### July 27

, 2015

Exemption No. 12161

Regulatory Docket No. FAA

– 20 15

– 0488

Mr. Ian R. Hatfield

Arizona Public Service Company

PO Box 53933 Sta 4618

Phoenix, AZ 85072

Dear Mr. Hatfield :

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.

By letter dated February 24, 2015

, 1 

### you petitioned the Federal Aviation Administration (FAA)

on behalf of Arizona Public Service Company ( hereinafter petitioner or operator ) for an

exemption

. The petitioner requested to operate an unmanned ai rcraft system (UAS) to

conduct visual inspection s of energy infrastructure

.

See Appendix A for the petition submitted to the FAA des cribing 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 the Microdr one MD4

- 1000

.

1 On July 9, 2015, the petitioner responded to the FAA’s request for information.

### 2

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

and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria

provided in Section 333 of P ublic 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. There fore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness

Certificates , 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 No s

. 11062 to Astraeu s 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 Lab s , 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 propo rtions, 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 a ll 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 th e Administrator, Arizona Public Service Company 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.

### 3

Conditions and Limitations

In this grant of exemption, Arizona Public Service Company is hereafter referred to as

the operator.

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 Microdrone, MD4

-

1000 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 clo sed

- 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 req uirement as long as the PIC always maintains VLOS

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

e lectronic messaging or texting is not permitted during flight operations. The PIC

must be designated before the flight and c annot 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,

### 4

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

Otherwise, the operator must follow the procedures as outli ned 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 req uest. The

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 exempt ion, then

the operator must petition for an amendment to its grant of exemption. The FA A’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 maintenan ce 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 onl y 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 an d 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

potent ial 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 m ust 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal

G overnment. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

### 5

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

(traini ng, 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 exe mption. However,

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

traini ng, 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 A RP, the center of the airport symbo l as denoted on the current

FAA

- published 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 agreemen t 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 sign al, the UA must return to a

pre

- determined location within the pr ivate 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 5 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 cond ucted in accordance with an ATO

- issued COA. The

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

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

.

### 6

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

(N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must

be as large as practicable.

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

any documents required under 14 CFR §§ 9 1.9 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 nonpartici pating

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 r emain 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 control led

- access property with

permission from the property owner/controller or aut horized 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 opera tional area as defined by the applicable COA must be reported

to the FA A'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

.

### 7

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.

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 a rea 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 th e 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 cer tificate 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 availa ble 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

es sential 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 spe cified 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.

### 8

This exemption terminates on July 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan

Director, Flight Standards Service

EnclosuresPage 1 of 19 

## APS ’s Petition f or Exe m ption

Pursuant to Section 333 of the FAA M odernization and

Reform Act of 2012

APS :

Arizona Public Service Company, a subsidiary of the Pinnacle West Capital Corporation

ATTN: Ian R. Hatfield

– Predictive Maintenance Sr. Technician

PO Box 53933 Sta 4618

Phoenix, AZ 85072

Phone: ( 602) 809

- 0545

Ian.hatfield@aps.comPage 2 of 19 I. SUMMARY O F PETITION

Pursuant to Section 333 o f the FAA Modernization an d Reform A ct o f 2012 (“Section 333”),

Arizona Public Service Company (“APS ”) her e by re s pect f ully requests exped i ted approval t o use Small

Unmann e d Aircraft Syst e m (“ s UAS”) u nder the te r ms and cond i tions descr ib ed in this Pet i tion for

Exemption (“Petition”) t o cond u ct in s pections o f e nergy i n fras truc t u r e. Arizona Public Service Company

also reque s ts the exemptions that are necessary to such approval pur s uant to 49 U

. S.C. § 44701(f), and

14 C.F.R. § 11.81

. 1

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

transmission and distr i but io n lines an d s ubstations and Solar generation fields

, in order to f ur t her the

publ i c interest in the safe and reliable deli v ery o f el e ctr ic ity to cust om ers. S m al l UAS are i deally suited for

in s pection o f en ergy infrastructu r e

— they can safely, inexp e nsively, and quickly deliver high‐quality

Infrared and digital photo and video, which eliminates th e ne e d for physic al insp e ction and thus speeds

the p r ocess o f tro u ble‐shooting, and ultim a tely i n cr ea s es the r e l iability o f the electr i c grid. In part i cular,

sUAS allow f o r safer operations and inspection o f the crit i cal i n f rastructur e

. Util i ty worke r s would b e a ble

to con d uct insp e ctions without being in close proxim i ty to high‐voltage equi p me n t o r subject to t h e

he i ght related h a zards o f b u ck e t trucks o r co n ventional aircraft. They c a n also facilit a te the safe

inspection o f hard‐t o ‐access or environmentally sensitive areas without the use o f b uck e t trucks,

helicopters, and other util i ty vehicles that may ha v e more i mp ac t than sUAS. In add i tion, because o f the

small size o f the craft, th e re 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 mainten ance costs would be

of benefit to 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 necessaryPage 3 of 19 exemptions will enhance worker and public safety, increase electric system reliability and decrease

customer costs.

M o re o ver, approving the r equest e d use would represent a significant ste p for w ard in the Federal

Aviation Administ r ation’s (“A d ministration ” ) efforts to integrate sUAS into the nati o nal airspace system.

Arizona Public Service Company ’ request provides the A dmini s t rat i o n with an oppor t unity to partner

with a leading el e ct r ic e nergy provider as it works to dev e lop its r ulem a k i ng p ursuant t o the FAA

Reauthorization Act o f 20 1 2

— while do i ng s o for a compell i ng pub l ic p u r p os e an d u n der strict operational

a nd safety gu i delines. Giv e n t h e u n i q ue ne s s o f APS

— the c o mpany has a diverse geographical and

environmental footprint an d a distinctive resource mix

— it is ideally suited to help the Administr a tion

u n derstand the pot e ntial util i ty applications for sUAS.

