April 16, 2015 

 Exemption No. 11326 

 Regulatory Docket No. FAA−2015−0020 

Mr. Joel Eline 

PPL Electric Utilities Corporation 

2 North 9th Street 

Allentown, PA 18101 

Dear Mr. Eline: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter posted to the public docket on January 7, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of PPL Electric Utilities Corporation (hereinafter petitioner 

or operator) for an exemption. The exemption would allow the petitioner to operate an 

unmanned aircraft system (UAS) to conduct inspections of energy infrastructure, such as 

transmission and distribution lines and substations. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. 

Airworthiness Certification 

The UAS proposed by the petitioner is a DJI S900. 
2 

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, and any associated noise certification and testing requirements of part 36, is 

not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, PPL Electric Utilities Corporation is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed below. 

Conditions and Limitations 

In this grant of exemption, PPL Electric Utilities Corporation is hereafter referred to as 

the operator. 
3 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the DJI S900 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC must 

be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 
4 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the 

operator must petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold 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 U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also 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. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
5 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable. 
6 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption. 
7 

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption; 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N-Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91. 

This exemption terminates on April 30, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 

 
Applicant’s Petition for Exemption 

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

Applicant: Airspace Consultant of Applicant: 

PPL Electric Utilities Corporation, 

Attn: Joel Eline 

2 N. 9th Street 

Allentown, PA 18101 

Phone: (610) 774-6088 

Email: jdeline@pplweb.com 

Clyde J. Pittman 

Director of Engineering 

Federal Airways & Airspace 

1423 S. Patrick Dr.

Satellite Beach, FL 32937 

Phone: (321) 777-1266
1 

I.    SUMMARY OF PETITION

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“Section 333”), PPL

Electric Utilities(“Applicant”) hereby respectfully requests expedited approval to use Small Unmanned

Aircraft System (“sUAS”) under the terms and conditions described in this Petition for Exemption

(“Petition”) to conduct inspections of energy infrastructure. PPL Electric Utilities also requests the

exemptions that are necessary to such approval pursuant to 49 U.S.C. § 44701(f), and 14 C.F.R. § 11.81.1

Applicant seeks to use sUAS to perform visual inspections of vital energy infrastructure, such as

transmission and distribution lines and substations, in order to further the public interest in the safe and

reliable delivery of electricity to customers.  Small UAS are ideally suited for inspection of energy

infrastructure—they can safely, inexpensively, and quickly deliver high‐quality photo and video, which

eliminates the need for physical inspection and thus speeds the process of trouble‐shooting, and

ultimately increases the reliability of the electric grid.  In particular, sUAS allow for safer operations and

inspection of the critical infrastructure. Utility workers would be able to conduct inspections without

being in close proximity to high‐voltage equipment or subject to the height related hazards of bucket

trucks or conventional aircraft.  They can also facilitate the safe inspection of hard‐to‐access or

environmentally sensitive areas without the use of bucket trucks, helicopters, and other utility vehicles

that may have more impact than sUAS.  In addition, because of the small size of the craft, there is not

the exposure and risk to public safety as with traditional helicopter use. In many cases sUAS can be more

efficient and cost effective than traditional methods, which can help to reduce operations and

maintenance costs and, perhaps most importantly, provide a means for faster resolution of any

problems on the electric system.  A reduction to the overall maintenance costs would be of benefit to

 

1

 As described in Appendix A to this Petition, Applicant requests an exemption from the following regulations: 14 

C.F.R. Part 21;14 C.F.R. Part 27; 14 C.F.R. §§ 45.23(b); 61.113 (a) and (b); 61.133(a); 91.7(b); 91.9(b)(2); 91.103; 

91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.319(a)(1); 91.405(a); 91.407(a)(1); 91.409 (a)(2); 91.417 

(a) and (b); 91.1501. 
2 

the public by being able to pass any reduction of costs directly to the rate payer.  The public interest is

critical to our success and the approval of this request and the provision of the necessary exemptions

will enhance worker and public safety, increase electric system reliability and decrease customer costs.

Moreover, approving the requested use would represent a significant step forward in the

Federal Aviation Administration’s (“Administration”) efforts to integrate sUAS into the national airspace

system.  PPL Electric Utilities’ request provides the Administration with an opportunity to partner with a

leading electric energy provider as it works to develop its rulemaking pursuant to the FAA

Reauthorization Act of 2012—while doing so for a compelling public purpose and under strict

operational and safety guidelines.  Given the uniqueness of Applicant—the company has a diverse

geographical and environmental footprint and a distinctive resource mix—it is ideally suited to help the

Administration understand the potential utility applications for sUAS.

