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 Switzerland, 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 operations 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 proprietary under 14 C.F.R. 

11.35(b) and does not include this document in the public docket) 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 that 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 railroads and rail transit agencies and port 

authorities alike. 

Our firm also serves as first responders involving railroad incidents for several private and public 

railroad owners and agencies. As such it is common for our organization 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 specifically prevents the need of personnel 

to enter dangerous areas of an operating railroad which is subject to strict FRA rules under 49 CFR 

Part 214, Subpart C - Roadway Worker Protection. By approving these 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 Command (PIC) 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 ft. above ground level 

(AGL). 

 Operations will occur over railroad properties with the permission 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 greater than 1/2NM 

from the PIC at all times 

o While the aircraft is airborne, the VO will be positioned within 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 docket; 

o Has a Private Pilot license. 

 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 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 rights-of-way, the PIC and VO will 

be under the jurisdiction of the Federal Railroad Administration (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 initial 40 hours of owner approved safety 

training and an 8 hour annual refresher course. It is JLP policy 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 an approved ID detailing the time and 

date of the conforming training. While FRA regulations do not apply to the National Airspace 

System (NAS), we feel these added safety regulations further enhance 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, the 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 injury 

and 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 (maximum take-off weight of 1.7 

pounds) platform made of flexible foam that performs pre-programmed precision aerial mapping 

missions thanks to the on-board GPS and the related flight management software (eMotion) that 

allows the operator to plan safely and efficiently a mission in 3D, and then monitor it in real-time. 

Thanks to the embedded camera, protected by a foam envelope, the eBee takes a collection of highdefinition still images that are used later to generate maps and contour lines of the surveyed area. 

The four main characteristics of the eBee are: 

a. Very light weight 

The eBee is so light that the operator can launch it by hand and let it land on almost any surface 

without requiring a parachute or landing net (belly land). Its low impact energy (38 J in case of a 

controlled emergency landing) also significantly reduces the risk of hazardous situations. Finally, 

the wings of the eBee are detachable and made of flexible foam with no sharp or hard edges and 

almost no internal strengthening structure. 

b. Electric-powered 

The eBee is electric powered. A brushless engine technology makes it silent and reliable. The 

propeller is attached with a rubber band to the body of the plane so that it can easily flex away in 

case of contact with any object. 

c. Semi-automatic flight 

The artificial intelligence incorporated within the eBee autopilot system continuously analyzes data 

from the Inertial Measurement Unit and from the onboard GPS and takes care of all the aspects of 

the flight under the supervision of the operator. 

d. Option for Manual control 

Additionally, the eBee provides an override capability that allows the operator to take manual 

actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend 

automated operations and take manual control of the aircraft should it become necessary to respond 

emergent circumstances, thanks to the remote controller provided 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 support: 

 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 STANDARD UNDER SECTION 333

a. Airworthiness assessment of the eBee 

JLP notes that the airworthiness of the eBee has already been demonstrated for different projects in 

the United States, involving state/federal agencies or universities (among others the New Mexico 

State University: https://newscenter.nmsu.edu/Articles/view/10208/nmsu-uas-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 required in order to operate the eBee 

UAS). 

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

authorities) in many countries, among others: 

 Switzerland (flight approval for VLOS operations) 

 Canada (flight approval for VLOS operations) 

 Australia (flight approval for VLOS operations) 

 France (flight approval for Extended-VLOS operations) 

 Germany (flight approval for VLOS operations) 

 United Kingdom (flight approval for VLOS operations) 

 Norway (flight approval for VLOS operations) 

 Sweden (flight approval for VLOS operations) 

 Denmark (flight approval for VLOS operations) 

b. Operating requirements 

Grant of the exemption to JLP for the eBee will be subject to the following operating conditions, 

based on the operating conditions set forth by the Academy of Model 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/authority required before commencing 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 aircraft and obstacles at all times 

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

hours 

 Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually 

monitored at all times; 

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

 Flight ceiling pre-programed at 400 feet; 

 All operations conducted within 5 miles from an airport shall only 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 enforcement, fire, or other appropriate 

governmental agencies. 