Arizona Public Service Company proposes to use sUA S th a t are rotorcraft, weigh 15 o r fe w er

pounds, operate at a s peed o f no mor e than 50 k n o t s

, and co n tain built‐ i n s afety features. In add i tio n

,

Arizona Public Service Company proposes t o use the aircraft at low a l titudes, not in proximity to airports

o r d e nsely populated areas

, o n prop e rty th a t is owned o r contr o lled by Arizona Public Service Company

o r is a util i ty r ight o f way or easement

, within t h e vi s ual line o f sight o f the operator, and u n der

controll e d conditions. Accordingly, the request e d ex emptions satisfy the a ppl ic able statutory criteria and

policies, will serve t h e p ub l ic interest, will not adversely affect safety, and will provide a le v el o f safety a t

least e qual t o the exist i ng airworthiness and r e lated r egulations. A pproval o f th i s Petition is therefore

co n sistent with Section 333’s directive to “establish requirements for the safe op eration of [unmanned

aircraft systems] in the national airspace system” i f the S e creta r y o f Transportation determines that

c e rtain u nma nne d aircraft systems may operate safel y in the nati o nal airspace s ystem

. 2

2 Secti o n 33 3 ( c ) o f t h e F AA M od er n izati o n a n d Ref o rm Act o f 2 01 2

, Pu b

. L

. N o

. 1 1 2

- 9 5

, 1 2 6 Sta t 1 1

.Page 4 of 19 II. APS BACKGROUND

Arizona Public Service Company is a n Arizona b a sed ut i lity th a t services a b o ut 1.3 million

customers. We maintain more th a n 4 4 ,000 miles o f power lines ranging from distribution lines to

transmission lines with voltages over 500kv. We also operate and maintain 4 16 subst a tions in Arizona and

multiple generation sites

. Arizona Public Service Company is c o mmitted, first an d fo rem os t to s afety.

Arizona Publi c Service Company is focused o n the reli a bility o f its system through maint e nance a nd

i n sp ecti o n o f t h e existing el e ctrical system a s well as bui l d‐out of additional f a cilities. Consistent w ith

Arizona Public Service Company ' efforts for providing safe and reliable service to our customers, Arizona

Public Service Company seeks to use s UAS to more safely and effectively perform inspections o f the

electr i cal infrastr uc ture and solar generation fields.

III. RELEVANT STAT U TORY AUT H O R ITY

A. Sec t ion 333

Section 333( a ) states th a t the Administ r ation “shall de te r m i ne if certain unma n ned aircraft

system befo r e co m pletion o f the plan a nd ru l emak in g [to broadly integrate U A S into t h e n a tional

airspace] required by S e ct io n 332 o f this Act.” Section 333 is also describ e d as a pathway f o r “ exp e dit ed

operational a uthorization. ” 3

Section 333(b)( 1 ) outlines the factors t h at t h e Administration shall use to dete r mine whether

UAS may b e operated safely in the nat i onal airspace system: size, weight, speed, operation a l capabi l ity,

proximity to airports and populated areas

, and ope r ation within v isual line o f sight. I n addition, and

importantly fo r this Pet i ti o n, Section 3 3 3(b)( 2 ) prov i des t h e Administration wit h t h e dis c ret i on

To dete r mine t h at a certif i cate o f waiver, certificate o f a uthorization, o r airworthiness ce r tif ica t io n is

not required to o perate UAS that are found to b e appro p riate u nder 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.Page 5 of 19 B

. Sec t ion 44701(f)

In add i tion to its sp e cific a uthority related to author i zing UAS op e ration u n der Section 333, the

Administr a tion has general authority to grant e xe m ptions from its safety requi r eme n ts and mini m um

standards if the Administ r ation finds t h at t h e e xemption is i n the publ i c intere s t

. Administr a tion

regulations s et forth t h e i nformation that m u s t be i ncl u ded in t h e p e tition for exemption: (1) the APS ’s

na me and mai l ing address; (2) the r e gulations from which the APS seeks ex e mption; ( 3 ) the extent o f

relief soug h t and why; ( 4 ) the r e aso ns why gra n ting the r equest would be in the p ubl i c interest and how

it would benefit the public as a whole; and (5) the reasons w hy granting the e xempti o n would not

adversely affect safety, o r h o w the exemption would p r ovide a level o f safety at leas t equal to the r ule

from which the APS seeks exemption

.

IV. DISC U SSION

A. APS ’s P ro p osal Sat i sfies the Sec t ion 333 Criteria f or A pp r oval.

As describ e d above, Secti o n 333(b)(1) outlines the f a ctors th a t the Administration shall use to

dete r mine w hether UAS may be ope r ated safely i n the national airspace system: size, w ei ght, speed,

operational capability, pr o ximity to airports and populated areas, and operati o n within visual line of

sight. A p ply i ng the cri t er i a outlin e d in Section 333(b)( 1 ) an d othe r relevant criteria to this c a se

demonstrat e s that APS ’s proposed te r ms and conditions o f operation wil l result in the sUAS being

operated safely in the nat i onal airspace system, consistent with S e ction 333. Base d o n the small size of

the s UAS i nvolved, the low altitude an d restricted e n v i ro nment i n which they will operate, and the f a ct

that they will be operated within t h e vi s ual line o f sight o f the operator, there is more than s ufficient

basis to find that the s UAS can b e oper a ted safely u n der this proposal.

