1 of 6 23 July 2014 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, Advanced Aviation Solutions LLC (“ ADAVSO ”), seeks an exemption

from Federal Avia tion Regulations (“FARs”) detailed below for the eBee Ag Unma nned Aircraft System manufactured by SenseFly SA of Switzerland.

The requested exemption would support an application for a commercial Certificate of

Authorization to use th e system to support agriculture. The eBee Ag system consists of a lightweight (1. 5 lb) battery operated aircraft, a PC

- based gr ound control station, and associated communications equipment. The aircraft carries an onboard geo

- referenced still camera that

allow s it to conduct precision photogrammetry and crop scouting at the resolution s necessary for precision agriculture. This high

- resolution data can direct variable seeding rates as well as the precise application of fertilizer and chemicals reducing their use. This data help s farmers to maximize yields while reducing cost s and impact s to the environment. By approving these exemptions, the FAA will create benefits to both agriculture and the environment which are ultimately in the public interest. 1

The aircraft will be operated in the field with both a Pilot in Command (P IC) and a ground

- based Visual Observer (VO) in accordance with FAA Policy N 8900.227 Section 14 " Operational Requirements for UAS " with the following additional restrictions:

- All operations will occur in Class G airspace at no more than 400 ' AGL

- Opera tions will be operated over private property with the permission of the land owner

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

- The aircraft will not be operated over urban or populated areas

- The aircraft w ill not be operated at air shows or over an open

- air assembly of people

- The aircraft will not be operated over heavily trafficked roads

- The aircraft will not be operated within 5 NM of an airport or heliport

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight at no greater than 1/2 NM of the PIC at all time

- Wh ile the aircraft is airborne, the VO will be positioned within voice distance to the PIC

- PIC will file a NOTAM providing radial/DME, radius, and a date/time group for each operation

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel Qualifications

. Additionally, the PIC and VO will perform maintenance on the system

1 We will provide an explanation of equivalent level of safety for each exemption request, but will point back to the benefits to agriculture and the environment to justify why the requests are in the public interest.2 of 6

and will com plete a course of maintenance instruction as p art of their initial training. Due to the simplicity of the system, we do not anticipate the need for a supplemental pilot.

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

The name and contact information of the applicant are:

Advanced Aviation Solutions LLC Attn: Bradley Ward

Ph: 509

- 534

- 2042

Fax: 509

- 534

- 6895

Email: bradw@adavso.com

The regulations from which the exemption is requested are as follows:

- 14 C FR Part 21

- 14 CFR 91.203

- 14 CFR 45.23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 91.109

, 91.119

- 14 CFR 91.121

, 91.151

- 14 CFR Subpart E (91.401

- 91.417)

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety . We look forward to working with your office

. Please contact us at any time if you require additional information or clarification.

Sincerely,

Bradley J. Ward

Vice President

Appendices : A . Exemption Request and Equivalent Level of Safety

B

. Privacy Issues

C

. Safety Case

D. Maintenance Procedures

E. User Manual F. Training Program

G. Aviation ExperienceAppendix A

3 of 6 EXEMPTION REQUEST S AND EQUIVALENT LEVEL OF SAFETY

Advanced Aviation Solutions requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the SenseFly eBee Ag:

14 CFR Part 21 , Subpart H: Airworthiness Certificate s

This part esta blishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for UAS, we request an experimental

certificate be issued for the SenseFly eBee Ag under either or both of the foll owing provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new

uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and suppl emental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as mark et surveys, sales demonstrations, and customer crew training , we would expect that an experimental certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the fact that the aircraft weighs only 1.5 pounds and is constructed primarily out of foam, we propose that the eBee Ag will be at least as safe, if not safer, than a conventionally certificated aircra ft performing the same mission.

If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equ ivalent level of safety outlined in the previous paragraph.

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 that it is legible to passengers or crew." At 1.5 lbs, the eBee is too small to carry do cumentation

, 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 d ocuments 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

. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via plac ard:Appendix A

4 of 6 Manufacturer: SenseFly SA Model: eBee Ag

Serial Number: 14

- XXXX

Registered to:

Advanced Aviation Solutions LLC

8111 Moerkle Street Anytown, OH 12345

If found please contact: (800)

- 555

- 1234

.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

The s e regulation s provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. T he 1.5 pound eBee Ag 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

.

We propose to achieve an equi valent level of safety by including the word "EXPERIMENTAL"

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. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft 's registration information should it be found on the ground . Finally, we will display at the ground s tatio n 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 1/2 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate it's point of origin.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

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

manual is in the aircr aft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documen tation, the

documentation would not be available to the crew.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved Airplane Flight Manual (appendix E) must be available to the crew at the ground station anytime the aircraft is in, or preparing for

, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations.

