Dear Sir or Madame, The Carova BeachVolunteer Fire and Rescue is respectfullyrequesting and would appreciate an expedited review of our application for the FAA- 333 exemption. As this is our busiest time of year, we would like to have the opportunityto begin operations for public benefit as soon as possible. Thank you Sincerely,



# Firef.~ffreyA. 

### GearhartU.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590 CarovaBeachVolunteerFire &Rescue, Inc.



### RE: Exemption Request under Section 333 ofthe FAAModernization and ReformAct and 14 C.F.R. Part 11 To whom itmay concern: Pursuant to Section 333 ofthe FAAModernization and ReformAct of2012 (the ReformAct) and 14 C.F.R. Part 11, Carova BeachVolunteer Fire & Rescue, Inc. (a 501(c)3 non-profit corporation herein after referred to a CBVF&R), seeks an exemption from the FederalAviation Regulations (FARs) listed and discussed inAppendixA in order to allow for the operation ofsmall UnmannedAircraft Systems (UAS) under the conditions and limitations set forth inthis application for Petition.

CBVF&Rrequests the exemption to permit the operation ofsmall UnmannedAircraft Systems to supportAerial Observation Operations for Fires, Missing Persons, Post Disaster Assessments, Investigating Potential Hazardous Ordinance washing up onthe beach etc. The use ofsUAS will enhance both the success ofthe search andthe safety ofthe searchers in the rural areas that we typically conduct operations. The requested exemption would authorize CBVF&Rto perform operations withthe sUAS that will benefit the public as follows: Acquire real-time aerial views ofFire Locations and SearchAreas that are difficult or dangerous to access on the ground. Real-time information can be used to direct ground teams to areas ofinterest. Water searches in sections that are too rough for divers or boats, and onremote waterways where the sUAS canbe flown in. Acquire digital imagery which canbe analyzed using a Secured PC with the Databeing separately stored and secured. The use ofthe sUAS will significantly reduce the risk and time it would take rescuers onthe ground to the groundto perform searches while increasing the likely-hood ofa successful operation.

1CarovaBeachVolunteerFire &Rescue,**Inc~**

Statement ofBackground and Public Benefit Purpose: To provide anAdvancedAerial/Observation Capability that will Augment 911 responses in the Carova BeachArea. Carova BeachVolunteer Fire & Rescue, Inc. (a 501(c)3 non-profit corporation) and was founded in 1982. Carova Beach is part ofthe NortheastNorth CarolinaRegion and is situated in a 4 wheel drive vehicle only area. The Fire Station houses FourWheel Drive Fire Engines, BrushTrucks, a Tanker and anAmbulance. The RunArea is around 10 miles North and South and is surrounded by The Atlantic Ocean on one side and The Currituck Sound onthe other. Itis a favorite vacationing spot for thousands on any given summer day. There are also around 200 year round residents. Operations will be purely for the benefit ofthe public and no payment will be requested for services provided. The use ofthe sUAS will significantly improve our ability to conduct searches for fires and missing persons inthe remote wilderness areas in which we operate. All imagery collected will be utilized solely for the purpose ofspecific missions and training, A DataManagement Policy has been developed to ensure proper handling ofacquired images and video. The physical risk to the public is minimal and is easily off-set bythe benefits of quickly locating fires and missing persons. This reduces the number offire apparatus onthe beachresponding to incidents and dramatically reduces the riskto the public and search personnel. This will also save time and resources as well as wear and tear on vehicles.

