U.S. Department ofTransportation Docket Management System 1200 New Jersey Avenue, S.E. West Building Ground Floor, Room Wl2-140 Washington, DC 20590


## RE: Petition for Exemption under Section 333 ofthe FAA Modernization and Reform Act and Part 11.81 ofthe Federal Aviation Regulations

January 25, 2016 Petitioner: Ogden Engineering & Consulting, LLC, Dba, OEC Forensics Jerry S. Ogden, PhD, PE, President /Owner Physical Address: 8315 South Wadsworth Boulevard Littleton, Colorado 80 128 Mailing Addres : PO Box 621519 Littleton, Colorado 80162-1519 Telephone: Email: Website:

Dear Sir or Madam, (303) 795-1515 jogden@OEC4N6.com www.OEC4N6.com

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R

. Part II .81, Ogden Engineering & Consulting, LLC, Dba OEC Forensics (hereafter, "OEC Forensics") hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its small, unmanned aircraft for photogrammetry, building inspection, land surveying for engineering studies and general geespacial data acquisition

. All operations shall be conducted within and under the conditions and limitations outlined previously by the FAA as required by Section 333 and conducted in compliance with the operator's manuals/pilot handbook. Background Ogden Engineering & Consulting, LLC, Dba OEC Forensics, was established in 2000 by its founder, Jerry S. Ogden, PhD, PE. OEC Forensics is a small, specialized consulting engineering firm ofless than I0 employees that serves a nationwide market for the investigation, analysis and expert testimony regarding motor vehicle collision events, structural and mechanical failures, and product design analysis. Dr. Ogden has extensive knowledge in sUAS operations and implementation garnered from graduate studies at the University of Colorado in Geographic Information Systems (GIS) and Advanced Geomatics. Each engineer at OEC Forensics undergoes extensive flight planning, sUAS inspection and flight training by certified sUAS flight instructors. The engineers of OEC Forensics are licensed to practice Civil or Mechanical Engineering in multiple states, having NCEES Records which allow licensure by comity in all states in the US. As Licensed Civil or Mechanical Engineers, OEC Forensics is permitted to conduct engineering surveys regarding structure and machine failures, highway design, mining, agricultural and motor vehicle collision events subject to forensic analysis by OEC Forensics' engineering staff

. 

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### 1. Sections from which exemptions are sought: Application is hereby made for exemption from:
a. 14 CFR Part 21, subpart H 

### b. 14 CFR Part 45.23(b) c. 14 CFR Part 45.27(a) d. 14 CFR Part 61.113(a) and (b) e. 14 CFT Part 91 : I. 

### 91.7(a) ii. 91.9(b)(2) iii. 91.9© IV. 

### 91.103(b)(2) v. 91.105 VI. 

### 91.109 VII. 

### 91.119 VIII. 

### 91.121

IX. 

### 91.151 X. 

### 91.405 XI. 

### 91.407 XII. 

### 91.409 xiii. 91.417 2. Rei iefsought: a. OEC Forensics wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to include (but not be limited to) photogrammetry, land surveying for engineering studies, building and industrial inspections and general geo-spacial data acquisition. This reliefis sought because commercial use of sUAS is currently prohibited by law unless performed under an exemption. b. This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds including payload and energy sources: 1. 

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### iv. Other service-drone models to be added by future amendment to this exemption. 3. Public benefit: a.

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### uf sUAS lt:chnulugy to obtain imagery, information and data currently obtained by use of manned flight or manual methods: 1. 

### Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure inspections) and due to other dangerous activities that can be avoided (e.g

., scaffolding/rigging failures during structure or bridge inspections, land survey methods that encroach upon highway right-of-way and result in traffic conflicts with surveyors). ii. Reduces the cost of obtaining such information, which benefits consumers and the economy. iii

. Reduces environmental impact by eliminating sources of hydrocarbon emissions from manned aircraft. 4. Safety not adversely affected: a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C. b. Aircraft will comply with maintenance and inspection requirements ofthe manufacturer

. All repair and maintenance work will be conducted or approved by qualified personnel such as those authorized by

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### (or equivalent), and will require a test flight after such work. Records ofall maintenance and repair work will be kept in a maintenance log for each aircraft. c. All flight operations will be conducted by at least two individuals (Pilot-in-Command (PIC) and observer) who will maintain verbal communication capability with each other at all times during the flight, and who will remain stationary on the ground during the flight operations: 

### Page 2 of31. A PIC who possess the following credentials: I. An Airman Certificate issued under 14 CFR 61 (Sport Pilot license or higher) 2. A medical certificate as required under 14 CFR 67 3. A bi-annual flight review under 14 CFR 61.56 4. Successful completion ofa UAS knowledge test in a specified form. 5. At least 200 cycles and 25 hours offlight experience in a UAS rotorcraft similar to the ones delineated in Section 2.b above. Such cycles and hours may be gained during flights under this exemption ifa safe distance is maintained rrom persons in accordance with 14 CFR 91.119. 6

. At least 5 hours of flight experience and 

### 3 takeoffs and landings in make and model being flown in the prior 90 days. Such cycles and hours may be gained during flights under this exemption ifa safe distance is maintained from persons in accordance with I4 CFR 91.119. ii. A Visual Observer (VO). 111. A Sensor Operator as necessary. d. All flight operations will be conducted in accordance with valid Certificates ofAuthorization. e. All flight operations will comply with the following: 1. The manufacturers' user manuals. 11. OEC Forensics' Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals (AFM) which include lost communication and other emergency and safety procedures

. 111. Conducted in VFRIVMC conditions during daylight hours. 1v. PIC and VO will maintain VLOS at all times. v. Pre-flight inspections (including ground control station, ifany) and safety risk assessments will be conducted prior to each flight. v1. Flight altitudes will remain at or below 200' AGL unless authorized otherwise by specific COA. vu. Flight ground speeds will not exceed 50 knots. vu1. Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take place within 5 nautical miles ofan airport without prior permission. IX. Notbe made near persons as required in 14 CFR91.119 and not over persons on the ground without their prior permission. x. Each flight will be logged in both the PIC's logbook and the aircraft logbook. xi. Not exceed 75% ofthe battery or fuel capacity ofthe aircraft, or 60 minutes, whichever occurs first. xn. Any incidents will be reported within 24 hours ofoccurrence. xiii. OEC Funmsil:s will maintain liability insuranl:e of at least $1,000,000 issued by a major aviation insurance underwriter. x1v

. Any applicable local FSDO requirements. xv. All other applicable regulations concerned with the operation ofaircraft. f. Aircraft will use FCC compliant 2.4 GHz for command & control ofthe aircraft with well-defined and tested lost link procedures

.

Please advise us ofany additional information or changes that may be required.



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