December 2, 201S 

Re: Petition to Amend Exemption 11326; Docket No. FAA-2015-0020 

PPL Electric Utilities (PPL) herby petitions for an amendment to Exemption No. 11326, which the FAA 

issued to PPL on April16, 201S, to permit the following request regarding #26 of the approved 

exemption during UAS operations: 

1. Minimum distance away from structures and personal property be equal to the maximum 

height of the flight (i.e. SO foot pole is surveyed, the aircraft remains at least SO feet from 

objects); and 

2. 100 feet minimum distance away from non-participating personnel, or the height of the flight 

plus SO feet (i.e. 1SO foot pole is surveyed, the aircraft remains at least 200 feet from nonparticipants), whichever is greater. 

In addition, PPL would like to request an amendment to the issued COA associated with Exemption No. 

11326 (Docket No. FAA-201S-0020) to permit the following conditions: 

1. Maximum operational altitude be increased to 300 feet AGL. 

2. Ability to request a NOT AM for UAS operations no more than 72 hours and no less than one (1) 

hour prior to flight; and 

PPL shall continue to abide by the rest of the operational requirements set forth by the FAA in the issued 

exemption and COA if this amendment is approved. 

PPL Electric Utilities serves approximately 1.4 million customers in 29 counties in central and eastern 

Pennsylvania and maintains more than 48,000 miles of power lines. PPL is investing more than $3 billion 

over the next several years to improve the electric delivery system. This includes replacing aging 

facilities as well as building new ones to meet the growth in demand and make the network even more 

reliable. PPL has consistently won awards for top-quality service to both residential and business 

customers and had been an industry leader for nearly 30 years in helping customers in need. 

REQUESTED AMENDMENT TO CONDITION #26 OF APPROVED EXEMPTION 

I MINIMUM DISTANCE FROM STRUCTURES AND PERSONAL PROPERTY 

A majority of the transmission and distribution lines maintained by PPL have an existing barrier in the 

form of a tree line to protect other structures and personal property during UAS operations. However, in 

a number of areas these transmission and distribution lines venture close to, if not attached to, other 

structures and personal property, making it impracticable to stay the required minimum distance of SOO 

feet away. PPL respectfully requests that the minimum required distance away from structures and 

personal property be equal to the maximum height of the flight (i.e. surveying a SO foot pole, operations 
shall remain a minimum of SO feet away}. The following shall be observed to maintain an equal level of 

safety: 

• PPL shall alert owners of structures and personal property within SOO feet of the operational 

area that UAS operations shall be conducted; 

• Permission shall be obtained from owners of structures and personal property within a distance 

equal to the maximum height of the flight (If the pole to be surveyed is 100 feet tall, permission 

shall be obtained from owners of structures and personal property within a 100 foot radius of 

the pole}; 

• The pilot-in-command (PIC} shall make a safety assessment of the risk of operating closer to 

structures and personal property and determined that it does not present an undue hazard. 

PPL shall make every effort to avoid flying directly over vessels, vehicles, or structures and will abide by 

the Academy of Model Aeronautics' (AMA} Code of Safety. 

I MINIMUM DISTANCE FROM NON-PARTICIPATING PERSONNEL 

PPL will make every reasonable effort to keep a barrier or structure between UAS operations and any 

non-participating personnel. A majority ofthe transmission and distribution lines maintained by PPL 

have an existing barrier in the form of a tree line to protect non-participating personnel from any 

potential accidents during UAS operations. However, in a number of areas these transmission and 

distribution lines venture into locations that are not as sparsely populated as the areas protected by tree 

lines. This makes the requirement that all flight operations be conducted at least SOO feet from all 

nonparticipating persons impracticable. PPL respectfully requests that the minimum required distance 

away from nonparticipating persons be reduced to 100 feet or equal to the height of the flight plus SO 

feet (i.e. inspection of a pole that is 1SO feet AGL, minimum distance from nonparticipating people is 

200 feet}, whichever is greater. 

