February 26, 2015 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Avenue., SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

Re: Exemption Request of GridHawk Aviation, LLC, Pursuant to Section 

333 of the Federal Aviation Reform Act of 2012, et. al. 

Dear Sir or Madam: 

Pursuant to the FAA Modernization and Reform Act of 2012 ("Reform Act") and 

the procedures outlined in 14 CFR 11, we are requesting that GridHawk Aviation,LLC 

as the owner and operator of small unmanned aircraft, be exempted from the Federal 

Aviation Regulations ("F ARs") listed below so that GridHawk Aviation, LLC, may 

operate its small unmanned aircraft/lightweight unmanned aircraft systems ("UAS") 

commercially in airspace regulated by the Federal Aviation Administration, so long as 

such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by §333. 

As described herein, Justin Schwigen is an experienced journeyman lineman and 

has held such a position for the past 16 years. He holds a Journeyman Lineman's 

credentials. Additionally, Justin Schwigen is a FAA licensed private pilot and actively 

flies and maintains his currency pursuant to the F ARs. 

Justin Schwigen has been actively involved in the process of inspection of hightension power distribution lines, systems, and structures both as a lineman, but also as 

an airborne inspector and repairman. More specifically, Justin Schwigen has for several 

years engaged in the process of accessing, inspecting, and repairing structures and 

high-tension power distribution lines from an airborne platform, typically a helicopter. 

During those years of work in that capacity, and having been exposed to the associated 

dangers, Justin Schwigen and his company, GridHawk Aviation, LLC are pioneering 

inspection and documentation of condition of various electrical distribution systems 

and structures in both highly populated areas as well as remote areas throughout the 

United States. 

GridHawk Aviation, LLC envisions the use of a "SkyRanger", a UAS with a 

Ground Control System (GCS) to monitor (but not operate or control) the UAS unit's 

downlink of data and/ or video. The Aeryon Sky Ranger has weighs with imaging 

Section 333 Exemption Request of GridHawk Aviation, LLC 

Page 1 of8 
payload less than 7 pounds. It can operate in line of sight (LOS) from the surface to 500 

feet AGL for a period of between 35 and 40 minutes with on-board battery packs. (See 

attached documentations) 

To date, Justin Schwigen and his company, GridHawk 'Aviation, LLC, have 

rejected all offers to conduct inspections of power distribution systems and structures 

through the use of U AS's for the purpose of first ensuring compliance with the Federal 

Aviation Regulations. Notwithstanding the decision of Judge Patrick G. Geraghty in 

the matter of Michael P. Huerta vs. Raphaelle Pirker, Docket Number CP-217, in which 

he reasoned that no FAR prohibited the use of small unmanned aircraft or lightweight 

UAS Grid Hawk Aviation, LLC, submits its Petition for Exemption under §333. 

GridHawk Aviation, LLC' s exemption request would permit its operation of 

lightweight unmanned UAS's remotely controlled in the line of site of the operator. The 

operation would take place in those areas surrounding power distribution systems.and , 

structures which may be near both populated or congested areas as well as extremely · 

remote areas. It is contemplated that GridHawk Aviation will establish marked areas of 

operation, cordoned-off locations and corresponding predetermined enhancements in 

those areas of operations. 

Generally, as we have detailed below, the operations contemplated by 

GridHawk Aviation, LLC, and Justin Schwigen serve the public interest in many ways. 

Inspections of power distribution systems and related structures are necessitated by 

both engineering limitations and regulations. The cost of these inspections are 

extensive and often involve the use of an individual perched on a platform associated 

with an airborne helicopter to perform inspections and repairs. There is a 

corresponding danger to the lineman, the pilot, the aircraft, and those on the ground. 

While the technology associated with UASs has not yet reached the level where repairs 

can be conducted to power distribution systems and related .structures, location .and 

identification of the nature and extent of needed repairs can be quickly, safely, and_cost 

affectively identified by the use of UASs as contemplated by GridHawk Aviation,_LLC, 

and Justin Schwigen. 

