September 12, 2014 

Petition for Exemption concerning operation of San Diego Gas & Electric Company 

Unmanned Aircraft System in accordance with Section 333 of the FAA Modernization and 

Reform Act of 2012 

Registered Owner Name: 

San Diego Gas & Electric Company 

Registered Owner Address: 

101 Ash Street 

San Diego CA 92101 

Aircraft Description: 

IYertical Take Off and Landing (VTOL) 

s UAS 

Aircraft Registration/Serial Number: 

N500VD/ MK2GEN2-00005 

N544L/ MK2GEN2-00004 

Aircraft Builder: 

Physical Sciences Inc. 

Year Manufactured: 

2013 

Aircraft Model Designation: 

InstantEye Mk-2 Gen2 

Engine Model: 

Mk-2 Gen Brushless Motor 

Propeller Model: 

PSI 7 x 5 Pusher 

1. Overview. 

San Diego Gas & Electric Company (SDG&E) is a regulated public utility that provides safe and 

reliable energy service to 3.4 million consumers through 1.4 million electric meters and 861, 000 

natural gas meters in San.Diego and southern Orange counties. SDG&E's service area spans 

4,100 square miles. SDG&E is committed to providing safe, reliable infrastructure and services 

that allow our communities to grow and prosper. Key areas of focus for SDG&E are public 

safety, restoring outages in a safe and timely manner and creating new methods enabling our 

customers to save energy every day. 

SDG&E's electric transmission system delivers energy to both San Diego and Orange Counties 

in California, which provides electricity to 3.4 million SDG&E customers. The electric 

transmission system is regulated by the Federal Energy Regulatory Commission. Presidential 

Policy Directive 21 identifies the Energy Sector as uniquely critical because itprovides an 

"enabling function " across all critical infrastructure sectors. 

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

Airworthiness Certificate in the Experimental category, for the InstantEye small Unmanned 

Aircraft System (s UAS). This will allow SDG&E to perform research, development, and training, 

in a sparsely populated area in Eastern San Diego County. SDG&E is the first utility in the 

nation to be granted FAA approval for this technology. To further the SUAS program, provide 

benefits of this new technology to our customers, and increase the safe operation of its electric 

grid, SDGE is requesting an exemption arnder Section 333 of the FAA Modernization and Reform 

Act. 

Enclosure (1) will include proprietary information✓confidential material for this exemption and 

will be sent via a separate correspondence. 

Page 1 of 12 
September 12, 2014 

2. Approved Exemptions. 

a. § 91.9 (b)(2) and 91.203 (a) and (b). FAA letter datedApril 1, 2014, exemption No. 

10968, Regulatory Docket No. FAA-2013-1127, grants an exemption to allow 

SDG&E to operate the InstantEye without carrying and displaying an airworthiness 

certiftcate, registration flight manual, and any other required documentation 

onboard the aircraft. All required paperwork will be located at the ground control 

station. (See page I of approved exemption, below. The full exemption will be 

submitted as an Enclosure (2) with this request.) 

Lr n 

US.DepartlMDl 8001MepeiMence Ave. S W 

otTfanSpOftOI1C(1 Wazhingion. DC.20591 

Federal Avlation 

AdrrJolstration 

April l, 2014 

Exemption No. 10968 

Regulatory Docket No. FAA-2013-1127 

Mr. Dallas Cormier, SD1173 

San Diego Gas & Electric, Sempra Energy 

101 Ash Street 

San Diego, CA 92101 

DearMr. Cormier 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letters dated December 20, 2013 and January 14, 2014, you petitioned the Federal 

Aviation Administration (FAA) on behalf of San Diego Gas & Electric (SDGE) for an 

exemption from §§ 91.9(b)(2) and 91.203(a) and (b) of Title 14, Code of Federal Regulations 

(14 CFR). That exemption would allow SDGE to operate the InstantEye IvIK-2 N544L and 

N500VD unmanned aerial vehicles (UAVs) without canying and displaying the airworthiness 

certificate, registration, flight manual, and any other required documentation onboard the 

aircraft. You requested that all required paperwork be located at the ground control station or 

within close proximity to the pilot in command. 

The FAA has determined that good cause exists for not publisbing a summary of the petition 

in the Federal Reeister because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to SDGE. 

The FAA has issued grants of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 8607 (copy enclosed), the FAA 

found it unnecessary to carry and display the airworthiness, certification, and registration 

documents in unmanned aircraft systems (UASs) and UAVs for the operations described by 

the petitioner. The original intent of the subject regulation was to display the airworthiness, 

AFS-14-084-E 

Page 2 of 12 
September 12, 2014 

b. § 91.9(c) exemption. FAA letter dated Jan 07, 2014, from AIR-230, grants an 

exemption for alternative markings per Title 14 of the Code of Federal Regulation 45. 

