Aug 20, 2015

Page 1 of 9

Supplemental information for docket FAA-2015-2819 for the Petition for Exemption 

concerning operation of Hawaiian Electric Companies Unmanned Aircraft Systems in 

accordance with Section 333 of the FAA Modernization and Reform Act of 2012. 

Name and Address of Applicant: 

Hawaiian Electric Companies

Attn: Joanne Williamson

820 Ward Avenue,

Honolulu, HI 96814

(808) 543-7881

1. Overview. 

Hawaiian Electric Companies have provided the energy that has fueled the islands' 

development from a Hawaiian kingdom to a modern state. Hawaiian Electric Company 

(HECO), Maui Electric Company (MECO), and Hawaii Electric Light Company (HELCO), 

serve 95% of the state’s 1.4 million residents on the islands of Oahu, Maui, Hawaii Island, 

Lanai and Molokai. Our mission is to provide secure, clean energy for Hawaii. HECO, 

MECO, and HELCO are seeking an exemption from the Federal Aviation Regulations 

(FARs) so that it can safely operate small Unmanned Aircraft System (sUAS), and utilize this 

technology for aerial inspections. 

This exemption request is similar in all material respects to relief previously requested in 

Grant of Exemption Nos. 11062, 11109, 11112, 11213, and 11238. In addition the InstantEye 

Mk-2 sUAS has been granted exemption approval in Exemption No. 11217 and 11238. 

The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 

also apply to this situation and a grant of exemption is in the public interest. 

The InstantEye sUAS weighs 1.1lbs and will mainly be used for electrical transmission and 

distribution utility system monitoring, power line inspections, aerial inspection of its 

electrical and gas facilities including emergency response damage assessments. The sUAS to 

be operated under this request is way less than 55 lbs. fully loaded, will normally fly at 

speeds of no more that approximately 30 knots, doesn’t carry a pilot or passenger or no 

explosive material or flammable fuel. It will operate less than 400 feet, in daytime VFR flight 

only. 

The InstantEye is a high-performance, low-cost aerial system that can be hand-launched, 

flown and hand-recovered by a single person. At approximately one pound, the vehicle can 

go from a stowed configuration to airborne in under 30 seconds and provide rapid situational 

awareness and tactical sensor operation for up to 30 minutes.

InstantEye uses 100% custom control algorithms derived from Physical Sciences Inc. (PSI) 

biomimetic research of hawk moths in turbulent winds and collisions. InstantEye offers 

exceptional stability, position hold, and responsiveness unlike any other UAV in its class. 

‘Manual’ mode gives the user total control and speeds up to 60 mph, while ‘Alt’ and ‘GPS’ 

provide vertical and horizontal position hold and speeds up to 30 mph and vertical climb rates 

greater than 2000 ft/min.
Aug 20, 2015

Page 2 of 9

2. Aircraft Configuration. InstantEye’s performance characteristics: Figure 1 shows a 

complete description of the aircraft. 

a. Three- view drawings or three-view dimensioned: 

 

Figure 1 - InstantEye Mk-2 Components

b. Wing span. 25.0 cm (9.84 inches) (frame); 43.0 cm (16.92 inches) (frame + props)

c. Length. 25.0 cm (9.84 inches) (frame); 43.0 cm (16.92 inches) (frame + props)

d. Maximum gross takeoff weight. 730 g (1.6 lb) 

e. Fuel capacity. N/A

f. Payload capacity. 200 g (0.44 ounces) 

g. Maximum altitude. 12,000 ft MSL

h. Endurance. 30 min of battery life

i. Maximum airspeed. 60 mph

j. Description of ground support equipment. InstantEye Mk-2 uses 4000 mAh Li-poly 

batteries and supplied charger.

k. Description of launch and recovery equipment. N/A

3. Ground Control Station System (GCS) Configuration. Description and a diagram (Figure 

2), of the GCS.

Ground Control Station (GCS) Control Interface

The GCS control interface can be broken into three main groups, 2 joysticks, 8 primary control 

buttons, and 4 menu buttons, see Figure 2. 