Granting the Request for Exemption is consistent with the Secretary of 

Transportation's responsibilities to not only integrate UAS's into the National Airspace 

System, but to "establish requirements for the safe operation of such aircraft systems.in 

the National Airspace System" under §333(c) of the Reform Act. GridHawk Aviation, 

LLC, and Justin Schwigen will conduct operations in compliance with protocols 

described herein or as otherwise established by the FAA. 

Accordingly, GridHawk Aviation, LLC, respectfully requests the grant of .an 

exemption allowing it to operate lightweight, remote controlled UASs to conduct Utility 

Company electrified power lines and associated structure inspections. 

Section 333 Exemption Request of GridHawk Aviation, LLC 

Page 2of8 
Name and Mailing Address: , 

GridHawk Aviation, LLC 

cf o Justin Schwigen 

3426 Elik Lane 

Alton, IL 62002 

(618) 372-3579 

Email: I ustin@gridhawkavia tion.com 

I. Federal Regulations from Which Exemption is Sought: 

The Petition, pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations, seeks exemption from: 

14 CFR 21; 14 CFR 45.23(b);14 CFR 45.27 (a); 14 CFR 61.113 (a) and (b); 14 CFR 91, et. 

seq. including: 91.407(a)(1), 91.409(a)(1), 91.417(a)&(b), 91.7(a), 91.9(b)&(c), 91,103(b), 

91.109(a), 91.119, 91.121, 91.151, 91.203(a), 91.405(a)(a). 

Exemptions from the foregoing would allow the operation and use of a UAS for 

the purpose of inspections of electrical distribution and transmission lines .and 

associated structures. Without such exemptions the benefits to safety and efficiency 

by reason of the use of UAS technology will be lost. 

II. Nature and Extent of Relief Sought and Reasons Therefore: 

The United States electric grid consists of thousands of miles of distribution.and 

transmission power lines and related structures, all of which are inextricably 

interconnected. These thousands of miles of electrified lines and structures require 

an ongoing inspection and maintenance process and program to ensure 

uninterrupted service and minimized delays in delivery of the product, electricity. 

America's dependency on electricity justifies all efforts necessary to ensure .minimal 

interruptions or delays in delivery of electricity. But, to date, inspection necessarily 

involves direct human interface almost always involving either ascending a tall 

structure or hovering above a structure in a helicopter. And, since most transmission 

lines and associated structures are located in remote areas with very difficult.terrain, 

relocating teams of workers and all of their necessary gear to the site is often 

necessary simply to conduct an inspection or find a problem. The cost to Electricity 

vendors, the risk of interruptions in delivery of electricity, and the danger to 

workers who must scale structures or be lifted by helicopters, demands a more cost 

effective, reliable and safe approach to inspections and maintenance of transmission 

lines and associated structures. 

Section 333 Exemption Request of GridHawk Aviation,.LLC 

Page 3of8 
With the advent of UAS technology, inspections and tasks leading up to 

necessary maintenance have become potentially much more inexpensive, effective 

and safe. It is important to note that these inspections may serve either the purpose 

of prevention or the locating and addressing an existing problem that threatens 

delivery. Routine inspections are often conducted at great expense and risk. UASs 

will not only conduct these on-site inspections and relay real-time video to the 

inspector, but the video can be stored for training and verification purposes. The 

operator and inspector remain safely on the ground, in sight of the UAS. Instead of 

teams of linemen and loads of equipment or the involvement of a helicopter, two 

I} individuals, a pilot/ operator of the UAS and an inspector/ observer is all that is 

needed to conduct the same inspection. 

