### 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. 10048500Document 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