See below, this exemption will be submitted as Enclosure (3) with this request. 

2- C~ 

U.S. Uepatment 

of Tronspalalbn - 

redoral Aviatlon 

Admktbtratlon 

80e IndepentlenceAve. SW 

Washln9ton, DC 2e591 

JAN 0 7 2q14 

Mr. Dallas Cormier 

SunDiego Gas C: Glcctric 

Sempm Energy 

101 A.sh St. 

San Diego, CA 92101 

Dear Mr. Cormier: 

77iank you for your letter dated December 28, 2013, requesting approval for a different 

marking procedttre for San Diego Gas and Electric's In.stantEye Mk-2 Gen 2 umnanned 

aircraft. Title 14 of the Code of Federal Regulations 45.22(d), Exhibition, antique, and other 

aircraft: Special rules, pennits persons to apply to the Administrator for a different marking 

procedure if it is impossible to mark an aircmft per §§ 45.21 and 45.23 through 45.33. 

Your request for altemative Tnarking has been reviewed. You arc hereby authorized to identify 

your InstantEye Mk-2 Ge» 2 unmanned aircralt with the following marking. Place the word 

"EXPERIMEN'I Al," on llte top of the main body of the aircraft in letteong at least %z inches 

high. 

This marking proc-edure applies to all San Diego Gas and Electric InstatTtEve Mk-2 Gen 2 

unmanned aircrafl of the same configuration for which future certi6eation tnay be requested. 

The following must be kept with the ainvorthiness certificate: 

• A copy of your original request letter; and 

• A copy ofthis response letter. 

If you have any questions, plfv<tse contact the Airworthiness Certification Branch, AIIi-230, at 

(202)385-6346. 

Sittcerely, 

James D. Seipel 

Manager, Production and Ainvorthiness Uivision 

Page 3 of 12 
September 12, 2014 

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

a. § 91.7(a) Civil Aircraft Airworthiness: No person shall operate a civil aircraft 

unless it is in an airworthy condition. On June 25, 2014, the FAA granted 

SDG&E a Special Airworthiness Certificate in the Experimental category. During 

this process the aircraft was proven to be in an airworthy condition and safe for the 

public. In addition, the InstantEye has been proven airworthy and received 

Certification with ZISArmy Special Operations Command. (Air Worthiness Release, 

AWR# IEMK220130521; see page I ofAWR below. Full AWR will be submitted as 

Enclosure (4) with this request.) 

DEPARTMENT QF THE ARMY 

~ US ARMY RESEARCH, DEVELOPMENT AND ENGINEERING COMMAND 

AVIATION AND MISSILE RESEARCH, DEVELOPMENT, AMD ENGINEERING CENTER 

6400 FON/LER RD 

REDSTONE ARSENAL, AL 356983009 

RDMR-AEV AWRIEMK220130521 21 May 2013 

MEMORAiVDUM FOR: Chief, of Staff, Army Special Operations 

Avintion (ARSOA), 2929 Desert Storm Drlve, Fort Bragg, NC 283 1 0-91 10. 

SUBJECT: Airworthiness Release (AWR) for Operation of UAS quad-rotor Instant Eye 

known as [EMK2 Gen2 and Gen3 ('ITl 123556). 

1. Scope: 'rhis memorandum constitutes a Qualification Level 3 Airworthiness Release 

(ASVR) for the IEMK2 Gen2 and Gen3 to Army G-3 UAS Program Manager for operations in 

activc restricted airspace, in accordance with "Memorandwu of Agreement for Operation of 

Unmanned Aircratt Syslems in the Netional Airspace System" (Appendix D-4) and Combal 

Operations. 

2. Validity: This Airworthiness Release (AWR) terminates 30 May 2015 or upon change in 

configuration of the subject equipment, or upon issuance of a later ANR; tivbichever occurs 

ftrst. This AWRapplies to IEMK2 Gcn2 and Gen3UAS aircraft with the following 

inlerchangeable payloads 1.) IR Illununation 2.) Thermal Imaging and 3.) Ejector Rack that 

are owned and/or operated by the ARSOA. 

3, Appendices: 7his tnemorandum and its appendices shall be briefed to flight crew prior to 

flight opezations, cerried in the log books and present in controlling Gmund Control Station 

(GCS). 

