Drive Muncie, Indiana 47302 (800) 435

- 9262
– Membership Services

www. modelaircraft.org

11.	A	modeler	should	never	place	any	consideration	for	the	well-being	of	the	model	aircraft	above	the
safety	of	manned	aircraft.	Maneuvering	to	avoid	the	conflict	may	require	that	the	model	aircraft	be

sacrificed.

12.	Free	flight	models	should	not	be	launched	with	relatively	low	altitude	manned
aircraft	in	sight	and	downwind	or	headed	downwind	from	the	launch	site.



## B.	Spotters:

1.	Before	a	flight,	the	pilot	must	insure	that	the	spotter	understands	his/her	duties
and	expectations.

2.	A	spotter	should	be	used	to	assist	in	monitoring	the	surrounding	airspace	for	manned	aircraft	whenever
a	flight	is	expected	to	exceed	400	feet	above	the	ground	and	that	operation	is	expected	to	be	in	proximity
to	known	manned	aircraft	traffic	such	as	at	a	mixed-use	facility	or	within	three	miles	of	an	airport.	The
spotter	must	have	sufficient	visual	acuity	and	be	mature	enough	to	take	this	responsibility	very seriously.

3.	A	spotter	should	also	be	prepared	to	assist	his/her	pilot	in	the	event	that	another	model	aircraft	or
spectators	become	endangered	or	in	turn	are	perceived	to	be	a	danger	to	the	pilot	or	the	pilot’s	model

aircraft.

4.	If	a	model	aircraft	pilot	experiences	what	he	or	she	considers	a	near	miss	with	a	manned	aircraft,	that
model	aircraft	pilot	should	notify	AMA	Headquarters	with	a	written	report	of	the	incident,	including	action
taken	by	the	model	aircraft	pilot	to	avoid	the	manned	aircraft.	This	report	is	intended	to	help	the	modeler,
the	club,	and	the	AMA	capture	as	much	detail	as	possible	so	that	it	may	be	used	to	assist	all	parties	in
recalling	the	particulars	of	the	incident	at	a	later	time.	Call	1- 800

- 435

- 9262 (1

- 800 -IFLYAMA)	extension	230

or	251	for assistance	with	this	report.PAGE 1 OF 3 (Revision 01/14/2013 ) AM A Document # 56 0


### Acade my of Model Aer onautics

AMA Ad va n ce d Flight S ys t em s Co mmit te e amaflights y st e ms@ g mail.com

Ra di o Controlled Model A ircraft Operation
Utilizing Fail s afe, Stabilization and A utopilot S y stems

1

. DEFINITION OF TERMS:

Please refer to Page 3, section 7 w hich con tai ns an alphabetical list ing of the d e finitions of the

terms in italics that are used in this docu m ent.

2 . G ENER A L:

All model aircraft fligh t s utili z ing stabilization and autopilot cont r ol s y stems must be conducted

in accor d ance w ith AMA’s current Na ti onal M odel Aircraft S a fet y Code and an y addit i onal r ules

spec i fic to a fl y ing site /location.

3

. OPER A TIONS – REQUIREMENTS – LI M IT A TIONS:



### a) AMA members flying radio controlled model aircra ft equipped with f light stabili z

ation and autopi l ot systems must maintai n VLOS w ith the aircr a ft at all t ime s including program m ed autopilot way point f lig ht.



### b) AMA Pilot s must be able to instantaneously deactivate pr o grammed flight of autopi lo t
systems at any time during flight and resume manual contro l of the model aircra f t.



### c) AMA Pil o ts must perform an R/C Test Flight of a model aircraft before acti v ating a new ly

in s talle d autopilo t o r stabili z

ation system and/or after any repair s or replacement o f m odel

aircraft essential flig ht systems

.



### d) Model aircraft exceeding 1 5 lbs and/or 70mph may only u se an autopilot for a pr og rammed

“return to launch” (RTL) flight and not for programmed waypoint flying o f a pred e termi n ed

c ourse.



### e) STABILI Z ATION & AUTOPIL O T SYS T EM S MAY BE USED FOR/ TO:

• Stabilization/automatically stabilize aircraft to level flight when control sticks are centered.

• Recovery/activate TRX switch to recover an out of control aircraft to level f light.

• Heading/activate TRX switch to hold a model aircraft’s he ading f o r p rec isi on fl igh t pa th.

• Altitude/activate TRX switch to maintain f ixed aircraft altitude w hile allowing directiona l con t rol.

