### August 10,2015

U.S. Department ofTransportation Docket Management System 1200 New JerseyAve, SE Washington, DC 20590

Re: Exemption Requestunder Section 333 ofthe FAA ReformAct and Part 11 ofthe Federal Aviation Regulations Dear Sir orMadam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, Westar Energy, Inc. ("Westar Energy") the operator ofan Aeryon SkyRanger and/orAltus UAS Delta X-8 ("sUAS" or "SkyRanger" or "Delta X8"), seeks an exemption from the FederalAviation Regulations ("FARs") listed below and discussed in Appendix

### A. A summary ofWestarEnergy's Section 333 Exemption Request is at Appendix B. 

### Westar Energy's sUAS Operations and Safety Policy is at Appendix 

### C. Aircraft manuals will be provided upon request. The requested exemption would permitWestar Energyto conduct commercial operations ofthe SkyRanger and/or Delta X-8, which weigh approximately 61bs. and 12 lbs., respectively, and are capable ofcapturing still imagery, video and other data collection. The application for the sUAS will be aerial data collection for inspection ofutility infrastructure, property and features in furtherance ofWestar Energy's operations as an electric utility. 1

### In particular, the use ofsUAS will allow utility workers to conduct inspections withoutbeing in close proximityto high-voltage equipment or subject to the hazards ofworking height. The use ofsUAS will also facilitate the safe inspection of hard-to-access or environmentally sensitive areas without the use ofbucket trucks, helicopters, and other utility vehicles that have more environmental impact than sUAS. In addition, the use ofsUAS will be more efficient and cost effective thantraditional methods ofinspection in many instances, which will reduce operations and maintenance costs and provide a means for faster resolution ofproblems on the electric system. In short, approval ofthis request will increase electric systemreliability, decrease customer costs, and enhance worker safety.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the sUAS. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any othergathering ofdata byinstruments aboard the sUAS.

1Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level ofsafetyto currently authorized operations using manned aircraft. As described more fully below, the requested exemption would authorize commercial operations ofremote sensing using the SkyRanger or DeltaX-8, which at approximately 6 lbs. and 12 lbs., respectively, are small in size. The SkyRanger orDelta X-8 will be operated under controlled conditions at low altitude in airspace that is limited in scope, as described more fully herein. It will have automated control features, as described below. The SkyRanger or DeltaX-8 will be operated by a PIC with an airline transport, commercial, private, recreational, or sport pilot certificate who also holds a current FAA airman medical certificate or a valid driver's license. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft inwhich the PIC is rated onhis or herpilot certificate. See Appendix C. Finally, Westar Energy will comply with the airspace limitations contained within the blanket COAfor sUAS inplace for all Sec. 333 exemption holders upon issuance ofthe exemption and will apply for a separate COA inthe event it seeks to operate its sUAS beyond the parameters ofthe blanket COA. It will file NOTAMs in advance ofsUAS operations as required bythe exemption, applicable COA, regulation or the FAA. Westar Energy respectfully submits that because its sUAS, the SkyRanger and/or Delta X-8, will be used inlieu ofcomparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft, the FAA can have confidence that the operations will achieve at least an equivalent or greater level ofsafety. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAAAdministrator's) responsibilities under Section 333(c) ofthe ReformAct to "establishrequirements for the safe operation ofsuch aircraft systems in the national airspace system." The name and address ofthe applicant are: Westar Energy, Inc. Address: 818 S. Kansas Avenue PO Box 889 Topeka, KS 6660 1 Attn: Jason Klenklen Ph: 785-575-8187 Email: Jason.klenklen@westarenergy.com The regulations from which the exemption is requested are as follows: 14 C.F.R. 61.23(a) and (c); 14 C.F.R. 61.10l(e) (4) and (5): 14 C.F.R. 61.113(a) & (b):