 The eBee operations will be compliant with existing safety procedures inherent to the 

activities of the related company. 

c. Operator Requirements 

The eBee operator will have a Private Pilot license and will successfully 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 equivalent 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 Case 
 

APPENDIX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

JLP requests an exemption from the following regulations as well as any additional regulations that 

may technically apply to the operation of the eBee: 

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

14 CFR § 91.203(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 limited operating area associated with 

its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 

Subpart H in order to achieve or exceed current safety levels. 

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 

333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration 

of the size, weight, speed, operational capability, and proximity to airports and populated areas of 

the UAS involved. An analysis of these different criteria demonstrates that the eBee operated 

without an airworthiness certificate, under the conditions proposed in that exemption, will be at 

least as safe, or safer, than a conventional aircraft with an airworthiness certificate. A proprietary 

risk assessment for operations with the eBee, which demonstrates that assertion, is also being 

submitted to the FAA as part of this application. JLP requests the FAA treat the eBee risk 

assessment as proprietary under 14 C.F.R. 11.35(b) and not include this document in the public 

docket. 

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

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

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

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

station. 

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

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

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations 

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

aircraft of the United States, unless that person: 

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

physical possession or readily accessible in the aircraft when exercising the privileges of that pilot 

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

license issued by that country may be used. 

The regulation provides also that no person that holds a private pilot certificate may act as pilot in 
 

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

pilot in command of an aircraft in connection with any business or employment if: 

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

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

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

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

that operators of the eBee should not be required to hold a commercial 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 aircraft unless it is in airworthy 

condition. Should the exemption be granted allowing commercial operation of the eBee without 

an airworthiness certificate, no standard will exist for airworthiness of the eBee. Given the size of 

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

 New Mexico State University: https://newscenter.nmsu.edu/Articles/view/10208/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 construction 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 placard 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 too small to carry documentation, the 

documentation would not be available to the crew. 

The equivalent level of safety will be achieved by keeping a hard 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 aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." 

Flight instruction will be accomplished through an elaborated training program, using first the 

simulation mode of the flight management software eMotion. The equivalent level of safety during 

the training will be achieved by the manufacturer or authorized distributor providing the training 
 

and 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. Since the aircraft will be operating at a 

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

The equivalent level of safety will be achieved because the eBee will only fly over private property 

with the permission of the landowner. The operator will define before every flight a working area 

radius and a flight area ceiling, preventing the eBee to go beyond the flight area. 

The landowner and the persons who may be on the ground in the flight area will be briefed of the 

expected route of flight and the associated risks to persons and property on the ground. Due to the 

small size of the eBee and the material with which the eBee is built, the hazard to persons, vessels, 

vehicles, and structures is not comparable to manned aircraft and should be considered in granting 

the exemption. 

Moreover, the aircraft will not be operated over congested areas 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 surface. 

14 CFR 91.121 – Altimeter settings 

This section requires that each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating 

below 18,000 feet MSL to: 

 The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft; 

 If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the 

current reported altimeter setting of an appropriate available station; 

 In the case of an aircraft not equipped with a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before departure. 

To provide an equivalent level of safety, the eBee autopilot calculates the reference altitude (ground 

level) with the on-board GPS during the pre-flight tests. The GPS and barometer data are merged 

with respect to their respective precisions. The GPS provides reliable information to correct 

potential barometric bias, while rapid variations in altitude are detected through the barometer. 

Hence, barometric bias induced by environmental factors is rejected. 

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

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 

30 minutes. 

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 accept a take-off order is the battery 

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

warnings and implemented a “return to Home” (and “Go Land”) actions in these situations. 
 

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

This regulation provides as follows: 

 No person may operate a civil aircraft unless it has an appropriate and current 

airworthiness certificate. 

 No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

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 them 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-located 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 Maintenance, and 

Alterations

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

airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 

require 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 owner or operator to keep records 

showing certain maintenance work that has been accomplished by certificated mechanics, under 

Part 43, or licensed pilots and records of approval of the aircraft for return to service. 

