Great River Energy Petition for Exemption

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

Great River Energy

Attn" Kyle A Leier- Sr. Engineering Project Manager

12300 Elm Creek Blvd

Maple Grove, MN 55369

Ph: 763-445-5000

kleier@grenergy.com
TABLE OF CONTENTS

EXECUTIVE SUMMARY .................................................................................................................... i

APPLICANT BACKGROUND ......................................... . ............... , .................................................... 1

EXEMPTIONS GREAT RIVER ENERGY IS REQUESTING ..................................................................... 2

NAME AND MAILING ADDRESS OF APPLICANT .............................................................................. 2

APPLICANT REQUESTS EXEMPTION FROM THE FOLLOWING FARs" 2

THE EXTENT OF RELIEF GRE SEEKS AND THE REASON GRE SEEKS THE RELIEF ............................... 3

GRANTING GRE'S REQUEST BENEFITS THE PUBLIC INTEREST AND WILL NOT ADVERSELY AFFECT

SAFETY ........................................................................................................................................... 22

SUMMARY ..................................................................................................................................... 12

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EXECUTIVE SUMMARY

Great River Energy (Great River Energy, "GRE", or "Applicant") a not-for-profit generation and

transmission electric cooperative based in Maple Grove, MN, respectfully requests authority to

commercially operate small, Unmanned Aerial Systems ("sUASs") under the conditions and

terms set forth in this Petition for Exemption ("Petition".)

APPLICANT BACKGROUND

Great River Energy is a not-for-profit electric cooperative owned by its 28 member

cooperatives. We generate and transmit electricity for those members, located in the outerring suburbs of the Twin Cities up to the Arrowhead region of Minnesota and down to the

farmland region in the southwestern portion of the state.

Great River Energy's cooperative structure has proven to be central to our continued success in

delivering on our mission - providing member-owners with affordable, reliable energy in

harmony with a sustainable environment. Collaboration with our members, stakeholders,

community leaders and employees has made us the strong and respected organization we are.

Like other cooperatives, Great River Energy exists to serve its membership and is dedicated to

helping the communities in which it operates.

We are member-controlled and governed by a democratically elected board of directors who

are electric cooperative members themselves. Board members establish rates and develop

policies in the best interest of Great River Energy and its members. Great River Energy owns

and maintains a resource mix that includes 12 power plants and nearly 4,700 miles of

transmission lines, making us the second largest power supplier in Minnesota. Great River

Energy offers a diverse mix of baseload and peaking power plants, including coal, refusederived fuel, natural gas and fuel oil, as well as wind and solar generation. ÿ

http://greatriverenergy.com/
EXEMPTIONS GREAT RIVER ENERGY IS REQUESTING

Applicant Great River Energy (GRE,) pursuant Section 333 of the FAA Modernization and Reform

Act of 2012, Pub. L. No. 112-95, 126 Stat. 11 (amending 49 U.S.C.) (hereinafter, the "Reform

Ac__tt") and 14 C.F.R. Part 11, petitions the administrator for an exemption from the requirements

of 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b);

91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a)(1); 91.409 (a)(1) &

(2); 91.417 (a) & (b).

NAME AND MAILING ADDRESS OF APPLICANT

Great River Energy

Attn: Kyle A Leier

12300 Elm Creek Blvd

Maple Grove, MN 55369

Phone: 763-445-5820

Email: kleier@grenergy.com

APPLICANT REQUESTS EXEMPTION FROM THE FOLLOWING FARs:

1)

2)

3)

4)

5)

6)

7)

8)

9)

lO)

11)

12)

13)

14)

is)

14 C.F.R § 21

14 C.F.R 45.23(b)

14 C.F.R § 61.113 (a)and (b)

14 C.F.R § 91.7(a)

14 C.F.R § 91.9(b)(2)

14 C.F.R § 91.103

14 C.F.R § 91.109

14 C.F.R § 91.119

14 C.F.R § 91.121

14 C.F.R § 91.151(a)

14 C.F.R § 91.203(a) and (b)

14 C.F.R § 91.405(a)

14 C.F.R § 91.407(a)(1)

14 C.F.R. §91.409(a)(1) and (2)

14 C.F.R. §91.417(a) and (b)

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THE EXTENT OF RELIEF GRE SEEKS AND THE REASON GRE SEEKS THE RELIEF

This exemption application is expressly submitted to fulfill Congress' goal in passing

