## Petition of Exelon Generation Company, LLC for Exemption Pursuant to

Section 333 of the FAA Modernization and Reform Act of 2012

August 17 , 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590



## Exemption Request Section 333 of FAA Reform Act and Part 11 of Federal Aviation Regulations from :
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) and (b); 14 C.F.R. 61.315(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a) (1); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a) (1); 14 C.F.R. 91.409(a) (1) and (2); 14 C.F.R. 91.417(a) and (b).

Exelon Generation Company, LLC 300 Exelon Way
Kennett Square, PA 193482

Table of Contents

1) Terms of Reference 3

2) Relevant Statutory Authority 4

3) Petitioner’s Description 4

a) Purpose for Exemption 4

b) Proposed Usage 5

c) Conditions and Limitations 5

d) Proposed Aircraft 7

e) Flight Operations 10

f) Pilot in Command and Visual Observer Qualifications 1 1

4) Basis for Petition 1 1

a) Name, Address , and Point of Contact of P etitioner 1 1

b) Federal Register Summ ary 12

c) Specific Sections of 14 C

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. from which Exelon Seeks Exemption and R elief that is R equested 1 3

d) Public Interest 1 7

e) Why Exemption will not Adversely Affect Safety 1 7

f) Privacy 1 8

5) Conclusion 1 83

1) Terms of Reference

AGL A b o v e G r o u n d L e v e l

CFR Code of Federal Regulations

C O A C e r t i f i c a t e s o f Waiver or A u t h o r i za t i o n

FAA Federal Aviation Administration

FAR Federal Aviation Regulations

GCS Ground Control Station

N A S N a t i o n a l A i r s p ac e S y s t e m

PIC Pilot in Command

S ec t i o n 333 F AA M o d e r n i za t i o n a n d R e f o r m A c t o f 2012, S e c t i o n 333

UAS Un m a n n e d A i r c r a f t S y s t e m

V F R V i s u a l F l i g h t R u l e s

VLOS Visual Line of Sight

V M C V i s u a l M e t e o r o l og i ca l C o n d i t i o n s

VO Visual Observer4

2) Relevant Statutory Authority This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system.” Pursuant to Section 333 of the Reform Act , the FAA Administrator is to safely permit operation of an unmanned aircraft system where it does not pose a threat to national security or

create a hazard to us ers of the NAS or the public based on the following: i) Size, weight, speed, and operational capability ii) Operation in proximity to populated areas and airports iii) Operation within visual line of sight of operator

The FAA Administrator is given authority from the Federal Aviation Act to grant exemptions from its safety regulations and minimum standard s when the administrator decides a requested exemption is in the public interest. See 49 U.S. C ode § § 106(f), 44701

- 44716, et seq. A party requesting exemption must explain reasons for exemption and why it would 1) benefit the public 2) not adversely affect safety. See

14 C

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. § 11.81.

3) Petitioner’s Description a) Purpose for E xemption Headquartered in Kennett Sq uare, Pennsylvania
, Exelon Generation Company, LLC (“Exelon”) is an energy generation company that requires inspection and maintenance of its power generation facilities and properties

. Exelon seeks to operate Unmanned Aircraft Sys tems (“UAS”) as a safer and more cost

an d time effective alternative to conventional inspection techniques for these facilities , as well as to efficiently conduct aerial data collection of Exelon

- owned assets, property and rights of way

. 1 UAS technology has the potential to enhan ce how Exelon gathers information about the condition of our system, allowing us to improve service to customers, reduce injury risks to employees and the public and improve how we preserve the environment. While following the highest standard of quality,

maintenance , and reliability, Exelon will provide proper documentation and control for the ir UAS’s

. Exelon will ensure complete safety on its facilities utilizing procedures and training programs with a
focus on hazard identification /mitigation

.

1 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.5

b) Proposed U sage i) Inspections , surveillance and aerial data collection at p ower generation facilities ; i ncluding wind, solar, hydro, and other non

- nuclear generation facilities ii) E mergency planning and response activity iii) Aerial imagery of Exelon properties and rights of way

c) Conditions and Limitations

1. The DJI Phantom II, DJI Inspire I and the , InspecTools

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- 8 will weigh less than 55 pounds

. 2. The speed of the UAS will not exceed 87 knots or at airspeeds greater than the maximum airspeed recommended by the ma nufacturer

. 3. The UAS will be visible in PIC and/or VO ’s l ine of sight at all times

. 4. The UAS will not be operated at night. Operations will only occur during daytime

VMC.

