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 Syste ms in

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

Name and Address of Applicant:

Hawaiian Electric Co mpanies

Attn: Jo a nne Willia ms on 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 Compan y (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. HEC O, 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 mat erial 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 g ranting 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 ha nd

- 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 algorith ms 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 MS L

h. Endurance. 3 0 min of battery life

i. Maximum airspeed. 60 mph
j. Description of ground support equipment. InstantEye Mk

- 2 uses 4 000 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 mov es 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 t hat 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 S an D iego G as &E lectric a Special Airworthiness Certificate in the Experi mental 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. T he InstantEye has been proven airworthy and received Certification with US Army Special Operations Command. ( Air Worthiness Releas e

, 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 t he InstantEye has a fully functioning Ground Control Station (GCS) . ( SeeAug 20 , 2015

Page 4 of 9 figure 2. ) When flight s 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 Se e 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 maint ai ned 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 observer s 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 V FR weather minimu ms ). There will be no adverse impact to the public because each visual o bserver 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

, n o 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 400 ft AGL and will avo id 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 s UAS uses barometri c 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 suff icient 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 n ot pose any risk to the public and provide a leve l 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 max imum flying time of 30 minutes. Howe ver, 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 toAug 20 , 2015

Page 5 of 9 operate after that for at least fi ve minutes. In addition, relief has been granted for manned aircraft to operate at less then the

minimu ms of § 91.151 including exemption Nos 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in exemption Nos 8811, 10808, an d 10673 for day time VFR. Since this request is for daytime VFR only, t his exemption would not poses any risk to the public and provides an equivalent level of safe ty for the exemption requested.

g. § 9 1.207 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.

T

his 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 Syste m 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 cond ucted 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 15 00 hrs of test and evaluation time on the InstantEye Mk

- 2 syste ms and more than 3600 hrs of test and evaluation time on the syste ms it is derived from. P hysical S cience I nc. 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 S an D iego G as &E lectric a Special Airworthiness Certificate in the Experimental category, it has flown numerous sorties in support of operations and has always operate d in a safe manner.

7. Flight Recovery and Lost Link Proce dures

. Ai rcraft lost link a nd 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 com ms ” mode.

b. O perational procedu res 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. Des cribe 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. A fter tethering has been achieved the air vehicle will respond to commands from that ground station only. In operation, due to radioAug 20 , 2015

Page 6 of 9 interference or flight beyond communication range, the aircraft can lose command and control lock with the ground control s tation. In this event the aircraft will enter

into its “lost comm” mode and will e xecute 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 comm unication is not reestablished, vehicle will hover over last known location of ground co ntrol 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# IEMK2 20130521

.

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

com ms ” 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 ra te 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 e nters it “lost com ms 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. Unde r what conditions is a return home mode both manually and automatically

activated? The InstantEye Mk

- 2 either enters its return home mode in “ lost com ms 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 automatic ally 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 non

existent as well.Aug 20 , 2015

Page 7 of 9 Response action: In ~7 seconds, the vehicle will enter lost communi cations 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 positio n 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

indicat or 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 gr aphic.

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 obstru ctions) 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 po int, 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 FA A airman medical certificate.

9. Flight areas

a. Operat ions 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 wi l l be

conducted.

10. Specif ications 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 indiv idual 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

• PurchasingAug 20 , 2015

Page 8 of 9 • Privacy

• Compan y

- wide Communications

c. The s UAS weighs ~17 oz., much less than the weight of a Canada g oose, and will operate under 400 ft. AGL. The aircraft internal software regulates the s UAS s o that it will not fly above 400 AGL and will limit aircraft ground speed to less than 25 mph.

The i mpact 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 syste ms (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

block ing 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 saf ely than a

gr ound

- 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 ai rcraft syste ms (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 ti me 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 i nstance s , 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 outflowAug 20 , 2015

Page 9 of 9 temperatures, spill containment and assessment, and air quality issues around power
plants can be accomplished faster and mor e 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 t han 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 a dvantage 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 we re 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 p lease direct all questions and concerns to Ms

. Joanne

Willia ms on at Hawaiian Electric C ompany : joanne.willia ms on@hawaiianelectric.com