214 C.P.R. 61.315(a); 14 C.P.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R

. 9 1. 121 ; 14 C.P.R. 91.151(a) (1); 14 C.P.R. 91.405(a); 14 C.P.R. 91.407(a) (1); 14 C.F.R. 91.409(a) (1) and (2); 14 C.P.R. 91.417(a) & (b). AppendixA discusses eachrule listed above and explains why exemptions pursuant to the proposal set forth inthis letter are appropriate, provide an equivalent level ofsafety, and are in the public interest. The FAA has previously granted Sec. 333 exemptions for commercial use ofsUAS for utility and infrastructure inspection in exemptions 11185 (Commonwealth Edison), 11238 (San Diego Gas & Electric Co.), 12040 (Burns & McDonnell Engineering Co., Inc.) and 11783 (Precision Design and Drafting, Inc.), and has approved Sec. 333 exemptions for the SkyRanger in exemptions 11112 and 11213 and others, and for the DeltaX-8 in exemption 11172A. THEAPPLICABLE LEGAL STANDARD UNDER SECTION 333 Westar Energy submits that granting ofthis exemption application for use ofthe SkyRanger and or Delta X-8 for aerial data collection will advance the Congressional mandate in Section 333 ofthe ReformAct to accelerate the introduction ofUASs into the national airspace system ("NAS") ifit can be accomplished safely. This law directs the Secretary ofTransportation to consider whether certain UASs may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretaryis required to determine which types ofUASs do not create a hazard to users ofthe NAS orthe public orpose a threat to national security in light ofthe following:

• The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximity to airports and populated areas; and • Operation ofthe UAS within visual1ine ofsight ofthe operator. The granting ofthe requested exemptionis in the public interest based on the clear direction in Section 333 ofthe ReformAct; the additional authority in the Federal AviationAct, as amended; the strong equivalent level ofsafety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost-savings associated with transitioning to UASs for aerial data collection. Accordingly, the applicantrespectfully requests that the FAA grant the requested exemptionwithout delay.

3

### The sUAS Each ofthe SkyRanger and Delta X-8 complies with the requirements set forth by Section 333 byits small size, weight, speed and limited operating area associated with the aircraft and its operations as set forth herein, in the proposed conditions ofoperation and the operating manual available upon request. As a result under this exemptionthe SkyRanger or Delta X-8 are not deemed airworthy by an airworthiness certificate, but rather they are deemed airworthy bythe operator conducting a thorough preflight ofthe aircraft. The aircraft will also be registered in accordance to 14 CFRPart 47, marked in accordance to 14 CFR Part 45 Subpart C, and accompanied by a letter ofalternative marking due to the unconventional design ofa quadcopter. Markings will be as large as practicable. The SkyRanger is the same aircraft for which the FAAhas already granted exemptions in exemptions 11112, 11209, 11213, 11239, 11259, and 11265, and the Delta X-8 is the same aircraft for which the FAAhas already granted an exemption in exemption 11172A. Aircraft Make and Model: SkyRanger Configuration: Quadcopter Aircraft Performance/Specifications: • Ground Control Station (GCS): The aircraft will be primarily controlledthrough the use ofa tablet via 900 MHz, 2.4 GHz, and 5.8GHz. • Lost Com: Aircraft will autonomously return to the launch location and safely land. • Emergency Procedure: Should the need arise the aircraft canbe commanded by the pilot in command via the tablet GCS to safely land immediately orreturn and land at the launch location. • Power Supply: Lithiumpolymerbatteries are self-containedhigh duration systems \Vith "S1-1ART" intelligence onboard. This includes cycle charge times, locations, GPS antenna, chemical management, and real-time data feeds to ensure maximum flight duration and subsystem safetyprocesses. Charging is done in the included Aeryon Battery charger and canbe charged via standard wall outlet, or via a vehicle. • Dimensions: 40 in (102 em) diameter, 9.3 in (24 em) height • Maximum Speed: 50 knots • Normal operating speed: Less than 30 knots • Weight without payload: 5.3 lbs. • Maximum weight with payload: 6.6 lbs. • Security: Secure networkpairing, AES 256 bit encryption Aircraft Make and Model: Delta X-8 : Configuration: Quadcopter

4

### Aircraft Performance/Specifications: • Wingspan (propellers fitted) 140cm (50") • Motors 8 x 400kV • Propellers 18" diameter • Battery type Lithium Polymer (LiPo) 6S, 22V, 16,000mAh, LiPo 6S, 22V, 16,000/22,000mAh • Empty Weight 5.5kg (12lb) • Take OffWeight 9.5kg (2llb) • Maximum Take OffWeight 22.5kg (49lb) • Flight Specifications (UnderAutopilot at TOW) • Max climb rate 2 m/s • Max descent rate 2 m/s • Maximum speed 12 m/s • Endurance 12-15 minutes 

### • Command and 

### ControlFrequency • • 2.4Ghz (Spectrum DSMX modulation) • Telemetry (Wi-Fi) 2.4Ghz (meets Directive 1999/5/EC specs) • Telemetry (Data link) 915-928Mhz FHSS (complies with AS/NZS 4268:2012) 

### • Failsafe's • 1. Automatic Returnto Home on C&C FailureAutomatic Parachute deployment at 70 degrees ofroll • 2. Automatic Parachute deployment onviolent shake state • 3. Dual AP, GPS and IMU for comparison checks X-8: Motor redundancy configuration Aircraft manuals will be provided upon request. 