In terms of cost, the expense of the UAS-based inspections will prove to be a 

fraction of the cost of interfaced-human inspections. Currently, it is estimated_that a 

helicopter costs the electricity vendor between $1,500.00 and $2,000.00 per hour of 

operation. In addition, the cost of locating teams and equipment can vary widely, 

depending on the access that the terrain allows, the distance, etc, but adds 

significantly to the expense of the inspection. It is difficult to estimate with certainty 

the per-hour cost with interfaced-human illspections, but it is clear that the use of 

UASs as a substitute will much more cost effective. 

Accordingly, the petitioner seeks exemption from the Regulations noted above so 

that examination and inspection can be made to various electrified distribution_and 

transmission lines, structures, and components throughout the continental United 

States while complying with other Federal Aviation Regulations_ 

III. The Benefit to the Public Interest as a Whole if Petition is Granted: 

As mentioned above, the cost of using UAS technology is only a fraction of _the 

cost of the current methods of inspections. This reduction in costs would 

presumably be passed along to the consumer. Since the distribution of electricity is 

heavily governed throughout the United States, these cost savings would become 

readily apparent to the regulating authority and presumably addressed accordingly. 

The use of UAS technology for the purpose of conducting inspections will 

produce a higher degree of reliability in the delivery of electricity. This is so largely 

because inspections, as they would be more cost effective, will be conducted_ more 

regularly. Additionally, each inspection with UAS technology will have the capacity 

to download imagery and save the entirety of the inspection in a video format. 

These can be used for inspection on site or later by personnel in office. There is the 

added benefit that the efficacy of these inspections in the future will evolve due to 

the training capacity that stored videotaped inspections have. 

Section 333 Exemption Request of GridHawk Aviation, LLC 

Page4 of8 
As well, safety will be enhanced and the costs associated with safety will be 

reduced. With the introduction of human factor into a dangerous environment, 

such as when human inspections take place with transmission lines and associated 

structures, the cost of maintaining a level of safety naturally increases. Remove the 

human interaction with the structure itself, and the risk of harm naturally reduces. 

With use of UAS technology, and the lack of need for interfaced-human inspection, 

the dangers to those involved will be reduced and, accordingly, there will be a 

corresponding reduction in cost of delivery of the product. 

Americans are highly dependent on the uninterrupted supply of electricity. 

Today, electrical distribution systems constitute targets-for terrorists and with that 

threat comes the threat to lives. (http://www.bloomberg.com/news/articles/2012-

11-14/ thousands-seen-dying-if-terrorists-attack-vulnerable-u-s-grid). A widespread 

or regional interruption in the delivery of electricity, even if for a short period, will 

result in immeasurable monetary loss as well. It is anticipated that with the increase 

in the frequency and the thoroughness of the inspections, the efforts of terrorists to 

damage or destroy central distribution systems can possibly be at the very least, 

hindered, and very possibly completely thwarted, and disaster averted. 

Reduction in costs, increase in reliability, and improvement of safety will 

enhance the benefit to the public and ensure the delivery of electricity to the 

consumer. 

IV. The Grant of the Requested Exemption Will Not Adversely Mfect Safety: 

As indicted, the current method of inspection necessarily involves the human 

interfacing with the electrical transmission lines and associated structures. These 

inspections involve a high risk of injury or even death to those working around_the 

site of the inspection. Those who are in danger include those on board the 

helicopter, if that method is used, as well as the linemen who climb the structures 

and the supporting crew below. Difficult and hazardous terrain often increases the 

risk of injury and death. 

From these concerns alone, there is an obvious increase in the safety to those 

involved in the inspection. At the same time, there is a potential increase in safety to 

the members of the general public in that more frequent and thorough inspections 

can be conducted. With more frequent and thorough inspections, there comes a 

reduction in the probability of dangerous circumstances to present themselves. 

A. UAS Platform and Safety Features 

Gridhawk envisions the use of a UAS, the Aeryon SkyRanger platform 

("Sky Ranger"). 