2

### CarovaBeachVolun!_eerFire &

### Rescue, Inc.

The sUAS operations proposed inthis application ofpetition for exemptions qualify for expedited approval under Section 33 3 ofthe ReformAct. This petition outlines how each statutory criteria and other potentially relevant factors are satisfied. The proposed operations wouldpermitthe use ofsmall UAS withinthe National Airspace (NAS) under controlled operational conditions. CBVF&R is proposing to operate a Quad-Copter rotor craftthat will weigh less than 5lbs in flight condition. Operations would occur under normal VFR conditions and at speeds less than 30mph. (the sUAS that will be used are DSLRPros P-2 Nighthawk and the DJI Phantom II Vision-Plus.) Operations will be conductedby qualified operator/observer teams to maximize operational success and safety. For both operational and safety reasons the sUAS will operate at less than400'AGL and within visual line ofsight. The systems will include fail-safe fly-home capability and software preventing operations in controlled/restricted airspace will be utilized. Pertaining to the sUAS: sUAS will weigh typically less than 3 lbs., and always less than 10 lbs. sUAS will operate at a maximum speed ofno greater than 30mph. sUAS will operate below400ftAGL. sUAS shall notbe operated within 5 miles ofan airport sUAS will be operated within visual line ofsight (VLOS) ofthe (PIC) and (VO). sUAS may follow pre-determined flight paths over the mission area conducted via automated navigational flight software. sUAS will be operated under visibility and cloud clearance requirements equivalent to Visual Flight Rules (VFR). sUAS will be equipped with an autopilot system. UAS will utilize GPS navigation, systematic pre-flight checks, and failure safety mechanisms including return-to-home (RTH), auto-land, and flight abort safety features.

3CarovaBeachVolunteerFire &Rescue, Inc.



### Pertainingto Pilots, Visual Observer(s) and Ground Control Station crew: Minimum crew for each operation will consist ofthe UAS Pilot in Command (PIC), Visual Observer (VO) and/or Ground Control Station (GCS) crew. The sUAS pilot will be considered the PIC and be responsible for conducting safe flight operations. GCS personnel will complete training equivalent to a Private Pilots Ground school prior to operational deployment in addition to training onthe hardware and software being utilized, and mission oriented operational requirements. PIC, VO(s) and/or GCS crewwill have communications established in advance ofany flight operations. The sUAS PIC will be trained in advance for the safe operation ofthe sUAS. This will include operation ofthe sUAS both in normal and emergency procedures and will include familiarization with the flight manual furnished by the sUAS manufacturer as well as the Standard Operating Procedures developed by CBVF&R. Training will include basic flight maneuvers, navigational awareness, emergency procedures, loss ofup-link, loss ofdown-link, loss ofGPS and safe flight operations in relation to persons, property and applicable airspace. Training will include a minimum of50 takeoff/landing cycles, 12 hours oftotal time as a sUAS rotor craft pilot and at least 6 hours logged in an internal ground school. The PIC will log a minimum of 1 hour offlight time quarterly for a total minimum of4 hours annually. Specific training will include normal and emergency modes ofoperation and will include familiarization with the operation manual published bythe sUAS manufacturer. Training will also include types ofmaneuvers to be performed during operations including safe operation in relation to persons, property and applicable airspace. sUAS PIC will establish a working relationship with a representative at the local Flight Standards district Office (FSDO) with whichto annually review safety procedures and other operations to further enhance safety.

4

### CarovaBeachVo!unteerFire &

### Rescue, Inc.

Pertaining to Flight Operations: Safety is paramount and risk assessment evaluations will be conducted for safe site operations and flight conditions before eachmission. Prior to a sUAS flight, an area ofoperation will be established. This area of operation will include a defined lateral and vertical area, where the sUAS will operate. Safety procedures will be established for persons, property and applicable airspace withinthe area ofoperation. A briefing will be conducted in regard to the planned sUAS flights prior to operation at each new location. All personnel who will be performing duties within the boundaries ofthe area ofoperation will be present for this briefing. Flights will be conducted in Class G airspace. See and avoid: Ifat any time the operator sees orhears another aircraft and it appears that aircraft may come within one (1) mile ofthe sUAS, or it is questionable whether ornot it will do so, the PIC shall immediately descend the sUAS and direct it on a heading toward the designated landing area, or an alternate landing area ifnecessary, until the sUAS has landed or it is determined the other aircraft has maintained a separation ofone (1) mile. The sUAS shall operate from on-site launch/landing locations directly next to the PIC and GCS crew. Non-essential flight operationpersonnel will be at an appropriate distance away or a minimum of50ft from the operation unless barriers or structures are in place which may sufficiently protect observers or other personnel in case ofsUAS emergency. Flightplanning will include flight completion after 14 minutes or less. A Ground Control Station (GCS) will be connected by radio communication to the sUAS during the entire flight operation. Flight informationrelayed to the PIC will include sUAS altitude, speed, flight time, battery power remaining, horizontal/vertical rate ofchange, azimuth and angle to home.

