OCRG Consultant Group LLC. Richard Myers

20018 Pinehurst Trail Dr Humble, TX. 77346 TEL: 832-687-7225 FAX: 281-852-3546

Email: Richard1@OurPublicAdjusters.com

August 18, 2015

U.S. Department of Transportation

Federal Aviation Administration

Document Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

RE: Exemption Request – Section 333 of the FAA Report Act and Part 11 of the Federal

Aviation Regulations including Airworthiness Certificates.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95,

126 Stat.11 (amending 49 U.S.C.) (hereinafter, the “Reform Act”) and 14 C.F.R. Part 11, OCRG Consultant 

Group LLC – Richard Myers, a developer and operator of small unmanned aircraft systems (singularly a 

“sUAS” or cumulatively “sUASs”) seeks an exemption from the Federal Aviation Regulations listed below, 

to allow commercial operation of its sUASs.

OCRG Consultant Group LLC – Richard Myers, since 2010, provides property and agricultural solutions as 

professionals involved in estimating all phases of inspections, building and repair. In addition, Insurance

Claims Investigations, Infrared reports. Including future 3D geospatial presentations for all types of 

disasters, design and construction projects. OCRG Consultant Group LLC – Richard Myers is a technology 

and services company specializing in the disaster application of 2D-3D imaging and technologies 

delivering highly accurate solutions to a wide variety of measurement and physical documentation tasks.

As described more fully below, the requested exemption would permit the operation of small,

Unmanned sUAS under controlled condition in airspace that (a) is limited, (b) is predetermined, (c)

Is controlled as to access, and (d) would provide safety enhancements to the already safe

Operations in the video & mapping industry. Approval of this exemption would thereby enhance safety 

and fulfill the Secretary of Transportation’s responsibilities to “... establish requirements for the safe

operation of such aircraft systems in the national airspace system.” Reform Act 333 (c).

The name and address of the applicant (“Applicant”): OCRG Consultant Group LLC – Richard Myers
OCRG Consultant Group LLC. Richard Myers

20018 Pinehurst Trail Dr Humble, TX. 77346 TEL: 832-687-7225 FAX: 281-852-3546

Email: Richard1@OurPublicAdjusters.com

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

P2V+ DJI Phantom 2 Vision+

CFR Code of Federal Regulations

COA Certificate Of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

3DRS 3D Robotics Solo

LOL Loss Of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line Of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
OCRG Consultant Group LLC. Richard Myers

20018 Pinehurst Trail Dr Humble, TX. 77346 TEL: 832-687-7225 FAX: 281-852-3546

Email: Richard1@OurPublicAdjusters.com

U.S. Department of Transportation – Federal Aviation Administration Page 2

Exemption Request – Section 333 of the FAA Reform Act April 28, 2015

The Applicant hereby requests exemption from the following FARs:

• 14 C.F.R. 21, subpart H

• 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. 91.9(b)(2)

• 14 C.F.R. 91.103(b)

• 14 C.F.R. 91.105

• 14 C.F.R. 91.109(a)

• 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 C.F.R. 91.319(a)(1)

• 14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417)

The requested exemption would authorize OCRG Consultant Group LLC – Richard Myers to conduct 

residential and commercial operations using one of 1.) SOLO 3dr smart drone, 2.) DJI Phantom 2 Vision+, 

and DJI Phantom 3, and Phantom FC40, 3.) Pixhawk 3DR X8-M. For mapping, inspection, photography

and videos of, large commercial facilities, natural disaster sites, landfills, agriculture, construction sites, 

forensic assessments, damage assessments and fire investigation applications, mining facilities, utilities, 

oil & gas facilities, Insurance claims Inspections and Investigations of all residential and commercial sites

related to insurance claims & loss recovery. 

