Quality Drone and Mapping Services

221 S Home Ave

Pittsburgh, PA 15202

February 9, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

To Whom It May Concern:

I, Kevin Cowey, on behalf of Quality Drone and Mapping Services, am writing pursuant to the 

FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, 

to request that the aforementioned organization may operate a SUAS commercially in airspace 

regulated by the Federal Aviation Administration.

Drone Capabilities and Public Safety/Interest

The UAV/UAS/UA which Quality Drone and Mapping Services, Petitioner, will be operating is 

the DJI Inspire 1, referred hereafter as Inspire. The inherent safety features, sophistication, 

programmability, GPS navigation, return home capability, airport vicinity no—f|y feature and 

restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft 

controller/receiver and for the camera make this a UAV particularly safe for the purposes of this 

petition. This is a hobby grade radio controlled UAV that has the capacity for software upgrades. 

It is light, less than 6.5 pounds including battery and camera. Incorporated into the programming 

of the Inspire is an automatic return home feature that automatically directs the craft back to 

point of take off should communication with the transmitter be lost. The Inspire has a maximum 

speed of 43 knots. It is designed to operate in less than 20 knot winds, but for safety, stability, 

and fear of financial loss, the Inspire will not be flown in winds exceeding 16 knots. Maximum 

flight time is 22 minutes. All flights will be limited to 15 minutes, as a safety precaution. Gross 

weight is 6.48 pounds. The craft has a gyro-stabilized gimbal and camera system as payload. The 

UAS will not be operated beyond 400 ft. AGL in order to maximize safe operations within NAS. 

The Inspire is also to remain 300 ft. from all persons, other than essential operational personnel, 

during flight operations and will not be operated past the speed of 35 knots. It will be operated 

within visual line of sight of PIC and visual observer at all times, in order to minimize risk to the 

NAS or persons and property on the ground. Operations will also require signage in the vicinity

of the operational area in order to secure a safe operational space during flight. In the instance 

that a non-essential or unauthorized person enters the operational space, operations will be 

immediately terminated in order to minimize risk to persons on the ground (with priority given to 

those not involved in the Inspire operation). The Inspire has an additional communication link 
between the camera and craft on a different rf for a smart phone connection. Allowing the 

operator or Pilot In Command (PIC) to monitor battery level, altitude (AGL), distance from PIC, 

camera imagery, and control camera angle.

The software for the Inspire allows the operator or PIC to set maximum altitude AGL for each 

flight, allowing customization of flights to no higher than 100 feet, 150 feet, or 250 feet AGL as 

an example. The 400 foot maximum AGL can be programmed into the UAV's DJI Pilot App to 

insure compliance with FAA standards. Adding to the safety capabilities of this UAV, this UAV 

is programmed to remain in position when controls are released, maintaining altitude and GPS 

location.

The Inspire has an altitude monitoring function that allows the operator more precise 

determination of height, direction of flight and distance from the operator PIC. The operator or 

PIC can monitor GPS lock status while UAV is in flight, with the ability to anticipate loss of 

GPS locking so the operator or PIC can land the UAV as a precaution.

The DJI Inspire 1’s 2.4 ghz transmitter/controller/receiver rf for managing flight with a 5.8 ghz rf 

transmitter/receiver for video/photography functions eliminates the rf conflict experienced with 

other UAS models. 

Drone Preflight, Maintenance and Safety of Flight

In order to promote the best interests in protecting persons and public property, a UAV checklist 

has been drafted in line with the manufacturers recommended operating procedures. Prior to 

each flight the PIC must execute the pre-flight checklist (as seen below) in accordance with the 

Inspire 1’s User Manual Version V1.1.1 Dated April 4,2014, p. 37, and compliance with 

operational documents. 
UAV Checklist

Preflight

 Arrive on site and make flight terrain and hazards assessment.

 Designate the landing site with cones and “drone in operation” signs.

 Install matched propellers to drone motors.

 Install propeller locks.

 Perform overall drone check.

 Damping absorbers are in good condition, not broken or worn.

 Anti-drop kits have been mounted correctly.

 Camera lens cap has been removed.

 Micro-SD card has been inserted if necessary.

 Gimbal is functioning as normal.

 Initialize drone system, battery packs, and camera gimbal.

 Verify battery status on transmitter.

1. Transmitter at least 50% for takeoff operation.

 Verify drone battery status.

1. Minimum drone battery is at least 75% for takeoff.

 Verify battery status on visual device.

1. Minimum battery is at least 50% for takeoff operation.

 Sensors and compass page.

1. IMU calibration, xyz and acceleration + - 0.1, z-1, + - 0.1, compass mod 1300-1600

 Verify live camera feed.

 Verify GPS lock on DJI Pilot Application.

 Set return to home point.

