Oct 20, 2014

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Supplementary information for Petition for Exemption concerning operation of San Diego 

Gas & Electric Company Unmanned Aircraft System in accordance with Section 333 of the 

FAA Modernization and Reform Act of 2012 

FAA docket ID: FAA-2014-0719

Registered Owner Name:

San Diego Gas & Electric Company

Registered Owner Address:

8330 Century Park Court

San Diego CA 92123

Aircraft Description:

Vertical Take Off and Landing (VTOL) 

sUAS

Aircraft Registration/Serial Number:

N500VD/ MK2GEN2-00005

N544L/ MK2GEN2-00004

Aircraft Builder:

Physical Sciences Inc.

Year Manufactured:

2013

Aircraft Model Designation:

InstantEye Mk-2 Gen2

Engine Model:

Mk-2 Gen Brushless Motor

Propeller Model:

PSI 7 x 5 Pusher

1. Overview. 

San Diego Gas & Electric Company (SDG&E) is submitting this document to include additional 

information for Petition for Exemption concerning operation of SDG&E Unmanned Aircraft 

System in accordance with Section 333 of the FAA Modernization and Reform Act of 2012. 

In our exemption submitted September 15, 2014 Docket ID: FAA-2014-0719 we need to include 

the following supplementary information. 

2. Supplementary information to Docket ID: FAA-2014-0719. 

A. Exemptions requested per 14 C.F.R :

a. § 61.113(a) and (b) Private Pilot privileges and limitations: Pilot in Command. 

As discussed in the exemption granted to Astraeus Aerial on September 25, 2014, the 

FAA has determined that the required knowledge for a commercial pilot cover the 

same fundamental principles as a private pilot. In addition, SDG&E flights will 

always be conducted under day VFR conditions and within line of sight 400 feet and 

below. As per our current operating limits from LA MIDO, NOTAMs will always be 

submitted 24hrs prior, and in some operating areas the PIC will call Los Angeles 

ARTCC no later than one hour prior with operating details. Given the restrictions of 

the operation, this would not adversely affect the safety of the NAS. 

In addition, the following Pilot Qualification will apply: 

o Pilot Qualifications: All pilots will possess a private pilots certificate and a 

minimum of a valid third-class medical certificate. 
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o Pilot Training. All pilots will be qualified in accordance with 14 CFR 61.3 and 

61.5 and will complete an internal training program. All pilots will follow 

SDG&E Standard Practice #0002, SDG&E Unmanned Aircraft System Training 

Procedure. As per Standard Practice #0002, any person operating the 

InstantEye will complete a 2-day operator training program that includes ground 

school and flight training. This training has been used in the past by Physical 

Sciences Inc. and approved by Army Special Operations Aviation Command. At 

the completion of the course the operator will be required to complete a verbal 

evaluation, written test, and hands on performance test. After passing all 3 

evaluations, the operator will receive a completion certificate authorizing them 

to operate the SDG&E InstantEye.

SDG&E Standard Practice #0002, San Diego Gas & Electric Unmanned Aircraft 

System Training Procedure are thorough and have been reviewed by the Federal 

Aviation Administration (FAA). On June 25, 2014, the FAA granted SDG&E a 

Special Airworthiness Certificate in the Experimental category, for the InstantEye 

small Unmanned Aircraft System (sUAS). Which allows SDG&E to perform research, 

development, and training, in a sparsely populated area in Eastern San Diego 

County. SDG&E is the first utility in the nation to be granted FAA approval for this 

technology. 

B. Inspection and Maintenance. (14 C.F.R § 91.405, 91.407, 91.409). In our exemption 

submitted September 15, 2014 Docket ID: FAA-2014-0719 we failed to mention § 91.417 

(a) and (b) Maintenance records. All pilots will follow San Diego Gas & Electric 

Standard Practice #0004, Approved small Unmanned Aircraft System InstantEye 

Maintenance program, and SDG&E Standard Practice #0006, Approved small 

Unmanned Aircraft System InstantEye Inspection Program. Both standard practices are 

approved programs from Western-Pacific Region Flight Standard District Office, 

specifically SDG&E Standard Practice #0004 discusses symptom based inspections and 

keeping thorough Maintenance records. All SDG&E standard practices are proprietary 

information/confidential material and have been sent via a separate correspondence.