In order to ensure at least an equivalent level of safety to currently authorized operations using

manned aircraft, all operations will be subject to the strict operating requirements defined in the

OCRG Consultant Group LLC – Richard Myers UAS Flight Operations Manual and Preflight Checklist for 

Residential and Commercial operation of an UAS, as described herein, which are equipped with 

camera(s) and sensors, would operate in the following manner:

Preflight Checklist (OCRG Consultant Group LLC – Richard Myers can provide these documents if 

required, but requests that the FAA treat them as proprietary under 14 C.F.R. 11.35(b) and not include 

this document in the public docket). Additionally, this petition for exemption is supported by the 

information contained in the 1.) SOLO 3dr smart drone User Manual, 2.) DJI Phantom 2 Vision+ User 

Manual, and DJI Phantom 3 User Manual, and Phantom FC40 User Manual, and 3.) Pixhawk 3DR X8-M

User Manual Pilot Training Guide’s and the Smart Flight Battery Safety Guidelines (hereafter

collectively referred to as “Manufacturer’s Operations and/or Safety Manuals”).
OCRG Consultant Group LLC. Richard Myers

20018 Pinehurst Trail Dr Humble, TX. 77346 TEL: 832-687-7225 FAX: 281-852-3546

Email: Richard1@OurPublicAdjusters.com

OCRG Consultant Group LLC – Richard Myers and team members that have participated in and passed

Our 6 hour training course based on the FAA rules and sUASs manufacture operation and safety manual 

meet the necessary operations requirement under this exemption. We request with this exemption 

should we not be required to hold a commercial, private pilot license. 

OCRG Consultant Group LLC – Richard Myers notes that the FAA has found safety factors permitted 

operation of sUASs by operators with these qualifications in the case of operations pursuant to public 

COAs when the mandatory operating conditions specified above were present. 

Notice of proposed Rulemaking entitled Operation and Certification of Small Unmanned Aircraft 

Systems, 80 F>R> 9544 (February 23, 2015) (“NPRM”), does not require the operator to hold a private 

pilot license or a third class medical.

 Aerial photography and/or video for public and/or private use including real estate, 

architecture,

 land surveying, engineering, insurance claims, roof inspections, large property, fire, natural 

disaster location damage and other related professional activities.

 Aerial video and/or photography of for public and/or private use including television, public 

events, cinematography and news gatherings.

 Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

 Aerial inspection/photography of residential/commercial utility infrastructure included but not

limited to electrical power lines, wind turbines and cell towers.

 Aerial video/photography or providing live video feed to assist with rescue operations in cases 

of an emergency or natural disaster only when the Individual, local authorities or government 

has requested it by contract and/or donation.

 The ability to offer training to persons or individuals belonging to both private and/or public

organizations that have interests in the use and application of UAS for the purpose of the Safe

Operation of a UAS to enhance the safety of national aerospace system (NAS) as well as for

protection of the persons and property.

 The Operator will obtain verbal/written consent of all persons involved with the planned 

operations and ensure only consenting persons will be allowed within 75 feet of the flight 

operation, and the radius may be reduce to 25 feet based upon an equivalent level of safety 

determination, as required under the FOM. With the advance permission of the FFDO, 

operations at closer range may be approved.

As described fully below, and to be used as FOM (exibit#1), the requested exemptions would permit

the operation of a UAS under controlled conditions in the NAS that would be a) limited, b)

controlled, c) predetermined, and d) will provide safety enhancements such as limited exposure to

Flight crew, climbing crews, weight of vehicles, speeds of usage, non-use of volatile fuels, etc.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportations (the FAA administrators) responsibilities to “....establish requirements for the safe

operation of such aircraft systems in the national airspace system.
OCRG Consultant Group LLC. Richard Myers

20018 Pinehurst Trail Dr Humble, TX. 77346 TEL: 832-687-7225 FAX: 281-852-3546

Email: Richard1@OurPublicAdjusters.com

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The primary vehicle to be used will be the 1.) SOLO 3dr smart drone, additional vehicles we request 

exemption will be optional for use. Any upgraded as new technological and safety advance occur the

bar for operation and safety will be set by manufacture and submitted for exemption, 2.) DJI Phantom 2 

Vision+, and DJI Phantom 3, and Phantom FC40, 3.) Pixhawk 3DR X8-M and any new vehicles or versions 

will meet or exceed the current safety and operational standards. No vehicle operated by OCRG 

Consultant Group LLC – Richard Myers, authorized team member will be modified from the

manufacturers design unless specifically directed by the same manufacturer.