 Motors can start and are functioning as normal.

RF Spectrum and FCC Compliance

The DJI Inspire 1’s 2.4 ghz transmitter/controller/receiver rf for managing flight with a 5.8 ghz 

rf transmitter/receiver for video/photography functions eliminates the rf conflict. The UAS 

system complies with all applicable FCC regulations. 

PIC Qualifications and Responsibilities

The PIC shall hold at minimum a private pilot certificate and a third class airman certificate. The 

PIC shall have accumulated and logged, in a manner consistent with 14 CFR61.51(B), 25 hours 

of total time as a UAS rotor-craft pilot, including at least 10 hours logged as a UAS pilot with a 

multi-rotor UAS. The PIC shall also have accumulated and logged a minimum of 5 hours as a 

UAS pilot operating the same make and model of the UAS to be used for operations under the 

exemption. The visual observer(VO) must be able to maintain visual line of sight with no 

assistance beyond corrective lenses. It is the responsibility of the PIC to make the determination 

for a qualified visual observer and to be aware of VO limitations. Moreover, the VO will not be 

operating the UAS and therefore does not require a medical certificate. 
Medical standards and Certification of PIC

The PIC will be required to hold a third class airman certificate. The visual observer(VO) must 

be able to maintain visual line of sight with no assistance beyond corrective lenses. It is the 

responsibility of the PIC to make the determination for a qualified visual observer and to be 

aware of VO limitations. Moreover, the VO will not be operating the UAS and therefore does not 

require a medical certificate. 

UAS Operations and Assurance of Public Safety 

The purpose of this UAS operation will be to create 3D and 2D imagery of construction and 

developmental worksites, industrial facilities, and commercial properties. The mapping 

information obtained through this imagery will help engineers, company owners, and developers 

to perform virtual measurements and assessments to make operations more efficient and allow 

for safer project assessment on the part of professional staff, with less time on site. The use of a 

UAS for such operations will eliminate the need for a manned aircraft to gather data as well as 

the high cost also associated with such an operation. All non-essential flight personnel will be 

asked to leave the UAS operational area and will be informed of the presence of UAS flight in 

progress. Both PIC and VO will maintain visual line of sight at all times. For additional safety in 

maintaining line of sight, the UAS is equipped with a return to home feature. Therefore, every

effort will be made to ensure that no threat is posed to those on an active worksite. UAS 

operations will only be performed in reasonably safe environments that are strictly controlled, 

away from airports, actively populated areas, and passersby. Flight operations will be conducted 

within the clearly defined operational borders of the developmental worksite and commercial 

properties. In addition to the clearly defined premises, a pre-flight safety risk assessment will be 

conducted before every operation, to determine that the planned operation can be completed 

safely. Details of the pre-flight safety assessment can be found within page 3 of this document. 

Currently, the only way to obtain this type of specific imagery is through the use of manned 

aircraft such as a rotor-craft or fixed wing aircraft. By using a UAS for such operations, a higher 

level of safety can be achieved for three primary reasons:

 First, the potential loss of life is diminished because a UAS carries no person onboard 

and will only be operated in specific areas, away from mass populations. 

 Second, there is no fuel on-board a UAS, and thus the potential for fire or explosion is 

greatly diminished. 

 Third, the small size and extreme maneuverability allows for greater control on the behalf 

of the pilot in order to avoid and move away from hazards quickly and safely. 

Drone Limitations and Operating Requirements

The maximum proposed operating speed of the Inspire will be 35 knots and the maximum 

altitude will be 400 ft. AGL. The UAS may not be operated less than 500 ft. below or less than 

2000 ft. horizontally from a cloud or when the visibility is less than 3 miles from the PIC. These 

proposed limitations will provide a level of safety equal to VFR flight. 
Area of Intended Operations

The intended operational areas will be construction and developmental worksites, industrial 

facilities, and commercial properties. Therefore, access to the general public is already restricted 

which helps to facilitate a safe area of operations. With respect to 14 CFR 91.119, we can 

comply with each section in the following ways, regarding this UAS waiver request:

 Section A- For the purpose these UAS operations, with respect to power unit failure, an 

emergency landing will be able to be completed without undue hazards to persons or 

property on the surface. No waiver is requested, full compliance can be achieved for 

these UAS operations.

 Section B- These UAS operations will not take place over congested areas of a city, town 

or settlement, or over any open air assembly of persons. No waiver is requested, full 

compliance can be achieved for these UAS operations.