PPL Electric Utilities proposes to use sUAS that are rotorcraft, weigh 15 or fewer pounds,

operate at a speed of no more than 50 knots, and contain built‐in safety features.  In addition, PPL

Electric Utilities proposes to use the aircraft at low altitudes, not in proximity to airports or densely

populated areas, on property that is owned or controlled by PPL Electric Utilities or is utility right of way,

within the visual line of sight of the operator, and under controlled conditions.  Accordingly, the

requested exemptions satisfy the applicable statutory criteria and policies, will serve the public interest,

will not adversely affect safety, and will provide a level of safety at least equal to the existing

airworthiness and related regulations.  Approval of this Petition is therefore consistent with Section

333’s directive to “establish requirements for the safe operation of [unmanned aircraft systems] in the

national airspace system” if the Secretary of Transportation determines that certain unmanned aircraft

systems may operate safely in the national airspace system.2

 

2

 Section 333(c) of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95, 126 Stat 11. 
3 

II. APPLICANT BACKGROUND

PPL Electric Utilities is a Pennsylvania based utility that services about 1.4 million customers in

29 counties.  We maintain more than 48,000 miles of power lines and power over 400 substations in

central and eastern Pennsylvania.  PPL Electric Utilities is committed, first and foremost to safety. We

were the first electric utility company in the country to have all field worksites qualify for “Star” status in

the federal Voluntary Protection Program — a status we’ve maintained.  The program recognizes

companies for going beyond compliance to protect worker health and safety.  We believe safety is the

cornerstone of every job, every day. Additionally, PPL Electric Utilities is focused on the reliability of its

system through maintenance and inspection of the existing electrical system as well as build‐out of

additional facilities. Consistent with PPL Electric Utilities' efforts for providing safe and reliable service to

our customers, PPL Electric Utilities seeks to use sUAS to more safely and effectively perform inspections

of the electrical infrastructure.

III. RELEVANT STATUTORY AUTHORITY

A. Section 333

Section 333(a) states that the Administration “shall determine if certain unmanned aircraft

system before completion of the plan and rulemaking [to broadly integrate UAS into the national

airspace] required by Section 332 of this Act.”  Section 333 is also described as a pathway for “expedited

operational authorization.”3

   

Section 333(b)(1) outlines the factors that the Administration shall use to determine whether

UAS may be operated safely in the national airspace system:  size, weight, speed, operational capability,

proximity to airports and populated areas, and operation within visual line of sight.  In addition, and

importantly for this Petition, Section 333(b)(2) provides the Administration with the discretion to

 

3

 Section 332(b)(1). 
4 

determine that a certificate of waiver, certificate of authorization, or airworthiness certification is not

required to operate UAS that are found to be appropriate under Section 333(b)(1).  Finally, Section

333(c) allows the Administration to establish requirements for safe operation of the UAS determined to

be able to be operated safely in the national airspace system.

B. Section 44701(f)

In addition to its specific authority related to authorizing UAS operation under Section 333, the

Administration has general authority to grant exemptions from its safety requirements and minimum

standards if the Administration finds that the exemption is in the public interest.4

  Administration

regulations set forth the information that must be included in the petition for exemption: (1) the

applicant’s name and mailing address; (2) the regulations from which the applicant seeks exemption; (3)

the extent of relief sought and why; (4) the reasons why granting the request would be in the public

interest and how it would benefit the public as a whole; and (5) the reasons why granting the exemption

would not adversely affect safety, or how the exemption would provide a level of safety at least equal to

the rule from which the applicant seeks exemption.5   

IV. DISCUSSION

A. Applicant’s Proposal Satisfies the Section 333 Criteria for Approval.

As described above, Section 333(b)(1) outlines the factors that the Administration shall use to

determine whether UAS may be operated safely in the national airspace system:  size, weight, speed,

operational capability, proximity to airports and populated areas, and operation within visual line of

sight.  Applying the criteria outlined in Section 333(b)(1) and other relevant criteria to this case

demonstrates that Applicant’s proposed terms and conditions of operation will result in the sUAS being

operated safely in the national airspace system, consistent with Section 333.  Based on the small size of

 

4

 49 U.S.C. § 44701(f). 

5

 14 C.F.R. § 11.81. 
5 

the sUASs involved, the low altitude and restricted environment in which they will operate, and the fact

that they will be operated within the visual line of sight of the operator, there is more than sufficient

basis to find that the sUAS can be operated safely under Applicant’s proposal.   