Section 333 Exemption Request of GridHawk Aviation,.LLC 

Page 5 of8 
The SkyRanger provides two semi-autonomous flight modes using a point~andclick map and video interface. The user clicks on a map to direct the Sky Ranger to fly to 

point of the map where the operator is pointing, or program flight plans may be entered 

for a series of way points or grid based area. Additional navigation age including 

landing zones and flight areas may be designated to ensure the SkyRanger operates 

only within user specified flight parameters. All flight operations are GPS controlled 

making the system easy to navigate, and the flight control system also employs a 

variety of sensors including sonar, barometric pressure, temperature, wind speed, and 

others to ensure high stability and reliability even in challenging weather conditions. 

At all times during flight operations, the operator has the command authority to 

intervene a program flight and take immediate control. Attached hereto as Exhibit A is 

brochure material regarding anticipated UAS technology to be utilized. 

The Sky Ranger features the following additional automated safety functions: 

• Automated pre-flight system performance checks. 

• User pre-flight checklist. 

• Automated condition or fault detection, warnings, and predefined 

responses to a number of flight and system conditions including winds, 

power status, temperature, and lost-link communications. 

• Predefined responses include behavior such as attempting to reestablish 

radio communication, return to home position and hover, return to home 

position and land, or land in current position. 

• In the case of lost GPS, a manual user flight mode is enabled which.allows 

the operator to provide manual navigation inputs to assist in the landing 

of the vehicle. 

The Sky Ranger specifications are as follows: 

Payload . 

Empty weight 

Maximum wind 

Operational radius range 

Dimensions 

Fuel 

Maximum altitude 

Maximum endurance 

up to 1.3 pounds 

5.3 pounds 

40MPH 

up to 1.6 nautical miles 

40 inches diameter deployed 

lithium polymer batteries 

1,500 feet 

50 minutes 

B. Operator-Pilot Qualifications, Experience, Currency and Safety 

Section 333 Exemption Request of Grid.Hawk Aviation. LLC 

Page 6of8 
•' . 

GridHawk will utilize only Private or Commercial Rated pilots who are current 

and hold at least a Class III FAA Medical Certificate. Furthermore, GridHawk will 

require at least 20 hours of flight time and 200 cycles prior to conducting operations 

pursuant to the grant of an exemption. Pilot currency demands consistent with 

existing FAR requirements will also be employed to ensure that pilots maintain_their 

effectiveness. 

For all exempted flight operations, one qualified individual will be designated_as 

Pilot in Command (PIC) and second individual will be designated visual observer 

(VO). The PIC shall act as team leader and shall be responsible for safety of flight 

and operations. The VO shall be responsible for the Ground Control Station (GCS) 

assembly and will maintain visual identification of the UAS while scanning for_and 

pointing out flight hazards, such as other aircraft, obstacles, boundaries of the predesignated safe operations areas and persons. 

C. Airspace and Related Safety 

The UAS will only be used to conduct flight operations under day & VFR 

conditions. It is contemplated that the UAS will launched from a location within or 

very near and below the right of way for the transmission line and associated 

structures, unless more immediate hazard concerns dictate otherwise. Creation of 

the safe operation areas and the actual operations will take into iji.CCount the 

possibility of equipment failure such that it will not present an undue hazard to 

persons or property. 

On rare occasion, current inspections may be conducted in densely populated 

areas or areas extending over heavily traveled thoroughfares. It is contemplated 

that no UAS-based inspection will take place in areas where an unexpected accident 

would endanger members of the public. Alternative methods of inspection as well 

as density of the population or volume of traffic will be considered and any doubt 

for safety be resolved against UAS operations. It is anticipated that, in such_areas, 

UAS-based inspections will be minimal and only be conducted in accordance with 

existing Federal Aviation regulations. 