• Return GPS/activate TRX switch to return a ircraft v ia GPS t o launch po i nt.

• Return FSS/failsa f e activated f rom r adio s i gnal loss to return air cra ft v ia GPS to launc h point.

• Fixed circle/activate TRX switch to circle aircraft at point of activation at fixed altitude.

• Waypoint/activate TRX switch to initiate an a u topilot programmed flight path via waypo ints.

• Fencing/autopilot programed to display site unique boundaries on video monitor/goggles.PAGE 2 OF 3 (Revision 01/14/2013 ) 4 . RA NGE – A LTITUDE – WE I GHT – SPE ED:

a) One of the requirements in Federal Law (Public Law 11 2- 95 Sec 336 (c) (2) February 14, 2012) for model aircraft to be e x cluded fr o m F AA regulati o ns is t h at model aircr a ft be

flow n w ithin VLOS of the operator

.

b) Model aircraft must be flown at or below 400 feet AGL when within 3 mile s of an airport as

st ated in t he AMA Safet y Cod e.

c) Model aircraft utilizing an autopi l ot for w aypoint fl y ing are limited to a ma x imu m w ei g ht (including fuel, batteries

, an d o nbo a rd autopilot systems ) of 15lbs and a spee d of 70mp h.

5

. RECOMMEND A TIONS & INFORM A TION:

a) If your radio s y stem lacks failsafe capability, consider using programm a ble di g ital ser v os or

au x iliar y fails afe mo d ules. In the event of a radio signal failur e the s e components w ill activate desired safe servo settings or an autopilo t for retur n to ba s e/launch (RTL).

b) W hen using an a utopilot system the “return to launch” (R TL) featu r e should be

program m ed to return the aircr a ft to a safe lo c ation and safel y term in ate the flight s hou l d

manual control of the aircraft be lost. When using RTL, pa y particular attention to the

manufa c turer’s thr o ttle recommendations to pre v ent stalling.

c) The use of stabili z

ation systems is recommended when flying FPV to i mprove flight

stabilit y and v ideo qua l it y.

d) Pilots usually choose to incorporate stabi liz ation and autopilo t systems for model a ircra ft

fl y ing to enhance flight pe r for m an c e, correc t bad t endencies of t he model aircraf t

, maintain stabilit y in wi nd y w eather, establish precision heading holds for takeoffs/landings, flight training for novice pilots, cre a te a steady f light plat f orm for

cam eras, and general ly just to m ake an airp l ane easier and safer to fl y.

e) W hen purchasing stabili z

ation and autopilot syste ms , always try to select quality equipment

f rom reputable dealers, ensure for co m patibility with other onboard systems, and install

com ponents accordin g to m anufacturers’ instructio ns.

6

. PRIV A CY PROTE C TION S A FEGU A RDS:

The u s e of ima g ing technology for aerial surveillance with radio control model aircra f t having the capability of obtaining high

- resolution photograph s and/or v ideo, or using any types of sen s or s , for the collection, retention, or dissemination of sur v eillance data or information on individuals, homes, businesses, or p r opert y at locations where there is a reasonable expectation of privacy is strictly prohibited by the AMA unless written expressed permis s ion is obtained f r om the individual propert y ow ners or m a na g ers

.PAGE 3 OF 3 (Revision 07/ 20/2013 ) 7. D EFINITION S OF TERM S:

**AM A Pilot**  is an AMA member w ho is capabl e of manuall y operating an R/C tran s mitter to control a model aircraft’s flight path within its safe intended flight envelope w ithou t losi n g control or ha v ing a coll is i on.

**Autopilot Sy s**  **tem s**  incorporate programmable f li ght stab il ization with an altit ud e sensor an d

a GPS receiver for accu ra te posi ti oning an d to navig at e/control a r ad io contr ol le d mo de l

a ir cra ft ’ s fl ig ht pa th. Adv anc ed sy st ems offer so ft ware fo r entering navig ab le way po ints. The flight data way po ints may be saved to aut op ilot’s/GPS me mo ry fo r pr og ra mm e d fligh t.

**Essential Flight System s**  ar e any systems or components necessar y to mai n tain stable flight w ithin a model ai rcraft’s flight envelope

. (This includes primar y R/C s ystems and any stabili z

ation or gy ros required to maintain s t abilit y and heading in c ertain types of model aircraft that would be uncontrollable/unstable without their use).

**Failsaf e S**  **ystems** are designed to minimize or prevent damage and sa f ely terminate a flight when a radio controlled model aircraft loses radi o signal. Modern r a dio s yste ms c a n be programmed to position servos to a desired control setting in the event of radio signal

failure.