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to

consider whether certain unmanned aircraft systems ("UAS") may operate safely in the national

airspace system ("NAS") before completion of the rulemaking required under Section 332 of

the Reform Act. In making this determination, the Secretary of Transportation is required to

determine which types of unmanned aircraft systems do not create a hazard to users of the

NAS or the public or pose a threat to national security in light of (i) the UAS's size, weight,

speed, and operational capability, (ii) operation of the UAS in close proximity to airports and

populated areas, and (iii) operation of the UAS within visual line of sight of the operator. Id. §

333 (b) (1). Lastly, if the Secretary of Transportation determines that such vehicles "may

operate safely in the national airspace system, the Secretary of Transportation shall establish

requirements for the safe operation of such aircraft in the national airspace system." Id. § 333

(c) (underline added).2

The Federal Aviation Act, 49 U.S.C. (the "Act") expressly grants the FAA the authority to issue

exemptions. This statutory authority by its terms includes exempting "civil aircraft," as the term

is defined under §40102 of the Act that includes sUASs from the requirement that all civil

aircraft must have a current airworthiness certificate.

The FAA Administrator may grant an exemption from a requirement of a regulation prescribed

under the Act if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701

(f). See also 49 USC § 44711 (a); 49 USC § 44704; 14 CFR § 91.203 (a) (1).

GRE's sUASs are rotorcraft, weighing 55 or fewer Ibs. including payload. They will operate,

under normal conditions, at a speed of no more than 50 knots. They will operate only in line of

sight and will operate only within the airspace above property owned, leased, controlled by

easement or otherwise controlled by GRE, cooperative members or its customers with

permission from said cooperative members, land owners or customers prior to any operation of

sUAS as described in the Safety Checklist, attached as Exhibit A (hereinafter, the Safety

Checklist").3 Such operations will ensure that the sUASs will, "not create a hazard to users of

the national airspace system or the public." Reform Act § 333 (b).

Given the small size of the sUASs involved and the proposed diligence for safety of people

involved with the operation as well as any bystanders, the Applicant falls squarely within that

2 The Applicant interprets this provision to place the duty on the Administrator to not only process applications for

exemptions under Section 333 of the Reform Act, but for the Administrator to craft conditions for the safe

operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory

requirements for approval.

3 The Applicant submits the Safety Checklist as a confidential document under 14 C.F.R. 11.35 (b) as the entire

safety checklist contains proprietary information that the Applicant has not and will not share with others. The

safety checklist contains operating conditions and procedures that are not available to the public and are

protected from release under the Freedom of Information Act, 5 U.S.C. 552 et seq.
zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must,

by exemption, allow commercial operations of UASs to commence immediately. Also due to the

size of the sUASs and the public service, non-profit nature of Applicant's commercial activities,

approval of the application presents no national security issue. Given the clear direction in

Section 333 of the Reform Act, the authority contained in the Act, as amended; the strong

equivalent level of safety surrounding the proposed operations, and the significant public

benefit, including enhanced safety, reduction in environmental impacts, including reduced

emissions associated with allowing UAS for aerial photography, videography, aerial inspections,

surveying and mapping and any other aerial data collection operations as opposed to full scale

aircraft, the grant of the requested exemption is in the public interest. Accordingly, the

Applicant respectfully requests that the FAA grant the requested exemption without delay.

The Applicant proposes that the exemption requested herein apply to civil aircraft that have the

characteristics and that operate with the limitations listed herein. These limitations provide for

at least an equivalent or even higher level of safety to operations under the current regulatory

structure because the proposed operations represent a safety enhancement to the already safe

aerial photography, videography, aerial inspections, surveying and mapping and any other

aerial data collection operations conducted with conventional aircraft.

These limitations and conditions to which GRE agrees to be bound when conducting

commercial operations under an FAA issued exemption include:

, Each sUAS will weigh less than 55 Ibs.

. Flights will be operated within line of sight of the Pilot in Command ("PIC".)