### OperatorRequirements The PIC will have an airline transport, commercial, private, recreational, or sportpilot certificate and will also hold a current FAA airman medical certificate or a valid driver's license. The PIC will also meet the flight review requirements specified in 14 CFR 

### § 61.56 in an aircraft in which the PIC is rated on his or herpilot certificate and will complete sUAS flight training as specified in

### Appendix C. Operations will be conducted in a manner consistent with this exemption, including evasive and emergency maneuvers while maintaining appropriate distances from persons, vessels, vehicles and structures.

5Proposed Operating Conditions Westar Energy agrees to be bound bythe following conditions for flight operations.

• Operations will occur over utility right ofway orpermission from landowner will be obtained before commencing flights. • Operations will only occur during Visual Meteorological Conditions (VMC) under Visual Flight Rules (VFR). • Operations will not occur 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. • The sUAS will remain clear ofmanned aircraft and yield right ofway. • A flight test will be conducted after any major repair or alteration. • A preflight check will be conductedbefore each flight to assure the sUAS is in a condition for safe flight. • Aircraft will remain within Visual Line ofSight (VLOS) ofthe operator. • All operations will be conducted with a Visual Observer (VO). • Operations will be conducted from sunrise to sunset. • Operations will be concluded \vith no less than 25% battery power remaining. • Operations will not exceed 400 feet AGL. • Operations will not occur within 5 nautical miles ofany airport unless a letter of agreement with that airport's management is obtained. • Operations will take place under a COA. • The operator will be responsible for maintaining and inspecting the sUAS to ensure that it is in a condition for safe operation. • Operator will follow the sUAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements and safety bulletins for the aircraft and aircraft components. • The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the sUAS in a manner consistent with how the sUAS \Vill 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 

### § 61.5l(b). The VO is also required to complete the operator's training requirements

.A record oftraining must be documented and made available upon request bythe Administrator. Flights for the purposes oftraining the operator's PICs and VOs (training, proficiency, and experience-building), are permitted under the terms ofthis exemption. However, training operations may onlybe conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the sUAS with appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91

. 119

6• All non-participants will keep 500 feet away from operations unless there are adequate barriers to protectthem. • All operations will be conducted according to the manufacturer's manuals. • All documents that will be kept at the GCS include but are not limited to: the aircraft manuals, maintenance logs, aircraft registration, grant ofexemption, and COA. • sUAS will not be operated at a speed exceeding 87 knots (100 miles perhour) and in no case at airspeeds greater than the maximum operating airspeed recommended bythe aircraft manufacturer. • The sUAS will autonomously return to the launch location and safely land in the event ofloss ofcommunication and control. • The sUAS will be registered in accordance to 14 CFR Part 47, marked in accordance to 14 CFRPart45 Subpart C, and accompanied by a letter of alternative marking due to the unconventional design ofa quadcopter. Markings will be as large as practicable. • The sUAS will notbe operated bythe PIC from any moving vehicle or device. • Anyincident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COAmust 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: www.ntsb.gov. Public Interest Consistent with the requirements of 14 C.F.R. §11.8l(d), Petitioner offers the following reasons why granting this petition for exemption is in the public interest, i.e., how granting it would benefit the public as a whole. Approval ofthis exemption allowing commercial operations ofsUAS for aerial data collectionbenefits the public as a whole inthe following ways:



### • It helps fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act, namely, the FAAAdministrator's assessment ofwhether certain UAS may operate safely in the NationalAirspace System before completion ofthe rulemaking requiredunder Section 332 ofthe ReformAct.

• The operation significantly improves safety and reduces risk byalleviating human exposure to danger associated with current aerial remote sensing methods, namely, full size helicopters. Reducing human exposure to death or serious injury associated with manned aircraftperforming these tasks furthers the public's interest.