5CarovaBeach**Volunt~er**Fire &Rescue,**In~:**

In summary, it is the Applicant's beliefthatthe size, weight, speed, operating environment, and operational capabilities ofeach sUAS will provide an "equivalent level ofsafety" or better when operating for public interest as outlined in Section 333 ofthe ReformAct. TheApplicant appreciates the time and consideration given to this request for exemption to permit safe and legal sUAS operations withinthe NAS. Respectfully,

# 9~ Carova BeachVolunteer Fire & Rescue Attn: JeffreyA. Gearhart Telephone: (252) 256-0400 Email: Firemedic@webmail.us 

### P.0. Box 1212, Kill Devil Hills NC, 27948

Attached: Glossary ofTerminology AppendixA- Exemption Requests

6CarovaBeachVo!unteerFire &Rescue, Inc.

GLOSSARY OFTERMINOLOGY:

COA- Certificate ofAuthorization FAA- FederalAviationAdministration FLIR- Forward Looking Infrared GIS- Geographic Information Systems GPS- Global Positioning System GCS- Ground Control Station NAS- NationalAirspace NIR- Near-Infrared NOTAM- Notice to Airmen PIC- Pilot in Command RS- Remote Sensing TIR- Thermal Image Recorder VFR- Visual Flight Rules VLOS- Visual Line ofSight VO- Visual Observer sUAS- Small UnmannedAircraft System

7CarovaBeachVolunteerFire &Rescue, Inc.

APPENDIXA EXEMPTION IS REQUESTED FROM THE FOLLOWING REGULATIONS: Part 21 prescribes the procedural requirements for issuing and changing design approvals, productions approvals, airworthiness certificates, and airworthiness approvals. Exemption Requested Reason: Should not apply to small UAS. Section 45.23(b) prescribes 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 onthat 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. Exemption Requested Reason: Physically impossible to implement on a small UAS. Section 45.29(b)(iii) prescribes, in pertinentpart, that marks at least 3 inches high may be displayed on an aircraft for which the FAA has issued an experimental certificate under §21.191(d), § 21.191 (g), or §21.191(i) ofthis chapter to operate as an exhibition aircraft, an amateur-built aircraft, or a light-sport aircraft whenthe maximum cruising speed ofthe aircraft does not exceed 180 knots calibrated airspeed. Exemption Requested Reason: Physically impossible to implement on a small UAS. Section 61.113 (a)(b) pertains to Private pilotprivileges and limitations: Pilot in command. Exemption Requested Reason: The sUAS won't be carrying any passengers or cargo for compensation or for hire. The operators training from the manufacturer manual creates a higher level ofsafety for the public. A commercial pilot's certificate does notprovide specific safe operational training ofa remote controlled sUAS tethered to the operator orthe ground. Section 61.3 Requirement for certificates, ratings, and authorizations. Exemption Requested Reason: Pilot certification is designed for manned aircraft. Section 91.7 (a) civil aircraft airworthiness. Exemption Requested Reason: No airworthiness certificate is available for this aircraft. The sUAS will be inspected prior to any flight as perthe Standard Operating Guidelines.

8CarovaBeachVolunteerFire &Rescue, Inc.

Section 91.9(b)(2) prohibits operation ofU.S.-registered civil aircraft unless there is available inthe aircraft a current approvedAirplane or Rotor Craft Flight Manual, approved manual material, markings, and placards, or any combinationthereof. Exemption Requested Reason: Physically impossible to implement on a small UAS. Section 91.103 refers to pre-flight action. Exemption Requested Reason: sUAS is not a mannedAircraft. However, all operators will be required to complete pre-flight check offsheets to ensure safe operation prior to flight. The check offincludes: Aircraft inspection, GPS calibration, Transmitter and Video Operation, Battery Level and any Hazards that may be present. Entries will also be made into log books that record flight mission reason, weather conditions at the time offlight, flight date and times, and the sUAS information. Section 91.109(a) prescribes, inpertinent part, 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. Exemption Requested Reason: Physically impossible to implement on a small UAS. Section 91.119 prescribes that, except when necessary for takeoffor landing, no person may operate an aircraft belowthe following altitudes: (a) Anywhere. At an altitude allowing, ifa powerunit fails, an emergency landing without undue hazard to persons orproperty onthe surface. (b) Over congested areas. Over any congested area ofa city, town, or settlement, or over any open air assembly ofpersons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of2,000 feet ofthe aircraft. (c) Over other than congested areas. An altitude of500 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. Ifthe operation is conducted without hazard to persons orproperty onthe surface- (1) A helicopter may be operated at less than the minimums prescribed inparagraph (b) or (c) ofthis section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA, (2) A powered parachute or weight-shift-control aircraft may be operated at less than the minimums prescribed inparagraph (c) ofthis section. Exemption Requested Reason: For operational and safety reasons the UAS needs to operate below400' AGL at all times.