. Maximum total flight time for each operational flight will be determined by battery

capacity. For example, current battery technology for the Inspire sUAS allows for 18

minute operations for the standard battery and 22 minutes for the extended life

battery. Should battery technology increase operational flight times, flights will be

terminated at ~20% battery power reserve. Future battery technology will likely

increase operational flight times, and as such, the maximum flight time will continue to

increase. However, in any event, all operational flights will be terminated at ~20% of

capacity remaining to allow safe return of the sUAS to base.

. Flights will be operated at an altitude of no more than 400 feet AGL unless prior

approval from Air Traffic Control is authorized and a Notice to Airmen (NOTAM) is filed

and published.

. Minimum crew for each operation will consist of the sUAS pilot.

. The sUAS pilot will be an FAA licensed airman with at least a sport or recreational pilot's

certificate and valid driver's license.

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1 The sUAS pilot will be the Pilot in Command ("PIC"). If a pilot certificate holder other

than the sUAS pilot, who possesses the necessary PIC qualifications, is also present

during operations that person can also be designated as a PIC.

1 The sUAS will only operate over property owned by, leased, controlled via easement or

otherwise by GRE with permission from the relevant property holders as set forth in the

Safety Checklist.

, A briefing between the sUAS pilot and any observer (if applicable) will be conducted in

regard to the planned sUAS operations prior to each day's operational flights.

The Applicant will file a FAA Form 7711-1, or its equivalent, as modified in light of the

requested exemption, with the appropriate Flight Standards District Office ("FSDO.").

Whenever possible, the Applicant will submit a written Plan of Activities to the FSDO

three days before the proposed operational flights as required in the Safety Checklist.

However, in the event that there are weather related emergency inspections required,

Applicant will provide contemporaneous notice to the FAA but will only conduct

operations if approved by the FAA.

The sUAS pilot and observer (if applicable) will have been trained in operation of sUASs

generally and received up-to-date information on the particular sUAS to be operated as

required in Safety Checklist.

The sUAS pilot and observer (if applicable) will at all times be able to communicate by

voice and/or text.

Written and/or oral permission from the relevant property holders will be obtained.

All required permissions and permits will be obtained from territorial, state, county or

city jurisdictions, including local law enforcement, fire, or other appropriate

governmental agencies.

If the sUASs lose communications or lose their GPS signal during operational flights, the

sUASs will have capability to return to and land at a pre-determined and preprogrammed location.

The sUASs will have the capability to abort an operational flight in case of unpredicted

obstacles or emergencies.

Ii 14 C.F.R. Part 21, Subpart H" Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airworthiness certificates as required by FAR § 91.203 (a) (1). Given the size and

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limited operating area associated with the aircraft to be utilized by the Applicant, an exemption

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11

and Section 333 of the Reform Act. Section 44701 (f) of the Act and Section 333 of the

Reform Act both authorize the FAA to exempt aircraft from the requirement for an

airworthiness certificate upon consideration of the size, weight, speed, operational capability,

and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of

these criteria demonstrates that the sUASs operated without an airworthiness certificate, in the

restricted environment and under the conditions proposed herein will be at least as safe, or

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness

certificate without the restrictions and conditions proposed.

The sUASs to be operated hereunder are less than 55 Ibs. fully loaded, carries neither a pilot

nor passenger, carries no explosive materials or flammable liquid fuels, and operates

exclusively within a secured area as set out in the Safety Checklist. Unlike other civil aircraft,

operations under this exemption will be tightly controlled and monitored by the Applicant

pursuant to the Safety Checklist's requirements, and under the requirements and in

compliance with local public safety requirements, to provide security for the areas of

operations as is now done with conventional aerial photography, videography, aerial

inspections, surveying and mapping and any other aerial data collection operations. The FAA

will have advance notice of all operations or if permitted by the FAA, will have

contemporaneous notice in the event of weather related inspection emergencies. These safety

enhancements provide a greater degree of safety to the public and property owners than

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part

21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible

threat to national security posed by the sUAS, due to its size, speed of operation, location of

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a

substantial external load.

II. 14 C.F.R. § 45.23 (b). Marking of the Aircraft

This regulation requires"

"When marks include only the Roman capital letter "N" and the registration

number is displayed on limited, restricted or light-sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also display

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in

letters not less than 2 inches nor more than 6 inches high, the words "limited,"

"restricted," "light-sport," "experimental," or "provisional," as applicable."

