December 21, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

RE: Petition for exemption pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 to Operate Unmanned 

Aircraft Systems forAerial Data Collection 

Dear Sir or Madam, 

This petition is being submitted by Cude Engineers, LLC on our own behalf to request exemption pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012, and 14 C.F.R. Part 11 to allow for the commercial use and operation of the 

"eBee" by senseFly, an unmanned aircraft system for aerial data collection, in airspace regulated by the Federal Aviation 

Administration. 

Cude Engineers, LLC requests that the Federal Aviation Administration review this petition for exemption pursuant to its 

"summary grant" process as the FAA has previously granted exemptions that are similar in all respects to this petition. The 

following exemptions have been previously granted for aerial data collection using Small Unmanned Aircraft Systems 

(sUAS): Grants 11062, 11109, 11112, 11213, 12445, and 12851. 

Cude Engineers, LLC will conduct the majority of its operations over rural areas outside of controlled airspace. All flights will 

occur either over private property or controlled access property with the owner's prior consent and knowledge or over 

publicly owned property with the proper authority granted by the public entity for which services are being provided. Only 

those who have consented to the aerial photography will be in the area at the time the aerial photography and data is 

captured. In addition, Cude Engineers' pilots will hold an FAA Private Pilot License with Class III Medical Certificates at 

minimum, and field observers will be properly trained to understand their responsibilities to include: communication 

procedures, visual scanning procedures, operating procedures near airports, and the appropriate sections of the 

Aeronautical Information Manual. 

Regulations from which exemption is requested: 

14 C.F.R. 45.23 (b) 

14 C.F.R. 61.113(a) 

14 C.F.R. 61.113(b) 

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b) (2) 

14 C. F. R. 91.109 

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) 

14 C.F.R. 91.203(b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401- 91.417 

CUDE ENGINEERS 4122 POND HILL ROAD, STE 101 PHONE: (210) 681-2951 TBPE NO. 455 

SAN ANTONIO, TEXAS 78231 CUDEENGINEERS.COM TBPLS NO. 10048500 
Document Name 2/2 

We are petitioning for an exemption in order to enable Cude Engineers, LLC to operate the eBee, a fixed wing sUAS equipped 

with a multi-spectral camera. This sUAS weighs less than 25 pounds and is equipped with systems that limit flight height, 

limit duration of flight to preserve battery levels to maintain safe operating power, limit radius from operator, and a fail-safe 

autopilot system that will recall the sUAS to the operator's location and perform a safe landing in the event of a 

communication failure between the operator and the sUAS. The specifications listed above and detailed in the description 

of operations below meet the minimum standards to adhere to the Reform Act's safety requirements. 

Description of operations: 

o The petitioner will only operate the sUAS in line of sight to either the pilot or observer. 

o The minimum crew for all operations will be a pilot and an observer. 

o If operations occur within 3 miles of an active airport the proper notifications will be given to the airport operators 

as to time and location of flight operations. 

o The sUAS will be operated at an altitude of 400 feet AGL or less. 

o The maximum operating ground speed will be 60 miles per hour. 

o The pilot and observer will maintain the ability to communicate verbally for the duration of the operations. 

o The pilot will inspect the sUAS prior to any operations and will perform all maintenance required by the 

manufacturer's manual (Enclosed). 

o All operations will take place during daylight hours and proper weather conditions. 

o Copies of all manuals and documents related to the safe operation of the sUAS will be with the pilot and observer 

at all times of operation. 

o All operations will occur over private property with the owner's consent. 

Cude Engineers, LLC hereby respectfully request exemption under Section 333 to safely preform low risk commercial sUAV 

operations using the above stated equipment and procedures. We believe that allowing the use of sUAS will benefit the 

public by allowing us to safely provide a variety of mapping services at a lower cost while having less of an impact on the 

environment than traditional aerial surveying methods. 

Sincerely, 

— 

ol 

Mason Liebau, PE, SIT, CFM 

Vice President 

Cude Engineers, LLC 

4122 Pond Hill Road, Suite 101 

San Antonio, Texas 78231 

Office: 210-681-2951 

mliebauC@cudeengineers.com 

CUDE ENGINEERS 4122 POND HILL ROAD, STE 101 PHONE: (210) 681-2951 TBPE NO. 455 

SAN ANTONIO, TEXAS 78231 CUDEENGINEERS.COM TBPLS NO. 10048500