1. Joysticks

The joysticks are used to reposition the aircraft once it is airborne. Pushing the right joystick up 

and down causes the aircraft to climb and descend. Pushing it left and right rotates its heading 

(yaw). Pushing the left joystick up and down moves the aircraft forward and back. Pushing it left 

and right moves the aircraft left and right.
Aug 20, 2015

Page 3 of 9

2. Primary Control Buttons

ALT, NAV, CAM, MOTOR, HOME, UTIL1, and UTIL2 / IR 

3. Menu Buttons

The menu buttons are just below the screen and are configurable based on context. The context 

menu can be brought up by pressing the menu button on the left. The other three buttons then 

perform the function described just above them on the screen. Pressing the left menu button a 

second time will bring up a second context menu again defining the function of the other three 

buttons. 

Figure 2: GCS Button and Joystick Configuration

4. Exemptions requested per 14 C.F.R:

a. § 91.7(a) Civil Aircraft Airworthiness: No person shall operate a civil aircraft 

unless it is in an airworthy condition. This Unmanned Aircraft has proven to be 

airworthy on multiple occasions listed below. In addition, the PIC will use all 

checklists to include the manual for maintenance and operations to ensure the UA is 

safe for flight. There will be no adverse impact to the public because the PIC will 

sign the aircraft safe for flight each time the UA conducts operations. Having 

maintenance log books that require the PIC to sign ‘safe for flight’ provides a level 

of safety above that provided by the rule for which we’re requesting the exemption. 

i. On June 25, 2014, the FAA granted San Diego Gas &Electric a Special 

Airworthiness Certificate in the Experimental category for the InstantEye 

Mk-2. During this process the aircraft was proven to be in an airworthy 

condition and safe for the public.

ii. The InstantEye has been proven airworthy and received Certification with 

US Army Special Operations Command. (Air Worthiness Release, AWR# 

IEMK220130521; Full AWR has been submitted in the past and can be 

submitted with this request.) 

b. § 91.109 (a) Flight Instruction: No person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft 

has fully functioning dual controls. The InstantEye does not have dual controls;

instead the InstantEye has a fully functioning Ground Control Station (GCS). (See 
Aug 20, 2015

Page 4 of 9

figure 2.) When flights are performed, no pilots will be on the aircraft and the GCS 

will be a safe distance from the InstantEye and the public, causing no safety hazard.

The PIC will undergo an extensive training program by a qualified evaluator to 

ensure each PIC is fully qualified before any operations. This will not adversely 

affect safety because we have a proven training program to ensure the PIC is fully 

qualified. 

c. § 91.113 See and Avoid: Method for See-and-Avoid (§ 91.113). When weather 

conditions permit, regardless of whether an operation is conducted under 

instrument flight rules or visual flight rules, vigilance shall be maintained by 

each person operating an aircraft so as to see and avoid other aircraft. The sUAS

is strictly line of sight and will always be in constant contact with the operator and 

visual observer. See and Avoid will be conducted by the operator and vigilance shall 

be maintained by each operator so as to “see and avoid” any other aircraft. 

All visual observers will be qualified and understand the rules and responsibilities 

described in § 91.111 (Operating near other aircraft), § 91.113 (Right-of-way rules: 

Except water operations), and § 91.155 (Basic VFR weather minimums). There will 

be no adverse impact to the public because each visual observer will be fully 

qualified and would not adversely affect safety because the visual observer will have 

constant eye contact with the UA at all times. This provides a level of safety above 

and beyond what’s required in § 91.113.

d. § 91.119 Minimum Safe Altitudes, no person may operate an aircraft below the 

following altitudes: Over other than congested areas. An altitude of 500 feet 

above the surface, except over open water or sparsely populated areas. 

Operations will never be conducted higher than 400ft AGL and will avoid congested 

or populated areas and will pose no risk to the public. The PIC will always operate 

the UA an appropriate distance from nonparticipants as required by § 91.119 and 

because of this will not adversely affect safety. 

e. § 91.121 Altimeter settings: Each person operating an aircraft shall maintain the 

cruising altitude or fight level of that aircraft, as the case may be, by reference 

to an altimeter that is set to the appropriate station. The InstantEye sUAS uses 

barometric altitude pressure but does not program in an altimeter setting. The 

altitude is monitored by the Pilot In Command on the GCS, this information is 

downlinked from the UA to the GCS and constantly watched by the visual observer, 

this is proven to be a sufficient method for ensuring the UAS operations do not 

adversely affect safety. This exemption will benefit the public because the visual 

observer and operator are visual line of sight at all times, and will not pose any risk 

to the public and provide a level of safety required by this exemption. 