5. Preflight inspection will occur before each flight

. 6. PIC will hold either an airline transport, commercial, priv a t e, r e c r eatio n al, or
sport p i lot certificate, as well as a curre n t FAA air m an m edical certificate or a valid U.S. driver’s license issued by a state, the District of Colo m bia, Puerto Rico, a territory, a possession, or the Federal government.

7. The PIC will be trained and certified in the proper safety and operations of the

UAS.

9. Flights will be operated at an altitude of no more than 400 feet AGL

. 10. Operations will occur over utility right s of way or permission from landowner
will be obtained before commencing flights over property not controll ed by Exelon (owned, leased, rights of way or easement).

11. Operations will not occur less than 500 feet below or less than 2,000 feet

ho rizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

12. The UAS will remain clear of manned aircraft and yield right of way.

13. A flight test will be conducted after any major repair or alteration.

14. All operations will be conducted with a VO.6 15. Operations will b e concluded with no less than the greater of 10 % reserve

power remaining or the manufacturer’s recommended reserve power remaining

. 16. Operations will not occur within 5nm of any airport unless a letter of agreement
with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder

. 17. Operations will take place under and in accordance with an applicable COA.

18. The operator will be responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

19. Operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements and safety bulletins for the aircraft and aircraft components.

20. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates 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 mane uvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C

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. § 61.51(b) and can be compared to currency requirements . The VO is also required to complete the operator’s training requirements. A record of training must be documented and made available upon request by the Administrator. Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- buildin g), are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

building flights, all persons not essential for flight operations are c onsidered nonparticipants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 C

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. § 91.119

. 21. All non

- participants will keep an appropriate distance from operations unless there are adequate barriers to protect them.

22. All operations will be conducted according to the manufacturer’s manuals.7 23. All documents that will be kept at the GCS include but are not limited to; the aircraft manuals, maintenance logs, aircraft registration, grant of exemption,

and COA.

24. The UAS has the ability to autonomously return to the launch location and safely land in an emergency

. 25. The UAS will be registered in accordance to 14 C

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. Part 47, marked in

accordance to 14 C

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. Part 45 Subpart C, and accompanied by a letter of

altern ative marking due to the unconventional design of a multirotor . Markings will be as large as practicable.

26. The UAS will not be operated by the PIC from any moving vehicle or device except as permitted from a boat or other watercraft

. 27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) with in 24 hours.

Accidents must be reported to the National Tra nsportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

d) P r oposed Aircraft i) Exelon seeks exemption to operate DJI Phantom I I, DJI Inspire I , and InspecTools

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. These UAS’s were chosen because of their diverse features, ease of use, adaptability, and efficiency . These systems are both reliable and safe

. In addition, they are currently in use by other companies with much success. Each User’s Manual has been submitt ed as an attachment to this petition

. ii) The DJI Phantom II, DJI Inspire I, InspecTools

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- 8 compl y with the requirements set forth by Section 333 by their small size, weight, speed and limited operating area associated with the
aircraft and their operations as set forth herein, in the proposed conditions of operation and the operating manual submitted herewith. As a result under this exemption the DJI Phantom II, DJI Inspire I, InspecTools

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- 8 are not deemed airworthy by an airworthiness
certific ate, but rather they are deemed airworthy by the operator conducting a thorough preflight of the aircraft. Th ese aircraft will also be registered in accordance to 14 C

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. Part 47, marked in accordance to 14 C

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. Part 45 Subpart C, and accompanied by a letter of8 alternative marking due to the unconventional design of a multirotor . Markings will be as large as practicable. iii) The UAS’s are equipped with failsafe features that will automatically return the aircraft to

home if connection with controller is lo st. Each User Manual contains more details on the UAS’s specific features. iv) Th e FAA has already granted Section 333 exemptions for use of the DJI Phantom II in Exemption No. 11138 and the DJI Inspire I in Exemption 11279

. The InspecTools

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- 8 has similar op erational, size, weight and speed characteristics as the DJI Phantom II and DJI
Inspire I

.