Even though the sUASs will have no airworthiness certificate, an exemption may be needed as

the sUASs will have no entrance to the cabin, cockpit or pilot station on which the words,

II II II "limited," "restricted," "light-sport," "experimental, or provisional, can be placed.
However, the Applicant shall also ensure its sUASs are registered with the FAA and that the

nationality marks relating to such sUASs are marked on the sUASs in a visible manner. Given the

size of the sUASs, two-inch lettering may be impossible. The relevant N markings will be placed

• in the most visible location on the sUASs possible.

The equivalent level of safety will be provided by having each sUAS marked in the visible

location where the sUAS pilot, observer and others working with the sUAS will see the

identification of the UAS.

III. 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations" Pilot in Command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUASs

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of

safety of current operations by requiring the PICs operating the sUASs to have a sport or

recreational pilot's license rather than a commercial pilot's license to operate the sUASs.

Unlike a conventional aircraft that carries the pilot and passengers, the sUASs are remotelycontrolled with no living thing on board. The area of operation is controlled and restricted, and

all flights are planned and coordinated in advance as set forth in the Safety Checklist. The level

of safety provided by the requirements included in the Safety Checklist exceeds that provided

by a single individual holding a commercial pilot's certificate operating a conventional aircraft.

The risks associated with the operation of the sUASs are so diminished from the level of risk

associated with commercial operations contemplated by Part 61 when drafted, that allowing

operations of the sUASs as requested with a sport or recreational pilot as the PIC exceeds the

present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

IV. 14 C.F.R. §91.7(a)" Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft and the requirements contained in the Safety Checklist for

maintenance and use of the Safety Checklist prior to each flight, an equivalent level of safety

will be provided.

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

Section 91.9 (b)(2) provides"

"No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by

§21.5 of this chapter, unless there is available in the aircraft a current approved

airplane or Rotorcraft Flight Manual, approved manual material, markings, and

placards, or any combination thereof."

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The sUASs, given their size and configuration have no ability or place to carry such a flight

manual on the aircraft, not only because there is no pilot on board, but because there is no

room or capacity to carry such an item on the sUASs.

The equivalent level of safety will be maintained by keeping the flight manual at the ground

control point to which the sUASs pilots flying the sUASs will have immediate access. The FAA

has issued the following exemptions to this regulation" Exemption Nos. 8607, 8737, 8738,

9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

Vl. 14 C.F.R. § 91.103" Preflight Action

This regulation requires each pilot in command to take certain actions before flight to ensure

the safety of flight. As FAA-approved rotorcraft flight manuals will not be provided for the

aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth

in the Safety Checklist. The PIC will take all actions including reviewing weather, flight battery

requirements, landing and takeoff distances and aircraft performance data before initiation of

flight.

VII. 14 C.F.R. § 91.109: Flight Instruction

Section 91.109 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls.

Flight control is accomplished through the use of a control box that communicates with the

aircraft via radio communications. The FAA has approved exemptions for flight training without

fully functional dual controls for a number of aircraft and for flight instruction in experimental

aircraft. See Exemption Nos. 57781( & 9862A. The equivalent level of safety is provided by the

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

of the aircraft.

VIII. 14 C.F.R. § 91.119" Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d)

allows helicopters, powered parachutes and weight-shift-control aircraft to be operated at

less than the minimums prescribed because their low speed and responsive controls allow

operations to be conducted, "without hazard to persons or property on the surface ...". As

sUAS possess similar flight and control characteristics, and as the exemption requests

authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such

operations. As set forth herein, except for the limited conditions stated in the Safety

Checklist, the sUASs will never operate at higher than 400 AGL. It will however be operated in
a restricted area, where buildings and people will not be exposed to operations without their

pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the sUASs as

well as the locations where they are operated. No flight will be taken without the permission

of the property owner or local officials as applicable. Such permission may be obtained or

presumed by the Applicant in the event that Applicant has an easement over the property.