1. Size, Weight, Spee d

, and Operational Capability

APS proposes to use small, (VTOL) mu l ti‐ ro t o r craft wit h a m a xi m um w ei g ht o f 7 pou n ds o r less

,

that are powered by electric batteries and car r y no flammable fuel o r car g o. Arizona Public ServicePage 6 of 19 Company wil l u s e small craft typically referred to as q u a dcopters with a m a xi m um takeoff weight o f 10

pounds including the payload options when situations require specialized equipment, such as infrared

cameras for thermal inspection of power equipme nt are needed.

The s UAS us e d by Arizona Public Service Company will have i nt e gr a ted GPS a utopilot systems.

The integrated GP S autopilots provide stable, precise flight, and stable hovering and GPS hold

— e nabling

field workers to focus o n situational awareness ( e.g., p r oximity to h ig h voltage equipment) and safety o f

t he mselves and the publ i c. I n addition, t h e GPS a utopil o t system provides an a u t o matic return to home

cap a bility i n the unlikely case o f signal loss with the operator and preprogramed route function for safe

return. Additional safety feature include, a base station that constantly provides real

- time feedback on

the operational effectiveness of the battery, rotors, signal strength, telemetry data and a “black box”

that will continually capture operational data during the flight.

These small, multi‐rotor c r aft are ideally suited for in s pection o f p o wer lines, ge nerating pla n ts

and other p o wer‐related i n fras truc t u r e bec a use the y often deliv e r high

‐ quality photo an d video more

efficiently an d cost effectively than tr a ditional met h ods. Us i ng s UAS can also be safer for utility workers

because it wil l avoid p u tti n g utility workers in close proximity to h i gh‐voltage e q uipm e nt and work

conditions with hi gh elevations, eliminating the risk o f injuries from falls and electrocutions

. They also

allow the s afe inspection o f hard‐t o ‐access o r environmentally sen s itive areas without t h e use o f b u ck e t

t r u cks and other utility v ehicles. Ove r all, sUAS can provide signi f icant be n efits over traditional ene r gy

infrastructu r e insp e ction methods to utility workers and customers.

2. Proximity t o Airpo r ts/ P o p ula t ed Areas

APS will avoid operating the sUAS over densely populated area s and will operate a t lea s t three

naut i c a l miles away f r o m the nea r est p u blic use airport. T h e sUAS will be operated a t low altitudes of

250 feet or less

— much lower than the airspace in which manned vehicles operate and lower than thePage 7 of 19 altitude at which hobby aircraft fly. Finally, all operations will occur over utility property or utility

right of way or easements.

In add i tion, Arizona Public Service Company ’s flights will likely occur in airspace that is subj ec t to

a Not i ce to Airmen (“ NO TAM”). The Administr a tion has issued a standing n o tice to pilots to avoid

loit e ring in the “airspace above, o r in prox i mity to, sites such as nuc le ar power pl a nts, power p l ants,

dams, r efineries, industrial c o mple x es, mil i tary facilities, and other s i milar facil i ti e s.” This N OT AM shoul d

further l i mit t h e potential int e raction o f an y flights near Arizona Public Service Company power

transmission facilities.

3. Visual L i ne of Sight

A pil o t (operator) with proper training will have passed an aeronautical test and obtain an UAS

operator pilot certificate. The operator will only operate the sUAS dur i ng da y light hours, in good

weather, and within the operator’s line o f sight

. I n addition, the operator will be accompanied by a

trained spotter, who also will be posit i oned in line o f sight o f t h e aircraft and will be in co n stant

comm u nication with the operator to identify an d alert t h e operator to any potential obstacles. T h i s

e liminates t h e need for other “sense and avoid” c a pabilities dur i ng operation, as well as t h e ne e d for an y

method o f air traffic co n trol comm u nic a t i ons

. 6

See I n terim O p e r ati o n a l A p

p ro v al G u i da n c e 0 8

- 0 1, U n ma nn e d Aircraft S ystems Op e rat i ons in th e U

. S. N a ti o n a l

Airspace System a t 4 ( Ma r. 1 3

, 2 0 08 ).

B

. APS ’s P ro p osal Als o Satisfies the Standard f or Exem p t i on u nder Sec t ion 44701 and 14

C.F.R. § 11. 8 1.

1. Granting APS ’s R eq u est Would N ot Adversely Affect Safety and Would Pr o vide a

Level of Safe ty a t L e ast Eq ual t o Exist i ng Rules.

Granti n g Arizona Public Service Company ’ Petition w ill not adversely affect safety. APS ’s

proposed terms an d conditions o f o peration would provide a l e v el o f safety at least equal to e xisti n g

r ule s

. As discussed abov e with r e sp ect to Section 333(b)( 1 ) criteria, the size, weight, speed, and

operational capability o f the sUA S that will be used i n t h e propo s ed operations indic a te th a t the aircraftPage 8 of 19 can be operated safely in the nat i onal airspace system. M o re o ver, the aircraft will be operated at l o w

altitudes, not in prox im ity to airports o r densely po pulated areas

, and withi n t h e visual li ne o f sight o f the

operator and spotter. In a ddition, Arizona Public Service Company proposes t h e following conditions to

ensure that the r equest e d exemption would result i n a level o f safety at least e qual to the rules from

whic h Arizona Public Service Company is seeking an ex e mption.

a. Safety Systems : APS will use sUAS th a t has a sem i ‐autonomous navigation a nd

control system compri s ed o f a Gr o u n d Control Stat io n and “aut o ‐pilot” system.

Aut o mat e d safety f unctions and safety e n hanc i ng features o f th e sUAS th a t Arizona Public

Service Company will use include the fo llowing:



### • Precision F l ight a n d Stable Hovering : In tegr a t e d GPS autopilot system provides

position holding, a l titude l o ck, an d stable hovering to all field personnel to focus o n

situational awareness and safely g e tt i ng the job d o ne.