The following shall be observed to maintain an equal level of safety: 

• PPL shall erect a "Do Not Cross" line, which may be in the form of a mobile fence, the minimum 

requested distance from the UAS operational area; 

• The PIC shall make a safety assessment of the risk of operating closer to nonparticipating 

persons and determined that it does not present an undue hazard; and 

• If the "Do Not Cross" line is breached by any nonparticipants, UAS flight operations shall cease 

immediately to ensure the safety of these people. 

The minimum distance from non-participating personnel PPL is requested is much greater than the 

distance the Academy of Model Aeronautics (AMA} requires of their members. PPL shall avoid flying 

directly over unprotected people and will abide by the AMA's Code of Safety. 
REQUESTED AMENDMENT TO COA 

I MAXIMUM OPERATIONAL HEIGHT 

PPL respectfully requests that UAS operations be conducted at an altitude no more than 300 feet AGL. 

Exemption No. 11326, #4 grants PPL a maximum altitude of 400 feet AGL however, the COA issued to 

PPL grants operations to be conducted at 200 feet AGL. PPL requests that this maximum allowable 

operational height be increased to 300 feet AGL. This would allow for data to be collected, including the 

full height of the poles (maximum height of the tallest pole is 250 feet AGL). This would allow a buffer of 

200 feet between the maximum altitude PPL can operate their UAS and the lowest altitude for manned 

aircraft. The following shall be observed to maintain an equal level of safety: 

• Operations shall remain a minimum of five (5) nautical miles of an airport reference point listed 

in the current FAA Airport/Facility Directory, are denoted on the current FAA published 

aeronautical chart, or otherwise permitted by a COA issued to PPL unless a letter of agreement 

with that airport's management is obtained prior to flight; 

• A NOT AM shall be requested per the minimum requirements set forth by the FAA in the issued 

COA during non-emergencies (requested alteration for NOTAMs during emergencies listed 

below). 

Coordination requirements set forth by PPL's issued COA shall be adhered to, including MTRs. 

I NOTAM REQUESTS 

For planned operations, such as typical maintenance on a power pole/line, the NOT AM request time 

frame of no more than 72 hours but no less than 24 hours does not present a problem. However, after 

storms occur or during an emergency situation (i.e. after a natural disaster) the requirement of 

requesting a NOT AM for UAS operations no less than 24 hours presents an issue. In many cases, the 

violence of a storm cannot be predicted and commonly results in downed power lines or outages. This is 

also a common occurrence when natural disasters, such as a hurricane, take place. Since Pennsylvania is 

located along the Northeastern portion of the United States, not far from the coast, the potential of a 

hurricane affecting Pennsylvania is a very real possibility. This was a potential issue during October of 

2015 with the potential impact from hurricane Joaquin. 

Between 2000 and 2013, two tropical depressions (Ernesto- 2006, Barry- 2007), five tropical storms 

(Allison- 2001, Henri- 2003, Hanna- 2008, Lee- 2011, Andrea- 2013), and four hurricanes (Isabel2003, Ike- 2008, Irene- 2011, Sandy- 2012) have impacted Pennsylvania causing extensive damage not 

only to the state itself but to the energy infrastructure as well. One of the most devastating was 

Hurricane Sandy in 2012. This super storm caused 16 deaths and left 1.2 million people without 

electricity throughout the state. 
Typically when NOTAMs are requested, they may be requested no more than 72 hours and no less than 

one (1) hour before the operation/structure/etc. is to be in the vicinity. This is common protocol with 

construction projects and structures such as cranes. 

PPL respectfully requests that NOTAMs be allowed to be requested no less than one (1) hour from the 

operational flight time during emergency situations. This less restrictive time frame will allow PPL to 

request a NOT AM and mobilize their UAS team as soon as possible in order to restore power to their 

customers. The following shall be observed to maintain an equal level of safety: 

• Operations shall remain a minimum of five (5) nautical miles of an airport reference point listed 

in the current FAA Airport/Facility Directory or are denoted on the current FAA published 

aeronautical chart, or otherwise permitted by a COA issued to PPL unless a letter of agreement 

with that airport's management is obtained prior to flight; 

• If the above requirements are met during an emergency situation, PPL shall contact that 

airport's management directly to alert them to UAS operations in the vicinity; 

• sUASs shall be operating at low altitudes of no more than 300 feet above ground level (AGL); 

• UAS operations shall only be conducted during daytime VFR conditions. 

