Dear Sir or Madame, 

The Carova Beach Volunteer Fire and Rescue is respectfully requesting 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 opportunity to begin operations for public benefit as soon as possible. Thank you 

Sincerely, 

Firef.~ffrey A. Gearhart 
U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Carova Beach Volunteer Fire & Rescue, Inc. 

RE: Exemption Request under Section 333 of the FAA Modernization and 

Reform Act and 14 C.F.R. Part 11 

To whom it may concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the 

Reform Act) and 14 C.F.R. Part 11, Carova Beach Volunteer Fire & Rescue, Inc. (a 501(c)3 non-profit 

corporation herein after referred to a CBVF&R), seeks an exemption from the Federal Aviation Regulations 

(FARs) 

listed and discussed in Appendix A in order to allow for the operation of small 

Unmanned Aircraft Systems (UAS) under the conditions and limitations set forth 

in this application for Petition. 

CBVF&R requests the exemption to permit the operation of small 

Unmanned Aircraft Systems to support Aerial Observation Operations for Fires, Missing Persons, Post Disaster 

Assessments, Investigating Potential Hazardous Ordinance washing up on the beach etc. The use of sUAS will 

enhance both the success of the search and the safety of the searchers in the rural areas that we typically conduct 

operations. 

The requested exemption would authorize CBVF &R to perform 

operations with the sUAS that will benefit the public as follows: 

Acquire real-time aerial views of Fire Locations and Search Areas that are difficult or dangerous to access on 

the ground. Real-time information can be used to direct ground 

teams to areas of interest. Water searches in sections that are too rough 

for divers or boats, and on remote waterways where the sUAS can be flown in. 

Acquire digital imagery which can be analyzed using a Secured PC with the Data being separately stored and 

secured. 

The use of the sUAS will significantly reduce the risk and time it would take rescuers on the ground to the 

ground to perform searches while increasing the likely-hood of a successful operation. 

1 
Carova Beach Volunteer Fire & Rescue, Inc~ 

Statement of Background and Public Benefit 

Purpose: To provide an Advanced Aerial/Observation Capability that will Augment 911 responses in the Carova 

Beach Area. 

Carova Beach Volunteer Fire & Rescue, Inc. (a 501(c)3 non-profit corporation) and was founded in 1982. 

Carova Beach is part of the Northeast North Carolina Region and is situated in a 4 wheel drive vehicle only 

area. The Fire Station houses Four Wheel Drive Fire Engines, Brush Trucks, a Tanker and an Ambulance. The 

Run Area is around 10 miles North and South and is surrounded by The Atlantic Ocean on one side and The 

Currituck Sound on the other. It is 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 of the 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 in the remote wilderness areas in which we operate. 

All imagery collected will be utilized solely for the purpose of specific missions 

and training, A Data Management Policy has been developed to ensure proper handling of acquired images and 

video. 

The physical risk to the public is minimal and is easily off-set by the benefits of 

quickly locating fires and missing persons. This reduces the number of fire apparatus on the beach responding 

to incidents and dramatically reduces the risk to the public and search personnel. This will also save time and 

resources as well as wear and tear on vehicles. 

2 
Carova Beach Volun!_eer Fire & Rescue, Inc. 

The sUAS operations proposed in this application of petition for exemptions qualify 

for expedited approval under Section 3 3 3 of the Reform Act. This petition outlines 

how each statutory criteria and other potentially relevant factors are satisfied. 

The proposed operations would permit the use of small UAS within the National 

Airspace (NAS) under controlled operational conditions. 

CBVF&R is proposing to operate a Quad-Copter rotor craft that 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 DSLR Pros P-2 Nighthawk and the 

DJI Phantom II Vision-Plus.) Operations will be conducted by qualified 

operator/observer teams to maximize operational success and safety. For both 

operational and safety reasons the sUAS will operate at less than 400' AGL and 

within visual line of sight. 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 of no greater than 30mph. 

sUAS will operate below 400ft AGL. 

sUAS shall not be operated within 5 miles of an airport 

sUAS will be operated within visual line of sight (VLOS) of the (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. 

3 
Carova Beach Volunteer Fire & Rescue, Inc. 

Pertaining to Pilots, Visual Observer(s) and Ground Control Station crew: 

Minimum crew for each operation will consist of the 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 on the 

hardware and software being utilized, and mission oriented operational 

requirements. 

PIC, VO(s) and/or GCS crew will have communications established in 

advance of any flight operations. 

The sUAS PIC will be trained in advance for the safe operation of the sUAS. This will include operation of the 

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 of up-link, 

loss of down-link, loss of GPS and safe flight operations in relation to persons, property and applicable airspace. 

Training will include a minimum of 50 takeoff/landing cycles, 12 hours of total 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 of flight time 

quarterly for a total minimum of 4 hours annually. Specific training will include normal and emergency modes 

of operation and will include familiarization with the operation manual published by the sUAS manufacturer. 

Training will also include types of maneuvers 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 which to annually review safety procedures and other operations to further enhance safety. 

4 
Carova Beach Vo!unteer Fire & Rescue, Inc. 

Pertaining to Flight Operations: 

Safety is paramount and risk assessment evaluations will be conducted for 

safe site operations and flight conditions before each mission. 

Prior to a sUAS flight, an area of operation 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 within the area of operation. 

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 of the area of operation will be present for this 

briefing. 

