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.