### • Auto R et u rn

‐ To‐Home : F a il‐safe featu r e will a utom a tically a ctivate in case o f

s i gnal loss with ground station, using GPS‐Enabled autopilot to a utomat i cally follow a

predetermined safe route of return and l a nding the craft a t the original t a ke‐off point.



### • Clearly Visib l e B a tt e ry an d GPS S t a tus : Battery and GPS S t a tus will be available

on the receiver a nd available through the g r ound station displ a y. Automatic return to

home at a set battery level, APS proposes 20%



### • Longest Battery Life in Class : The sUAS APS will utilize has 88 minutes of

possible flight time. APS will not operate with less than 20% battery life or no longer

than 60 minutes during a continuous flight, whichever comes first.



### • N o Wa y point Zones: The Ground Contr o l Station features a functi o n call e d

"No Waypoint Z o nes." This fe a ture provides an e xtra e l e ment o f safety around major

airports by no t allowing t h e sUAS to operate within a pred e term i ned rad i us o f these

airports.



### • Virtual Fence Option : This feature exists to make sure your SUAS doesn’t

operate in a undented area, such over a road or other structure.

b. Mandatory O per a ting Conditions

In add i tion to the safety fea tures de s cr i bed above, Arizona Public Service Company

proposes that its exemption b e subj e ct to the following mandatory conditions to ensure safe

o perati o n:

• Operations w ill avoid d e nsely popul a ted areas and only operate over APS property, rights of

way or easements.Page 9 of 19 • Operations will n ot be conducted over highways, freeways or major roads where traffic is

not being controlled.

• Maxi m um to t al flight t i me for each fligh t will be 60 m inutes. Flights will be te r m inated

at 20 % b a tte r y power reserve, should that occur be fo re this time limit.

• Operations w ill occur d u rin g Visual F l ig h t Rules M e teorological Conditions.

• Aircraft to remain within Visual Line o f Sig h t (“VLO S ”). V LOS will be guaranteed with a

cylinder o f operation aroun d operator o f 1/4 na u tical miles.

• Operations w ill occur d u rin g dayli g ht hours.

• Flights will be operated at an altitude o f no more th a n 250 fee t Abov e Ground L e v el (“AGL”).

• All operations to remain more th a n thre e na u tical miles from t h e airport re f e rence point

o f publ i c use airports.

• Operators an d spotters wil l me e t the operator traini n g and ce r tification requirements

proposed be lo w.

• Operators an d spotters wil l be in com m unica t ion at all t i mes.

• Operator will perform required ma i nt en ance per the manufacturer’s recomm e ndations

and k e ep a log o f any maintenance per f ormed.

• Operator will perform any safety c h ecks specif i ed i n the m a nufacturer’s user guide prior to

each flight.

c

. Operator Training and Certificat i on

As discussed above, the sU AS Arizona Public Service Company will use are characterized by a

high d e gree of control and built‐in t e c h nical capabil i ties that lim i t the potential for operation outside the

op e rating conditions set forth in this Petition. M o re o ver, the m andatory op e rating cond i t i ons

(max i m u m alt i tu d e, proximity to airfields, visual line o f sight) min i mize a ny pot e ntial weather i m pa c t an d

inte r actions with other aircraft.

Situational awareness around hig h ‐voltage e q uip me nt, a thorough working kn owledge o f the

sUAS, and strict a dher e nce to corporate sUAS flight policy are key to safe sUAS operations. Given the

significa n t di f ferences between s UAS a nd p i loted aircraft, the safety features i nhere n t i n th e sUAS, a ndPage 10 of 19 the strict op e rating cond i t i ons that will apply. Arizona Public Service Company proposes th a t, in a ddition

to holding a UAS pilot certificate from an accredited training facility and completed the FAA aeronautical

test

, operators o f the s UAS shall also be required to have:



### • Proven know l edge o f Arizona Public Service Company UAS flight policy ( i nc l ud i ng

Mandato r y Operating C o nditions spec i fied in this P e titio n )



### • Proven working knowledge o f safe sUA S operations, flight characteristics,

safety features, GP S /Battery St a t us ind i cators, and emerg e ncy proce d ures



### • Util i ty k now l edge r egard i ng safe operations around high volt a ge power lines,

s ubstation equi p me n t, a nd power pl a nts; and



### • A valid drive r ’s license.

APS is receptive to f uture regul a t io ns and industry guid a nce o n l i censing sUAS p i lots using

training and testing that is relevant to operating sUA S in a lim i ted flight area.

d. Privacy C ons i derations

APS will not operate sUAS in any way that may invade personal privacy and will co m p l y with any

federal, state, o r lo c al privacy law s that may apply i n are a s where Arizona Public Service Company

operates sUAS. In add i tion, as a pr a ct i cal m a tter, flights will oc cur over util i ty property o r utility right o f

way, so privacy is unl i kely to be a con c ern i n relation to APS ’s propo s ed use.

2. Granting APS ’s R eq u est Would B e in t h e Public Interest and Would Benefit the

Public as a W hole.

Allowing the request e d u s e will provide signific a nt benefits to the pub l ic, Arizona Public Service

Company customers, a nd Arizona Public Service Company em ployees. Us i ng sUA S to inspect ene r gy

infrastructu r e can be safer and m o re efficient t h an trad i tional m e thods o f i n fras truc t u r e insp e ction, s uch

as t h e u s e of helicopters

, b u c k e t tr u cks and climbing inspections

. T h e inc r eased safety and efficiency o f

using sUAS to i n s pe c t infrastructu r e following s i gnifica n t we a ther events is especially important to

Arizona Public Service Company

, which serves 1.3 mi l lion cu s tom e rs in Arizona

, where s t o rms occur with

fr e qu en cy during the Monson season

. An infrastructu r e inspection p r ocess that is safer and m o rePage 11 of 19 efficient c a n he l p to lower operations and maintenance costs and more qu i ckly resolve problems in t h e

delivery o f electr i city, b o th o f w hich w ill b e nefit cu s tomers.

