Tar Heel Drone Imaging 

Joseph Neill Howell, Jr. (Owner) 

4628 Howell Road 

Lumberton, North Carolina 28358 

November 1, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Re: Petition ofT ARHEEL DRONE IMAGING Exemption from Certain Federal Aviation 

Regulations to Operate Unmanned Aircraft Systems Pursuant to Section 333 of 

The FAA Modernization and R-eform Act · · - --

Dear Sir or Madam: 

Pursuant to Section333 of the FAA Modernization and Reform Act ("FMRA") and 14 

C.P.R. part 11, TARHEEL DRONE IMAGING hereby petitions the Federal Aviation Administration 

("FAA") for exemption from 14 C.P.R.§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 

61.315(a), 91.7(a), 91.119(c), 91.121, 91.15l(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) and 

(2), and 91.417(a) and (b), and any other rules the FAA deems necessary, to enable TARHEEL 

DRONE IMAGING to operate unmanned aircraft systems ("UAS") for aerial data collection. 

Specifically, TARHEEL DRONE IMAGING seeks to operate VAS for agricultural and geological 

surveying and research, real estate surveying, evaluation and marketing, wildlife, forestry, and 

rangeland research and management, newsgathering for public interest, and facilities inspection 

using the DJI Phantom 3, DJI Phantom 2, 3DR Solo, Yuneec Q500+, and the DJI Inspire 1. Because 

this petition is similar in all material respects to previously-granted Section 333 petitions, 

TARHEEL DRONE IMAGING requests expedited approval pursuant to the FAA's summary grant 

process. 

I. PROPOSED OPERATIONS AND PUBLIC INTEREST BENEFITS 

The requested exemption would permit Tar Heel Drone Imaging to provide services to 

consumersJ111ere?ted aerial data capture using a small ag'{Q.nced_ UAS in the following areas of 

aerial data collection (but not limited to): - -.. . . .. · . .. . 

• Agricultural and geological surveying and research 

• Real estate surveying, evaluation, and marketing 

• Wildlife, forestry, and rangeland research and management 

• Newsgathering for public interest 

• Facilities Inspections 

Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard 

the UAS. Examples include imagery (photography, video, infrared, etc.), electronic 

measurement 
-

(precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), 

or any other gathering of data by instruments aboard the UAS. 

In addition to fostering significant public benefits, Tar Heel Drone Imaging's operations will 

carry minimal risk. Using UAS for aerial data collection will both eliminate the dangers associated 

with conducting these activities on foot or in manned aircraft and enable Tar Heel Drone Imaging to 

efficiently and quickly deliver aerial data collection to the necessary businesses. As discussed in 

more detail below, Tar Heel Drone Imaging is committed to the safe operation of its UAS, and will 

adhere to stringent operating conditions in conformity with past grants of exemption. These 

conditions ensure that Tar Heel Drone Imaging will operate safely in the national airspace, mitigate 

the risks of harming other aircraft or people or property on the ground, and present no threat to 

national security. Adhering to these parameters, Tar Heel Drone Imaging will be able to safely and 

effectively operate its UAS to the benefit of the public and employees. 

II. THE UAS 

Tar Heel Drone Imagingrequests an exernptionto·operate the DJI Phantom 3, DJI Phantom2, ·· 

3DR Solo, Yuneec Q500+, and the DJI Inspire 1, all of which are well below 55 pounds including 

payload. Through the Section 333 exemption process, the FAA has authorized use of all UAS for 

which exemption is requested herein. 1 

III. REQUEST FOR SUMMARY GRANT 

Because this petition is similar in material respects to previous petitions the FAA has 

granted, Tar Heel Drone Imaging requests that the FAA issue a summary grant of exemption 

pursuant to the agency's expedited summary grant process. Specifically, the public interest and safety 

benefits Tar Heel Drone Imaging operations will achieve are materially similar to those recognized in 

Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), Ill 09 to Clay 

co, Inc. (see Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC (see Docket No. FAA2014-0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642). 

TARHEEL DRONE IMAGING will adhere to a series of operating parameters that will offer the 

same level of safety as the conditions the FAA currently requires in its summary grants2 

IV. APPLICANT INFORMATION 

The name and contact information of the applicant is: 

. ~ JQs~ph Neill Bowell, Jr. (Owner). 

Tar Heel Drone Imaging 

4628 Howell Road 

Lumberton, North Carolina 28358 

• Regulations from which exemption is requested: 

See Exemption No. 11274A to United Services Automobile Association, Regulatory Docket No. FAA2014-0796 (authorizing use of the 3DR Solo, DJI Phantom 3, and DJI Inspire); Exemption No. 11875 to Green Bee 

Limited, Regulatory Docket No. F AA-20 15-0698 (authorizing use of the DJI Phantom 2); Exemption No. 12023 to 

William J. Henderson, Regulatory Docket No. FAA-2015-1518 (authorizing use of the Yuneec Q500 Typhoon). 

See, e.g., Exemption No. 12160 to Star Engineering Services LLC, Regulatory Docket No. FAA-20 15-

1690 (Jul. 27, 20 15). 
3 

14 C.P.R. §§ 61.23(a) and (c); 

14 C.P.R.§§ 61.101(e)(4) and (5); 

14 C.P.R. § 61.113(a); 

14 C.P.R.§ 61.315(a); 

14 C.P.R. § 91.7(a); 

14 C.P.R.§ 91.119(c); 

14 C.P.R.§ 91.121; 

14 C.P.R.§ 91.151(a)(l); 

14 C.P.R.§ 91.405(a); 

14 C.P.R. § 91.407(a)(1); 

14 C.P.R. §§ 91.409(a)(l) and (2); 

14 C.P.R.§§ 91.417(a) and (b). 

V. OPERATING PARAMETERS 

Tar Heel Drone Imagingwilladhete to the following-operating parameters when operating UAS · 

pursuant to a grant of the requested exemption: 

1. Operations will be conducted using the DJI Phantom 3, DJI Phantom 2, 3DR Solo, 

Yuneec Q500+, and the DJI Inspire 1. 

