December 2, 201S 

### Re: Petition to Amend Exemption 11326; Docket No. FAA-2015-0020 PPL Electric Utilities (PPL) herby petitions for an amendmentto Exemption No. 11326, which the FAA issued to PPL on April16, 201S, to permitthefollowing request regarding #26 ofthe approved exemption during UAS operations: 

### 1. Minimum distance away from structures and personal property be equal tothe maximum height oftheflight (i.e. SO foot pole is surveyed, the aircraft remains at least SO feet from objects); and 2. 100feet minimum distance away from non-participating personnel, orthe height oftheflight 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 amendmenttothe issued COA associated with Exemption No. 11326 (Docket No. FAA-201S-0020) to permitthefollowing conditions: 

### 1. Maximum operational altitude be increased to 300 feetAGL. 2. Abilityto request a NOTAM for UAS operations no more than 72 hours and no less than one (1) hour priorto flight; and PPL shall continue to abide bythe rest ofthe operational requirements set forth by the FAA in the issued exemption and COA ifthis amendment is approved. PPL Electric Utilities serves approximately 1.4 million customers in 29 counties in central and eastern Pennsylvania and maintains morethan 48,000 miles of power lines. PPL is investing morethan $3 billion overthe next several years to improve the electric delivery system. This includes replacing aging facilities as well as building new ones to meetthe growth in demand and make the networkeven more reliable. PPL has consistently won awards fortop-qualityservice to both residential and business customers and had been an industry leaderfor nearly 30 years in helping customers in need.

REQUESTED AMENDMENT TO CONDITION #26 OF APPROVED EXEMPTION 

# IMINIMUM DISTANCE FROM STRUCTURES AND PERSONAL PROPERTY A majority ofthe transmission and distribution lines maintained by PPL have an existing barrier in the form ofatree line to protect otherstructures and personal property during UAS operations. However, in a numberofareas 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 ofSOO feet away. PPL respectfully requests thatthe minimum required distance away from structures and personal property be equal tothe maximum height oftheflight (i.e. surveying a SO foot pole, operations

### shall remain a minimum ofSO 

### feet away}. The following shall be observed to maintain an equal level of safety:

• PPL shall alert owners ofstructures and personal propertywithin SOO 

### feet ofthe operational area that UAS operations shall be conducted; • Permission shall be obtained from owners ofstructures and personal property within adistance equal tothe maximum height ofthe flight (Ifthe pole to be surveyed is 100feettall, permission shall be obtained from owners ofstructures and personal propertywithin a 100foot radius of the pole}; • The pilot-in-command (PIC} shall make asafety assessment ofthe risk ofoperating closerto structures and personal property and determined that itdoes not present an undue hazard. PPL shall make every effortto avoid flying directly overvessels, vehicles, orstructures and will abide by the Academy of Model Aeronautics' (AMA} Code ofSafety. 

# IMINIMUM DISTANCE FROM NON-PARTICIPATING PERSONNEL

PPL will make every reasonable effortto keep a barrierorstructure between UAS operations and any non-participating personnel. A majority ofthetransmission and distribution lines maintained by PPL have an existing barrier in the form ofatree line to protect non-participating personnel from any potential accidents during UAS operations. However, in a number ofareas 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 

### feetfrom all nonparticipating persons impracticable. PPL respectfully requests thatthe minimum required distance away from nonparticipating persons be reduced to 100feet or equal tothe height oftheflight plus SO 

### feet (i.e. inspection ofa pole that is 1SO 

### feet AGL, minimum distancefrom nonparticipating people is 200 feet}, whichever is greater. The following shall be observed to maintain an equal level ofsafety:

• PPL shall erect a "Do Not Cross" line, which may be in the form ofa mobilefence, the minimum requested distance from the UAS operational area; • The PIC shall make asafety assessment ofthe risk ofoperating closerto nonparticipating persons and determined that itdoes not present an undue hazard; and • Ifthe "Do Not Cross" line is breached by any nonparticipants, UAS flight operations shall cease immediatelyto ensure the safety ofthese people. The minimum distance from non-participating personnel PPL is requested is much greaterthan the distance the Academy of Model Aeronautics (AMA} requires oftheir members. PPL shall avoid flying directly over unprotected people and will abide by the AMA's Code ofSafety.REQUESTED AMENDMENT TO COA 