9CarovaBeachVolunteerFire &Rescue, Inc. Section 91.121 requires, inpertinentpart, each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." Exemption Requested Reason: The small UAS will utilize GPS for altitude control. Section 91.151(a) prescribes that no person may begin a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed, during the day, to fly after that for at least 30 minutes. Exemption Requested Reason: Flights will be withinvisual sight, will typically last less than 15 minutes, and battery level will be monitored to ensure a safe UAS recovery. Section 91.203(a) prohibits, in pertinent part, 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 oftheAircraft registrationApplication as provided for in 

### § 47.31(c). Exemption Requested Reason: Physically impossible to implement on a small UAS. Section 91.203(b) prescribes, in pertinent part, that 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. Exemption Requested Reason: Physically impossible to implement on a small UAS. Section 91.205 refers to Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements. Exemption Requested Reason: There is no cockpit and therefore should not apply to a small UAS. Section 91.215 refers to ATC transponder and altitude reporting equipment and use. Exemption Requested Reason: Operations will be below400 feet andATC Radar capabilities. Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E ofthe same part and shall, between required inspections, except as provided in paragraph (c) ofthe same section, have discrepancies repaired as prescribed inpart 43 ofthe chapter. Exemption Requested Reason: Inspections ofsmall UAS will be limited to operational checks ofthe hardware and software prior to each flight.



### 10I ,**~arova**BeachVolunteerFire_&Rescue, Inc.

Section 9L407(a)(1) prohibits, inpertinent part, anyperson from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless ithas been approved for return to service by a person authorized under§ 43.7 ofthe same chapter. Exemption Requested Reason: The small UAS do notpresentthe same risks as manned aircraft and require minimal maintenance. Alterations from manufacturer configuration will notbe made. Section 91 .409(a)(2) prescribes, inpertinentpart, that no person may operate an aircraft unless, withinthe preceding 12 calendar months, it has had an inspection for the issuance ofan airworthiness certificate in accordance withpart 21 ofthis chapter. Exemption Requested Reason: Should not apply to a small UAS. Section 9L417(a) and (b) prescribes, inpertinent part, that- (a) Each registered owner or operator shall keep the following records for the periods specified inparagraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100-hour, annual, progressive, and otherrequired or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include-4 (i) A description (or reference to data acceptable to the Administrator) ofthe work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor. (ii) The current status oflife-limitedparts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed onthe aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection required bythe inspectionprogram under which the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. IftheAD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter for each major alterationto 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 inparagraph (a)(l) ofthis section shall be retained until the work is repeated or superseded by other work orfor 1year after the work is performed. (2) The records specified inparagraph (a)(2) ofthis section shall be retained and transferred withthe aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator Exemption Requested Reason: These records would serve no purpose in enhancing the safe operation of the small UAS. 11CarovaBeach

**Voluntee~**Fire &Rescue, Inc:



### § 4 3.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to serviCe. Exemption Requested Because: These records would serve no purpose in enhancing the safe operation ofthe small UAS FAANotice 8900.227, paragraph 16.c.(4), 

### PICMedical, states that the PIC must maintain, at a minimum, a valid FAA second-class medical certificate issued under 14 CFRpart 67, Medical Standards and Certification, or the FAA-recognized equivalent. Exemption Requested Reason: The medical certificate is predicated onmanned flight. Paragraph 16.e.(l),

### Medical, states that all observers must have a valid FAA second-class medical certificate issued under part 67; an FAA-recognized equivalent is an acceptable means ofdemonstrating compliance with this requirement. Exemption Requested Reason: The medical certificate is predicated onmanned flight.



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