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 19348
2

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 11

4) Basis for Petition 11

a) Name, Address, and Point of Contact of Petitioner 11

b) Federal Register Summary 12

c) Specific Sections of 14 C.F.R. from which Exelon Seeks Exemption and Relief that is Requested 13

d) Public Interest 17

e) Why Exemption will not Adversely Affect Safety 17

f) Privacy 18

5) Conclusion 18
3

1) Terms of Reference

AGL Above Ground Level

CFR Code of Federal Regulations

COA Certificates of Waiver or Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulations

GCS Ground Control Station

NAS National Airspace System

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of 2012, Section 333

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer
4

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 users 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 standards when the administrator decides a requested exemption is in 

the public interest. See 49 U.S. Code §§ 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.F.R. § 11.81.

3) Petitioner’s Description 

a) Purpose for Exemption

Headquartered in Kennett Square, 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 Systems (“UAS”) as a safer and more cost 

and 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 enhance 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 their 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.
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b) Proposed Usage

i) Inspections, surveillance and aerial data collection at power generation facilities; including 

wind, solar, hydro, and other non-nuclear generation facilities

ii) Emergency 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-X-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 manufacturer.

3. The UAS will be visible in PIC and/or VO’s line 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, private, recreational, or 

sport pilot certificate, as well as a current FAA airman medical certificate or a

valid U.S. driver’s license issued by a state, the District of Colombia, 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 rights of way or permission from landowner 

will be obtained before commencing flights over property not controlled 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 

horizontally 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 be 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 maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

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-building), are permitted under the terms of this 

exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UAS with appropriate distance 

from nonparticipants in accordance with 14 C.F.R. § 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.F.R. Part 47, marked in 

accordance to 14 C.F.R. Part 45 Subpart C, and accompanied by a letter of 

alternative 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) within 24 hours. 

Accidents must be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov.

d) Proposed Aircraft

i) Exelon seeks exemption to operate DJI Phantom II, DJI Inspire I, and InspecTools-X-8. 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 submitted as an 

attachment to this petition.

ii) The DJI Phantom II, DJI Inspire I, InspecTools-X-8 comply 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-X-8 are not deemed airworthy by an airworthiness 

certificate, but rather they are deemed airworthy by the operator conducting a thorough 

preflight of the aircraft. These aircraft will also be registered in accordance to 14 C.F.R. Part 

47, marked in accordance to 14 C.F.R. Part 45 Subpart C, and accompanied by a letter of 
8

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 lost. Each User Manual contains more details on the 

UAS’s specific features.

iv) The 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-X-8 has 

similar operational, 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@3.7V
9

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: 900mA
10

vii) InspecTools-X-8

(1) Specifications

Dimensions 775mm x 775mm x 150mm

Empty Weight 2.5kg

Maximum Take-off Weight 5.5kg

Maximum Airspeed 20m/s

Maximum Operating Altitude (ASL) 3000m

Maximum Operating Altitude (AGL) 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 conduct flights during the day in accordance with the blanket COA provided upon 

issuance of the exemption requested. In those instances where Exelon 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, eliminating 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 UAS 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 current 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 Section 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 national security

issue. 

f) PIC and VO Qualifications

To operate a UAS under this exemption, 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 hours 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 the 

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, infrastructure and equipment inspection and maintenance 

operations.

4) Basis for Petition

a) Name, Address, and Point of Contact of Petitioner

i) Name and Address of Petitioner

(1) Exelon Generation Company, LLC

300 Exelon Way
12

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-X-8 

unmanned aircraft for aerial data collection in connection with utility and infrastructure inspection. An 

exemption is requested from the following regulations:

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-X-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 applicable COA. The 
13

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

Inspire I, and InspecTools-X-8, conducted in the conditions outlined below will provide an equivalent 

level of safety, while still allowing commercial 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 support the request. The DJI Phantom II, DJI Inspire I, 

InspecTools-X-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 

operations, weigh heavily in favor of granting the exemption.

 c) Specific Sections of 14 C.F.R. from which Exelon Seeks Exemption and Relief that is Requested 

Exelon petitions for exemption from the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA 

Modernization and reform Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft

Systems, 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) 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 Command 

Requirements

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 certificate or a valid driver’s 

license. The PIC will also meet the flight review requirements specified in 14 C.F.R. § 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 with 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 exemption 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 especially 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-X-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 determined 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.

To 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 the 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 permitted in a COA), where 

buildings and people unaffiliated with Exelon will not be exposed to operations without their preobtained consent. Because of the advance notice to the property owners and participants, all affected 

individuals will be well aware of 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 is 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 achieved 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

14 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 fly after that for at least 30 minutes;

Here, the battery powering the DJI Phantom II, DJI Inspire I, InspecTools-X-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 flights 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 still 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 43 
17

of this chapter"). An exemption to these regulations is needed because Part 43 and these sections only 

apply to aircraft with an airworthiness 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, perform 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 risk from structural inspections

iii) Enhancing early detection of damages and thus decreasing the potential risk to the public

iv) Reducing 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 nonaerial 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 normally have to repel 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 working at heights is reduced. At 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 Section 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-X-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 operations, weigh heavily in favor of granting the exemption.

f) Privacy

Flights will occur over property owned or controlled by Exelon through leases, easements and rights of 

way. If Exelon needs to fly over privately owned 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 

maintenance costs of these facilities is also an added benefit.

Respectfully submitted,

Dennis Dunning

Exelon Generation Company, LLC