Because of the advance notice to the property owner, or in the event that the property owner

hasn't granted explicit blanket ingress and egress easements to the property,

contemporaneous notice, all affected individuals will be aware of the planned flight operations

as set forth in the Safety Checklist. Compared to flight operations with aircraft or rotorcraft

weighting far more than the maximum 551bs. proposed herein and the lack of flammable fuel,

any risk associated with these operations is far less than those presently presented with

conventional aircraft operating at or below 500 AGL in the aerial photography, videography,

aerial inspections, surveying and mapping and any other aerial data collection industries. In

addition, the low-altitude operations of the sUASs will ensure separation between these sUAS

operations and the operations of conventional aircraft that must comply with Section 91.119.

J

IX. 14 C.F.R. § 91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set "... to the elevation of the departure airport or an

appropriate altimeter setting available before departure." As the sUASs may not have a

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An

equivalent level of safety will be achieved by the operator, pursuant to the Safety Checklist,

confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

Xl 14 C.F.R. § 91.151 (a)" Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to

fly to the first point of intended landing, and, assuming normal cruising speed - (1) During the

day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least

45 minutes."

The current battery technology powering sUASs is much more limited than that of combustion

powered flight. As such, the Applicant's sUASs cannot presently and likely may never meet the

reserve requirement in 14 CFR § 91.151. Given the limitations on the UAS's proposed flight area

and the location of its proposed operations within a predetermined area, a longer time frame

for flight in daylight VFR conditions is reasonable. As no night flight will occur, that portion is

inapplicable.

Applicant believes that an exemption from 14 CFR § 91.151 (a) falls within the scope of prior

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without

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compliance with FAR 91.151 (a)). Operating the sUASs in a tightly controlled area where only

people and property owners or official representatives who have signed waivers will be

allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that

Section 91.151 (a) was intended to alleviate given the size, speed and limited operating area of

the sUASs.

Applicant believes that an equivalent level of safety can be achieved by limiting flights based on

expected battery life, currently 20 minutes, or 20% of battery power when future technology

expands the battery life. This restriction would be more than adequate to return the sUASs to

their planned landing zone from anywhere in its limited operatingarea.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745,

10673, and 10808.

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

J

The regulation provides in pertinent part:

"(a) Except as provided in § 91.715, no person may operate a civil aircraft

unless it has within it the following"

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued

under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to

II

passengers or crew.

The sUASs fully loaded weigh no more than 55 Ibs. and are operated without an onboard pilot.

As such, there is no ability or place to carry certification and registration documents, or to

display them on the sUASs.

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the sUASs pilots flying the sUASs will have immediate access to them; to

the extent they are applicable to the sUASs. The FAA has issued numerous exemptions to this

regulation. A representative sample of other exemptions includes Exemption Nos. 9565, 9665,

9789, 9789A, 9797, 9797A, 9816A, and 10700.

Xll. 14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417 (a) & (b): Maintenance

Inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected

as prescribed in subpart E of this part and shall between required inspections, except as
provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of

this chapter ...," and others shall inspect or maintain the aircraft in compliance with Part 43.

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

these sections will not apply to the sUASs as proposed to be operated by the Applicant.

Maintenance will be accomplished by the Applicant pursuant to the flight manual and operating

handbook as referenced in the Safety Checklist. An equivalent level of safety will be achieved

because these sUASs are very limited in size and will carry a small payload and operate only in

restricted areas for limited periods of time. If mechanical issues arise, the sUASs can land

immediately and will be operating from no higher than 400 feet AGL. As provided for in the

Safety Checklist, the Applicant will ensure that the sUAS is in working order prior to initiating

flight, perform required maintenance, and keep a log of any maintenance performed.

Moreover, the Applicant is the person most familiar with the aircraft and best suited to

maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

GRANTING GRE'S REQUEST BENEFITS THE PUBLIC INTEREST,

AND WILL NOT ADVERSELY AFFECT SAFETY

Great River Energy believes the use of UAS will have a beneficial impact on our Company vision,

mission, and triple bottom line which in turn benefits the public interest of our members.

Great River Energy's vision is to keep cooperative energy competitive. Our mission is to provide

member-owners with affordable, reliable energy in harmony with a sustainable environment. In

order to execute this mission, Great River Energy has adopted a decision-making formula that

gives equal importance to our three highest priorities" affordable rates, reliable service and

environmental stewardship---it's called our triple bottom line.