v) DJI Phantom II

(1) Specifications Diagonal Length 350mm Weight 1000g Maximum Take

- off Weight 1300g Maximum Flight Speed 15m/s (not recommended) Flight Duration 25min Operating Frequency (remote control) 2.4GHz ISM Communication Distance (open area) 1000m Working Current/Voltage 120mA@3.7V9

vi) DJI Inspire I

(1) Specifications Diagonal Length 559

- 581mm Weight 2935g Maximum Speed 22m/s (ATTI mode, no wind) Maximum Wind Speed Resistance 10m/s Max Flight Altitude 4500m Flight Duration ~18mins Operating Frequency (remote control) 5.725~50825GHz 2.400~2.483GHz Transmitting Distance ( outdoor and unobstructed ) 2km Output Power of gimbal (with camera) Static: 9W In motion: 11W Operating Current of gimbal Station: 750mA Motion: 900mA10

vii) InspecTools

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(1) Specifications Dimensions 775mm x 775mm x 150mm Empty W eight 2.5kg Maximum Take

- off Weight 5.5kg Maximum Airspeed 20m/s Maximum Operating Altitude (ASL) 3000m Maximum Operating Altitude (AG L) Altitude limit setting enforced by flight controller Maximum Range 25km total flight path length Maximum Flight Duration 30min Maximum Winds (sustained/gust) 10/14m/s Maximum Control Link Range 1km Ground Control Station Radio FHSS 915 MHz

e) Flight Operations

Exelon will con duct flights during the day in accordance with the blanket COA provided upon issuance of the exemption requested. In those instances where Exel on needs to operate under the exemption beyond the parameters of the blanket COA , a COA will be secured before flights as required by latest FAA guidance. Any notices will be sent out as required. Temporary flight restrictions and weather conditions will be acknowledged and observed

. As all flights will take place under 400 ft AGL,
the UAS’s will not operate near other aircraft , thus, elimina ting any risk or threat to NAS. For all flights, equivalent levels of safety will be maintained in order to keep the public safe.

Exelon proposes that the exemption apply to UA S that have the characteristics and that operate with the limitations proposed herein. These limitations provide for a level of safety at least equivalent to or higher than manned aircraft operations under the curren t regulatory structure.11

Exelon has identified herein the limitations and conditions to which it agrees to be bound when conducting commercial operations under a grant of this petition. These same conditions have previously been approved by the FAA in its S ection 333 exemptions for commercial use of UAS as being adequate to provide an equivalent level of safety as that provided in the regulations for which exemption are sought. Approval of the commercial operations outlined in this petition presents no natio nal security

issue.

f) PIC and VO Qualifications To operate a UAS under this e xemption, the PIC will have an airline transport, commercial, private, recreational, or sport pilot certificate and will also hold a current FAA airman medical certificate or a valid driver’s license. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate and training as defined below. Flight training and currency to include, but not limited to, hours logged as a UAS rotorcraft pilot including specific training on the particular make and model of the UAS for commercial flight operations, as well as demonstrating the ability to safely operate the UAS in a manner consistent with this exemption, including using evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. Exelon will ensure that their PICs will meet established qualification criteria. PIC qualification flight hour s will be logged in a manner consistent with 14 CFR § 61.51(b) and can be compared to established currency requirements. The VO will also complete Exelon’s training requirements. A record of training will be documented and made available upon request by th e
Administrator. Exelon has a strong commitment to safety as demonstrated throughout its history in the creation, adoption and implementation of its safety programs. Exelon will integrate its UAS operations into its current safety program for property, inf rastructure and equipment inspection and maintenance
operations.

4) Basis for Petition a) N ame, A ddress , and Point of Contact of Petitioner i) Name and Address of Petitioner (1) Exelon Generation Company, LLC 300 Exelon Way12 Kennett Square, PA 19348 ii) Point of Contact for Petition (1) Dennis Dunning Exelon Generation Company, LLC 300 Exelon Way
Kennett Square, PA 19348

610

- 765

- 6718 dennis.dunning@exeloncorp.com

b) Federal Register Summary Exelon Generation Company, LLC hereby provides pursuant to Part 11 a summary of its exemption application to allow commercial operation of the DJI Phantom II, DJI Inspire I, InspecTools

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- 8 unmanned aircraft for aerial data collection in connection with utility and infrastructure inspection. An exemption is requested from the following re gulations:

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) and (b); 14 C.F.R. 61.315(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c);
14 C.F.R. 91.121; 14 C.F.R. 91.151(a) (1); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a) (1); 14 C.F.R. 91.409(a) (1) and (2); 14 C.F.R. 91.417(a) and (b).

