U.S. Department of Transportation 

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 of the 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 of the 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 of less than I 0 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 ief sought: 

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 relief is 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. MUL TIROTOR service-drone G4 Surveying Robot (see www ,service-

~J.IQJ1 .com/e / hop/uav/mu1Lirotor-g4· ·urveyLr:t!!-robot ) 

ii. MULTJROTOR service-drone G4 Eagle (see www. rv ~edJ' .,\;Q JJ!P /shc.?.P!. H~Y. nJq!UrqJ r-g4: r::il. lgfmnlti qJQ. r-o4~g r;;~yJ. ) 

iii. DJI Phantom 3 (see !Jp;// Y.\Y Y. ~iJL 0I.D.:'Qrod ll'2.1:/ Qh t.9m :::l :Qr i!!.(Q/.:t~~ ) 

iv. Other servi ce-drone models to be added by future amendment to this exemption. 

3. Public benefit: 

a. Us~:: 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 of the manufacturer. All repair 

and maintenance work will be conducted or approved by qualified personnel such as those 

authorized by fSQ 9H\; $!~i~ ~ (or equivalent), and will require a test flight after such work. Records 

of all 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: 

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1. 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 of a UAS knowledge test in a specified form. 

5. At least 200 cycles and 25 hours of flight 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 if a 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 if a safe distance is maintained from persons 

in accordance with I 4 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 of Authorization. 

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, if any) 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 

CO A. 

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 of an airport without prior permission. 

IX. Not be made near persons as required in 14 CFR 91.119 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% of the battery or fuel capacity of the aircraft, or 60 minutes, whichever 

occurs first. 

xn. Any incidents will be reported within 24 hours of occurrence. 

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 of aircraft. 

f. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well-defined 

and tested lost link procedures. 

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

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