With regard to airspace concerns, it is not anticipated that there will be frequent 

entry into the existing airspace system as most operations will be in remote_areas 

and within 400 feet of the surface. In those cases where an airspace is from __ the 

surface to a given altitude AGL, consultation with and notification of the local.air 

traffic control system will be undertaken, and the publication, if appropriate, of 

notice to airmen through the normal channels will be posted. Operations shall be 

conducted in that airspace only after permission is obtained and only during.the 

effective time of the NOT AMs. Again, given the remoteness of most flight 

operations, the frequency of operations involving anything other than Class G 

Section 333 Exemption Request of GridHawk A via lion, LLC 

Page 7of8 
airspace will be very low. And, it should be emphasized here that, since the 

exemption sought is to operate very near and at the same elevation as existing 

transmission lines and associated structures, the operation of GridHawk's UAS will 

not significantly expand or enlarge risks to other airborne aircraft beyond the_risks 

already presented by the transmission lines and structures themselves. 

All operators being FAA licensed pilots will be aware of and knowledgeable 

about any overlying or involved airspace as well as right of way rules. 

V. Summary for Publication in the Federal Register: 

GridHawk Aviation, LLC, seeks an exemption pursuant to Section 333 to 

conduct UAS-based inspections of power distribution and transmission lines, _and 

associated structures, within the continental United States. The Petition seeks 

exemption from: 

14 CFR 21; 14 CFR 45.23(b);14 CFR 45.27 (a); 14 CFR 61.113 (a) and (b); 14 CFR 91, et. 

seq. including: 91.407(a)(1), 91.409(a)(1), 91.417(a)&(b), 91.7(a), 91.9(b)&(c), 91,103(b), 

91.109(a), 91.119, 91.121, 91.151, 91.203(a), 91.405(a)(a). 

VI. List of Supporting Exhibits: 

A. Brochure regarding anticipated UAS technology to be utilized consisting of 

the Sky Ranger Aeyron UAS and supporting equipment. 

B. Graphic-United States Electric Grid (2009) 

C. GridHawk Operation limitations 

Respectfully submitted, 

GridHa Aviation, L C 

By: ---R-------"---¥--~])~ Justin Schwigen, Owne 

3426 Elik Lane 

Alton, IL 62002 

(618) 372-3579 

Email: Iustin@gridhawkaviation.com 

Section 333 Exemption Request of GridHawk Aviation, LLC 

Page8of8 
Field-tested and battle-proven. Aeryon small UAS set the 

standard for immediate aerial intelligence gathtring by 

ANYONE, ANYWHERE, at ANYTIME: 

+ Intuitive wuchscreen interrace and advanced ieatures. 

minimal user trainirog 

+Single operator transport and deployment. no launch 

or recovery equipment 

+Reliable flight periormance even in the most demanding 

weather conditions, 1Nhen other systems cannot fly 

The Aeryon SkyRangerrM introduces a new airframe and integrated 

system design to the Aeryon sUAS platform. based on thousands 

of hours of flight time and successful customer exercises and missions 

around the world. Designed to military and government specifications. 

SkyRangerTM extends industry-leading performance and system capabilities. 

Intuitive interface and autonomous 

capabilities - no joysticks required 

+ Point-and-dick touchscreen 

navigation and camera control 

+ Dynamic flight plans including 

Follow-Merx protection and AUloGrid'" 

mapping modes 

Advanced optics and networking -smart 

imagery and seamless integration 

+ Stabilized. simultaneously-streaming 

dual EO/IR high resolution cameras 

EO: 1 080p2k HD H.26f video. 

15MP still images 

- IR: 66-0xl!SO H.264 video and s;iU images. 

white-hot and black-hot modes 

+ Low-latency all-digital network256bii AES encrypted streaming video 

to muliiple devices. embedded geotags 

and metadata 

+ Beyond line-of-sight range 

1. 9 mi 13 km) integrated capability. 

extensible beyond 3. i mi 15 km) 

EXHIBIT 

A 

Rugged, reliable and capable 

-dependable in extreme environments 

+ Up to 50-minute endurance with payload. 

continuous operation model 

+ High wind tolerance -

1.0 mph {65 kph] susiained. 