M o re o ver, t h e requested use presents a comp e lling case for t h e Administr a tion moving forward

with efforts t o integr a te s UAS i nto the national airspace system a s required by Section 333. The publ i c

has a signif i cant interest i n efficient an d safe inspection o f ene r gy infrastructu r e to e n s u r e r eliable

delivery o f p o wer, and Arizona Public Service Company has proposed using sUA S to fu r ther this pu b lic

interest in a way that is at least as safe as operation o f aircraft un d e r e xisting r egulations. APS ’s request,

therefore, p r ovides the Administration an appropriate vehicle to f urther Congress’ mandate to e xpe d ite

integration o f UA S

. In a dd i tion, APS ’s operati o nal experience result i ng f r om t h e use o f sUAS in utility

operations may be v aluable to t h e Administration in devel o ping comp re hensive rules governing sUAS for

the electr i c i ndu s try.

C. Description o f Relief Sou g ht a n d R e g u l at i ons from Which Exe m pt i on is Requested

Based o n t h e foregoing, APS ’s proposal satisfies the criteria for approval u n der S e ction

333. In add i t i on, APS ’s proposal meets the r e quirements and policies for e xem p ti o ns f r om

Administr a tion regulations. Arizona Public Service Company therefore respect f ully requests that the

Administration grant e xe m ptions from t h e regulations set forth in A p pend i x A to this Petitio n.

V. CONCLUSION

For the reasons discussed above, Arizona Public Service Company satisfies the relevant cr it eria

for approval under Secti o n 333 and exemptions from referenced regulations p ursuant to S e ction

4470 1 (f). APS 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 safetyPage 12 of 19 regulations might apply to APS ’s proposed use, APS further requests that this Petition be deemed to

seek an exemption from those requirements.

Accordi n gly, Arizona Public Service Company r espectfully r e quests that the Administration grant the

relief requested in this Pet i tion to allow t h e use o f s UAS for the pu rpo ses and u nde r t h e co n dit io ns set

forth herein. Granti n g this Petition will no t only fu r ther Congress’ instruction to expedite t h e safe

integr a t io n o f UAS into the nati o nal airspace s ystem, b ut wi ll also further the signif i c a nt p ubl i c i nt er e s t in

the safe and reliable deli v ery o f el e ctr ic ity to cust o m ers.

February, 24 , 2015 Resp e ctfully subm i tt e d,

Ian R. Hatfield

Arizona Public Service Co.

PO Box 53933 Sta 4618

Phoenix, AZ 85072

Phone: ( 602) 809

- 0545

ian.hatfield@aps.comPage 13 of 19 App e ndix A: Regulations f rom W hich Exemp t ion is Requested

APS has att e mp t ed t o identify the appl i cable r e gulations for which an ex e mption is required for

the proposed use. To the e xte n t that t h e Administration determi n es that any other safety regulations

mig h t apply t o APS ’s proposed us e

, Arizona Public Service Company fu r ther requests that this Petition

be deemed to see k an ex e mpt io n from those requi r em en ts.

1. 14 C.F.R. Pa r t 21: Airworthiness Certif i cation

Part 21 establishes proce d ural requi r e m ents for certi f ications u nd e r Section 44 7 04, including

airworthiness ce r tificates. Both S e ctions 333 and 44701(b) authorize the Administration to e xem pt

aircraft from airworthiness ce r tification under this Par t based up o n considerat io n o f its size, weight,

speed, oper a tional cap a bi l ity, and prox i mity to airp o rts and popu l ated areas. S ee S e ction 3 3 3.

An analysis o f these cr i ter i a demonstrates that t h e s UAS operate d without a n airworthiness

certif i cate, i n the r e s tri c ted environm e nt, and u nder the conditions proposed wil l be a t least a s safe, or

safer, than a conventional aircraft oper a ting with an a irworthiness certif i cate without t h e re s trictions

and conditi o ns proposed.

The sUAS Arizona Public Service Company will use a re 15 pou n ds o r less, carry no pilot o r

p a ssengers, and carry no e xp l osive materi a ls o r flamma b le liquid f uel s

. Operations under this exemption

will be t i ghtly controlled an d mon i tored by t h e operator and spotter. T h es e safety enhancements

provide at least the same deg r ee o f safety to the p ubl i c and property owners than co n ventional

operations con d uct e d with airworthiness ce r tificates.

2. 14 C.F.R. Pa r t 27: Airworthiness Standards for Normal C ate g ory Rotorc r aft

Part 27 sets fo rth t h e pr o c edural r e qui r eme n ts for a i rworthiness certification o f normal cate go ry

rotorcraft. To the extent t h e sUAS would otherwise r e quire certif ic ation u n der P a rt 27, as a rotorcraft,

Arizona Public Service Company r eque s ts an e xe m pt io n from Part 27’s airworthiness standa r ds for the

same reasons identif i ed abo ve with r e sp ect to Part 21 requirements.Page 14 of 19 3. 14 C.F.R. § 4 5 .23(b): M ar k ing R e qui r e m ents

Section 45.2 3 (b) requires that o n l imi te d, restricted, o r light‐sport category aircraft, or

exper i mental o r provisionally ce r tificat e d aircraft, m a rkings i n dic a ting the aircr a ft c a tegory m u s t be

displayed i n l etters not le s s than two inches nor mo r e th a n six inches hi g h “near each entrance to t h e

cabin, coc k pi t

, o r pilot station.” Exemption from 14 C.F.R. § 45.23(b) is warrante d b e cause t h e aircraft

has no entrance to the c a bin, c o ckp i t, o r pilot stati o n o n w hich th e requi r ed marking can be displaye d

.

