Quality Drone and Mapping Services **221 S Home Ave Pittsburgh, PA 15202** 
February 9, 2015 U.S. Department of Transportation Docket Management Sy stem 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 commerciall y in airspace regulated b y 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 DJ I Inspire 1, referred hereafter as Inspire. The inherent safety features, sophis tication, programmability , GPS navigation, return home capability , airport vicinit y 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 particularl y safe for the purposes of this petition. This is a hobby

grade radio controlled UAV that has the capacit y for software upgrades. It is light, less than 6.5 pounds including battery and camera. Incorporated into the programming of the Inspire is an aut omatic 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 gy ro - stabi lized gimbal and camera sy stem 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 op erations and will not be operated past the speed of 35 knots. It will be operated within visual line of sight of PI C 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 minim ize risk to persons on the ground (with priority given to those not involved in the Inspire operation). The Inspire has an additional communication linkbetween the camera and craft on a different rf for a smart phone connection. Allowing the

operator or P ilot In Command (PI C) to monitor battery level, altitude (AGL), distance from PI C, camera imagery , and control camera angle. The software for the Inspire allows the operator or PI C 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 AGLcan be programmed into the UAV's DJ I 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 PI C can monitor GPS lock status while UAV is in flight, with the ability to anticipate loss of GPS locking so the operator or PI C can land the UAV as a precaution. The DJ I Inspire 1’s 2.4 ghz transmitter/controller/receiver rf for managing flight with a 5.8 ghz rf transmitter/receiver for video/photograph y 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 s ys tem, 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. IM U calibration, xy

z and acceleration +

- 0.1, z

- 1, +

- 0.1, compass mod 1300

- 1600

 Verify

live camera feed.

 Verify

GPS lock on DJ I Pilot Application.

 Set return to home point.

 Motors can start and are functioning as normal.
**RF Spectrum and FCC Compliance** The DJ I Inspire 1’s 2.4 ghz transmitter/controller/receiver rf for managing flight with a 5.8 ghz rf transmitter/receiver for video/photograph y functions eliminates the rf conflict. The UAS sy stem complies with all applicable FCC regulations. **PIC Qualifications and Responsibilities** The PI C shall hold at minimum a private pilot certificate and a third class airman certificate. The PI C 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 co rrective 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 PI C 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 develop ers 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 manne d 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 PI C and VO wi ll maintain visual line of sight at all times. For additional safet y 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 clearl y defined operational borders of the develo pmental worksite and commercial properties. In addition to the clearl y defined premises, a pre

- flight safet y risk assessment will be conducted before every

operation, to determine that the planned operation can be completed safel y. Details of the pre

- flight safety assessment can be found within page 3 of this document. Currently , the onl y way t o obtain this ty pe 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 highe r 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 greatl y 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 Li mi**  **tations 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 PI C. 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 way s, regar ding 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 propert y on the surface. No waiver is requested, full c ompliance 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 fo r 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 Qualit y Drone Services to conduct operation s 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 PI C 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 maneuverabilit y 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 applicabl e 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). Qualit y Drone Services would use these waivers for the use of unmanned aircraft s ys tems (UAS) for the purpose of collection aerial data for various clients requesting services. Such data c ollecting 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 speci fied 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 e xperimental 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 an y business or emplo ym ent if: (1) The flight is only

inc idental to that business or employ ment; 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 airworth y 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 for ecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and an y known traffic delays of which the pilot in command has been advised by ATC; (b) For an y flight, runway lengths at airports of intended use, and the followi ng 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 ci vil 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 wi nd 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 full y functioning dual controls. **Section 91.119** states that, except wh en necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) An ywh ere. An altitude allowing, if a power unit fails, an emergency landing withoutundue hazard to persons or propert y on the surface.

(b) Over conge sted areas. Over any congested area of a cit y, 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 an y person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and wei ght

- 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 b y 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 fl y after that for at least 30 minutes; or (2) At night, to fl y after that for at least 45 minutes. **Section 91.203** states that: (a) prohibit an y 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 cop y 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 operato r 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 b y a person authorized under§ 43.7 of the same chapte r.**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, annu al, 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 accep table 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 item s 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 safet y directives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safety directive involves r ecurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The own er 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 b y other work or for 1 ye ar 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 ret ained until the defects are repaired and the aircraft is approved for return to serviceIn 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 Pi lot (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