55 mph (90 kphl gusts 

+ Ruggedized and weather-sealed 

+ Environmental temperature range 

-22'F to 122'F 1-Jo•c to 50'Cl 

Pre-assembled backpack 

deployment- airborne in seconds 

+Folding design protects payload 

& includes battery for powered standby 

+Payload. battery, arms. and legs are 

easily replaced in the field without tools 
The Aeryon sUAS platform brings secure. real-time and simultaneous tactical situational 

awareness to ground forces and remote command. Advc:nced autonomous ca pabilities 

and simple touchscreen controls require minimal training for soldier. sq uad, or 

platoon-level deployment. 

Unlike fixed-wing systems. the Aeryon SkyRangerrM is a Vertical Take -Off and Landing IVTOLI 

sUAS- ideal for providing conti nuous eyes-on-target for situational awareness. ope•ations 

in confined environments. and low-risk launch and retrieval without periphera l equipment. 

SkyRangerrM is ideally suited for both land and maritime military use including covert ISR. 

convoy and compound security. and ship boarding operations. 

Immediate deployment. small size. quiet operation and specialized imaging payloads 

make SkyRanger'- the ideal platfoom for a wide range of missions in any conditions. including: 

+ Tactical situational awa reness & targeting 

+ Perimeter & convoy security 

+ Covert Intelligence. Surveillance 

and Reconnaissance IISR) 

+ Anti-pi;-acy. tactical ship boarding 

+ De -mining 

+ Emergency & disaster response 

+ HAZMAT/CBRNE management 

For information about Aeryon sUAS solutions, contact your Aeryon Sales Representative: 

Call+ i -519-1:89-6726 ext: 320 or email salesfGaeryon.com 

www.aeryon.com I toaeryonlabs 

TECHNICAL SPECIFICATIONS: 

ENDURANCE: 

• Up to 50-minute flig ht time !with payload) 

WIND TOLERANCE: 

• 40 moh [65 kohl sustained 

• 55 mph (90 kph) gusts 

ENVIRONMENTAL TEMPERATURE RANGE: 

• -22•F to-i 22?F l-3o·c to SO'Cl 

BEYOND LINE-OF-SIGHT RANGE: 

• 1.9 mi 13 km) integrated capability 

• Extensible beyond 3.1 mi 15 kml 

ALTITUDE: 

• 1500 ft. 1450 ml A.GL, i 5000 it. ~500 m ) MSL 

LAUNCH & RECOVERY METHOD: 

· • Verticsl Take-Oif and Landing !VTOLl 

DIMENSIONS: 

• Deployed: £0 in.li02 em! diameter, 

9.3 in. 12L em) heioht 

• Folded: 20 in. 150 em) gth~ 

10 in. 125 cml width 

WEIGHT [WITHOUT PAYLOAD): 

• 5.3 lbs (2.L kg) 

ADDITIONAL PAYLOADS: 

• 3-axis stabilized hiah resolution EO camera 

• Custom payload development 

NAVIGATION LEOS: 

• Red/Green and Re.j/NIR 

RADIO FREQUENCIES: 

• 900 mhz, 2.4 GHz, custom 

CONTROL AND DATA LINK: 

• Low-latency all-digita l network 

SECURITY: 

• Secure network pairing. 

AES 256 bit encryption · 
Visualizing The U.S. Electric Grid : NPR 

THE GRID 

Ai>out Thi& Map •· 

EX IS nr•G Uf(ES 

345-199 f:V 

A< S!Xl-69£• I:V 

"' 700·799 kV 

"V t.OOO lo:V (OC) 

PROPOSED UliES 

•, New 765 kV 

- AC-DC·AC Link!O 

1~/TERCOlfiiECTI!»IS 

Major t>«C tors of thr 

U.S. electrical grid 

SOURCES OF POWER POWER PLANTS SOLAR POWER WINO POWER 

.l \ _.;:- ·~- .. -.. 