1. Size, Weight, Speed, and Operational Capability

Applicant proposes to use small, multi‐rotor craft with a maximum take‐off weight of 15 pounds

or less that are powered by electric batteries and carry no flammable fuel or cargo.  PPL Electric Utilities

anticipates the majority of flights will use much smaller craft—quadcopters with a maximum takeoff

weight of five pounds.  Heavier craft (up to 15 pounds) will only be used in situations requiring

specialized equipment, such as infrared cameras for thermal inspection of power equipment.   

The sUAS used by PPL Electric Utilities will have integrated GPS autopilot systems.  The

integrated GPS autopilots provide stable, precise flight, and stable hovering—enabling field workers to

focus on situational awareness (e.g., proximity to high voltage equipment) and safety of themselves and

the public.  In addition, the GPS autopilot system provides an automatic return to home capability in the

unlikely case of signal loss with the operator.

These small, multi‐rotor craft are ideally suited for inspection of power lines, generating plants

and other power‐related infrastructure because they often deliver high‐quality photo and video more

efficiently and cost effectively than traditional methods.  Using sUAS can also be safer for utility workers

because it will avoid putting utility workers in close proximity to high‐voltage equipment and work

conditions with high elevations, eliminating the risk of injuries from falls.  They also allow the safe

inspection of hard‐to‐access or environmentally sensitive areas without the use of bucket trucks and

other utility vehicles.  Overall, sUAS can provide significant benefits over traditional energy

infrastructure inspection methods to utility workers and customers.
6 

2. Proximity to Airports/Populated Areas

Applicant will avoid operating the sUAS over densely populated areas and will operate at least

three nautical miles away from the nearest public use airport.  The sUAS will be operated at low

altitudes of 250 feet or less—much lower than the airspace in which manned vehicles operate and lower

than the altitude at which hobby aircraft fly.  Finally, all operations will occur over utility property or

utility right of way.

In addition, PPL Electric Utilities’s flights will likely occur in airspace that is subject to a Notice to

Airmen (“NOTAM”).  The Administration has issued a standing notice to pilots to avoid loitering in the

“airspace above, or in proximity to, sites such as nuclear power plants, power plants, dams, refineries,

industrial complexes, military facilities, and other similar facilities.”  This NOTAM should further limit the

potential interaction of any flights near PPL Electric Utilities power transmission facilities.

3. Visual Line of Sight

A  FAA licensed pilot will operate the sUAS during daylight hours, in good weather, and within

the operator’s line of sight.  In addition, the operator will be accompanied by a trained spotter, who also

will be positioned in line of sight of the aircraft and will be in constant communication with the operator

to identify and alert the operator to any potential obstacles.  This eliminates the need for other “sense

and avoid” capabilities during operation, as well as the need for any method of air traffic control

communications.6

  

 

6 See Interim Operational Approval Guidance 08-01, Unmanned Aircraft Systems Operations in the U.S. National 

Airspace System at 4 (Mar. 13, 2008). 
7 

B. Applicant’s Proposal Also Satisfies the Standard for Exemption under Section 44701 and 14

C.F.R. § 11.81.

1. Granting Applicant’s Request Would Not Adversely Affect Safety and Would Provide a

Level of Safety at Least Equal to Existing Rules.

Granting PPL Electric Utilities’ Petition will not adversely affect safety.  Applicant’s proposed

terms and conditions of operation would provide a level of safety at least equal to existing rules.  As

discussed above with respect to Section 333(b)(1) criteria, the size, weight, speed, and operational

capability of the sUAS that will be used in the proposed operations indicate that the aircraft can be

operated safely in the national airspace system.  Moreover, the aircraft will be operated at low altitudes,

not in proximity to airports or densely populated areas, and within the visual line of sight of the

operator and spotter.  In addition, PPL Electric Utilities proposes the following conditions to ensure that

the requested exemption would result in a level of safety at least equal to the rules from which PPL

Electric Utilities is seeking an exemption.

a. Safety Systems

Applicant will use sUAS that have a semi‐autonomous navigation and control system comprised

of a Ground Control Station and “auto‐pilot” system.  Automated safety functions and safety enhancing

features of the sUAS that PPL Electric Utilities will use include the following:

 Precision Flight and Stable Hovering:  Integrated GPS autopilot system provides position

holding, altitude lock, and stable hovering to all field personnel to focus on situational

awareness and safely getting the job done.