Approval of the exemption requested by the petitioner will allow commercial operation of the DJI Phantom II, DJI Inspire I, InspecTools

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- 8 for the purpose of inspecting and maintaining its power generating facilities, such as wind turbine farms, solar plants, hydro facilities, and other non

- nuclear generation facilities, through aerial imagery, data collection, as conditioned by applicab le COA. The13

requested exemption should be granted because operation of small UAS, such as the DJI Phantom II, DJI Inspire I, and InspecTools

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- 8, conducted in the conditions outlined below will provide an equivalent level of safety, while still allowing c ommercial operations. The lightweight aircraft covered by the exemption are far safer than conventional operations conducted with manned aircraft weighing thousands of pounds, carrying highly flammable fuel, and operating in close proximity to the ground and people. The factors the FAA is required to consider when approving Section 333 exemption petitions

– size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line of sight

– each sup port the request. The DJI Phantom II, DJI Inspire I, InspecTools

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- 8 are small and operate at slow speeds, close to the ground. The increase in safety, decrease of risk to human life and property, coupled with the low risk use of UAS to conduct these

ope rations, weigh heavily in favor of granting the exemption.

c) Specific S ections of 14 C

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. f rom which Exelon S eek s E xemption and Relief that is Requested Exelon petitions for exemption from the Federal Aviation Regulations (14 C

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. § 11.61) and the FAA Modernization and reform Act of 2012, Section 333, S p ec i a l R u l e s f o r C e r t a i n U n m a n n e d A i r c r a f t

S y s t e m s , f r o m t h e r e q u i r e m e n t s o f: 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) and (b);

14 C.F.R. 61.315(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c);
14 C.F.R. 91.121; 14 C.F.R. 91.151(a) (1); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a) (1); 14 C.F.R. 91.409(a) (1) and (2); 14 C.F.R. 91.417(a) and (b).14

14 C.F.R. §§ 61.23(a) and (c), 61.101(e) (4) and (5), 61.113(a) and (b), and 61.315(a): Pilot in C ommand

R equirements

The FAA has recently determined that the PIC requirements for Section 333 exemptions for commercial operation of UAS are met by a PIC who has an airline transport, commercial, private, recreational, or sport pilot certificate and will also hold a current FAA airman medical certifica te or a valid driver’s
license. The PIC will also meet the flight review requirements specified in 14 C

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. § 61.56 in an aircraft
in which the PIC is rated on his or her pilot certificate. See eg. Exemption No. 11238 (San Diego Gas & Electric Co.) and Exemption No. 12040, (Burns & McDonnell Engineering Co., Inc.)

. Exelon requests the same decision by the FAA wit h respect to its request for exemption of the above referenced FARs regarding the PIC requirements.

Equivalent Level of Safety Currently, there are no applicable areas identified for UAS in either the private or commercial sector and therefore an exemptio n is required to conduct commercial operations. As flight operations will be conducted in a restricted environment as described in the operations section, these strict guidelines will achieve an equivalent level of safety for each individual flight especia lly when compared to commercial flights identified in Part 61 when originally developed.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Exelon seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy
condition to be operated. Inasmuch there will be no airworthiness certificate issued for the UAS, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Equivalent Level of Safety
Given the size of the DJI Phantom II, DJI Inspire I, InspecTools

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- 8 and the preflight procedures including the review of maintenance logs and preflight check lists, an equivalent level of safety will be provided to
assure the aircraft are in an airworthy condition. The FAA has previously det ermined that an operator ensures that its aircraft is an airworthy condition based upon compliance with the operating documents.15

14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Exelon requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c) which states that aircraft may not operate closer than 500 feet above the surface and away from any person, vessel, vehicle, or structure in non

- congested areas.

T o provide the intended operations, the UAS is operated below 400 feet AGL.

Equivalent Level of Safety Compared to flight operations with rotorcraft weighing far more than the weights of the UAS proposed herein, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of th e UAS, as well as the location where it is operated. As set forth in the operations section of this exemption, the UAS will be operated at least 5nm away from airports (unless a letter of agreement from the airport’s management is obtained or otherwise per mitted in a COA) , where buildings and people unaffiliated with Exelon will not be exposed to operations without their pre

obtained consent. Because of the advance notice to the property owners and participants, all affected
individuals will be well aware o f the planned flight operations.