Arizona Public Service Company r eque s ts an e xe m pt io n to 14 C.F.R. § 45.2 3 (b) ’ s marking requirements

an d proposes instead to di s play mark i n g s to t h e ful l est extent possible in c o mpl i ance with t h e location

r equirements o f 14 C.F.R. § 45.27(a) a nd the size requirements o f 1 4 C.F.R. § 45.29(f).

4. 14 C.F.R. § § 6 1.113(a) and (b); 61.133(a): Priv a te Pi lo t Privileges and Limi ta tio n s: Pi l ot in

Command; Com m ercial Pilot Privile g es and Lim i t a ti o ns

Sections 61. 1 13(a) an d ( b ) limit private pilots to non

‐ comme r cial o perations. S e ction 6 1 .133(a)

requires an i n dividual with a com m ercial pilot’s l i cen s e to be pilot i n co m mand o f an aircraft for

compensati o n o r hir e

. Un l ike a conve nt ional aircraft that carries a pilot, passengers, and cargo, the

sUAS propo s ed for use by Arizona Public Service Company are remotely cont ro lled with no passengers

o r cargo on board.

APS re s pect f ully requests exemptions from t he se requir e m e nts based o n the particular

characteristics o f the sUAS that w ill b e used. The risks associated with the ope r ation o f the s UAS

describ e d abov e (given th e size, speed, operational capabilities, a nd lack o f c o mbust i ble fu el) are m u ch

lower than t h e risks associated with private pilot operations o r commercial operations contempl a ted by

Part 61 with conventional aircraft. Giv e n t h e i nher en tly lower‐risk nature o f the sUAS an d thes e safety

features, Arizona Public Service Company proposes that operators be r equir e d t o successfully comp l ete

t h e train i ng describ e d above. T h i s tra i ning a nd the conditions an d restrictions o n operation proposed inPage 15 of 19 this Petition will provide a n equivalent l e v el o f safety as requir i ng operators to have a private pilot’s

certi f icate o r a comme r cial pilot’s certif i c a te.

5. 14 C.F.R. § 9 1 .7(a): Civil A i rcraft Wo r th i ness

Section 91. 7 ( a) requires tha t no person may operate a civil aircraft unless i t is i n airworthy

condition. If the A dm i ni s t ra ti o n grants APS ’s r e quest for ex e mption from the r equir em ent to obtain an

airworthiness certificate, no Administr a tion regulatory standard will exist for det e rmining airworthiness.

Arizona Public Service Company will, however, ma i ntain the sUAS as directed by the man u facturers and

c on d u c t any reco m m e nded safety checks prior t o each f l ight.

6. 14 C.F.R. § 9 1 .9(b)( 2): Civil Aircra f t Fli g ht M an u al i n the Aircraft

Section 91. 9 ( b)( 2 ) prohib it s a person fr o m operating a civil aircraft “[f]or which an Airplane or

Rotorcraft F l i ght Ma n ual is not required by § 2 1 .5 o f this ch a pter, u n les s the r e is available in the aircraft

a current approved Airplane o r Rotorcr a ft Flight M a n ual, approved ma n ual m a terial, mark in gs, and

placards, o r a ny combinat io n the r eof.”

Given the siz e and configuration o f t h e sUAS Arizona Public Service Company will use, i t is not

possible to carry such a f light ma n ual o n the aircra f t. The equivalent level o f s afety will be achieved by

keeping the flight manual (sp e cifically, the manuf a cturer’s user g u ide) at the g r ound control point w here

the operator will have immed i ate access to it.

7. 14 C.F.R. § 9 1 .103: Prefli g ht A c tion

Section 91.1 0 3 requires a pilot in co m mand to b e co m e familiar wit h sp e cific in fo rmation be fo re

each fl i ght, i n clud i ng i nformation cont a ined i n the A dmini s t rat i on ‐approved Fl i ght Ma n ual o n board the

aircraft. As n o Admini s tration‐approved Flight Manu a l will be provided, Arizona Public Service Company

r equests an exemption from this requirement. T h e operator would, however, become familiar with the

manufacturer’s user gui de

.Page 16 of 19 8. 14 C.F.R. § § 9 1.109, 91.319(a)(1): F l ight Instru c tion

These r e gulations provide that no person may operat e a civil aircr a ft (except a manned free

balloon) that is being used for flight inst r uction un l ess that aircraft has fully functioning dual controls.

The s UAS Arizona Public Service Company will use a re remotely

‐ piloted aircr a ft and de signe d without

fully functioning d u a l controls. Flight co n trol is accompli s hed throu g h the use o f a control box t h at

comm u nic a t e s with the aircraft via radio com m unic a tions. The equivalent level o f safety pr o vided by

the f a ct that neither a pilot nor passen g ers will b e c a rried in t h e aircraft, by the size and speed o f the

aircraft, and the safety f e at ures o f t h e aircraft that l i mit the pot e ntial for ope r ation outside the

operating c o nditions se t fo rth in this Petition.

9. 14 C.F.R. § 9 1 .119: M i ni m um Safe A l titudes

Section 91.1 1 9(c) p r escrib e s the min i m u m safe alt i tu d es un d er which aircraft ma y not operate,

including 500 feet above the surface an d away from any person, v essel, vehicle, o r structure in non‐

congest e d areas

. S e ction 91.119(d)(1) allows for a helicopter to o perate a t less than those mini m um

altitu d es u nde r ce r tain conditions.