**First Person Vie w**  **(FP V)**  refers to the operation of a radio co n trolled (R/C) mo del aircraft

us i ng an onboard camera’s cockpit view to orient and control the aircr aft. (AM A Docu me nt #550).

**Flight Envelope** is defined as the range of airspeeds, attitudes and flight ma n eu v ers which

a model aircraft can safel y pe r fo r m/opera t e for its i n tended u s e.

**Non**

**- Essentia**  **l Fl**  **i gh**  **t Systems**  are any systems or components that are not ne c essa ry to maintain stable flight within the model aircraft’s intended flight en v elope

. (This inclu des autopilot or stabilization sy s te ms that can be activated and deactivated in flight by the p i lot

w ithout affecting manuall y controlled stab l e flight).

**R/C T**  **est Flight** r eq uires an AMA Pilot to manuall y operate an R /C tran s mitter t o contr o l a model aircraft’s flight path and determi n e i f the aircraft is cap a ble o f maintaini ng stable flight within its sa f e intended flight envelop e

.

**Stabilization System**  **s** ar e designed to maintain intended mod el ai r craft flight attitudes. The pilot can install, program and/or activate a system to stabilize yaw, pitch, o r roll or any

one atti t ude or c o mbination of a t titudes. Systems are often based o n rate/heading hold gyros or inertial motion sensors utilizing multi -ax is gyros and ac c elerometers for

atti tu de s tabili z ation.

**V**

**isua l**  **Line of Sig**  **ht (V**  **LOS )**  is the distance at which the pilot is able to maintain v isual

contact w ith the aircraft and dete r mine its orientation and attitude without enhan c ements
other than corrective len ses.APPENDIX C: PRIVACY ISSUES

The eBee is proposed to be flown over sterile, unpopulated to l ightly populated areas generally over private railroad property not open to the general public at the direction of the owner railroad or agency. In addition, we propose to obtain landowner permission to fly over properties as part of our services and to notify non-landowners over which we will be fly ing. Finally, most of our flights will be 300 to 400 feet above ground surface, making visual recognit ion of people on the ground impossible. Because of the sterile environment and the pre-noti fication of landowners and personnel on the ground, privacy compromises due to JLP activities are an ticipated to be alleviated. Under no circumstances will JLP’s aircraft be utilized to purposefully i nvade the privacy of peoples or properties in areas within our studies or outside of our study boundaries.APPENDIX D: SAFETY CASE

Safety of our flight crew, other aircraft, people on the ground , and public and private properties is of utmost importance to JLP. JLP’s Pilot in Command (PIC) will be responsible for all safety procedures and protocols while on the ground. The Visual Obser ver (VO) will assist the PIC in maintaining safety procedures throughout the course of a projec t. Safety procedures to be utilized in the filed include the following:

 A full diagnostic check of the aircraft by the PIC and VO using a pre-flight checklist will be performed on the ground prior to commencement of each project;

 High visibility (day-glow orange or green) will be worn by the flight crew during each project. In addition, at the ground station, a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" will be placed prior t o any flights;

 Operations to be conducted over private or public controlled-ac cess property where approved;

 Permission from the land owner/authority required before commen cing any flight;

 Operations over congested areas shall be avoided;

 Operations will not interfere with manned aircraft operations, will yield the right of way to manned aircraft, and operators must See & A void other aircraft and obstacles at all times. Use of an ADS-B receiver by the VO will assist in monitoring th e presence of other proximal aircraft;

 Operations limited to Visual Flight Rules Meteorological Condit ions (VMC) and daylight

hours

 Aircraft operations will remain within Visual Line of Sight (VL OS) and will be visually monitored at all times;

 Use of a high-definition first-person view from the aircraft wi ll assist the PIC and VO identify potential flight conflicts and terminate or alter the pre-programmed flight plan;

 VLOS guaranteed with a GPS geo-fence around operator of 0.5 mil es

 Flight ceiling pre-programed at 400 feet;

 All operations conducted within 5 miles from an airport shall o nly be initiated after verbal coordination with the airport authority, or air traffic control when a control tower is present at the airport;

 All operations will comply with required permissions and permit s established by territorial, state, county or city jurisdictions; including local law enforc ement, fire, or other appropriate governmental agencies; Post-flight inspection of the aircraft will be performed by the PIC and VO utilizing a postflight checklist;

 The eBee operations will be compliant with existing safety proc edures inherent to the activities of the related company.