Source: American Electric Power, American Wind Energy Association, Center tor American Progress, Department of Energy, 

Edison Electric Institute, Energy Information Administration, Electric Power Research Institute, Federal Energy Regulatory 

Commission, National Renewable Energy Laboratory, U.S. Environmental Protection Agency, Western Resource Advocates 

Credit: Producer: Andrew Prince; Designer: Alyson Hurt; Editors: A vie Schneider and Vikki Valentine; Supervising Editors: Anne 

Gudenkaut and Quinn O'Toole; Additional Research: Jenny Gold; Database and GIS Analysis: Robert Benincasa 

NPR Series 

EXHIBIT 

Power Hungry: Reinventing The U.S. Electric Grid May 1. 2009 B 

http: //www.npr.orgl2009/04/24/110997398/visualizing-the-u-s-e!ectric-grid 

2/6115 9:36PM 

Page 2 of 3 
~~··----·-· ____________________ ..._.__ 

OPERATION LIMITATIONS AND RESTRICTIONS FOR 

GRIDHA vVK AVIATION, LLC 

VER.1.00 February 2015 

EXHIBIT 

c 
1. Operations authorized by this grant of exemption are limited to the following 

aircraft described in the operating documents which has four rotors and four 

motors in a quadcopter configuration and weighing less than 7 pounds including 

imaging payload: The SkyRanger currently manufactured by Aeryon. Proposed 

operations of any other aircraft will require a new petition or a petition to amend 

this grant. 

2. UAS operations under this· exemption are limited to the inspection electrical 

distribution and transmission lines, and associated structures. 

3. The UA may not be flown at a ground speed exceeding 25 mph. 

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

level (AGL), or 50 feet above any structure being inspected, as indicated by the 

procedures specified in the operator's manual. All altitudes reported to ATC 

must be in feet AGL. 

5. All operations to occur in Class G airspace unless othenvise authorized by local 

ground control/ air control, ARTCC or other authority over the involved 

airspace. 

6. Operations to avoid congested or populated areas, which are depicted in yellow 

on official VFR navigational Sectional Charts, unless it is determined that 

operation will be pose no unreasonable risk of harm or danger to those nonparticipating individuals and/ or personal or real property. 

7. All operations shall be within the right-of-way or easement if any, of the utility 

except as may be necessary for the purpose of transition from the base of 

operation to the structure to be inspected and for ingress and egress purposes 

only, in which case permission of the affected landowner shall first be obtained. 

8. All operations conducted in the vicinity of an airport are to remain more than 2.5 

nautical miles from the center line azimuth of the corresponding runway center 

line measured from the runway threshold. 

9. 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 obsenration unaided by any 

device other than corrective lenses, as specified on the PIC s FAA-issued medical 

certificate. 

10. All operations must utilize a visual observer (VO) and within VLOS of the VO at 

all times. This requires the VO to be able to use human vision unaided by any 

device other than corrective lenses. The VO may be used to satisfy the VLOS 
requirement as long as the PIC always maintains VLOS capability. The VO and 

PIC must be able to communicate verbally at all times. Electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated 

before the flight and cannot transfer his or her designation for the duration of the 

flight. The PIC must ensure that the VO can perform the functions prescribed in 

the operating documents. 

11. The VO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/ obstructions and 

is not permitted to operate the camera or other instruments. 

12. The operating documents and this grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exits between the conditions and limitations in this exemption and 

the procedures outlines in the operating documents, the conditions and 

limitations herein take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating documents. The 

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

responsibility to track such revisions and present updated and revised 

documents to the Administrator upon request. 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 exemption, then the 

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

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

updates or revisions to the operating documents. 

13. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for 

safe flight. 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 condition fore 

safe flight. The Ground Control Statio~ must be included in the preflight 

inspection. All maintenance and alterations must be properly documented in the 

aircraft records. 

14. Any UAS that has undergone maintenance or alteration that affect the UAS 

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

must undergo a functional test flight. The PIC who conducts the functional test 

flight must make an entry of the flight in the UAS aircraft records. 

15. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. 
16. The operator must follow the UAS manufacturer's aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

17. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance. with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/ overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

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

Safety Bulletins. 

19. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

20. The PIC must possess at least a private pilot certificate and at least a current 

third-class medical certificate. In accordance with 14 CFR 61.23, a pilot holding a 

commercial certificate must posses at least a second-class medical certificate. The 

PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in 

an aircraft in which the PIC is rated on his or her pilot certificate. 

21. Prior to operations conducted for the purpose of inspection, the PIC must have 

completed the operator's training as prescribed in the operating documents. 

During that training, the PIC must have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51(b), the minimum hours prescribe in the operating 

documents as UAS pilot operating the make and model of the UAS to be utilized 

for operations under the exemption. Training, proficiency, and experiencebuilding flights can be conducted under this grant of exemption to qualify the 

operator's PIC(s), VO(s) and other essential personnel as defined in the operating 

documents. However, said training operations may experience-building flights 

the PIC is required to operate the UA with appropriate distances in accordance 

with 14 CFR § 91.119. 

22. Prior to operations conducted for the purpose of inspection, the PIC must have 

completed the operator's currency requirements as prescribed in the operating 

documents. The PIC must have completed at least three take-offs and three 

landings in the preceding 90 days as UAS pilot operating the make and model of 

the UAS to be utilized for operations under the exemption to maintain currency. 

Take-off and landing currency flights can be conducted under this grant of 

exemption. \A/hen establishing or regaining currency, said currency flights may 

only be conducted during dedicated training/ currency sessions. During 
training, proficiency, experience-building flights, and dedicated currency flights 

the PIC is required to operate the UA with appropriate distances in accordance 

with 14 CFR § 91.119. 

23. Prior to operations conducted for the purpose of inspection, the PIC, VO, and 

other essential personnel as defined in the operating documents, must have met 

all qualification, training, and currency requirements, as outlined in the· 

operating documents. A record of completion of these requirements must be 

documents and made available to the Administrator upon request. 

24. The operator may not permit the PIC to operate the UAS for the purpose of 

inspection unless the PIC has demonstrated and logged in a manner consistent 

with 14 CFR § 61.51(b), the ability to safely operate the UAS in a manner 

consistent with hoe the UAS vvill be operated under this exemption, including 

evasive and emergency maneuvers and maintain appropriate distances from 

people, vessels, vehicles, and structures. 

25. 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. 

26. The UA may not operate within 5 nautical miles of the airport reference point as 

denoted on a current FAA-published aeronautical chart. 

27. 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 

28. If the UAS loses communications or loses its GPS signat the UA must return to a 

pre-determined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

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

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% batter power 

remaining. 

31. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this 

grant of exemption. This COA will also require the operator to request a Notice 

··----
to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation .. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements. 

32. 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. 

33. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

34. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to 

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

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

enforcement official upon request. 

35. The U A must remain clear and yield the right of way to all manned operations 

and activities at all times. 

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

37. The UA may not be operated over congested or densely populated areas. 

38. Flight operations must be conducted no less than 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/ or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons are no 

longer under such protection and are within 500 feet of the UA, flight 

operations must cease immediately, and/ or; 

b. The aircraft is operated near vessels, vehicles, or structures where the 

owner/ COI)troller of such vessels, vehicles, or structures has granted 

permission 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, and; 

r-
: .,. . . 

c. Operations nearer to the PIC, VO, Sensor Operator, other essential 

personnel as defined in the operating documents, do not present an undue 

hazard to those persons per§ 91.119(a). · 

39. All operations shall be conducted with permission from the state or local 

government agency, organization, or owner, with authority for operating the 

bridge under inspection. Permission from the authority will be obtained for each 

flight to be conducted. 

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

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

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

Accidents must be reported to the National Transportation Safety Board (NTSB) · 

per instructions contained on the NTSB Web site: \Vvvvv.ntsb.gov. 

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