The r egulation provi des that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) TheAppendix A

5 of 6 flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

Our proposed operations meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilo t certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA Private Pilot written examination." Since t here are currently no means available for the pilot of a UAS to gain the experience in an equivalen t category and class

in order to apply for a commercial pilot's license

, we propose to generate an equivalent level of safety by requiring our pilots to complete , at a minimum, FAA commercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition to completing the private pilot requirements

. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagr aph (b) even though the intent of this application is to

conduct a business.

14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight tests

The regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The eBee ground control

station is based on a small hand

- held computer and while it does not offer a second set of

"controls"

, both the student and instructor can, and will, op erate the single set of controls simultaneously. With both student and instructor having "hands

- on" the controls during flight

, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe alti tudes: General.

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a
maximum of 400 feet AGL, we cannot comply with this requirement.

To provide an equivalent level of safety we will only fly over private property with the permission of the land owner . The land owner will be briefed of the expected route of flight and

the associate d risks to persons and property on the ground. We maintain that due to the small size of the eBee Ag, the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in granting the exemption. (see ap pendix C section 6.4.1 Consideration about risks related to ground impacts)

The aircraft will not be operated over congested areas n or over a ny 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 surface.

14 CFR 91.121 Altimeter settings

.

The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical mile s of the aircraft . The aircraft will fly below 400 feet

AGL and will not need to maintain hemispherical cruising altitudes in order to de

- conflict with

other aircraft. As such, an appropriate altimeter measurement presented to the pilot should be

Above G round Level and should be based on the barometric pressure at the point of launch. To provide an equivalent level of safety, the UAS's AGL altimeter will be set to zero on the ground prior to every flight. Since the aircraft will fly no more than 5 0 minu tes , even rapid changes in barometric pressure will have limited affect on the safety of the flight.Appendix A

6 of 6 14 CFR 91.151 Fuel requirements for flight in VFR conditions.

Th e regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes. We feel the intention of this paragrap h is to provide a reserve of energy as a safety buffer for go

- arounds and other delays to landing.

The eBee Ag is ba ttery operated and the maximum duration of flight from a single battery charge is 50 minutes. Since the aircraft will never fly more than 1 /2 nm from the point of intended landing

, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy"

.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, and

Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 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. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service."

As provided in the attached Maintenance Procedures (appendix D ) , the PIC will ensure that the aircraft is in an airworthy condition prior to flight and conduct detailed inspections after every 10

hours. M aintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, and updating softwar e and firmware. All other maintenance will be performed by the

manufacture r . The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft , the PIC can ensure an equivalent lev el

of safet y.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical.

This policy provides that both the PIC and VO must have a valid FAA second

- class medical certificate issued under part 67 in order to perform as a pilot or observer

. The aircraft weighs 1.5 pounds and is constructed out of foam. Requiring the crew to meet the same medical requirements as a commercial pilot carrying passengers i n a l a r g e a i r c r a f t is an un n e c e s s a r y burden

.

We propose that the minimum medical requirement s be vision corrected to 20/20 and a valid, state

issued driver's license. D u e t o t h e s i z e a n d w e i g h t o f t h e a i r c r a f t

, t h e g r e a t e s t h a z a r d o f o u r p r o p o s e d

o p e r a t i o n w i l l b e d r i v i n g t o t h e l a u n c h s i t e

. A l i c e n s e d d r i v e r i s m e d i c a l l y q u a l i f i e d t o o p e r a t e a

m u c h l a r g e r v e h i c l e

. T h e 2 0 / 2 0 v i s i o n r e q u i r e m e n t w i l l e n s u r e t h a t t h e P I C a n d V O c a n s e e a n d

a v o i d a i r t

r a f f i c

. G i v e n t h e u n l i k e l y e v e n t t h a t b o t h t h e P I C a n d V O b e c o m e m e d i c a l l y i n c a p a c i t a t e d

w h i l e t h e a i r c r a f

t i s i n f l i g h t

, t h e e B e e A g w i l l r e c o v e r a u t o n o m o u s l y t o t h e l a n d i n g l o c a t i o n d e s i g n a t e d p r i o r t o l a u n c h w i t h o u t c r e w i n t e r v e n t i o n

. It is our intention to hire and train military veterans that have experience operating electric UAS of similar size. Some of these veterans are

disabled . D espite their disability

, they can not only safely operate the aircraft, they will bring

invaluable o p e r a t i o n a l expe rience ultimately making our operations safer

. T h i s r e q u e s t i s i n t h e

p u b l i c i n t e r e s t a s i t o p e n s a v i a t i o n r e l a t e d j o b s t o a s e c t i o n o f t h e p u b l i c t h a t w o u l d n o t o t h e r w i s e b e

m e d i c a l l y q u a l i f

i e d w i t h o u t i n t r o d u c i n g a d d i t i o n a l r i s k

.