• Petitioner's sUAS is batterypowered and creates no emissions. IfPetitioner's sUAS crashes, there is no fuel to ignite and explode. Any impact ofPetitioner's

7lightweight sUAS is far less than a full size manned aircraft. The public's interest is furthered byminimizing ecological impact ofan accident and byreducing human exposure to potentiallyharmful emissions associated with manned aircraft.

• Aerial data collectionby sUAS is a valuable tool for mapping, real estate, insurance evaluations, and industrial inspection. However, problems with safety, cost, statistical integrity, and logistics impede aerial data collections from conventional manned aircraft. The use ofsUAS addresses these problems and is a powerful tool for performing a wide-range ofaerial data collection applications. Thepublic as a whole will benefit from the safer and more cost-effective aerial data collection services that sUAS operations provide. Privacy Westar Energywill not operate sUAS in any way that may invade personal privacy and will comply with any federal, state, or local privacy laws that may apply in areas where Westar Energy operates sUAS. In addition, as a practical matter, flights will occur over utilityproperty or utility right ofway or with landownerpermission, so privacy is unlikely to be a concern inrelation to Westar Energy's proposeduse. Conclusion Westar Energy seeks an exemption from the FARs set forth above and in Appendix A to allow commercial operations ofsUAS to conduct aerial data collection. Approval ofthis exemption allowing commercial operations ofthe Sky Ranger and/or Delta X-8 for aerial data collection will enhance safetybyreducing risk. Conventional aerial data collection operations, using turbine orpiston-powered aircraft present risks associated with vehicles that can weigh 5,000 to 7,000 lbs., or more, carry large quantities offuel, passengers, and, in some cases, cargo. In contrast, a Sky Ranger and/or Delta X-8 weighing approximately 6 lbs. and 49 lbs., respectively, and powered by batteries eliminates a great portion ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The SkyRanger or Delta X-8 will carryno passengers or crew and, therefore, will not expose any individuals to the risks associated with manned aircraft flights. Additionally, no national securityissue is raised bythe grant ofthe requested exemptions due to all pilots being certified through the FAA. The operation ofthe SkyRanger and/or Delta X-8, weighing approximately 6 lbs. and 12 lbs, respectively, for aerial data collection in accordance with the conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein.

8

### The SkyRanger's and Delta X-8's satisfaction ofthe criteria set forth in Section 333 of the ReformAct-size, weight, speed, operating capabilities, lack ofproximity to airports, operation within visual line ofsight, and national security-and its showing ofan equivalent level ofsafety stronglyjustifies the grant ofthe requested exemptions allowing commercial operation ofthe SkyRanger and/or Delta X-8 for aerial data collection.



# ~ Jason Klenklen Supervisor, Transmission Maintenance

9APPENDIXA: EXEMPTIONREQUEST**Al~D** EQUIVALENT LEVELOFSAFETYSHOWINGS UNDERAPPLICABLE RULES SUBJECTTO EXENIPTION Westar Energyrequests an exemption from the following regulations, all of\Vhich have been granted by every approved Section 333 exemption at the time ofthis submission. 14 C.F.R. §§ 61.23(a) and (c), 61.10l(e) (4) and (5), 61.113(a) and 61.315(a): Pilot in commandrequirements. The FAA has recently determined that the PIC requirements for Section 333 exemptions for commercial operation ofsUAS are met by a PIC who has an airline transport, commercial, private, recreational, or sport pilot certificate and will also hold a current FAA airman medical certificate or a valid driver's license. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated onhis orherpilot certificate. See eg. ExemptionNo. 11238 (SanDiego Gas & Electric Co.) and ExemptionNo. 12040, (Bums & McDonnell Engineering Co., Inc.) Westar Energy requests the same decision by the FAAwithrespect to its request for exemption ofthe above referenced FARs regarding the PIC requirements. Equivalent Level ofSafety Currently, there are no applicable areas identified for sUAS in either the private or commercial sector and therefore an exemption is required to conduct commercial operations. As flight operations will be conducted in a restricted environment as described in the operations section, these strict guidelines will achieve an equivalent level ofsafety for each individual flight especially when compared to commercial flights identified in Part 61 when originally developed. 14 C.F.R. § 91.7(a): Civil AircraftAirworthiness Petitioner seeks an exemption from 14 C.P.R.§ 91.7(a), whichrequires that a civil aircraft be in airworthy condition to be operated. Inasmuch there will be no airworthiness certificate issued for the sUAS, shouldthis exemption be granted, no FAAregulatory standardwill exist for determining airworthiness. Equivalent Level ofSafety Given the size ofthe SkyRanger and/or Delta X-8 andthe preflight procedures including the review ofmaintenance logs and preflight checklists, an equivalent level ofsafety will be provided to assure the aircraft is in an airworthy condition. The FAAhas previously determined that an operator ensures that its aircraft is in an airworthy condition based upon compliance withthe operating documents. 14 C.F.R. § 91.119(c): Minimum SafeAltitudes

