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August 30, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12-140

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act of 2012 and Part 11 of the 

Federal Aviation Regulations

Dear Sir or Madam:

I am writing pursuant to the FAA Modernization and Reform Act of 2012 (the “Reform 

Act”) and the procedures contained in 14 C.F.R. 11, to request that Drone Search and Rescue 

(Drone SAR), owned and operated by Karl D Carichner petition for exemption from the Federal 

Aviation Regulations (“FARs”) listed below so that Drone Search and Rescue may operate its 

small unmanned aircraft/lightweight unmanned aircraft systems (“UAS”) commercially in

airspace regulated by the Federal Aviation Administration (“FAA”).

Primary uses will be the contracted, search and rescue for lost individuals, disaster 

mitigation (when called upon by state and local agencies; including county Emergency 

Management Agencies as well as local fire departments) and low altitude aerial photography for 

use on websites, print pieces and video for client use.

I have operated current UAS on many occasions non-commercially without incident. The

specific UAS that Drone Search and Rescue will operate, utilizes battery power, not combustible 

fuels. Flight time ranges between five and thirty minutes. The UAS has GPS functionality to 

hover in place as well as a return to programmed takeoff and land position function in case of 

loss of contact with the radio. The programmable software will disable the UAS from taking off 

and also limit the UAS system from operating within specific GPS set no-fly zones. For further 

information please visit http://www.dji.com/fly-safe/category-mc. 

Drone Search and Rescue exemption request would permit its operation of lightweight, 

unmanned (piloted by remote control) and comparatively inexpensive UASs in tightly controlled 

and limited airspace. Currently, similar remote controlled UASs are legally operated by the 

general public with no flight experience, safety plan, Standard Operating Procedures (SOP’s) or 

controls in place to prevent a disaster. It is only logical to allow Karl D Carichner, an 

experienced remote control pilot, to operate a similar lightweight UAS for a commercial 

purpose. Drone Search and Rescue will conduct its operations in compliance with the protocols 

described herein or as otherwise established by the FAA along with its’ own company standard 

operating procedures.
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For the reasons stated below, Drone Search and Rescue respectfully requests the grant of 

an exemption allowing it to operate lightweight, remote controlled UAS.

1. Contact Information:

Karl D Carichner

Owner/Operator

Drone Search and Rescue

38 Remington Road

Tunkhannock, PA 18657

Tel.: (570) 903-2895

E-mail: karl@yourdronesolution.com

2. The Specific Sections of Title 14 of the Code of Federal Regulations from Which 

Drone Search and Rescue Request Exemption are:

14CFR 21:

14 C.F.R. 45.23 (b):

14 CFR 61m113 (a) & (b):

14 C.F.R. 91, et seq.:

14 CFR 407 (a) (1):

14 CFR 409 (a) (2):

14 CFR 417 (a) & (b).

3. The Extent of Relief Drone Search and Rescue Seeks and the Reason It Seeks 

Such Relief:

Drone Search and Rescue submits this application in accordance with the Reform Act, 

112 P.L. 95§§ 331-334, seeking relief from any currently applicable FARs operating in search 

and rescue operations, cinematic, research and other flight operations within the National 

Airspace System. The Reform Act in Section 332 provides for such integration of civil 

unmanned aircraft systems into our National Airspace System as it is in the public’s interest to 

do so. Drone Search and Rescue lightweight UAS meets the definition of “Small Unmanned 

Aircraft” as defined in Section 331 and therefore the integration of our lightweight UAS is 

expressly contemplated by the Reform Act. We would like to operate our lightweight UAS prior 

to the time period by which the Reform Act requires the FAA to promulgate rules governing 

such craft.
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The Reform Act guides the Secretary in determining the types of UASs that may operate

safely in our National Airspace System. Considerations include:

• The weight, size, speed and overall capabilities of the UAS:

• Whether the UAS will be operated near airports or populated areas: and,

• Whether the UAS will be operated by line of sight.

112 P.L. 95 § 333 (a). Each of these items militates in favor of an exemption for Drone Search 

and Rescue.

Our UAS (the DJI Phantom 3 Professional) utilizes four counter-rotating propellers for 

extreme balance, control and stability. It weighs less than five pounds, including battery and all 

available equipment. This small unmanned aircraft is designed to primarily hover in place and 

operate at less than a 50 knot maximum speed. It is capable of vertical and horizontal operation 

but operates only within the line of sight of the remote control pilot. In addition to the remote 

control pilot, our SOP dictates a spotter is used, making at minimum, two UAS trained Drone 

Search and Rescue personnel on-site to govern the safe flight of the aircraft at all times.

