### Frank G. Queen, PLLC Attorney

22 December 2015 US Department ofTransportation Docket ManagementSystem 1200 New JerseyAvenue, S.E. Washington DC 20590 154N. Main Street, Suite 2 Waynesville NC 28786 (828) 452-3336 Fax- (828) 707-9454 (rank@queenmountainlaw.com

Re: Petition ofHaywood Electric Membership Corporation for an exemption pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 Dear Department: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012, 49 U.S.C. § 44701 and 14 C.F.R. Part 11, Haywood Electric Membership Corporation ("Petitioner") herebyrequests exemption to permit small unmanned aircraft system ("sUAS") operations as describedherein. The purpose ofthe operations are aerial data collection and research for the use of such sUAS in utility operations. 1) Operator Haywood Electric Membership Corporation 376 Grindstone Road Waynesville NC 28785 Attn: Norman Sloan, Executive Vice President Haywood Electric Membership Corporation ("HEMC") is a North Carolina corporation operating an electric distribution network in the western portion ofNorth Carolina, northern Georgia and northwestern South Carolina. Ithas been in existence since 1938, serving rural electricity customers throughout the region. 2) Make and model ofaircraftfor proposed operations Make: Model: BirdsEye View Aerobatics (Sutton, New Hampshire) FireFLY6 The aircraft specifications include:Haywood Electric Membership Corporation Wingspan: Length: Weight: Flight time: Payload: Speed: Max speed: 6o" 37-4" 9 lbs, equipped 15 to 45 minutes, depending on configuration 1.5 to 2.5 lbs, depending on propulsion 30-45kts (34-40 mph) 

### so kts (57 mph) Page 2

The aircraft has been previously approved for a Section 333 exemption (See eg., Exemption 11677A, geoResources Technologies, Inc.). 3) Proposed operations HEMC will deploy the aircraft to survey existing distribution easements and structures. No operations for closed-set motion picture ortelevision filming will be conducted. The vehicle will notbe operated at a speed in excess of87knots (100 mph). The vehicle will be operatedby a pilot in command (PIC) holding either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid US driver's license. The PIC will meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated onhis orher pilot certificate. All operations will be conducted with a visual observer (VO) present. The area ofoperations, including launch, operation, and retrieval, will be on or over utilitylines where HEMC has a written easement for maintenance and inspection. The altitude ofoperations will belower than 400 feet above ground level. The operations will be conductedin daylight, VFR, with the vehicle in sight ofthe PIC and VO. All operations will be more than 5 miles from any airport unless a letter of agreement is obtained or otherwise permittedby a COA issued to HEMC. 4) Specific regulations from which reliefis required andhowthe operator will maintain an equivalent level ofsafety or no adverse impactto safety 14 CFR45.23 and Section 91.9(c) (aircraft marking) Because ofthe small size ofthe sUAS, the marking requirements cannot be met. The sUAS will be registered as an aircraft under 14 CFR part 47 and will marked in accordance with the registration numberissued bythe FAA in as large a size and location as is practical. The FAA has previouslyissued exemptions for these regulations (see, eg., Exemption No. 11239 and exemptions citedtherein).Haywood Electric Membership Corporation Page 4

before each launch. These self-checks andthe PIC's inspection provide an equivalent level ofsafety to the regulations. The FAA has previously granted exemptions from these regulations (see, eg., Exemption No. 11239). 5) Grantingthe exemptionwillbe inthe publicinterest Electric utilities have a dutyto inspect their facilities regularly in orderto insure their reliability and safety. Inspections in the mountainous and isolated portions ofwestern North Carolina, northern Georgia and northwestern South Carolina canbeboth expensive andhazardous to the men and women who perform those inspections. The use ofa sUAS to do routine inspections and to survey possible downed lines andtowers in the case ofnatural disasters has the potential to improve service and reduce the risk to service personnel. Based onthe foregoing, the Petitioner requests an exemption from the provisions described and for such other andfurther reliefas to the Department seems appropriate. Respectfully submitted, 

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Frank G. Queen Frank G. Queen, PLLC Attorneyfor Haywood Electric Membership Corporation