10Petitionerrequests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c) which states that aircraftmay not operate closer than 500 feet above the surface and away from anyperson, vessel, vehicle, or structure in non-congested areas. To provide the intended operations, the sUAS is operated below 400 feet AGL. Equivalent Level ofSafety Compared to flight operations with rotorcraft weighing far more than the approximately 6 lbs. and 12lbs. proposedherein, and given the lack offlammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. 

### An equivalent level ofsafety will be achieved given the size, weight, and speed ofthe UAS, as well as the location where it is operated. As set forth in the operations section of this exemption, the sUAS will be operated at least 5 nautical miles away from airports (unless a letter ofagreement from the airport's management is obtained), where buildings andpeople will not be exposed to operations without theirpre-obtained consent. Because ofthe advance notice to theproperty owners andparticipants, all affected individuals will be well aware ofthe planned flight operations. 14 C.F.R. § 91.121: Altimeter Settings Petitionerrequests an exemption from 14 C.F.R. 

### § 91.121 which requires a person operating an aircraft to maintain cruising altitude or flight level byreference to an altimeter that is set to the elevation ofthe departure airport orbarometric pressure. An exemption is required because the sUAS does not have a barometric altimeter, but rather a GPS altitude read out. Equivalent Level ofSafety An equivalent level ofsafety will be achievedbythe operator confirming the altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to constantlymonitor the sUAS's height, thus ensuring operation at safe altitudes. 14 C.F.R. 

### § 91.151(a) (1): Fuel Requirements for Flight 

### inVFR Conditions Petitioner requests an exemption from 14 C.F.R. § 91.151(a)(l)'s fuel requirements for flight inVFR conditions during the day. Section 91.151(a)(1) states: (a) No person may begin 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 intendedlanding and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes;

11Here, the batterypowering the sUAS provides power lasting less than the 30 minutes reserve requirement in 14 C.F.R. 

### § 91.151, and thus sUAS flights couldnot be conducted. Given the limitations onthe sUAS's proposed flight area andthe location ofits proposed operations within a predetermined area, a safetymargin based on a reserve amount of battery life is needed. Equivalent Level ofSafety An equivalent level ofsafety will be achieved because the operations will be conducted on-site without significant transit time by the sUAS. All flights will beplanned to be terminated with no less than 25% reserve battery power still available. This restriction would be more than adequate to return the sUAS safelyto the ground and its planned landing zone from anywhere in its limited operating area even in the event ofan unexpected occurrence. Operation ofthe sUAS with less than 30 minutes ofreserve fuel does not include the type ofrisks that Section 91.151(a)( 1) was intended to alleviate given the size and speed ofthe small sUAS, and the proximity ofthe flight operation to the landing zone. 14 C.F.R. § 91.405(a), 91.407(a) (1), 91.409(a) (1) and (2); 91.417(a) and (b): Maintenance Inspections Petitioner also seeks an exemption from the maintenance inspection requirements contained in 14 C.P.R.§ 91.405(a), 91.407(a) (1), 91.409(a) (1) and (2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.P.R. § 91.405(a) (stating that each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed 

### in subpart E ofthis part and shall betweenrequired inspections

...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed because Part 43 and these sections only applyto aircraft with an airworthiness certificate, which the sUAS will not have. Equivalent Level ofSafety An equivalent level ofsafety will be achievedbecause the operator will ensure that the sUAS is in working orderpriorto initiating flight by following the preflight checklist, performrequired maintenance, and keep a log ofany maintenance performed. The operator is the person most familiar with the aircraft andbest suited to maintain the aircraft in an airworthy condition.