The operation limitations proposed for an equivalent or higher level of safety because operations

will further enhance the safety of the persons and/or property using conventional aircraft. These

limitations and conditions to which the applicant agrees to adhere to when conducting commercial

operations under the FAA issued exemption as set forth in the flight operations manual include:

Exhibit #1

lbs.

the pilot in command and/or visual observer

5 minutes. Flights will be terminated at

25% battery power reserve or 35 minutes of flight time whichever occurs first

tude of no more than 400 feet above ground level and no more

than 400 feet above an equivalent platform from which filming is planned.

operate. (Within authorized range, location and must have written documented letter of 

authorization by a contracted work request approved by the airport and FAA for work with additional 

authorized (VO) for building or facility damage inspection).

(Maintain a safe distance from flying Aircraft)

ntrol tower; or

instrument flight procedure

(PIC), the visual observer (VO) and

may include but not limited to a camera operator

will be designated pilot in command and hold a FAA- certificate or private pilot’s license 

or a Current State Driver’s License. If the PIC feels another operator to be qualified with the necessary 

skills to be pilot in command and possesses Current qualified credentials, that person may be designated 

PIC provided they have a minimum of 4 hours of flight time with the UAS.

consisting of all days production activities

ogical conditions (VFR only).

operations and ensure only consenting persons will be allowed.

up-to-date information

for the particular UAS to be operated.
OCRG Consultant Group LLC. Richard Myers

20018 Pinehurst Trail Dr Humble, TX. 77346 TEL: 832-687-7225 FAX: 281-852-3546

Email: Richard1@OurPublicAdjusters.com

have the capability to return to a pre-determined location within a designated location and land

autonomously.

unpredicted obstacles, weather, or emergencies.

or PIC instructed to switch UAS to automatically return home in event either are

incapacitated.

https://www.faa.gov/uas/legislative_programs/section_333/how_to_file_a_petition/media/

section333_public_guidance.pdf

As of March 23, 2015, the FAA will automatically grant a "blanket" COA for flights at or below

200 feet to any UAS operator with a Section 333 exemption, provided the aircraft weighs less

than 55 pounds, operations are conducted during daytime Visual Flight Rules (VFR) conditions

and within visual line of sight (VLOS) of the pilots, and stay certain distances away from

airports or heliports.

In seeking authorization, petitioners will require exemptions from regulations with which they cannot 

fully comply. The table below provides guidance regarding regulations from which a petitioner may

require exemption. However, some proposed operations may require exemption from regulations not 

listed here, while others may not require exemption from all regulations listed here. 

14 CFR PART

Part 21 Airworthiness Certification

21, Subpart H Certification procedures for products and

parts, Airworthiness Certificates

91.103(b)(2) Preflight action

91.105 Flight crewmembers at stations

91.109 Flight instruction

91.119 Minimum safe altitudes

91.121 Altimeter settings

91.151 Fuel requirements for flights in VFR

conditions

91.405 Maintenance required

91.407 Operation after maintenance

91.409 Inspections

91.417 Maintenance

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. Sec 91.203(a)(1)

The UAS will operate @ 55lbs or less (Gross), carries neither a pilot or passenger*, carries no explosive

materials or flammable liquid fuels*, and operates in within a secured and pre-determined designated

area, at altitudes not to exceed 400 ft ALT or speeds in access of 100 MPH.
OCRG Consultant Group LLC. Richard Myers

20018 Pinehurst Trail Dr Humble, TX. 77346 TEL: 832-687-7225 FAX: 281-852-3546

Email: Richard1@OurPublicAdjusters.com

14 C.F.R. Sec 91.105 Flight crew members at station

Exemption may be required, the PIC may not leave his station nor shall VO leave station. In event that

PIC or VO become incapacitated, UAS is to automatically return to designated landing area, as

Outlined in FOM.

