December 31, 2015

US Department of Transportation - Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE

Washington, DC 20590

Petition of Quad Services, LLC for Exemption Pursuant to Section 333 of the FAA Reform Act

To Whom It May Concern:

General Petition Statement

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2102 (“Reform Act”),

Quad Services, LLC, (“Petitioner”), an insurance claim adjuster and property damage

assessment company that performs property damage assessments for the purpose of insurance

claims adjusting, property damage repair estimates and property damage scopes of work,

hereby applies for an exemption from the following Federal Aviation Administration regulations:

14 CFR Part 21, Subpart H - Airworthiness Certificates

14 CFR Part 27, Airworthiness Standards: Normal Category Rotorcraft

14 CFR Part 45, Aircraft Marking and Identification Requirements

14 CFR Part 61, Private Pilot Privileges and Limitations: Pilot in Command

14 CFR Part 91, General Operating and Flight Rules

Petitioner is a small business providing services for insurance claims adjusting, property

damage assessments, property damage repair scopes of work and property damage repair

estimates. The name and address of the Petitioner is as follows:

Quad Services, LLC

C/o Ronnie Miller

5909 CR 605

Burleson, TX 76208

Phone: 469-446-4615

Email: Ronnie.miller@quadservicesllc.com

Reason for Petitioning Relief

Exemption from FAA regulations governing the use the National Airspace System in order to

operate a small and lightweight Unmanned Aircraft System (sUAS) rotorcraft will allow this small

business the opportunity to provide services for insurance claims adjusting, property damage

assessments, property damage repair scopes of work and property damage repair estimates

more efficiently, in less time and in a manner that significantly reduces the risk of harm to our

employees
Operational Guidelines to Ensure Safety

Petitioner will utilize a small and lightweight Unmanned Aircraft System (sUAS) rotorcraft,

weighing 55 pounds or less, to conduct low-altitude aerial surveys of damaged property. The

aerial survey will occur in airspace conditions as follows:

Maximum flight times of 23 minutes

Minimum crew for each operation will consist of the sUAS operator

Written and/or oral permission will be obtained from property owners before conducting

aerial surveys

All required permissions/ permits from federal, state, local and/or tribal authorities,

agencies, jurisdictions and/or governmental officials will be obtained before conducting

aerial surveys

sUAS will operate by Visual line-of-sight (VLOS) only; the unmanned aircraft will remain

within VLOS of the operator or visual observer. At all times the small unmanned aircraft

will remain close enough to the operator for the operator to be capable of seeing the

aircraft with vision unaided by any device other than corrective lenses.

sUAS will not operate over any persons not directly involved in the operation.

Daylight-only operations (official sunrise to official sunset, local time).

sUAS will yield right-of-way to other aircraft, manned or unmanned. May use visual

observer (VO) but not required. The First-person view camera will not supersede “seeand-avoid” requirement but may be used as long as requirement is satisfied in other

ways.

Maximum airspeed of 50 mph (44 knots).

Maximum altitude of 200 feet above ground level.

Minimum weather visibility of 3 miles from control station.

No operations in Class A (18,000 feet & above) airspace. Operations in Class B, C, D

and E airspace are allowed with the required ATC permission. Operations in Class G

airspace are allowed without ATC permission

No person will act as an operator or VO for more than one unmanned aircraft operation

at one time.

No careless or reckless operations.

Preflight inspection by the operator. No person will operate a small unmanned aircraft if

he or she knows or has reason to know of any physical or mental condition that would

interfere with the safe operation of a sUAS.

As stated above, the Petitioner’s proposed sUAS operations will be conducted in a manner that

will not adversely affect safety and is at least equal to the existing rule. The sUAS is a small

battery-operated, remote-controlled rotorcraft weighing 55 pounds or less. It will not be flown in

areas predetermined by the FAA to be no-fly zones for unmanned aircraft systems. The sUAS

will be inspected prior to each flight, flights will be limited to 23-minute durations, flights will only

be conducted in controlled areas with the permission of the property owners and the appropriate

official representatives and flights will be at low altitudes (less than 200 feet above ground).
The Extent of Relief and Specific Sections of 14 CFR

The Federal Aviation Act grants the FAA the authority to exempt civil aircraft, including small

Unmanned Aircraft Systems, from its safety regulations and minimum standards when the

Administrator decides a requested exemption is in the public interest. Therefore, Petitioner

seeks an exemption from several interrelated provisions of 14 CFR Parts 21, 27, 45, 61 and 91

for the purposes of conducting aerial surveys of damaged property within the National Airspace

System.

Public Benefit

The proposed operation is in the public interest and provides a public benefitor the following

reasons:

Improves safety and reduces risk by alleviating human exposure to danger associated

with conducting visual inspections on or within damaged property, facilities, structures

and buildings.

Improves safety and reduces risk by alleviating human exposure to danger associated

with conducting aerial surveys with manned rotary aircraft (helicopters).

Improves environmental safety and reduces ecological impact by utilizing a batteryoperated sUAS versus a fueled aircraft. No carbon emissions from sUAS.

Improves delivery time of critical information needed by private, local public, state, tribal

and federal property owners in order to recover from catastrophic events. Speeding up

the delivery of damage assessments allows insurance carriers to settle claims faster,

property repairs to begin sooner and reconstitution to happen more timely; therefore the

public interest benefits from a speedier recovery.

Federal Register Summary

The following summary is provided for publication in the Federal Register, if determined that

publication is needed:

Quad Services, LLC seeks an exemption from the rules described in the following:

14 CFR Part 21, Subpart H - Airworthiness Certificates

14 CFR Part 27, Airworthiness Standards: Normal Category Rotorcraft

14 CFR Part 45, Aircraft Marking and Identification Requirements

14 CFR Part 61, Private Pilot Privileges and Limitations: Pilot in Command

14 CFR Part 91, General Operating and Flight Rules

Approval of exemptions that allow commercial operations of small and lightweight unmanned

aircraft systems in the insurance claims adjuster and property damage assessment industry will

enhance public safety and promote speedy recovery from catastrophic events