Frank G. Queen, PLLC 

Attorney 

22 December 2015 

US Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, S.E. 

Washington DC 20590 

154 N. Main Street, Suite 2 

Waynesville NC 28786 

(828) 452-3336 

Fax- (828) 707-9454 

(rank@queenmountainlaw.com 

Re: Petition of Haywood Electric Membership Corporation for an exemption 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

Dear Department: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, 49 U.S.C. § 

44701 and 14 C.F.R. Part 11, Haywood Electric Membership Corporation ("Petitioner") 

hereby requests exemption to permit small unmanned aircraft system ("sUAS") 

operations as described herein. 

The purpose of the 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 of North Carolina, 

northern Georgia and northwestern South Carolina. It has been in existence since 1938, 

serving rural electricity customers throughout the region. 

2) Make and model of aircraft for 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 

30-45 kts (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 or television filming will be conducted. 

The vehicle will not be operated at a speed in excess of 87 knots (100 mph). 

The vehicle will be operated by 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 on his or her pilot certificate. All operations will be conducted 

with a visual observer (VO) present. 

The area of operations, including launch, operation, and retrieval, will be on or over 

utility lines where HEMC has a written easement for maintenance and inspection. 

The altitude of operations will be lower than 400 feet above ground level. The 

operations will be conducted in daylight, VFR, with the vehicle in sight of the PIC and 

VO. All operations will be more than 5 miles from any airport unless a letter of 

agreement is obtained or otherwise permitted by a COA issued to HEMC. 

4) Specific regulations from which relief is required and how the operator 

will maintain an equivalent level of safety or no adverse impact to safety 

14 CFR 45.23 and Section 91.9(c) (aircraft marking) 

Because of the small size of the s UAS, 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 number issued by the FAA in as large a size and 

location as is practical. The FAA has previously issued exemptions for these regulations 

(see, eg., Exemption No. 11239 and exemptions cited therein). 
Haywood Electric Membership Corporation Page 4 

before each launch. These self-checks and the PIC's inspection provide an equivalent 

level of safety to the regulations. The FAA has previously granted exemptions from 

these regulations (see, eg., Exemption No. 11239). 

5) Granting the exemption will be in the public interest 

Electric utilities have a duty to inspect their facilities regularly in order to insure their 

reliability and safety. Inspections in the mountainous and isolated portions of western 

North Carolina, northern Georgia and northwestern South Carolina can be both 

expensive and hazardous to the men and women who perform those inspections. The 

use of a s UAS to do routine inspections and to survey possible downed lines and towers 

in the case of natural disasters has the potential to improve service and reduce the risk 

to service personnel. 

Based on the foregoing, the Petitioner requests an exemption from the provisions 

described and for such other and further relief as to the Department seems appropriate. 

Respectfully submitted, 

rftil_4tL 

Frank G. Queen 

Frank G. Queen, PLLC 

Attorney for Haywood Electric Membership Corporation