2. The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour), at an 

altitude greater than 400 feet above ground level, or, when visibility is less than 3 statute 

miles, less than 500 feet below or 2,000 feet horizontally from a cloud. All operations 

will be conducted during the day under visual meteorological conditions. 

3. All operations will be conducted in accordance with a Certificate of Waiver or 

Authorization ("COA''). 

4. All operations will use a pilot-in-command ("PIC") and a visual observer ("VO"), and the 

VAS will remain within the visual line of sight of the PIC or the VO at all times. The 

PIC will maintain VLOS capability and the ability to communicate verbally with the VO 

at all times. 

5. The PIC will hold an airline transport, commercial, private, recreational, or sport pilot 

certificate, as well as an FAA airman medical certificate or a valid U.S. driver's license. 

The PIC will meet the flight review requirements specified in 14 C.P.R. § 61.56 in an 

aircraft in which the PIC is rated on his-or her pilot-certificate~ 

6. Tar Heel Drone Imaging will ensure prior to operation that the PIC has demonstrated the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC qualification flight hours 

and currency will be logged in a manner consistent with 14 C.P.R. § 61.51 (b) 

7. Tar Heel Drone Imaging operating documents will be accessible during UAS operations and made 

available to the Administrator upon request. 
8. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is 

in a condition for safe flight. If the inspection reveals a condition that affects the safe 

operation of the UAS, the UAS will not be operated until the necessary maintenance has 

been performed and the U AS is found to be in a condition for safe flight. 

9. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g., replacement of a flight critical component, will undergo a 

functional test flight prior to conducting further operations under this exemption. 

10. TarHeel Drone Imaging will follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements, as well as safety bulletins, for the aircraft and 

aircraft components. 

11. The PIC will abort the flight in the event of unpredicted obstacles or emergencies, and 

will yield to all manned aviation activities. 

H. Tar Heel Drone Imaging wiH register-and-mar-kits UA&--in aceordance with 14--f;.P ,R; parts47 · --- -~ - ----

and 45. 

VI. THE FAA'S AUTHORITY TO GRANT THIS PETITION 

The FAA has authority to grant the exemption requested herein under the FMRA and the 

Federal Aviation Act. Section 333 of the FMRA deals specifically with integrating UAS into the 

national airspace, and directs the Secretary of Transportation to determine which UAS, "as a 

result of their size, weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users of the national 

airspace system or the public or pose a threat to national security. "3 Section 333 further directs 

the Secretary to "establish requirements for the safe operation of such aircraft systems in the 

national airspace system. "4 The Federal Aviation Act authorizes the Administrator of the FAA 

to grant exemptions from regulations prescribed under certain provisions of the Act where such 

exemptions are in the public interests Part 11 of the Federal Aviation Regulations governs the 

FAA's exemption process and requirements.6 The FAA has granted more than 1,100 exemptions 

to date pursuant to its Section 333 and exemption authority, enabling commercial UAS 

operations in a wide variety of industries. 

Pub. L. No. 112-95, 126 Stat. 75-76 (codified as a Note to 49 U.S. C.§ 40101). 

4/d. 

549 U.S.C. § 44701 (f) ("The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the Administrator 

findstheexeinptionlsiiithe-p1ihlicinteresi.").-- -- - ----- -- - - · .-. - -- ~- --- ---··---

6 See 49 C.P.R. Part I I. 

VII. SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER 

Should the FAA determine that publication in the Federal Register is required, Tar Heel Drone 

Imaging offers the following summary pursuant to section 11.81 of the FAA's rules:? 

Petitioner: Tar Heel Drone Imaging 

Sections of 14 C. FR. Affected: 14 C.F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.10l(e)(4) and (5); 

14 C.P.R.§ 61.113(a); 14 C.P.R.§ 61.315(a); 14 C.P.R.§ 91.7(a); 14 C.F.R. § 91.119(c); 14 

C.F.R. § 91.121; 14 C.F.R. § 91.15l(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 
C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b). 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§ 

61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 

61.315(a); 14 C.F.R. § 91.7(a); 14C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 

91.151(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(l) and 

(2); 14 C.F.R. §§ 91.417(a) and (b) to operate unmanned aerial systems for aerial data collection and 

facilities inspection. 

VIII. CONCLUSION 

As demonstrated above, the UAS operations Tar Heel Drone Imaging has proposed in this petition 

for exemption will garner significant public benefits while presenting minimal safety risks. 

Tar Heel Drone Imaging petition satisfies the criteria of Section 333 of the FMRA and is 

substantially similar to previous petitions the FAA has granted, meriting a summary grant of 

exemption. Tar Heel Drone Imaging respectfully requests that the FAA grant this petition to enhance 

Tar Heel-Drone Imaging's ability-to provide for~eriahlata-~oH-ecti-ott.-~ ~ - -~- -~------

Please do not hesitate to contact me, Joseph Neill Howell, Jr. at 910-734-1631 or 

tarheeldroneimaging@gmail.com with any questions about this filing. 

Sincerely, 

Joseph Neill Howell, Jr. 

1~~~, Tar Heel Drone Imaging