f. § 91.151 (b) Fuel requirements for flight in VFR conditions: No person may 

begin a flight in a rotorcraft under VFR conditions unless there is enough fuel to 

fly to the first point on intended landing and, assuming normal cruising speed, 

to fly that for at least 20 minutes. The sUAS is battery operated with a maximum

flying time of 30 minutes. However, this poses no safety risk because the take-off 

point is also located at the landing point and will cause no safety hazard to the public.

The PIC will ensure that there is enough power to conduct the operations and to 
Aug 20, 2015

Page 5 of 9

operate after that for at least five minutes. 

In addition, relief has been granted for manned aircraft to operate at less then the 

minimums of § 91.151 including exemption Nos 2689, 5745, and 10650. In addition, 

similar UAS specific relief has been granted in exemption Nos 8811, 10808, and 

10673 for day time VFR. 

Since this request is for daytime VFR only, this exemption would not poses any risk to 

the public and provides an equivalent level of safety for the exemption requested. 

g. § 91.207 Emergency Locator Transmitters: No person may operate a U.S.-

registered civil airplane unless there is attached to the airplane an approved 

automatic type emergency locator transmitter. The sUAS does not use an ELT, all 

operations are VFR and in line of sight with a visual observer. 

This exemption will benefit the public because the visual observer and operator are 

line of sight at all times with the sUAS. In addition if the sUAS needed to be located 

on the ground, the GCS will point to the sUAS to locate it and show range to the 

sUAS.

5. Inspection and Maintenance. (14 C.F.R § 91.405, 91.407, 91.409). All operators will 

follow PSI Unmanned Aircraft System InstantEye training manual and any UAS that has 

undergone maintenance or alterations that affect the UAS operation or flight characteristic 

will undergo a functional test flight prior to conducting further operations. Functional test 

flights will be conducted by a PIC and VO and will remain at least 500 feet from other people. 

6. Description of past flight history. There are in excess of 1500 hrs of test and evaluation 

time on the InstantEye Mk-2 systems and more than 3600 hrs of test and evaluation time on 

the systems it is derived from. Physical Science Inc. has already proven Airworthiness and 

has an Airworthiness Certification with US Army Special Operations Command. (AWR# 

IEMK220130521, attached.) In addition, As of June 25, 2014, after the FAA granted San 

Diego Gas &Electric a Special Airworthiness Certificate in the Experimental category, it has 

flown numerous sorties in support of operations and has always operated in a safe manner. 

7. Flight Recovery and Lost Link Procedures. Aircraft lost link and emergency recovery 

questions/procedures. 

a. How is it determined that the UA is experiencing lost link and how is this displayed 

to the pilot? Signal strength or quality is determined by error rate or number of lost 

data packets which are monitored during communications. When a threshold percent 

of data packets are lost the aircraft, the aircraft goes into”lost comms” mode.

b. Operational procedures in the event of a lost link: During a lost link event the 

operator monitors the data and video until communications are restored, then 

control is regained. If for some reason communications are not restored the operator 

should wait by the last know location of good communications. The aircraft will 

return there and auto land.

c. Describe how the aircraft will react during takeoff, climb, cruise, descent, and 

landing in the event of a lost link. During startup each InstantEye air vehicle is 

“tethered” to a ground control station through its command and control 

communication system. After tethering has been achieved the air vehicle will 

respond to commands from that ground station only. In operation, due to radio 
Aug 20, 2015

Page 6 of 9

interference or flight beyond communication range, the aircraft can lose command 

and control lock with the ground control station. In this event the aircraft will enter 

into its “lost comm” mode and will execute the following procedure:

i. Vehicle will immediately climb/descend to an altitude 300’ Above Ground 

Level (AGL)above its launch altitude;

ii. Vehicle will home toward last known location of ground control station (GPS 

position of ground control station is uploaded to air vehicle during flight);

iii. If command and control communication is reestablished, vehicle will stop 

and hover at current location. If command and control communication is not 

reestablished, vehicle will hover over last known location of ground control 

station (“home position”) and land immediately. 