# IMAXIMUM 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 of400 feet AGL however, the COA issued to PPL grants operations to be conducted at 200 feet AGL. PPL requests thatthis maximum allowable operational height be increased to 300 feet AGL. This would allow fordata to be collected, includingthe full height ofthe poles (maximum height ofthe tallest pole is 250 feet AGL). This would allow a buffer of 200 feet between the maximum altitude PPL can operatetheir UAS and the lowest altitude for manned aircraft. The following shall be observed to maintain an equal level ofsafety:

• Operations shall remain a minimum offive (5) nautical miles ofan 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 letterofagreement with that airport's management is obtained priortoflight; • A NOTAM shall be requested perthe 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. 

# INOTAM REQUESTS

For planned operations, such as typical maintenance on a power pole/line, the NOTAM request time frame of no more than 72 hours but no less than 24 hours does not present a problem. However, after storms occur orduring an emergency situation (i.e. aftera natural disaster) the requirement of requesting a NOTAM for UAS operations no less than 24 hours presents an issue. In many cases, the violence ofastorm 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 ofthe United States, notfarfrom the coast, the potential ofa hurricane affecting Pennsylvania is avery real possibility. This was a potential issue during Octoberof 2015 with the potential impact from hurricaneJoaquin. Between 2000 and 2013, twotropical 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 onlytothe state itself buttothe energy infrastructure as well. One ofthe most devastating was Hurricane Sandy in 2012. This super storm caused 16 deaths and left 1.2 million people without electricitythroughoutthe 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 thevicinity. 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) hourfrom the operational flight time during emergency situations. This less restrictive timeframe will allow PPL to request a NOTAM and mobilize their UAS team as soon as possible in orderto restore powertotheir customers. The following shall be observed to maintain an equal level ofsafety:

• Operations shall remain a minimum offive (5) nautical miles ofan airport reference point listed in the current FAA Airport/Facility Directory or are denoted on the current FAA published aeronautical chart, orotherwise permitted by aCOA issued to PPL unless a letterofagreement with that airport's management is obtained priortoflight; • Ifthe above requirements are met during an emergency situation, PPL shall contactthat airport's management directlyto alert them to UAS operations in thevicinity; • 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 amendmenttothe conditions and limitations listed in the preceding sections would be in the public interest as itwould benefit millions ofcitizens within the state of Pennsylvania. Grantingthe present petition for amendment(s) will continue tofurtherthe public interest as set forth in Grant of Exemption No. 11326, in which the Administratorfound 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 toflammable fuel. Grantingthe requested amendment(s) is in the public interest by alleviating human exposure to danger by working at high elevations and in proximityto 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 ofsUAS will be realized without implicating any privacy issues. Granting of PPL's proposed amendment will fulfill the Congressional mandate ofthe FAA Modernization and Reform Act of2012, by allowing PPL to safely, efficiently, and economically operate the DJI 5900 commercially within the NAS.Grantingthe hereto proposed amendments to conditions and limitationswill notadversely 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 toflights at an altitude of no morethan 300 feet AGL. All FAA mandated procedures and notifications listed in the issued COA and granted Exemption No. 11326shall be strictly adhered to. PPL respectfully submits that an equivalent level ofsafetywill be maintained, as presented in grant of Exemption No. 11326, as all other previously granted conditions and limitations shall remain in effect. In addition tothe increased safety measures listed in each ofthe above sections, PPL shall also require the following:

• Pilots shall be required to pass an UAS safetytraining 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 SafetyAwareness online training course. A Florida based company, USI has had courses added tothe 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 forthe use of DJI S-900) as well as navigation features. lfthere is an FAA certified UAS safety course that becomes available between thetimethis amendment is submitted and its review and approval, PPL shall make every effortto incorporate thattraining class into its curriculum. • Pilots shall be required to adhere tothe AMA safety code during the conduction ofany and all flight operations.

ADDITIONAL INFORMATION This Petition is made pursuant tothe FAA Modernization and Reform Act of2012 Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely in the NAS. As such, PPL's request for amendment may be granted pursuant tothe 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 of2012, Section 333, PPL respectfully requests thatthe Administratorgrantthis Petition for amendmentto grant of Exemption No. 11326, to the extent necessaryto allow PPL to operate the DJI 5900 within the NAS for the purpose ofthe conduction of inspections ofenergy 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