As describ e d above, Arizona Public Service Company will operate the sUAS at altitu d es up t o

250 feet AGL, and therefo r e requests an ex e mption f r om t h e 500‐ foo t min i mum altitude. Gi v en the

size, w eight, a nd speed o f the sUAS an d the lack o f flammable f uel, a ny risk associated with th e se

operations is far less than those p r esently pres e nted with conventional aircraft operating at o r bel o w

500 AG L

. I n add i tion, the low‐a l tit u de operations o f the sUAS will ensure separation b e tween these

sUAS operations and the operations o f conve n tional aircraft that must general l y operate abo ve 500

feet.

10. 14 C.F.R. § 9 1 .121: A l tim e ter SettingsPage 17 of 19 Section 121 r equires e a ch person oper a ting an aircr a ft to mainta i n cruisi n g alt i tude by reference

to an altimeter th a t is se t “to the elevation o f t h e d e parture airp o rt o r an a pp r opriate alt im eter s e tti n g

available be fo re departure.” As the sUAS may not hav e a barom e tric a l tim e ter, but instead us e GPS

tec h nology, Arizona Public Service Company requests an exempt io n from this r equire m ent t o the extent

i t operates sUAS without a barometr i c altim e ter. A n equivalent l e v el o f safety will b e achieved by the

operator confirmi n g th e acquisition o f GPS signa l s and an init i al ground le v el alt i tude o f zero prior to take

off.

11. 14 C.F.R. § 9 1 .151(a): Fuel Re q uire m e n ts f or F l ight i n V F R C ond i t i ons

Section 91.1 5 1(a) prohibits an i n dividual from b e ginn i ng “ a flight in an airplane u nder VFR

conditions u n less (c o nsi d ering wind an d forecast weather conditions) t h ere is e n ough fuel to f ly to the

first point o f i nte n ded lan d ing, and, assuming normal cruising speed

– ( 1 ) During the day, to fl y after that

for at least 3 0 mi n utes; o r ( 2 ) At n i ght, to fly after t h at for at l e as t 45 m i nutes.”

APS requests an ex e mption from the 30 mi n utes o f reserve fuel requirement. Given t h e

limitations o n flight l o cat i ons and operations set fo r th i n this Pet i tion, a longer ti m e frame fo r flight is

reasonable. Operating t h e sUAS in a t i ghtly control l ed area with l e s s than 30 min u tes o f reserve fuel

does not e n g ender the t yp e o f risks that Section 91. 1 51(a) was i ntended to alleviate given th e size and

speed o f the sUAS.

APS proposes that a n equival e nt l e vel o f safety ca n be achie v ed by lim i ting flights to 60

min u tes o r 2 0 % o f battery power, whichever ha p p e ns first. This restriction wo uld be more than

adequate to r eturn t h e sUAS to i ts pla n ned l a ndi n g zone from anywhere i n its l i mited operating area.

12. 14 C.F.R. § 9 1 .203(a) and ( b): Carrying Civil Aircra f t Certification and Regi s tration

Section 91.2 0 3 requires a civil aircraft to have “within it

. . . [a]n appropriate an d current

airworthiness ce r tificate” that m u s t be “ displayed at the c a bin o r cockpit entrance s o that i t i s legible to

passengers o r crew.” As discussed ab o ve with respect to S e ction 91.9(b)( 2 ) r e quiring t h e aircraft to carry

a flight manual, the physical characteristics o f sUAS are suc h th a t there i s no ability o r place to carryPage 18 of 19 registr a tion docum e nts o r to disp l ay th e m o n the sUAS. An equivale n t l e vel o f safety will be achieved by

keeping registration doc um ents at t h e g r ound control point w here the operator will have imme d iate

ac ce s s to the m

. M o re o ver, the requirem e nt to carry ai r worthiness certificate will not apply to Arizona

Public Service Company if the Administ r ation grants APS ’s r e quest for a n exemption from this

require m ent, as requested above.

13. 14 C.F.R. § § 9 1.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) and (b): Ma i ntenance

Inspect i ons

These r e gulations specify maint e nance and inspection standards i n reference t o 14 C.F.R. Part

43. Specif i ca l ly, 14 C.F.R. § 91.405(a) states th a t the owner o r operator o f an aircraft shall h a ve the

aircraft insp e cted as pre s cribed i n the rules and have discr e panci e s repaired as prescrib e d in part 43; 14

C.F.R. §§ 407(a)(1) and 40 9 (a)(2) requires that an aircraft be approved for return to service by a person

authorized u nder 14 C .F .R

. S e ction 43.7 after i t has u ndergone m a intenance o r receives an annual

inspection; a nd 14 C.F.R. § 417 requi r es an owner o r operator o f an aircraft to maintain sp e cific types of

maint e nance records, inc l uding s i gnatu r es o f the per s on authorized to approve the aircraft’s return to

service.

Given that thes e sections and Part 43 a pply only to a ircraft with a n airworthin e ss certif i cate,

these sections will not apply to APS ’s operation o f sUAS. Maintenance will be a ccompli s hed by the

operator pu r suant to the manufactur e r specif i cati o ns. A n e qui v alent l e v el o f safety to e xisting regulations

w ill be achieved b e cause t h ese sUAS ar e very l i mit e d in size, operate only in r e st ricted areas for limit e d

perio ds o f time, and carry no flammable fuel. If mechanical issues arise, the s UAS can land imme d iately

and will be operating from no hig h er than 250 fee t AGL. As described above, the operator will ensure

tha t t h e sUA S is in working order prior to i nitiating flight, perform a preflight safety checklist, perform

required ma i nt en ance, an d kee p a log o f an y maintenance perform e d. M o re o ver, the operator is thePage 19 of 19 person most familiar with t h e aircraft and best suited to ma i ntain the aircraft in an airworthy condition to

provide t h e e quivalent le v el o f safety.