JLP proposes that the maintenance of the eBee will be accomplished by the owner/operator 

according to the maintenance manual, provided by SenseFly. JLP requests the FAA treat the eBee 

training program as proprietary under 14 C.F.R. 11.35(b) and not 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 will 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, the eBee runs automatically a sequence of pre-flight tests to make sure 

that every sensor and every critical 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 interchangeable (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 AERONAUTICS SAFETY REQUIREMENTS
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.
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)

AMA Document # 560 

Academy of Model Aeronautics 

AMA Advanced Flight Systems Committee 

amaflightsystems@gmail.com

Radio Controlled Model Aircraft Operation

Utilizing Failsafe, Stabilization and Autopilot Systems

1. DEFINITION OF TERMS:

Please refer to Page 3, section 7 which contains an alphabetical listing of the definitions of the 

terms in italics that are used in this document.

2. GENERAL:

All model aircraft flights utilizing stabilization and autopilot control systems must be conducted 

in accordance with AMA’s current National Model Aircraft Safety Code and any additional rules 

specific to a flying site/location. 

3. OPERATIONS – REQUIREMENTS – LIMITATIONS:

a) AMA members flying radio controlled model aircraft equipped with flight stabilization and

autopilot systems must maintain VLOS with the aircraft at all times including programmed 

autopilot waypoint flight.

b) AMA Pilots must be able to instantaneously deactivate programmed flight of autopilot 

systems at any time during flight and resume manual control of the model aircraft.

c) AMA Pilots must perform an R/C Test Flight of a model aircraft before activating a newly

installed autopilot or stabilization system and/or after any repairs or replacement of model 

aircraft essential flight systems. 

d) Model aircraft exceeding 15lbs and/or 70mph may only use an autopilot for a programmed

“return to launch” (RTL) flight and not for programmed waypoint flying of a predetermined 

course.

e) STABILIZATION & AUTOPILOT SYSTEMS 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 flight.

• Heading/activate TRX switch to hold a model aircraft’s heading for precision flight path. 

• Altitude/activate TRX switch to maintain fixed aircraft altitude while allowing directional control.

• Return GPS/activate TRX switch to return aircraft via GPS to launch point.

• Return FSS/failsafe activated from radio signal loss to return aircraft via GPS to launch point.

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

• Waypoint/activate TRX switch to initiate an autopilot programmed flight path via waypoints.

• Fencing/autopilot programed to display site unique boundaries on video monitor/goggles.
PAGE 2 OF 3 (Revision 01/14/2013)

4. RANGE – ALTITUDE – WEIGHT – SPEED:

a) One of the requirements in Federal Law (Public Law 112-95 Sec 336 (c) (2) February 14,

2012) for model aircraft to be excluded from FAA regulations is that model aircraft be 

flown within VLOS of the operator. 

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

stated in the AMA Safety Code. 

c) Model aircraft utilizing an autopilot for waypoint flying are limited to a maximum weight

(including fuel, batteries, and onboard autopilot systems) of 15lbs and a speed of 

70mph. 

5. RECOMMENDATIONS & INFORMATION:

a) If your radio system lacks failsafe capability, consider using programmable digital servos or

auxiliary failsafe modules. In the event of a radio signal failure these components will 

activate desired safe servo settings or an autopilot for return to base/launch (RTL).

b) When using an autopilot system the “return to launch” (RTL) feature should be 

programmed to return the aircraft to a safe location and safely terminate the flight should 

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

manufacturer’s throttle recommendations to prevent stalling.

c) The use of stabilization systems is recommended when flying FPV to improve flight

stability and video quality. 

d) Pilots usually choose to incorporate stabilization and autopilot systems for model aircraft

flying to enhance flight performance, correct bad tendencies of the model aircraft, 

maintain stability in windy weather, establish precision heading holds for 

takeoffs/landings, flight training for novice pilots, create a steady flight platform for 

cameras, and generally just to make an airplane easier and safer to fly. 

e) When purchasing stabilization and autopilot systems, always try to select quality equipment

from reputable dealers, ensure for compatibility with other onboard systems, and install 

components according to manufacturers’ instructions. 