Flights will be conducted in Class G airspace. 

See and avoid: If at any time the operator sees or hears another aircraft and it 

appears that aircraft may come within one (1) mile of the sUAS, or it is 

questionable whether or not 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 if necessary, until the sUAS has landed or it is 

determined the other aircraft has maintained a separation of one (1) mile. 

The sUAS shall operate from on-site launch/landing locations directly next to 

the PIC and GCS crew. Non-essential flight operation personnel will be at an 

appropriate distance away or a minimum of 50ft from the operation unless 

barriers or structures are in place which may sufficiently protect observers or 

other personnel in case of sUAS emergency. 

Flight planning 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 information relayed to 

the PIC will include sUAS altitude, speed, flight time, battery power 

remaining, horizontal/vertical rate of change, azimuth and angle to home. 

5 
Carova Beach Volunt~er Fire & Rescue, In~: 

In summary, it is the Applicant's belief that the size, weight, speed, operating 

environment, and operational capabilities of each sUAS will provide an "equivalent 

level of safety" or better when operating for public interest as 

outlined in Section 333 of the Reform Act. The Applicant appreciates the time and 

consideration given to this request for exemption to permit safe and legal sUAS 

operations within the NAS. 

Respectfully, 

Carova 

9~ Beach Volunteer Fire & Rescue 

Attn: Jeffrey A. Gearhart 

Telephone: (252) 256-0400 

Email: Firemedic@webmail.us 

P. 0. Box 1212, Kill Devil Hills 

NC, 27948 

Attached: 

Glossary ofTerminology 

Appendix A- Exemption Requests 

6 
Carova Beach Vo!unteer Fire & Rescue, Inc. 

GLOSSARY OF TERMINOLOGY: 

COA- Certificate of Authorization 

FAA- Federal Aviation Administration 

FLIR- Forward Looking Infrared 

GIS- Geographic Information Systems 

GPS- Global Positioning System 

GCS- Ground Control Station 

NAS- National Airspace 

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 of Sight 

VO- Visual Observer 

sUAS- Small Unmanned Aircraft System 

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Carova Beach Volunteer Fire & Rescue, Inc. 

APPENDIX A 

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 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. 

Exemption Requested Reason: Physically impossible to implement on a small UAS. 

Section 45.29(b)(iii) prescribes, in pertinent part, 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) 

of this chapter to operate as an exhibition aircraft, an amateur-built aircraft, or a light-sport aircraft when the 

maximum cruising speed of the 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 pilot privileges 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 of safety for the 

public. A commercial pilot's certificate does not provide specific safe operational training of a remote 

controlled sUAS tethered to the operator or the 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 per the Standard Operating Guidelines. 

8 
Carova Beach Volunteer Fire & Rescue, Inc. 

Section 91.9(b)(2) prohibits operation ofU.S.-registered civil aircraft unless there is available in the aircraft a 

current approved Airplane or Rotor Craft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof. 

Exemption Requested Reason: Physically impossible to implement on a small UAS. 

Section 91.1 03 refers to pre-flight action. 

Exemption Requested Reason: sUAS is not a manned Aircraft. However, all operators will be required 

to complete pre-flight check off sheets to ensure safe operation prior to flight. The check off includes: 

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 of flight, flight date and times, and the sUAS information. 

Section 91.109(a) prescribes, in pertinent 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 takeoff or landing, no person may operate an aircraft 

below the following altitudes: 

(a) Anywhere. At 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 of 2,000 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, 

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

in paragraph (c) of this section. 

Exemption Requested Reason: For operational and safety reasons the UAS needs to operate below 400' 

AGL at all times. 

9 
Carova Beach Volunteer Fire & Rescue, Inc. 

Section 91.121 requires, in pertinent part, 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." 

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 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, during the day, to fly after that for at least 30 minutes. 

Exemption Requested Reason: Flights will be within visual 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 of the Aircraft registration Application as 

provided for in § 4 7.31 (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 below 400 feet and ATC 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 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. 

Exemption Requested Reason: Inspections of small UAS will be limited to operational checks of the 

hardware and software prior to each flight. 

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I , 

~arova Beach Volunteer Fire_& Rescue, Inc. 

Section 9L407(a)(1) prohibits, in pertinent part, 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. 

Exemption Requested Reason: The small U AS do not present the same risks as manned aircraft and 

require minimal maintenance. Alterations from manufacturer configuration will not be made. 

Section 91 .409(a)(2) prescribes, in pertinent part, 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. 

Exemption Requested Reason: Should not apply to a small UAS. 

Section 9L417(a) and (b) prescribes, in pertinent part, 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-4 

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and 

(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 oflife-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) ofthis 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) ofthis 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 

Exemption Requested Reason: These records would serve no purpose in enhancing the safe operation of 

the small UAS. 

11 
Carova Beach Voluntee~ Fire & Rescue, Inc: 

§ 4 3 .11 of this 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 of the 

small UAS FAA Notice 8900.227, paragraph 16.c.(4), PIC Medical, states that the PIC must maintain, at a 

minimum, a valid FAA second-class medical certificate issued under 14 CFR part 67, Medical Standards and 

Certification, or the FAA-recognized equivalent. 

Exemption Requested Reason: The medical certificate is predicated on manned 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 of demonstrating compliance with 

this requirement. 

Exemption Requested Reason: The medical certificate is predicated on manned flight. 

12