Utilizing battery power and non-combustible fuels, flights generally last between five and 

thirty minutes. We do not operate the UAS with less than twenty five percent battery capacity. 

Safety systems in place include a GPS monitor that allows the UAS to hover in place or return to 

takeoff (or programmed) location if communication with the radio control pilot is lost. Drone 

Search and Rescue never operates the UAS near airports or in highly populated areas. To date, 

we have only operated the UAS in a non-commercial manner.

Our operation of this small unmanned aircraft will not “create a hazard to users of the 

National Airspace System or the public.” 112 P.L. 95 § 333 (b). Given the small size, weight and 

operational parameters of the UAS, combined with its operation in cordoned off and wellcontrolled areas or emergency scenes, this falls within Congress’s contemplated safety zone 

when it promulgated the Reform Act and the corresponding directive to integrate UASs into the 

National Airspace System. Our UAS will, without question, not pose any threat to the general 

public or national security.

The FAA has the authority to issue the exemption sought by Drone Search and Rescue

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the “Act”).

4. How this Request Will Benefit the Public As A Whole:

Granting this exemption request furthers the public interest. Congress has already 

pronounced that it is in the public’s interest to integrate commercially flown UASs into the 

National Airspace System, hence the passing of the Reform Act. Drone Search and Rescue

conducts research into safe UAS operations every time it flies its UAS. Flight data, visual 

inspections, recorded observations and flight analyses are compiled to further enhance current 

safety protocols. Allowing Drone Search and Rescue to log more flight time directly relates to 

our ability to further enhance current safety measures. Drone Search and Rescue will directly be 

serving in the public’s best interest due to our company mission and goals. We will be an on-call 

resource for local and state emergency management agencies, fire departments or police 

departments to assist them in better serving the public in: search and rescues for missing/injured 
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person(s), wanted person(s) dangerous to those around them, and help mitigate disaster situations 

as they are happening.

Furthermore, the public has an interest in reducing the danger and emission associated 

with current aerial assisted searches and cinematic capture methods, namely, full size 

helicopters. Our UAS is battery powered and creates no emissions. If our UAS crashes there is 

no fuel to ignite and cause fire or explosions. The impact of our lightweight UAS is negligible 

when compared to a full size helicopter. The public’s interest is furthered by minimizing 

ecological and crash impacts by permitting search and rescue operations along with photo and 

motion picture capture through our lightweight UAS. Progression of the arts and sciences has 

been fundamental to our society since its inclusion in the United States Constitution. Congress 

mandated the integration of UASs into our National Airspace System, in part, to achieve 

progression in this noteworthy and inevitable field. Permitting Drone Search and Rescue to 

immediately fly within the United States furthers these goals. In addition granting this request 

will also allow the rapid and cost effective use of aerial surveillance in search and rescue 

operations, disasters. It will also allow small business owners and home owners to be able to 

afford high quality aerial images and video that they would otherwise have no access to due to 

several factors having cost being the largest burden.

5. Reasons Why Drone Search and Rescue Exemption Will Not Adversely Affect Safety Or 

How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

This exemption will not adversely affect safety. Due to the reasons stated previously, 

permitting Drone Search and Rescue to log more flight time in FAA controlled airspace will 

allow us to innovate and implement new, more efficient and widely dispersed safety protocols. In 

addition, the following specifications will help to ensure the safety of everyone involved in the 

operation of Drone Search and Rescue Drones’:

• Our UAS weighs less than five pounds complete with all mounted equipment, accessories and 

battery: 

• We only operate our UAS below 400 feet

• Our UAS only operates for 5-30 minutes per flight

• We land our UAS when it reaches 25% battery power

• Our UAS pilot and spotter are certified by a private company and attend in-house-training to 

fly the UAS

• Our remote control pilot operates the UAS by line of sight

• Our remote control pilot has video backup should he/she somehow lose sight of the UAS

• Each flight is staffed with a remote control pilot and spotter, with communication systems 

enabling real time communication between all three

• Our UAS has GPS flight modes that allow it to hover, return to takeoff position and slowly land

if communication with the remote control pilot is lost
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• We actively analyze electronic flight data, actively train pilots and constantly update the UAS’ 

on-board computer to help enhance our safety protocols (Appendix A includes a copy of our 