 Auto Return‐To‐Home:  Fail‐safe feature will automatically activate in case of signal loss

with ground station, using GPS‐Enabled autopilot to automatically return and landing

the craft at the original take‐off point.

 Clearly Visible Battery and GPS Status:  Battery and GPS Status will be available through

airframe status lights clearly visible to the operator and available through the ground

station display.

 No Waypoint Zones: The Ground Control Station features a function called "No

Waypoint Zones." This feature provides an extra element of safety around major

airports by not allowing the sUAS to operate within a predetermined radius of these

airports.
8 

b. Mandatory Operating Conditions

In addition to the safety features described above, PPL Electric Utilities proposes that its

exemption be subject to the following mandatory conditions to ensure safe operation:

 Operations will avoid densely populated areas.

 Operations will be conducted over property that is owned or controlled by PPL Electric

Utilities or is utility right of way.

 Maximum total flight time for each flight will be 60 minutes.  Flights will be terminated

at 25% battery power reserve, should that occur before this time limit.

 Operations will occur during Visual Flight Rules Meteorological Conditions.

 Aircraft to remain within Visual Line of Sight (“VLOS”).  VLOS will be guaranteed with a

cylinder of operation around operator of 1⁄2 nautical miles.

 Operations will occur during daylight hours.

 Flights will be operated at an altitude of no more than 250 feet Above Ground Level

(“AGL”).

 All operations to remain more than three nautical miles from the airport reference point

of public use airports.

 Operators and spotters will meet the operator training and certification requirements

proposed below.

 Operators and spotters will be in communication at all times.

 Operator will perform required maintenance per the manufacturer’s recommendations

and keep a log of any maintenance performed.

 Operator will perform any safety checks specified in the manufacturer’s user guide prior

to each flight.

c. Operator Training and Certification

As discussed above, the sUAS PPL Electric Utilities will use are characterized by a high degree of

control and built‐in technical capabilities that limit the potential for operation outside the operating

conditions set forth in this Petition.  Moreover, the mandatory operating conditions (maximum altitude,

proximity to airfields, visual line of sight) minimize any potential weather impact and interactions with

other aircraft.
9 

Situational awareness around high‐voltage equipment, a thorough working knowledge of the

sUAS, and strict adherence to corporate sUAS flight policy are key to safe sUAS operations.  Given the

significant differences between sUAS and piloted aircraft, the safety features inherent in the sUAS, and

the strict operating conditions that will apply, PPL Electric Utilities proposes that, in addition to holding a

commercial or private pilot license, operators of the sUAS shall also be required to have:

 Proven knowledge of PPL Electric Utilities UAS flight policy (including Mandatory

Operating Conditions specified in this Petition);  

 Proven working knowledge of safe sUAS operations, flight characteristics, safety

features, GPS/Battery Status indicators, and emergency procedures;  

 Utility knowledge regarding safe operations around high voltage power lines, substation

equipment, and power plants; and

 A valid driver’s license.

Applicant is receptive to future regulations and industry guidance on licensing sUAS pilots using

training and testing that is relevant to operating sUAS in a limited flight area.

d. Privacy Considerations

Applicant will not operate sUAS in any way that may invade personal privacy and will comply

with any federal, state, or local privacy laws that may apply in areas where PPL Electric Utilities operates

sUAS.  In addition, as a practical matter, flights will occur over utility property or utility right of way, so

privacy is unlikely to be a concern in relation to Applicant’s proposed use.

2. Granting Applicant’s Request Would Be in the Public Interest and Would Benefit the

Public as a Whole.