iv. If vehicle is at home position and command and control communication has 

not been reestablished, vehicle will autonomously descend and land.

d. How is it determined that the lost link functionality of the system is operational? The 

lost link functionality has been extensively tested and is used operationally, please 

refer to Airworthiness Release: US Army AWR# IEMK220130521.

e. How does the UA navigate when in the lost link mode? The InstantEye Mk-2 is 

continuously updated with the GCSs GPS location. When the aircraft goes into “lost 

comms” mode it then uses the last location of the GCS as its next waypoint. 

f. What parameters are used to define the lost link or return home point? How is this 

point selected? How is this point entered? What happens when the UA reaches this 

point? The InstantEye vehicle will enter its lost communication control mode if the 

error rate increases above 18.75 failed transmissions per successful transmission or 

after receiving no data from the ground station for 7.5 seconds. Logic exists to 

prevent the vehicle from oscillating in and out of lost communication control. When 

the aircraft enters it “lost comms mode” the aircraft ascends or descends to 300 ft.

AGL and then begins to navigate to the last known home position. If at any point 

communications are regained the operator can begin controlling again. 

g. Under what conditions is a return home mode both manually and automatically 

activated? The InstantEye Mk-2 either enters its return home mode in “lost comms

mode” after the aircraft climbs/descends to an altitude 300’ AGL above its launch 

altitude or when the “Home” button is pressed on the GCS. 

h. What do the control station displays indicate during lost link? Is it clear that the data 

is stale or invalid? Lost link is known by the operator when the on-screen data stops 

updating and the “Home” mode is automatically highlighted on the GCS screen. 

i. Lost link emergency procedures: 

i. Weak Command and Control (C2) Link

Indicator: “Warning: Weak C2 link” is displayed on-screen. Aircraft OSD data, such as the 

heading and altitude graphics, have stopped updating. Often video reception is poor or nonexistent as well.
Aug 20, 2015

Page 7 of 9

Response action: In ~7 seconds, the vehicle will enter lost communications mode. It will climb to 

an altitude of approximately 300 ft. AGL and then begin to fly back to the home location. If 

control communications are regained en route to the home location (indicated by the 

disappearance of the “Weak C2 link” warning and resumption of aircraft OSD data updates) the 

operator may resume controlling the aircraft and redirect it by using the joysticks.

ii. Loss of aircraft GPS fix 

Indicator: As GPS quality degrades, the color quality bar will shrink and change color and 

position hold will become less and less accurate. These effects are amplified when operating in 

windy conditions, or with very heavy payloads. When the quality bar underneath GPS coordinate 

is empty (completely gray) for 4 continuous seconds, the vehicle has lost operational GPS and an 

indicator is displayed: “Warning: Vehicle lost GPS; NAV mode disabled” NAV mode is 

automatically exited without operator action. Aircraft ceases to automatically hold position. The 

last know GPS is displayed in the GPS Coordinate graphic.

Response action: Ensure that ALT mode is engaged. The aircraft will maintain altitude while the 

operator can focus on controlling the lateral motion of the vehicle manually. When aircraft 

position has stabilized, climb to a safe height (above obstructions) and fly the aircraft towards 

the home location. Use the range/bearing graphic and video feed to assist in this. When over an 

optimal landing location, slowly decrease the aircraft’s altitude while focusing on maintaining 

lateral position. At any point, if the GPS quality bar shows a signal quality of medium (yellow) or 

high (green), it is likely safe to re-enter NAV mode.

8. Pilot Qualifications (14 CFR 61.3, Requirement for certificates, ratings, and authorizations, 

and 14 CFR 61.5, Certificates and ratings issued under this part).

a. Pilot Qualifications: All PIC will be current rated pilots with current medical. They 

will hold either a n airline, transport, commercial, private, recreation, or sport pilot 

certificate and the PIC will hold a current FAA airman medical certificate. 

9. Flight areas

a. Operations will be conducted under VFR of no more than 400 feet AGL. The UA will 

be operated within visual line of sight at all times. NO night operations will be 

conducted. 

10. Specifications and Operations 

a. Design of the UAS program for HECO/HELCO/MECO is the responsibility of the 

Survey Section of HECO’s Structural Division, part of the Engineering Division. 