14 C.F.R. § 91.121: Altimeter Settings

Exelon requests an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that i s set to the elevation of the departure airport or barometric pressure. An exemption is required because the UAS does not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety An equivalent level of safety will be ach ieved by the operator confirming the altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to constantly monitor the UAS's height, thus ensuring operation at safe altitudes.16

1 4 C.F.R. § 91.151(a) (1): Fuel Requirements for Flight in VFR Conditions

Exelon requests an exemption from 14 C.F.R. § 91.151(a)(1)'s fuel requirements for flight in VFR conditions during the day. Section 91.151(a)(1) states: (a) 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 f ly after that for at least 30 minutes;

Here, the battery powering the DJI Phantom II, DJI Inspire I, InspecTools

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- 8 UAS provide approximately 25, 18, and 30 minutes respectively . To meet the 30 minutes reserve requirement in 14 C.F.R. § 91.151, UAS fligh ts could not be conducted. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a safety margin based on a reserve amount of battery life is needed.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted on

- site without significant transit time by the UAS. All flights will be planned to be terminated with no less than 10 % or
the manufacturer’s recommended reserve power sti ll available. This restriction would be more than adequate to return the UAS safely to the ground and its planned landing zone from anywhere in its limited operating area even in the event of an unexpected occurrence. Operation of the UAS with less
than 30 minutes of reserve power does not include the type of risks that Section 91.151(a)(1) was intended to alleviate given the size and speed of the small UAS, and the proximity of the flight operation to the landing zone.

14 C.F.R. § 91.405(a), 91.407(a) (1) , 91.409(a) (1) and (2); 91.417(a) and (b): Maintenance Inspections

Exelon also seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a) (1), 91.409(a) (1) and (2)
, 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ...have discrepancies repaired as prescribed in part 4317

of this chapter"). An exemption to these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthin ess certificate, which the UAS will not have.

Equivalent Level of Safety An equivalent level of safety will be achieved because the operator will ensure that the UAS is in working order prior to initiating flight by following the preflight checklist, perf orm required maintenance, and keep a log of any maintenance performed. The operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition.

d) Public Interest
Exelon believes that relief from these regulations will benefit the public interest by: i) Improving safety ii) Removing human safety r isk from structural inspections iii) Enhancing early detection of damages and thus decreasing the potential risk to the public iv) R educing outage time and increasing reliability at generation facilities v) Reducing risks associated with generating facilities shutdowns and startups vi) Improving cost effectiveness of inspection techniques vii) Reducing environmental impact of inspection through manned aircraft and traditional non

a erial data collection methods

.

e) Why Exemption will not Adversely Affect Safety The use of UAS’s would enhance Exelon’s ability to protect the public by allowing for immediate damage inspection of power generation facilities, thus minimizing potential regional blackouts

. UAS’s will enhance security operations at generation facilities

.

Certain structures, such as dams or wind turbines, can be dangerous to inspect. The use of a UAS would provide safety for the ropes crew that would normall y have to repe l to complete a proper inspection of

a wind turbine or dam

. These inspections can take up to 8 hours per day and last for weeks. Using a UAS
would reduce safety hazards on the rope crew employees who would no longer be subject to working in

extreme conditions. Another common method of inspection is building scaffolding to different levels. By eliminating this hazardous technique at other power generation facilities , the standard of safety would

be increased with the use of UAS’s. Thus, the risk of wo rking at heights is reduced. A t solar farms
,18

current inspection methods are very time consuming and the use of UAS’s will not only save time, but

also prevent employees from working in extreme heat

. The lightweight aircraft covered by the exemption are far safer than conventional operations conducted with manned aircraft weighing thousands of pounds, carrying highly flammable fuel, and operating in close proximity to the ground and people. The factors the FAA is required to consider when
approving Sect ion 333 exemption petitions

– size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line of sight

– each support the request. The DJI Phantom II, DJI Inspire I, InspecTools

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- 8 are sm all and operate at slow speeds, close to the ground. The increase in safety, decrease of risk to human life and property, co upled with the low
risk use of UAS to conduct these operations, weigh heavily in favor of granting the exemption.

f) Privacy

F lights will occur over property owned or controlled by Exelon through lease s , easements and rights of

way. If Exelon needs to fly over privately owne d land, Exelon will obtain consent from owners. Therefore, no privacy issues will be implicated.

5) Conclusion Exelon’s proposed operations for the use of Unmanned Aircraft Systems will allow Exelon to safely, efficiently, and economically perform aerial data collection of its power generation facilities and other Exelon properties

. Safety levels equivalent to traditional methods will be achieved. Granting exemption will benefit the public by increasing reliability and improving safety. More frequent inspections will reduce risk and enhance early detection in potential emergency situations. The reduction in

main tenance costs of these facilities is also an added benefit.

Respectfully submitted,

Dennis Dunning
Exelon Generation Company, LLC