14 CFR Sec 91.109 Flight Instructions (Dual Controls)

Requiring that no person shall operate a civil aircraft for flight instruction unless the aircraft has fully

functioning dual controls. AS and Remote controlled aircraft by design do not have dual controls, to

do so on a radio controlled aircraft would lower the ability to safely operate the UAS. This section

cannot reasonably apply.

14 C.F.R. Sec 45.23(b). Marking of the Aircraft

Although exemption from said section cannot benefit nor exceed current stipulations, physical

limitations of UAV are reality, such as cabins, letter size, etc. The UAV will operate under my control

with registration lettering sized to fit fuselage in compliance of said section 45.23(b) under conditions

and or limitations deemed mandatory by FAA . I and my colleges must be held responsible for

compliancy, on behalf of Public’s safety and shared air space, as well as its need to identify and

Enforce the accountability and of this growing industry.

14 C.F.R. Sec 61.113(a) and (b): Private Pilot Privileges and Limitations: 

Pilot in Command by current regulations because the applicants UAS does not carry passengers, or 

property. The use of UAS is far less dangerous (weight, speed, Fuel) than the inherent usage of 

commercial activities outlined in 14 CFR.16. The pilot in command shall have a current Private pilot’s

license FAA-issued airman medical certificate or private pilot’s license or a Current State Driver’s 

License which will equal if not exceed safety regulations outlined in 14 CFR 16.113.(a) & (b).

14 C.F.R. Sec. 91.103: Preflight Action:

Exemption is requested due to fact that FAA rotor flight manuals are not available for UAV. The PIC

will take all actions as stated in FOM, under normal procedures included but not limited to review of

weather, examination of batteries for flight time analysis, landing and takeoff distances as well as

flight and aircraft performance in flight.

14 C.F.R. Sec 91.119; Minimum Safe Altitudes

Mandates safe altitude for operation of civil aircraft and allow helicopter to operates less then

minimums prescribed, providing the person operating helicopter complies with any route with and or

altitudes prescribed for Helicopter’s by FAA. Being that UAV is of Helicopters standards and operation

a request for exemption to operate at altitude’s not to exceed 200 AGL or not more than 400 ft above

any elevated platform from which take off is necessary to achieved filming. In the event of such

particular flight plan, property owners, filming crews and other personnel would all be briefed as to

safety and conduct procedures during flight. FOB or ATC having jurisdiction in such area would have

notification and briefing as mandated.
OCRG Consultant Group LLC. Richard Myers

20018 Pinehurst Trail Dr Humble, TX. 77346 TEL: 832-687-7225 FAX: 281-852-3546

Email: Richard1@OurPublicAdjusters.com

14 C.F.R. Sec 91.121 Altimeter Settings

The requirement of PIC is to use altimeter as means to navigate aircraft to cruise altitudes to and from

corresponding airports as predetermined in flight plan, unless ordered otherwise. As the UAS has no

barometric altimeter, but instead uses GPS altitude read out, an exemption would need be applied.

Per a preflight check list and live flight data monitoring, the altitude of launch site will be

predetermined and therefore calculated into the UAS- GPS indicator before flight.

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

Fuel requirements for flight. The maximum flight time under ideal conditions is 35 minutes with the

current manufacturers battery pack. The proposed rule under this exemption would require the UAS

to return to its point of launch if its battery reaches less than 25% provides a higher standard of safety

when applied to UAS.

14 C.F.R. Sec 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections

Referring to maintenance, preventive maintenance, and alterations to the UAS. The operator will

provide minor maintenance and inspection to the UAS, documented as outlined in the operational

and safety guidelines. Given the size and simplicity of the UAS combined with the operational and

safety guidelines outlined in this petition the operator can maintain or exceed the required level of

safety.

Sincerely

Richard Myers