 Section C- Quality Drone Services seeks a waiver to allow UAS operation closer than 

500 feet in proximity of any persons, vessels, vehicle, or structure. We request that the 

variance allow Quality Drone Services to conduct operations closer than 500 feet to 

vehicles, vessels, and structures when the owner/controller of any such vehicles, vessels 

or structures grants permission for the operator and the PIC makes a safety assessment of 

the risk of operating closer to those objects and determines that it does not present an 

undo hazard. With respect to persons, we request variance to allow operations no closer 

than 300 feet from non-participating persons. We believe this will provide an equivalent 

level of safety as the existing standard due to the small size and extreme maneuverability 

of the UAS. 

The UAS will be operated outside of 5 nautical miles of an airport reference point, as denoted on 

a published aeronautical chart, unless written permission is first obtained from any applicable 

airports, and the airport files a NOTAM describing flight duration and area of operation. Quality

Drone Services does not intend to conduct UAS operations that have existing requirement to 

notify the FSDO.

Request for Exemptions

Quality Drone Services, is requesting waivers that qualify under the following Federal Aviation 

Regulations. Part 21, §§45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 

91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and 

(b) of Title 14, Code of Federal Regulations (14 CFR). Quality Drone Services would use these 

waivers for the use of unmanned aircraft systems (UAS) for the purpose of collection aerial data 

for various clients requesting services. Such data collecting would include videos, optical 

registration, and topography.

Part 21 describes the procedural requirements for issuing and changing design approvals, 

production approvals, airworthiness certificates, and airworthiness approvals in addition to rules 

governing applicants for, and holders of, any approval or certificate specified in paragraph 

procedural requirements for the approval of articles.
Section 45.23(b) states that when marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or light- sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that aircraft 

near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable.

Section 61.113 states that:

(a) no person who holds a private pilot certificate may act as a pilot in command of an

aircraft that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as pilot in command of an aircraft.

(b) a private pilot may, for compensation or hire, act as pilot in command of an aircraft in 

connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

Section 91.7(a) states that no person may operate a civil aircraft unless it is in an airworthy 

condition.

Section 91.9(b)(2) states that the operation of U.S.-registered civil aircraft is prohibited unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

Section 91.103 states that each pilot in command shall, before beginning a flight, become 

familiar with all available information concerning that flight, to include:

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be 

completed, and any known traffic delays of which the pilot in command has been advised 

by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff 

and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual

containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(l) of this section, 

other

reliable information appropriate to the aircraft, relating to aircraft performance 

under expected values of airport elevation and runway slope, aircraft gross 

weight, and wind and temperature.

Section 91.109 states that no person may operate a civil aircraft (except a manned free balloon) 

that is being used for flight instruction unless that aircraft has fully functioning dual controls.

Section 91.119 states that, except when necessary for takeoff or landing, no person may operate 

an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without
undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over 

any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle 

within a horizontal radius of2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is

conducted without hazard to persons or property on the surface.

(1) A helicopter may be operated at less than the minimums prescribed in 

paragraph(b)or (c) of this section, provided each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the 

FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less 

than the minimums prescribed in paragraph (c) of this section.

Section 91.121 states that each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set "to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.

Section 91.151(a) states that no person may begin a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first 

point of intended landing and, assuming normal cruising speed,

(1) during the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Section 91.203 states that:

(a) prohibit any person from operating a civil aircraft unless it has within it (1) an 

appropriate and current airworthiness certificate; and (2) an effective U.S. registration 

certificate issued to its owner or, for operation within the United States, the second copy 

of the Aircraft Registration Application as provided for in § 4 7.31 (c).

(b) no person may operate a civil aircraft unless the airworthiness certificate or a special 

flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew.

Section 91.405(a) requires that an aircraft operator or owner shall have that aircraft inspected as 

prescribed in subpart E of the same part and shall, between required inspections, except as 

provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 

43 of the chapter.

Section 91.407(a)(l) prohibits any person from operating an aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for 

return to service by a person authorized under§ 43.7 of the same chapter.
Section 91.409(a)(2) states that no person may operate an aircraft unless, within the preceding 

12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter.

Section 91.417(a) and (b) states that:

(a) Each registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include:

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed;

(ii) The date of completion of the work performed; and

(iii) The signature and certificate number of the person approving the 

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(l) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service
In conclusion, I would like to take this time to inform you that if there are any issues that deserve 

further attention to the section 333 proposal for exemptions to contact Quality Drone and 

Mapping Services personnel at your convenience. Thank you for your time and consideration for 

our proposal.

Kevin Cowey

Owner, President, and Inspector for an FAA part 145 Avionics Repair Station, A&P Mechanic 

and Private Pilot

(304)224-5735

Gary Hutchinghson

Owner, Vice-President, and Chief Inspector for an FAA part 145 Avionics Repair Station, A&P 

Mechanic

724-971-9295

Robert Schattauer

Commercial Pilot, Chief Pilot for Part 141 Flight School, CFI, CFII, MEI

(724)991-9065