12APPENDIXB: SUMMARY OF WESTAR ENERGY SECTION 333 EXEMPTION REQUEST Westar Energyherebyprovides pursuantto Part 11 a summaryofits exemption application to allow commercial operation of the Aeryon SkyRanger and/or Altus UAS Delta X-8 unmanned aircraft for aerial data collection in connection with utility and infrastructure inspection. An exemption is requested from the following regulations: 14 C.F.R. 61.23(a) and (c); 14 C.F.R. 61.10l(e) (4) and (5); 14 C.F.R. 61.113(a) & (b); 14 C.P.R. 61.315(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.15l(a) (1); 14 C.P.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) & (b). Approval ofthe exemptionrequested bythe petitioner will allow commercial operation ofthe SkyRanger and/or Delta X-8 for the purpose ofutility and infrastructure inspections nationwide as conditionedby applicable COA. The requested exemption should be granted because operation ofsmall sUAS, such as the SkyRanger or Delta X-8 weighing approximately 6 pounds and 12lbs, respectively, conducted in the conditions outlinedbelow will provide an equivalent level ofsafety, while still allowing commercial operations. The lightweight aircraft coveredby the exemption is far saferthan conventional operations conducted with manned aircraft weighing thousands ofpounds, carrying highly flammable fuel, and operating in close proximity to the ground and people. The factors the FAA is required to consider when approving Section 333 exemption petitions- size, weight, speed, operational capability, proximityto airports, proximity to populated areas, and operation within visual line ofsight

- each support the request. Boththe Sky Ranger and DeltaX-8 are small and operate at slow speeds, close to the ground. The increase in safety, decrease ofrisk to human life andproperty, coupled withthe low riskuse ofsUAS to conduct these operations, weighheavily in favor ofgranting the exemption.



### 13APPENDIXC: WESTARENERGY's sUAS OPERATIONSAND SAFETY POLICY 

### Operator Requirements To operate a UAS under this exemption, the pilot in command (PIC) PIC will have an airline transport, commercial, private, recreational, or sport pilot certificate and \Vill also hold a current FAA airman medical certificate or a valid driver's license. The PIC 

### ·will also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his orherpilot certificate and training as defined below

. Flight training to include, but not limited to:

• 25 total hours as a UAS rotorcraft pilot including;

• 10 hours logged as a UAS pilot-in-command ofa multi-rotor UAS,

• 5 hours in the specific make and model ofthe UAS, and

• At least 3 take-offs and landings within the preceding 90 days 

### Operating Procedures Preflight Checklist AREACHECKS DDRecord Day, Date and Time: S M Tu \V Th F S , 20 at AM/PM DDCheck weather conditions (visually or via radar or\Vebsite) to confirm that no adverse weather conditions are expected 0 D Record current weather conditions to best estimate: Rain inArea? YES orNO Current Temperature= F (must be between 20°Fand95°F) Current\Vind Conditions = mph (must not exceed20 mph) Current\Vind Gusts= mph (must notexceed25 mph) Current Visibility= miles (must be 1 mile orgreater) DClConfirm that no otherUAS are flying in vicinity that may create signal interference 0 DRecord class ofairspace from sectional chart orvfrmap.com: Class (no operations in Class B, C, orD w /

out COA approval) 0 DNote the proximity ofnearest airport from sectional chart or vfrmap.com:

_____ _ miles IJ CJVisually survey the flight area, note any obstructions that could behazardous during flight: o Trees o Cell Towers o Flags I Light Posts o Low Clouds o Birds o Power Lines o Sun Glare o High Voltage Lines o Wind Turbines o Other: CJ D PIC evaluation ofwhether candidateArea ofOperation constitutes a congested area, a denselypopulated area, or an area over an open air assembly ofpersons: YES orNO (operations