The Survey section is facilitating the UAS Working Group, members of which are 

from all three individual companies. 

b. The UAS Working group is in charge of the structure of the UAS program and 

includes sub-groups that will oversee company protocols in the following areas:

• Program development

• Safety

• Training and Certification 

• Purchasing 
Aug 20, 2015

Page 8 of 9

• Privacy

• Company-wide Communications

c. The sUAS weighs ~17 oz., much less than the weight of a Canada goose, and will 

operate under 400 ft. AGL. The aircraft internal software regulates the sUAS so that 

it will not fly above 400 AGL and will limit aircraft ground speed to less than 25 mph. 

The impact to the public will be minimal. 

d. Air Traffic Control Provisions: sUAS will operate in Class G, C & D airspace, with 

the appropriate Certificate of Authorization. 

11. Granting the exemption would be in the public interest and benefit the public as a whole.

Unmanned aircraft systems (UAS) offer the utility industry new capabilities that reduce cost 

and operational risk while improving safety and efficiency. UAS can be used effectively to 

monitor water pipelines, power plants and utilities, from regular visual inspection to storm 

damage assessment. In the event of a power outage, utility companies require real-time 

information and imagery about the situation in order to make informed decisions. Damage 

assessment is critical to power restoration, but in many cases obstacles, such as downed trees 

blocking roads or flooding, make it difficult for utility crews to access and assess the damage. 

UAS provide a means of collecting important information more quickly and safely than a 

ground-based crew, reducing the time and number of personnel required to assess storm 

damage, dispatch repair crews and establish repair priorities. 

In addition, data captured by cameras is typically far more accurate than the human eye alone.

Unmanned aircraft systems (UAS) have been proven all over the world to increase reliability 

and safety while at the same time reducing costs.

HECO, HELCO and MECO, serve 95% of the residents of the state of Hawaii. Operational 

use of drones will benefit the public in many ways, including the following:

• Cost Savings: Currently operations consist of climbing, bucket trucks and helicopters 

being used for routine inspections of facilities (poles, lines, substations, various facilities 

within the power plants). Reconnaissance for engineering work in remote locations also 

requires helicopter flights. With a comprehensive UAS program in place, each time a 

climber, bucket truck or helicopter trip can be substituted with preliminary work done by 

UAS to isolate issues and for planning purposes, both time and money are saved. This is 

good for the communities which we serve.

• Safety: In each of the above instances, personnel can be spared from helicopter trips, pole 

and structure climbing, exposure to high voltage electricity, other hazardous work 

situations and dangerous environments. When UAS are utilized to isolate areas of 

concern through inspections, as a tool for mapping, and for assessment of disaster 

situations, personnel can be optimized and risk can be mitigated.

• Environmental Considerations: UAS will assist in working in environmentally sensitive 

areas. In areas that are endangered habitats, inspections of facilities will require fewer 

personnel accessing the areas of concern. Additionally, assessment of ocean outflow 
Aug 20, 2015

Page 9 of 9

temperatures, spill containment and assessment, and air quality issues around power 

plants can be accomplished faster and more effectively with the various sensors that can 

provide thermal, infrared and visual imaging.

• Reliability: In routine work, UAS will allow our companies to avoid hold-off situations 

( i.e. turning off the power) and system disruptions when they, rather than personnel, are 

used around high-voltage equipment.

During disaster situations such as fire, tsunami, hurricanes, earthquake, or any other event 

that will disrupt the grid, using UAS will allow faster, safer assessment of damage. This 

will be a great advantage for our island communities during disasters, when both 

personnel and aircrafts are limited resources. 

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft, and multiple UA larger then this UA, meet the conditions of 

Section 333. The FAA has found in multiple UA that the requested relief from 14 CFR part 

21, and any associated noise certification and testing requirements of part 36, is not necessary. 

Exemption No. 11217 from Notus Access and Exemption No. 11238 from San Diego Gas & 

Electric were granted in support of the InstantEye Mk-2 and San Diego Gas & Electric is 

conducting the same operations this exemption is requesting. 

Thank you for your time, and please direct all questions and concerns to Ms. Joanne 

Williamson at Hawaiian Electric Company: joanne.williamson@hawaiianelectric.com