14. 14 C.F.R. § 9 1 .1501: C o n t i nued Airworthiness

Section 91.1 5 01(a) “requires operators to support t h e c on t i n ue d a irworthiness o f each airplane.”

Arizona Public Service Company requests an ex e mption from this r e gulation bec a use t h e sUA S will not

be subject to an airworthiness ce r tificate.

App e ndix B : Summary S u i tab l e f or Publication i n t h e Fede r al Register

APS petitions t h e F e d e ra l Aviation Administr a tion for relief from compliance with 14 C.F.R. Part

21;14 C.F.R. Part 27; 14 C.F.R. § § 4 5.23(b); 61. 1 13 (a) and ( b ) ; 61.13 3 (a); 91.7(a); 91.9(b)( 2 ); 9 1 .103;

91.109; 91.119; 91.121; 91.151(a); 91.2 0 3(a) an d ( b ) ; 91.319(a)( 1 ); 91.405(a); 9 1 .407(a)(1); 91.409 (a ) ( 2 ) ;

91.417 (a) an d (b ) ; 91.15 0 1 for purpos e s o f operating small unm a nned aircraft 15 pounds o r less on

property that is owned o r controlled by Arizona Public Service Company o r i n utility right o f way to

i n s p e ct energy infrastructu r e and identify problems in the delivery o f electric i ty t o customers. Arizona

Public Service Company proposes th a t its operati o n be subj e ct t o the operating conditions and safety

standards set fo rth in t h e petition in li e u o f the abo v e‐referenced regulations i n order to provide a level

o f safety e q ui v alent to those regulations.From: Ian.Hatfield@aps.com

To: 9-AWA-AVS-333Exemptions (FAA)

Cc: Cooper, Thuy (FAA)

Subject: RE: Arizona Public Service Company (FAA-2015-0488) - Request for Information

Date: Tuesday, July 14, 2015 4:38:04 PM



### As per the conversation with Ms. Cooper I am writing to inform you the information requested

was submitted on June 25 th 

### . The contents of the comment can be found below as well.

Thanks again for all your help.

The requested information is stated below:

The make and model of this aircraft is a "Microdrone, MD4-1000", which is one of the most

widely used aircraft in the world for inspection purposes. The type of aircraft is classified as a

"Multi-rotorcraft" or "Rotorcraft'. The aircraft itself weighs 5.84 pounds (depending on setup) and

has a maximum payload weight of an additional 2.65 pounds which would be 8.49 pounds in

total during operation. The maximum stated takeoff weight (MTOW) is 13.23 pounds.

Additional information about the specific UAS. This aircraft is also unique as it has been

designed and lab tested to withstand high voltage interference up to 380kv making it one of the

safest UAS in the global market for the purpose of electrical utility inspections. It also has the

longest possible battery life (88 Minutes) for an added level of safety during operation. The Base

station with MdCockpit has the ability to view the current health of the aircrafts systems,

batteries, motor operation and temperature, signal strength of two controllers at different

frequencies and GPS. Virtual fence and roof options make sure the aircraft stays with-in range

and away from people, other aircraft and buildings. A pre-programmable return route or return to

home feature in case of loss of signal that can be adjusted for obstacles and differing heights.

From: Hatfield, Ian R

Sent: Thursday, June 25, 2015 11:24 AM

To: 'Thuy.Cooper@faa.gov'

Subject: RE: Arizona Public Service Company (FAA-2015-0488) - Request for Information



### Ms. Cooper,

Thank you so much, I have included the requested information in the docket in the comments

section.

### Have a great day,

Ian

From: Thuy.Cooper@faa.gov [ mailto:Thuy.Cooper@faa.gov ]

Sent: Wednesday, June 24, 2015 8:55 AM

To: Hatfield, Ian R

Cc: 9-AWA-AVS-333Exemptions@faa.gov

Subject: Arizona Public Service Company (FAA-2015-0488) - Request for Information

____________________________________________________ USE CAUTION - EXTERNAL SENDER: ( Thuy.Cooper@faa.gov )

Do not click on links or open attachments that are not expected.

Never give out your User IDs or passwords.

____________________________________________________



### June 24, 2015

Dear Mr. Hatfield:

This letter is to inform you that the following information is missing from your petition

(Docket No. FAA-2015-0488). This information is necessary for the Federal Aviation

Administration (FAA) to process your petition.

Describe the aircraft make(s), model(s), and type(s)(i.e. - fixed-wing, rotorcraft, lighter-thanair) for the proposed UAS operation. The description(s) should include the maximum

weight (including payload). This information can be located in the aircraft manual(s).



### Please submit the additional information (non-proprietary) to your docket at

www.regulations.gov . Any additional confidential/proprietary materials can be e-mailed

separately to 333exemptions@faa.gov . If you do send in supplemental documents separately,

please add a comment on the docket, indicating that you submitted supplemental information

separately. We will upload a copy of this email in your docket.

If you want us to process your request any further, we must receive the information described

above by July 8, 2015. If we do not receive the information, we will close the docket without

notifying you further.

Regards,

Ms. Thuy H. Cooper

Senior Rulemaking Analyst

Airspace and Airmen Rules Division - ARM 106

Office of Rulemaking

Federal Aviation Administration

Telephone: 202-267-4715

thuy.cooper@faa.gov



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