GRE believes the use of current UAS technology will immediately provide a positive impact to

our triple bottom line as outlined in the three points below. These positive impacts will in turn

benefit the more than 28 member co-operatives and 650,000 consumer members we serve.

UAS impact on affordable rates

- Improve system reliability by aiding in preventative and predictive maintenance of

energy infrastructure.

- Reduce response time and assessment of damaged infrastructure

- Improve safety of employees, reducing lost work due to injuries

- Improve environmental monitoring and awareness

UAS impacts on reliable service

- Preventative and predictive maintenance of energy infrastructure.

- Reduce response time and accelerated assessment of damaged infrastructure.

UAS Impacts on environmental stewardship

- Improve environmental monitoring and awareness
- Potential to monitor water discharge temperatures for steam power plants.

- Identify wildlife nesting locations on energy infrastructure to mitigate impacts.

Every decision we make as an organization is carefully evaluated and held up to these three

standards by working to balance each. The use on UASs will be no different. GRE believes the

UASs will become one more valuable tool used in achieving our vision of keeping cooperative

energy competitive.

All proposed activities to be conducted by sUASs operated by GRE under a granted Section 333

exemption request are currently being conducted via other means. FAA's approval of our

request will allow GRE to perform activities in a safer way. Where inspections at heights

previously would have required individuals with lanyards to be secured and climb to heights,

the UAS will now be able to complete such inspections from a position of safety. Where

manned aircraft may have been previously engaged to conduct aerial inspections and data

collections, sUAS will now provide safer operations for all personnel.

SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed"

APplicant seeks an exemption from the following rules:

14 C.F.R. § 21, subpart H, 14 C.F.R 45.23 (b), 14 C.F.R. §§ 61.113 (a) & (b), 91.7 (a); 91.9 (b)(2);

91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a)and (b); 91.405 (a); 91.407 (a)(1);

91.409 (a) (2); 91.409 (a) (1) & (2) and 91.417 (a) & (b) to operate commercially small

unmanned aircraft systems (55 Ibs. or less) in aerial photography, videography, aerial

inspections, surveying and mapping and any other aerial data collection operations.

Approval of exemptions allowing commercial operations of sUASs in the aerial photography,

videography, aerial inspections, surveying and mapping and other aerial data collection

operations industries will enhance safety by reducing risk. Conventional aerial photography,

videography, aerial inspections, surveying and mapping and any other aerial data collection

operations, using jet or piston power aircraft, operate at extremely low altitudes and in

extreme proximity to people and structures; and present the risks associated with vehicles that

weigh in the neighborhood of 4,000 Ibs., carrying large amounts of jet A or other fuel. Such

aircraft must fly to and from the aerial photography, videography, aerial inspections, surveying

and mapping and aerial data collection operations inspection locations. In contrast, a sUASs

weighing fewer than 55 Ibs. and powered by batteries eliminates virtually all of that risk given

the reduced mass and lack of combustible fuel carried on board. The sUASs are carried to the

aerial photography, videography, aerial inspections, surveying and mapping and aerial data

collection operations sites and not flown. The sUASs will carry no passengers or crew and,

therefore, cannot and. will not expose them to the risks associated with manned aircraft flights.
The operation of sUASs, weighing less than 55 Ibs., conducted in the strict conditions outlined

above, will provide an equivalent level of safety supporting the grant of the exemptions

requested herein, including exempting the Applicant from the requirements of Part 21 and

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the

ground, and in a sterile environment and, as a result, are far safer than conventional operations

conducted with turbine helicopters or other manned aircraft operating in close proximity to the

ground and people.

Satisfaction of the criteria provided in Section 333 of the Reform Act- size, weight, speed,

operating capabilities, proximity to airports and populated areas and operation within visual

line of sight and national security- provide more than adequate justification for the grant of

the requested exemptions allowing commercial operation of Applicant's sUASs in the aerial

photography, videography, aerial inspections, surveying and mapping and any other aerial data

collection operations industries pursuant to the Safety Checklist appended hereto.

Respectfully Submitted on behalf of Applicant,

GREAT RIVER ENEMY

Kyle A Leier-Sr. Engineering Project Manager

Encs." DJI Inspire User Manual, DJI Phantom User Manual, senseFly eXom User Manual,

GRE Safety Checklist and Operating Procedures