Allowing the requested use will provide significant benefits to the public, PPL Electric Utilities

customers, and PPL Electric Utilities employees.  Using sUAS to inspect energy infrastructure can be

safer and more efficient than traditional methods of infrastructure inspection, such as the use of
10 

helicopters and bucket trucks.  The increased safety and efficiency of using sUAS to inspect

infrastructure following significant weather events is especially important to PPL Electric Utilities, which

serves 1.4 million customers in Pennsylvania, where storms occur with frequency.  An infrastructure

inspection process that is safer and more efficient can help to lower operations and maintenance costs

and more quickly resolve problems in the delivery of electricity, both of which will benefit customers.   

Moreover, the requested use presents a compelling case for the Administration moving forward

with efforts to integrate sUAS into the national airspace system as required by Section 333.  The public

has a significant interest in efficient and safe inspection of energy infrastructure to ensure reliable

delivery of power, and PPL Electric Utilities has proposed using sUAS to further this public interest in a

way that is at least as safe as operation of aircraft under existing regulations.  Applicant’s request,

therefore, provides the Administration an appropriate vehicle to further Congress’ mandate to expedite

integration of UAS.  In addition, Applicant’s operational experience resulting from the use of sUAS in

utility operations may be valuable to the Administration in developing comprehensive rules governing

sUAS for the electric industry.   

C. Description of Relief Sought and Regulations from Which Exemption is Requested

Based on the foregoing, Applicant’s proposal satisfies the criteria for approval under Section

333.  In addition, Applicant’s proposal meets the requirements and policies for exemptions from

Administration regulations.  PPL Electric Utilities therefore respectfully requests that the Administration

grant exemptions from the regulations set forth in Appendix A to this Petition.7

V. CONCLUSION

For the reasons discussed above, PPL Electric Utilities satisfies the relevant criteria for approval

under Section 333 and exemptions from referenced regulations pursuant to Section 44701(f).  

 

7

 Applicant has attempted to identify the applicable regulations for which an exemption is required for the proposed 

use. To the extent that the Administration determines that any other safety regulations might apply to Applicant’s 

proposed use, Applicant further requests that this Petition be deemed to seek an exemption from those requirements. 
11 

Accordingly, PPL Electric Utilities respectfully requests that the Administration grant the relief requested

in this Petition to allow the use of sUAS for the purposes and under the conditions set forth herein.  

Granting this Petition will not only further Congress’ instruction to expedite the safe integration of UAS

into the national airspace system, but will also further the significant public interest in the safe and

reliable delivery of electricity to customers.   

January 05, 2015 Respectfully submitted,

_____________________________

Clyde J. Pittman

Director of Engineering

Federal Airways & Airspace

1423 S. Patrick Dr.

Satellite Beach, FL 32937

Phone: (321) 777‐1266
Appendix A to Applicant’s Petition for Exemption Page 1 

Appendix A:  Regulations from Which Exemption is Requested

Applicant has attempted to identify the applicable regulations for which an exemption is

required for the proposed use.  To the extent that the Administration determines that any other safety

regulations might apply to Applicant’s proposed use, PPL Electric Utilities further requests that this

Petition be deemed to seek an exemption from those requirements.

1. 14 C.F.R. Part 21:  Airworthiness Certification

Part 21 establishes procedural requirements for certifications under Section 44704, including

airworthiness certificates.  Both Sections 333 and 44701(b) authorize the Administration to exempt

aircraft from airworthiness certification under this Part based upon consideration of its size, weight,

speed, operational capability, and proximity to airports and populated areas.  See Section 333.

An analysis of these criteria demonstrates that the sUAS 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 operating with an airworthiness certificate without the restrictions

and conditions proposed.

The sUASs PPL Electric Utilities will use are 15 pounds or less, carry no pilot or passengers, and

carry no explosive materials or flammable liquid fuels.  Operations under this exemption will be tightly

controlled and monitored by the operator and spotter.  These safety enhancements provide at least the

same degree of safety to the public and property owners than conventional operations conducted with

airworthiness certificates.   

2. 14 C.F.R. Part 27:  Airworthiness Standards for Normal Category Rotorcraft

Part 27 sets forth the procedural requirements for airworthiness certification of normal category

rotorcraft. To the extent the sUAS would otherwise require certification under Part 27, as a rotorcraft,

PPL Electric Utilities requests an exemption from Part 27’s airworthiness standards for the same reasons

identified above with respect to Part 21 requirements.
Appendix A to Applicant’s Petition for Exemption Page 2 

3. 14 C.F.R. § 45.23(b):  Marking Requirements

Section 45.23(b) requires that on limited, restricted, or light‐sport category aircraft, or

experimental or provisionally certificated aircraft, markings indicating the aircraft category must be

displayed in letters not less than two inches nor more than six inches high “near each entrance to the

cabin, cockpit, or pilot station.”  Exemption from 14 C.F.R. § 45.23(b) is warranted because the aircraft

has no entrance to the cabin, cockpit, or pilot station on which the required marking can be displayed.  

