POWER SUPPORT LLC

3304 S. Boomer Rd, PO Box 1809, Stillwater, OK 74076 405-372-2884

March 14, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: Request for exemption from multiple regulatory provisions to allow the use of small

unmanned aerial systems controlled by Power Support LLC to assist in the safe evaluation of 

infrastructure and operations in the utility, energy, and agricultural industry.

Dear Sir or Madam:

Power Support LLC respectfully requests an exemption from several provisions of Title 14 of the 

Code of Federal Regulations (CFR) to permit the use of small unmanned aerial systems (sUAS) to 

provide commercial services focusing on the evaluation, inspection and asset management relating to 

the four market sectors listed below.

1. Utility Infrastructure Assessments

2. Energy Infrastructure Assessments

3. Emergency Management and Disaster Assessments

4. Agricultural Assessments

Background

Power Support LLC is headquartered in Stillwater, Oklahoma. Power Support LLC is a wholly

owned subsidiary of Central Rural Electric Cooperative and was formed to provide services to 

utilities and commercial businesses including energy management services, asset management 

services, and analytics. The safety and efficiency of infrastructure operations is heavily dependent 

upon constant analysis of assets, right-of-way, infrastructure and other facilities. There are a wide 

variety of factors that can affect conditions and cause problems for infrastructure. Even relatively 

small objects or minor failures can lead to accidents or other incidents causing downtime of 

infrastructure or potential public hazards. Extreme weather, vegetation, natural disasters, theft and 

vandalism are among the many risks that modern infrastructure faces.

Power Support LLC will provide as a service, the inspection of infrastructure, such as overhead lines,

substations, electrical apparatus, poles, right-of-way and other similar structures and assets in the 

energy and agricultural industry.

Infrastructure Safety Inspection Operations

Overhead Line Inspections

Substation Inspections

Pole Inspections

Electrical Apparatus Inspections

Right-of-Way Inspections

Storm Damage Assessments

Solar Panel Inspection

Emergency Management and Disaster Assessments
POWER SUPPORT LLC

3304 S. Boomer Rd, PO Box 1809, Stillwater, OK 74076 405-372-2884

Agricultural Assessments

Regulatory Basis for Exemption Request

This request is in accordance with Section 333 of the FAA Modernization and Reform Act of

2012 (Modernization Act) 1 through which Congress acknowledged the use of such systems prior to

the finalization of specific sUAS rules and regulations. Until such time as these regulations are

finalized, the Secretary of Transportation is required to make a determination whether certain

unmanned aircraft systems may operate safely in the national airspace system (NAS). As part of such 

determination the Secretary is to consider the following:

- The UAS’s size, weight, speed, and operational capability;

- Operation of the UAS in close proximity to airports and populated areas; and

- Operation of the UAS within visual line of sight of the operator.

In regards to specific requests the FAA has adopted requirements, providing that applicants of such 

requests shall explain why granting the exemption would not adversely affect safety or how the

exemption would provide at least an equivalent level of safety compliance with the underlying

regulation. In this case, approval of this exemption would advance the public interest by significantly

enhancing the safety and efficiency of infrastructure operations and by providing the

FAA with valuable user experience on sUAS in a context with appreciable economic and societal

benefits. As described more fully below, the requested exemption would permit the operation of

sUAS under tightly controlled conditions, thus ensuring that operations will not have an adverse

impact on safety to both public and worker. To the contrary, as explained below, Power Support LLC

expects that use of sUAS will enhance safety in infrastructure operations. Granting an exemption is 

in the public Interest. The safety and efficiency of infrastructure operations is heavily dependent 

upon constant analysis of assets, right-of-way, infrastructure and other assets/facilities.

Provisions for which an exemption is sought

14 CFR Part 21

14 C.F.R. Part 61

14 CFR 61.113 (a)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

Explanation:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)
POWER SUPPORT LLC

3304 S. Boomer Rd, PO Box 1809, Stillwater, OK 74076 405-372-2884

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited

operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21

Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of

the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon

consideration of the size, weight, speed, operational capability, and proximity to airports and

populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the

UAS operated without an airworthiness certificate, in the restricted environment and under the

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or

rotorcraft) operating with an airworthiness certificate without the restrictions and conditions

proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a

secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will

be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, and

under the requirements and in compliance with local public safety requirements, to provide security

for the area of operation as is now done with conventional filming. The FAA will have advance

notice of all operations. These safety enhancements, which already apply to civil aircraft operated in

connection with motion picture and television production, provide a greater degree of safety to the

public and property owners than conventional operations conducted with airworthiness certificates

issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates

that there is no credible threat to national security posed by the UAS, due to its size, speed of

operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability

to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft & 14 C.F.R. Part 47. Aircraft Registration

These regulations require:

When marks include only the Roman capital letter "N" and the registration number is displayed on

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft,

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot

station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted,"

"light-sport," "experimental," or "provisional," as applicable.

Power Support LLC will register all sUASs under the appropriate serial number in accordance with 

the referenced regulation.