6. PRIVACY PROTECTION SAFEGUARDS:

The use of imaging technology for aerial surveillance with radio control model aircraft 

having the capability of obtaining high-resolution photographs and/or video, or using any 

types of sensors, for the collection, retention, or dissemination of surveillance data or 

information on individuals, homes, businesses, or property at locations where there is

a reasonable expectation of privacy is strictly prohibited by the AMA unless written 

expressed permission is obtained from the individual property owners or managers. 
PAGE 3 OF 3 (Revision 07/20/2013)

7. DEFINITIONS OF TERMS: 

AMA Pilot is an AMA member who is capable of manually operating an R/C transmitter to 

control a model aircraft’s flight path within its safe intended flight envelope without losing 

control or having a collision.

Autopilot Systems incorporate programmable flight stabilization with an altitude sensor and 

a GPS receiver for accurate positioning and to navigate/control a radio controlled model 

aircraft’s flight path. Advanced systems offer software for entering navigable waypoints. The 

flight data waypoints may be saved to autopilot’s/GPS memory for programmed flight.

Essential Flight Systems are any systems or components necessary to maintain 

stable flight within a model aircraft’s flight envelope. (This includes primary R/C systems 

and any stabilization or gyros required to maintain stability and heading in certain

types of model aircraft that would be uncontrollable/unstable without their use).

Failsafe Systems are designed to minimize or prevent damage and safely terminate a 

flight when a radio controlled model aircraft loses radio signal. Modern radio systems can 

be programmed to position servos to a desired control setting in the event of radio signal 

failure.

First Person View (FPV) refers to the operation of a radio controlled (R/C) model aircraft 

using an onboard camera’s cockpit view to orient and control the aircraft. (AMA Document 

#550).

Flight Envelope is defined as the range of airspeeds, attitudes and flight maneuvers which 

a model aircraft can safely perform/operate for its intended use.

Non-Essential Flight Systems are any systems or components that are not necessary to 

maintain stable flight within the model aircraft’s intended flight envelope. (This includes 

autopilot or stabilization systems that can be activated and deactivated in flight by the pilot 

without affecting manually controlled stable flight).

R/C Test Flight requires an AMA Pilot to manually operate an R/C transmitter to control 

a model aircraft’s flight path and determine if the aircraft is capable of maintaining stable 

flight within its safe intended flight envelope. 

Stabilization Systems are designed to maintain intended model aircraft flight attitudes. 

The pilot can install, program and/or activate a system to stabilize yaw, pitch, or roll or any 

one attitude or combination of attitudes. Systems are often based on rate/heading hold 

gyros or inertial motion sensors utilizing multi-axis gyros and accelerometers for

attitude stabilization.

Visual Line of Sight (VLOS) is the distance at which the pilot is able to maintain visual

contact with the aircraft and determine its orientation and attitude without enhancements 

other than corrective lenses. 
 

APPENDIX C: PRIVACY ISSUES 

The eBee is proposed to be flown over sterile, unpopulated to lightly 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 flying. Finally, most of our flights will 

be 300 to 400 feet above ground surface, making visual recognition of people on the ground 

impossible. Because of the sterile environment and the pre-notification of landowners and personnel 

on the ground, privacy compromises due to JLP activities are anticipated to be alleviated. Under no 

circumstances will JLP’s aircraft be utilized to purposefully invade 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 Observer (VO) will assist the PIC in 

maintaining safety procedures throughout the course of a project. 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 to any flights; 

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

approved; 

 Permission from the land owner/authority required before commencing 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 the presence of other proximal 

aircraft; 

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

hours 

 Aircraft operations will remain within Visual Line of Sight (VLOS) and will be visually 

monitored at all times; 

 Use of a high-definition first-person view from the aircraft will 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 miles 

 Flight ceiling pre-programed at 400 feet; 

 All operations conducted within 5 miles from an airport shall only 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 permits established by territorial, 

state, county or city jurisdictions; including local law enforcement, 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 procedures inherent to the 

activities of the related company.