Phantom 3 Pre-Flight Checklist)

• We conduct extensive briefings prior to flight during which safety carries primary importance

• We have procedures in place to abort flights in the event of safety breaches, threats or potential 

danger

Our safety protocols provide a level of safety that exceeds existing rules and laws. It is important 

to note that without the integration of commercial UASs into our National Airspace System, 

helicopters are the primary means of search and rescue, wide area surveillance and aerial picture 

capture. While the safety record of such helicopters is impeccable, it is far safer and efficient to 

operate a battery powered lightweight UAS. The potential loss of life and destruction of property

is diminished because UASs carry no individuals on board and Drone Search and Rescue only 

operates the UAS in specific areas away from high populations. There is no fuel on board a UAS 

and thus the potential for fire or explosions is virtually non-existent. The small size and extreme 

maneuverability of our UAS allows our remote control pilot to avoid hazards and is much easier

to fly than traditional helicopters. Given their small size and weight, even when close enough to 

capture extremely high-resolution images, our UAS does not need to be close to the objects it is 

focused on. For these reasons, our UAS has operated and will continue to operate at and above 

current safety levels.

6. Summary: 

A. 14 C.F.R. 21 and 14 C>F>R> 91: Airworthiness certificates and Manuals. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, 

weight and enclosed operational area of Drone Search and Rescue’s UAS permits exemption 

from Part 21 because Drone Search and Rescue’s UAS meets an equivalent level of safety 

pursuant to Section333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f) and Section 333 

of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from the 

airworthiness certificate requirement in consideration of the weight, size speed, maneuverability 

and proximity to areas such as airports and dense populations. Drone Search and Rescue UAS 

meets or exceeds each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the FARs, this 

regulation is inapplicable. 

14 C.F.R § 91.9(b) (2) requires an aircraft flight manual in the aircraft. As there are no 

pilots or passengers, and given the size of the UASs, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a manual at the flight operations 

center. The FAA has previously issued exemptions to their regulation in Exemption Nos 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 
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14C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as Drone Search 

and Rescue utilizes electronic global positioning systems and internal gyroscopes to provide 

spatial coordination. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons previously stated above. The equivalent 

level of safety will be achieved by maintaining such certifications and registrations at Drone 

Search and Rescue flight operations center. 

B. 14 C.F.R § 45.23: Marking of the Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. Drone Search and Rescue UAS is, by definition, is unmanned. Therefore does not 

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Furthermore, 

two-inch lettering is difficult to place on such small aircraft. Regardless, Drone Search and 

Rescue will mark its UAS in the largest possible lettering by placing the phrase “DRONE SAR” 

on its fuselage as required by 14 C.F.R. § 45.29(f) so that the pilot, technician, spotter and others 

working with the UAS will see the markings. The FAA has previously issued exemptions to this 

regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. 

Pursuant to 14 C.F.R. § 61.113 (a) & (b) private pilots are limited to non-commercial 

operations. Drone Search and Rescue can achieve an equivalent level of safety as achieved by 

current regulations because Drone Search and Rescue UAS does not carry any pilots or 

passengers. Furthermore, while helpful, a pilot license will not ensure remote control piloting 

skills. Although it is not required, the UAS Operators for Drone Search and Rescue will be 

trained both by an outside company and undergo internal training to ensure the highest level of 

safety to everyone involved with the operation. The risks attendant to the operation of Drone 

Search and Rescue UAS is far less than the risk levels inherent in the commercial activities 

outlined in 14 C.F.R.§ 61, et seq. Thus, allowing Drone Search and Rescue to operate its UAS 

with a private pilot as the pilot in control will exceed current safety levels in relation to 14 C.F.R. 

§ 61.113 (a) & (b). 

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Drone Search and Rescue will 

never operate at an altitude greater than 400 AGL. Drone Search and Rescue will, however, 

operate its UAS in cordoned off areas with security perimeters, providing a level of safety at 

least equivalent to those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of Drone Search and Rescue UAS, an equivalent level of safety will 

be achieved. 