Power Support LLC will mark the fuselage with a Registration Number as large as practicable in 

locations on the sUAS as feasible.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will

not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of

current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather

than a commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that

carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The

area of operation is controlled and restricted, and all flights are planned and coordinated in advance

as set forth in the Manual. The level of safety provided by the requirements included in the Manual

exceeds that provided by a single individual holding a commercial pilot’s certificate operating a
POWER SUPPORT LLC

3304 S. Boomer Rd, PO Box 1809, Stillwater, OK 74076 405-372-2884

conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the

level of risk associated with commercial operations contemplated by Part 61 when drafted, that

allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present level

of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. Part 61, additional subparts

Power Support LLC requests the FAA to advise on the intended pilots licensing requirements. Power 

Support LLC intends to use employee(s) with a minimum of a recreational license but has an 

employee with commercial pilot certificate. When the FAA introduces sUAS specific regulations 

(such as 14 C.F.R. 107), Power Support LLC will transition to the appropriate licensure at that time.

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.

As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted,

no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft

and the requirements contained in the Manual for maintenance and use of safety check lists prior to

each flight an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless

there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved

manual material, markings, and placards, or any combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on

the aircraft, not only because there is no pilot on board, but because there is no room or capacity to

carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground control

point where the pilot flying the sUAS will have immediate access to appropriate manuals.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an

exemption will be needed.

Power Support LLC can provide an equivalent level of safety as set forth in owner’s manual. The 

PIC will take all actions including reviewing weather, flight battery requirements, landing and 

takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that 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.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight

control is accomplished through the use of a control box that communicates with the aircraft via

radio communications. The FAA has approved exemptions for flight training without fully functional

dual controls for a number of aircraft and for flight instruction in experimental aircraft.

The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried

in the aircraft and by the size and speed of the aircraft. Power Support LLC intends to provide flight 
POWER SUPPORT LLC

3304 S. Boomer Rd, PO Box 1809, Stillwater, OK 74076 405-372-2884

instruction to be in accordance with the manufacturer’s guidelines and by utilizing the 

manufacturer’s ‘Beginner Mode’ function to instruct in-house pilots with the built-in flight simulator.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (c) allows

aircraft to be operated at less than the minimums prescribed. As this exemption is for a sUAS, the

exemption requests authority to operate at altitudes up to 200 AGL As set forth herein, except for the 

limited conditions stated in the Manual, the

UAS will never operate at higher than 200 AGL.

It will however typically be operated in a restricted area, where buildings and people will not be

exposed to operations without their pre-obtained consent. The equivalent level of safety will be

achieved given the size, weight, speed of the UAS as well as the location where it is operated. No

flight will be taken without the permission of the property owner or local officials. Compared to

flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed

herein and the lack of flammable fuel, any risk associated with these operations is likely less than

those presently presented with conventional aircraft. In addition, the low-altitude operations of the

sUAS will ensure separation between these small-UAS operations and the operations of conventional

aircraft that must comply with Section 91.119.

Power Support LLC also notes that the proposed operations covered under this exemption request are 

intended to be conducted near infrastructure for the purposes of their inspection. The operation of a 

sUAS so close to much larger structures would provide a negligible flight hazard to other aircraft 

compared to the tower or utility line itself.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting

available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the

operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site

shown on the GPS altitude indicator before flight.

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

Section 91.151 (a) prohibits an individual from beginning “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; or (2) At night, to fly after that for at least 45 minutes.”

Power Support LLC believes that an exemption from 14 CFR §91.151(a) falls within the scope of 

prior exemptions. Operating the small UAS, in a tightly controlled area where only people and 

property owners or official representatives who have signed waivers will be allowed, with less than 

30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to

alleviate given the size and speed of the small UAS.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airworthiness certificate. . . .
POWER SUPPORT LLC

3304 S. Boomer Rd, PO Box 1809, Stillwater, OK 74076 405-372-2884

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph

(a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or

cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As 

such, there is no ability or place to carry certification and registration documents or to display them 

on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control

point where the pilot flying the sUAS will have immediate access to them, to the extent they are

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as

prescribed in subpart E of this part and shall between required inspections, except as provided in

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,”

and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these

sections should not apply to Power Support LLC’s sUAS(s). Maintenance will be accomplished by 

the operator pursuant to the flight manual and operating handbook as referenced in the Manual. An 

equivalent level of safety will be achieved because these small UASs are very limited in size and will 

carry a small payload and operate only in restricted areas for limited periods of time. If mechanical 

issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. 

As provided in the Manual, the operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety.

Regulatory Relief from Other Sections as deemed appropriate by FAA

Power Support LLC requests additional relief, to the extent practicable, from provisions which the 

FAA has learned through the rulemaking process have proven impractical for the use of sUASs.

Exhibit A – Specific sUASs operated by Power Support LLC

DJI Inspire 1

DJI S1000

EXHIBIT B – FEDERAL REGISTER PUBLICATION VERBIAGE

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b)

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409

(a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs

or less) for the purposes of inspecting electrical and telecommunications infrastructure.

Approval of exemptions allowing these particular commercial operations of sUASs will enhance

safety by reducing risk. Conventional inspections require fixed wing aircraft, rotary winged aircraft

or qualified climbers to work on or around electrical and other hazards. In contrast, a sUAS weighing
POWER SUPPORT LLC

3304 S. Boomer Rd, PO Box 1809, Stillwater, OK 74076 405-372-2884

fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced

mass and lack of combustible fuel carried on board as well as limiting risk to Power Support LLC

personnel. 

The sUAS is transported or carried to the location and not flown. The sUAS will carry no passengers 

or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions outlined

above, will provide an equivalent level of safety supporting the grant of the exemptions requested

herein, including exempting the applicant from the requirements of Part 21 and allowing commercial

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a controlled

environment and, as a result, are far safer than conventional operations conducted with manned

aircraft operating in close proximity to the ground and people.