Granting PPL's request for amendment to the conditions and limitations listed in the preceding sections 

would be in the public interest as it would benefit millions of citizens within the state of Pennsylvania. 

Granting the present petition for amendment(s) will continue to further the public interest as set forth 

in Grant of Exemption No. 11326, in which the Administrator found good cause for PPL's proposed UAS 

operation due to enhanced safety achieved by utilizing an unmanned aircraft with the specifications 

described by PPL, and by carrying no passengers or crew, as compared to a manned aircraft of 

significantly greater proportions, which carries crew in addition to flammable fuel. Granting the 

requested amendment(s) is in the public interest by alleviating human exposure to danger by working at 

high elevations and in proximity to high-voltage lines. The types of inspections proposed herein improve 

the quality of inspection services while decreasing operating costs associated therewith, comparative to 

conventional flight operations. Additionally, PPL's proposed operation significantly reduce hazards, as 

well as emissions, associated with the common practice of manned helicopter utilization to conduct 

similar inspection operations. 

PPL's proposed UAS operations will provide benefits to energy, science, and civil engineering. 

Furthermore, the benefits of PPL's proposed operation of sUAS will be realized without implicating any 

privacy issues. 

Granting of PPL's proposed amendment will fulfill the Congressional mandate of the FAA Modernization 

and Reform Act of 2012, by allowing PPL to safely, efficiently, and economically operate the DJI 5900 

commercially within the NAS. 
Granting the hereto proposed amendments to conditions and limitations will not adversely affect safety. 

PPL proposes that it may safely operate the DJI S900 UAS in accordance with its safety procedures and 

guidelines as outline in its Flight Operations Manual. Granting these amendments would ensure PPL's 

inspection operations are confined to flights at an altitude of no more than 300 feet AGL. 

All FAA mandated procedures and notifications listed in the issued COA and granted Exemption No. 

11326 shall be strictly adhered to. PPL respectfully submits that an equivalent level of safety will be 

maintained, as presented in grant of Exemption No. 11326, as all other previously granted conditions 

and limitations shall remain in effect. 

In addition to the increased safety measures listed in each of the above sections, PPL shall also require 

the following: 

• Pilots shall be required to pass an UAS safety training course. Topics shall include: see-and-avoid 

measures, Communication with an airport without an operating control tower, etc. Since there 

are no FAA certified UAS safety courses available to date, PPL has chosen the Unmanned Safety 

Institute's (USI) UAS Safety Awareness online training course. A Florida based company, USI has 

had courses added to the Florida CAPE (Career and Professional Education) Funding list for 2015. 

If in-person training is deemed necessary, PPL proposes to use Dart Drones' Advanced Class, 

which covers a number of DJI specific features (PPL is approved for the use of DJI S-900) as well 

as navigation features. lfthere is an FAA certified UAS safety course that becomes available 

between the time this amendment is submitted and its review and approval, PPL shall make 

every effort to incorporate that training class into its curriculum. 

• Pilots shall be required to adhere to the AMA safety code during the conduction of any and all 

flight operations. 

ADDITIONAL INFORMATION 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 Section 333, which 

directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As 

such, PPL's request for amendment may be granted pursuant to the authority of FMRA Section 333 and 

14 C.F.R. Part 11. 
CONCLUSION 

In accordance with the Federal Aviation Regulations (14 C.F.R.) and the FAA Modernization and Reform 

Act of 2012, Section 333, PPL respectfully requests that the Administrator grant this Petition for 

amendment to grant of Exemption No. 11326, to the extent necessary to allow PPL to operate the 

DJI 5900 within the NAS for the purpose of the conduction of inspections of energy 

infrastructure. 

December 2, 2015 Respectfully submitted, 

Clyde 

~~ J. Pittman 

Director of Engineering 

Federal Airways & Airspace 

1423 S. Patrick Dr. 

Satellite Beach, FL 32937 

Phone: (321) 777-1266