PPL Electric Utilities requests an exemption to 14 C.F.R. § 45.23(b)’s marking requirements and proposes

instead to display markings to the fullest extent possible in compliance with the location requirements

of 14 C.F.R. § 45.27(a) and the size requirements of 14 C.F.R. § 45.29(f).   

4. 14 C.F.R. §§ 61.113(a) and (b); 61.133(a):  Private Pilot Privileges and Limitations:  Pilot

in Command; Commercial Pilot Privileges and Limitations

Sections 61.113(a) and (b) limit private pilots to non‐commercial operations.  Section 61.133(a)

requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for

compensation or hire.  Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the

sUAS proposed for use by PPL Electric Utilities are remotely controlled with no passengers or cargo on

board.   

Applicant respectfully requests exemptions from these requirements based on the particular

characteristics of the sUAS that will be used.  The risks associated with the operation of the sUAS

described above (given the size, speed, operational capabilities, and lack of combustible fuel) are much

lower than the risks associated with private pilot operations or commercial operations contemplated by

Part 61 with conventional aircraft.  Given the inherently lower‐risk nature of the sUAS and these safety

features, PPL Electric Utilities proposes that operators be required to successfully complete the training

described above.  This training and the conditions and restrictions on operation proposed in this Petition

will provide an equivalent level of safety as requiring operators to have a private pilot’s certificate or a

commercial pilot’s certificate.
Appendix A to Applicant’s Petition for Exemption Page 3 

5. 14 C.F.R. § 91.7(a):  Civil Aircraft Worthiness

Section 91.7(a) requires that no person may operate a civil aircraft unless it is in airworthy

condition.  If the Administration grants Applicant’s request for exemption from the requirement to

obtain an airworthiness certificate, no Administration regulatory standard will exist for determining

airworthiness.  PPL Electric Utilities will, however, maintain the sUASs as directed by the manufacturers

and conduct any recommended safety checks prior to each flight.   

6. 14 C.F.R. § 91.9(b)(2):  Civil Aircraft Flight Manual in the Aircraft

Section 91.9(b)(2) prohibits a person from operating a civil aircraft “[f]or 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.”   

Given the size and configuration of the sUASs PPL Electric Utilities will use, it is not possible to

carry such a flight manual on the aircraft.  The equivalent level of safety will be achieved by keeping the

flight manual (specifically, the manufacturer’s user guide) at the ground control point where the

operator will have immediate access to it.

7. 14 C.F.R. § 91.103:  Preflight Action

Section 91.103 requires a pilot in command to become familiar with specific information before

each flight, including information contained in the Administration‐approved Flight Manual on board the

aircraft.  As no Administration‐approved Flight Manual will be provided, PPL Electric Utilities requests an

exemption from this requirement.  The operator would, however, become familiar with the

manufacturer’s user guide.   

8. 14 C.F.R. §§ 91.109, 91.319(a)(1):  Flight Instruction

These regulations provide 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.  
Appendix A to Applicant’s Petition for Exemption Page 4 

The sUASs PPL Electric Utilities will use are remotely‐piloted aircraft and designed without fully

functioning dual controls.  Flight control is accomplished through the use of a control box that

communicates with the aircraft via radio communications.  The equivalent level of safety provided by

the fact that neither a pilot nor passengers will be carried in the aircraft, by the size and speed of the

aircraft, and the safety features of the aircraft that limit the potential for operation outside the

operating conditions set forth in this Petition.

9. 14 C.F.R. § 91.119:  Minimum Safe Altitudes

Section 91.119(c) prescribes the minimum safe altitudes under which aircraft may not operate,

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non‐

congested areas.  Section 91.119(d)(1) allows for a helicopter to operate at less than those minimum

altitudes under certain conditions.