E. 14 C.F.R. 91.405 (a) (2); 417 (a) & (b): Maintenance Inspections. 

The above cited regulations require, amongst other things, aircraft owners and operators 

to “have aircraft inspected as prescribed in subpart E of this part and shall between required 

inspection, except as provided in paragraph © of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter....” These regulations only apply to aircraft with an 
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airworthiness certificate. Therefore, they will not apply to Drone Search and Rescue should its 

requested exemption be granted. Drone Search and Rescue will conduct extensive maintenance

programs that involves regular software updates and curative measures for any damaged 

hardware. In summary, an equivalent level of safety will be achieved. 

F. Summary to be published in the Federal Register:

Drone Search and Rescue seeks an exemption from the following Regulations: 14 C.F.R. 

21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R 

§ 91.9 (b)(2); 14 C.F.R.§ 91.103(b); 14 C.F.R.§ 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 

C.F.R. § 91.151 (a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 

(a) (1); 14 C.F.R. § 91.409 (a)(2);14 C.F.R. § 91.409 (a)(2);and 14 C.F.R.§§ 91.417 (a) & (b):

In order to commercially operate its lightweight unmanned aircraft in search and rescue

or photography operations and to conduct its own research. Granting Drone Search and Rescue

request for exemption will reduce current risk levels and thereby enhance safety. Currently 

search and rescue and air image capture relies primarily on the use of larger aircraft running 

combustible fuel. Drone Search and Rescue aircraft does not contain potentially explosive fuel, it 

is smaller, lighter and more maneuverable than conventional aircraft used in these scenarios. 

Drone Search and Rescue operates at lower altitudes and in controlled airspace. Drone Search 

and Rescue has been analyzing flight data and other information in compiling novel safety 

protocols and the implementation of a flight operations manual that exceeds currently accepted 

means and methods of safe flight. There are no individuals on board Drone Search and Rescue

UAS and therefore the likelihood of death or serious bodily injury is significantly limited. Drone 

Search and Rescue operation of its UAS, weighing less than five pounds and travelling at speeds 

lower than 50 knots in cordoned off areas will provide at least an equivalent level of safety as 

that achieved under current FARs. 

Accordingly, Drone Search and Rescue respectfully requests that the FAA grant its 

exemption request without delay. The FAA has the authority to issue the exemption sought by 

Drone Search and Rescue pursuant to the Federal Aviation Act, 85 P.L. 726(1958), as amended.

In closing, Drone Search and Rescue would like to state that it would be very easy to 

ignore the FAA and operate a UAS commercially without applying for any petition from the 

FAA. We hope the simple fact that someone such as ourselves who operate a small business and 

will be operating a UAS on a very small scale is applying for this exemption shows how serious 

we are about safety and doing things properly. Thank you for your time and consideration.

Regards, 

Karl D Carichner

Owner/Operator

Drone Search and Rescue

38 Remington Road

Tunkhannock, PA 18657

Office Phone: 570-903-2895

Email: karl@yourdronesolution.com
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Appendix A: Phantom 3 Pre-Flight Checklist

DRONE SAR Phantom 3 Professional Pre-Flight Checklist

The pilot and co-pilot will check the Phantom out to ensure the following are attached properly and 

functioning properly. Each flight is required to fill out the Phantom 3 Professional Pre-flight Checklist 

form.

Pre-flight:

1. Is weather within flying conditions?

a. Wind speeds above 20 MPH

b. Any amount of rain, snow, sleet, hail, fog, or precipitation

2. Safety zone cleared at least 100 feet in all directions of flight path and safety signs in place?

3. Phantom & R/C battery charged

4. Tablet charged (reset or remove apps from memory)

5. Propellers installed and tightened

6. Remove gimbal lock

7. Gimbal not obstructed (grass, etc.)

8. Tablet volume & luminosity to MAX

9. Tablet « Do Not Disturb and Airplane » Modes

10. Tablet to R/C cable attached

11. Tablet Wifi & BT OFF (If wifi is available then connect to a network)

12. R/C ON

13. R/C in P-Mode

14. Power on Phantom

15. Launch DJI Pilot app

Check values:

 Compass status

 IMU values (0, 1, 1400-1600)

 Gain values

 Max height

 RTH height (depends on flight location)

 R/C EXP & Gain (0,5-0,4-0,5)

 VPS ON (if indoor flight)

 Satellite status

16. Camera settings (LOG, video size, ...)

17. Gimbal configuration (1, 2 or 3)

18. CHECK HOME POINT

19. CHECK BATTERY STATUS (Cells)

Takeoff

1. Hover 30 seconds & check stability and all controls