14cease 

### if"yes ") 0 0 Identification ofalternate or emergencylanding spots: UASCHECKS D0 Ensure UAS is placed on a flat area for takeoff 0 DEnsure batteryhas beeninspected for signs ofdamage orleakage and considered satisfactory for flight 0 DCheckthat UAS batteryis fully charged 0 OVerifythat the flight batteryis fully installed 0 0 Set up remote controls/monitoring devices LJ llRemove gimbal clamp and lens cap from UAS, ifappropriate CJ [JInspectpropellers, gimbal, camera, and remote controller for any signs ofdamage 0 DVerifythat the micro SD card has beenproperly installed into memory slot, ifappropriate POWERING UP 0 OFollow respective user manuals for powering, linking, calibrating, and takeoffprocedures of the UAS STARTINGMOTORS 0 DAnnounce "CLEAR!" and make sure no one is within 5 ft ofUAS before it is powered up DOConfirm all propellers are spinning smoothly and at approximately the same rotational speed 0 DIs UAS deemed safe for flight bythe PIC? YES orNO (operations cease 

### if"no '') c::J CGPS position set END OFFLIGHT DOLand UAS 0 OTum offpower to the UAS 0 DPlace gimbal clamp back onto camera, and lens cover on camera lens, ifappropriate 0 OTum offpower to remote control 0 DRecord time that motors were turned offon copter:

______ _ 0 0 Record maximum height during flight: feet D0 Secure theUAS in a case, vehicle, or structure 

### Flight Conditions

• The UAS will weigh less than 55 lbs. • The speed ofthe UAS will not exceed 87 knots, or the manufacturer's suggested maximum speed, whichever is less. • All operations will be conducted with aVO. • The UAS will be operated in PIC's and/orVO's VLOS at all times. • PIC and VO will be in direct verbal contact during flight. • The UAS will not be operated at night. Operations will only occur during daytime VMC. • The UAS will not be operated from a moving vehicle or device, except as permitted from a boat orother water craft. • Flights will be operated at an altitude ofno more than 400 feetAGL.



### 15• Landowner consent prior to flight ifWestarEnergy does not own orhave rights ofaccess to property. • Operations will not occur less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibilityis less than 1 statute mile from the PIC. • The UAS will remain clear ofmanned aircraft and yield right ofway. • A flight test will be conducted after any major repair or alteration. • Operations will be concluded, and the UAS will be safely landed, with no less than 10% batterypowerremaining orthe manufacturer's recommendedbattery power remaining, whichever is more. • Minimum operational standoffdistances for nonparticipatingpersons, vehicles, and structures will bekept. • Operations will not occur within 5nm ofany airport unless a letter ofagreement with that airport's management is obtained or otherwise permittedby a COA issued to the exemption holder. • Operations will take place under and in accordance \vith an applicable COA. • The operator will beresponsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. • Operator will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements and safety bulletins for the aircraft and aircraft components. • All non-participants will keep an appropriate distance from operations unless there are adequate barriers to protect them. • All operations will be conducted according to the manufacturer's manuals. • All documents that will bekept at the Ground Control Station include but are not limited to; the aircraft manuals, maintenance logs, aircraft registration, grant ofexemption, and COA. • The UAS will beregistered in accordance to 14 C

.F.R. Part 47, marked in accordance to 14 C.F.R. Part 45 Subpart C, and accompanied by a letter ofalternative marking due to the unconventional design ofa quadcopter. Markings will be as large as practicable. • A GPS receiver will be used to determine and set altitude. • Takeoffand landing procedures will be conductedbased on stipulations in UAS's User Manual. • A preflight checklist will be completed in order to ensure the conditions are safe for flight. • A NOTAM will be filed prior to flight, as required. Logs and Records

• PICs will maintain a flight logbook to record all flights, including training. • A flight logbook will be kept to record all flight time for each aircraft. • Maintenance logbook will bekept for each UAS. • Maintenance and inspections w ·ill be completed based on manufacturer's recommendation. • All maintenance performed will be logged in this Maintenance Log

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16Emergency Procedures

• In the event ofan emergency, immediatelyland UAS at location that does not create an additional hazard. Examples ofpossible emergencies: loss ofcommunication, loss ofVLOS, critically lowbattery, battery fire, wind gusts, motor failure. • Utilize return to home feature in the event ofan emergency orunpredicted obstacle, ifnecessary and available. • Any damage or injury must be reported to the PIC's immediate manager within 12 hours ofevent. Safety Procedures

• Reportunplanned events, including near misses, hazard observation, or accidents that could or did harmpersonnel, equipment, property or environment. Report within 12 hours ofincident. • Any incident, accident, orflight operation that transgresses the lateral or vertical boundaries ofthe operational area as definedbythe applicable COAmust 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 onthe NTSB Web site: www.ntsb.gov

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