As described above, PPL Electric Utilities will operate the sUAS at altitudes up to 250 feet AGL,

and therefore requests an exemption from the 500‐foot minimum altitude.  Given the size, weight, and

speed of the sUAS and the lack of flammable fuel, any risk associated with these operations is far less

than those presently presented with conventional aircraft operating at or below 500 AGL.  In addition,

the low‐altitude operations of the sUAS will ensure separation between these sUAS operations and the

operations of conventional aircraft that must generally operate above 500 feet.

10. 14 C.F.R. § 91.121:  Altimeter Settings

Section 121 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 use GPS

technology, PPL Electric Utilities requests an exemption from this requirement to the extent it operates

sUAS without a barometric altimeter.  An equivalent level of safety will be achieved by the operator

confirming the acquisition of GPS signals and an initial ground level altitude of zero prior to take off.
Appendix A to Applicant’s Petition for Exemption Page 5 

11. 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.”     

Applicant requests an exemption from the 30 minutes of reserve fuel requirement.  Given the

limitations on flight locations and operations set forth in this Petition, a longer time frame for flight is

reasonable.  Operating the sUAS in a tightly controlled area 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 sUAS.   

Applicant proposes that an equivalent level of safety can be achieved by limiting flights to 60

minutes or 25% of battery power, whichever happens first.  This restriction would be more than

adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

12. 14 C.F.R. § 91.203(a) and (b):  Carrying Civil Aircraft Certification and Registration

Section 91.203 requires a civil aircraft to have “within it . . . [a]n appropriate and current

airworthiness certificate” that must be “displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.”  As discussed above with respect to Section 91.9(b)(2) requiring the aircraft to

carry a flight manual, the physical characteristics of sUAS are such that there is no ability or place to

carry registration documents or to display them on the sUAS.  An equivalent level of safety will be

achieved by keeping registration documents at the ground control point where the operator will have

immediate access to them.  Moreover, the requirement to carry airworthiness certificate will not apply

to PPL Electric Utilities if the Administration grants Applicant’s request for an exemption from this

requirement, as requested above.
Appendix A to Applicant’s Petition for Exemption Page 6 

13. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) and (b):  Maintenance

Inspections

These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part

43.  Specifically, 14 C.F.R. § 91.405(a) states that the owner or operator of an aircraft shall have the

aircraft inspected as prescribed in the rules and have discrepancies repaired as prescribed in part 43; 14

C.F.R. §§ 407(a)(1) and 409(a)(2) requires that an aircraft be approved for return to service by a person

authorized under 14 C.F.R. Section 43.7 after it has undergone maintenance or receives an annual

inspection; and 14 C.F.R. § 417 requires an owner or operator of an aircraft to maintain specific types of

maintenance records, including signatures of the person authorized to approve the aircraft’s return to

service.

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

these sections will not apply to Applicant’s operation of sUAS.  Maintenance will be accomplished by the

operator pursuant to the manufacturer specifications.  An equivalent level of safety to existing

regulations will be achieved because these sUASs are very limited in size, operate only in restricted areas

for limited periods of time, and carry no flammable fuel.  If mechanical issues arise, the sUAS can land

immediately and will be operating from no higher than 250 feet AGL.  As described above, the operator

will ensure that the sUAS is in working order prior to initiating flight, perform a preflight safety checklist,

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.

14. 14 C.F.R. § 91.1501:  Continued Airworthiness

Section 91.1501(a) “requires operators to support the continued airworthiness of each

airplane.”  PPL Electric Utilities requests an exemption from this regulation because the sUAS will not be

subject to an airworthiness certificate.   
Appendix B to Applicant’s Petition for Exemption Page 1 

Appendix B:  Summary Suitable for Publication in the Federal Register

Applicant petitions the Federal Aviation Administration for relief from compliance with 14 C.F.R.

Part 21;14 C.F.R. Part 27; 14 C.F.R. §§ 45.23(b); 61.113 (a) and  (b); 61.133(a); 91.7(a); 91.9(b)(2); 91.103;

91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.319(a)(1); 91.405(a); 91.407(a)(1); 91.409 (a)(2);

91.417 (a) and (b); 91.1501 for purposes of operating small unmanned aircraft 15 pounds or less on

property that is owned or controlled by PPL Electric Utilities or in utility right of way to inspect energy

infrastructure and identify problems in the delivery of electricity to customers.  PPL Electric Utilities

proposes that its operation be subject to the operating conditions and safety standards set forth in the

petition in lieu of the above‐referenced regulations in order to provide a level of safety equivalent to

those regulations.