Appendix A- Restrictions and Operating Infomtation 

Appendix B— Configuration and Installation Detail 

Appendix C- Inspections, Maintenance, and Logbook Listructions 

Appendix D - Refcrcnce List 

4. The points of contact OC) ar 

irector 

4Aviation Engineering 

FOROFFICIALUSEONLY . 

PnXHm 19YquW Vapv 

Page 4 of 12 
September 12, 2014 

b. § 91.109 (a) Flight Instruction: 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. The InstantEye does not have dual controls; 

instead the InstantEye has a fully functioning Ground Control Station (GCS). (See 

figure 2) When flight instruction is performed, no pilots will be on the aircraft and 

the GCS will be a safe distance from the InstantEye and the public, causing no safety 

hazard. 

Furthermore, as per SDG&E Standard Practice #0002, small Unmanned Aircraft 

System Training Procedures, all future operators will complete a thorough 2 day 

training course to show proficient knowledge of the InstantEye before they take 

control of the GCS without supervision. Enclosure (1) will include proprietary 

information/confidential material for this exemption and will be sent via a separate 

correspondence. 

c. § 91.113 See and Avoid: Method for See-and-Avoid (§ 91.113). When weather 

conditions permit, regardless of whether an operation is conducted under 

instrument flight rules or visual flight rules, vigilance shall be maintained b,y 

each person operating an aircraft so as to see and avoid other aircraft. The sUAS 

is strictly line of sight and will always be in constant contact with the operator and 

visual observer. See and Avoid will be conducted by the operator and vigilance shall 

be maintained by each operator so as to "see and avoid" any other aircraft. 

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

Procedures, vfsual observers will be qualified and understand the rules and 

responsibilities described in § 91.111 (Operating near other aircraft), § 91.113 

(Right-of-way rules: Except water operations), and § 91.155 (Basfc VFR weather 

minimums). There will be no adverse impact to the public because each visual 

observer will be fully qualified. 

d. § 91.119 Minimum Safe Altitudes, no person may operate an aircraft below the 

following altitudes: Over other than congested areas. An altitude of 500 feet 

above the surface, except over open water or sparsely populated areas. Due to 

the height of SDG&E assets, powerlines, poles, towers, equipment, the s UAS will fly 

~ 

in restrfcted airspace designated by 14 CFR 91.119, which is not normal operating 

airspace for civilian and commercial aircraft. 

Thts will pose no risk to the public because aircraft are not operating in these 

restricted areas. 

Enclosure (1) will include proprietary information/confidential material for this 

exemption and will be sent via a separate correspondence. 

Page 5 of 12 
September 12, 2014 

e. § 91.121 Altimeter settings: Each person operating an aircraft shall maintain the 

cruising altitude or fight level of that aircraft, as the case may be, by reference 

to an altimeter that is set to the appropriate station. The InstantEye sUAS uses 

baraalt pressure but does not program in an altimeter setting. The altitude is 

monitored by the Pilot In Command and constantly watched by the visual observer. 

This exemption will benefit the public because the visual observer and operator are 

visual line of sight at all times, and will not pose any risk to the public. 

f. § 91.151 (b) Fuel requirements for flight in VFR conditions: No person may 

begin a flight in a rotorcraft under VFR conditions unless there is enough fuel to 

fly to the first point on intended landing and, assuming normal cruising speed, 

to fly that for at least 20 minutes. The sUAS is battery operated with a maximum 

flying time of 20 to 30 minutes. However, this poses no safety risk because the takeoffpoint is also located at the landingpoint and will cause no safety hazard to the 

public. 

SDG&&E flights will be limited to inspecting our assets. In general, SDG&E will 

be operating over our Right of Ways and not over the public or 

commercfal/industrial buildings and residentfal housing. 

g. § 91.207 Emergency Locator Transmitters: No person may operate a U.S.- 

registered civil airplane unless there is attached to the airplane an approved 

automatic type emergency locator transmitter. The sUAS does not use an ELT, all 

operations are VFR and in line of sight with a visual observer. 

This exemption will benefit the public because the visual observer and operator 

are line of sight at all times with the sUAS. In addition if the sUAS needed to be 

located on the ground, the GCS will point to the sUAS to locate it and show range 

to the sUAS. 

Page 6 of 12 
September 12, 2014 

4. Inspection and Maintenance. (14 C.F.R § 91.405, 91.407, 91.409). All pilots will follow 

San Diego Gas & Electric Standard Practice #0004 Approved small Unmanned Aircraft 

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

small Unmanned Aircraft System InstantEye Inspection below Program. (See below the 

approved letter from Western-Pacific Region Flight Standard District Office, this exemption 

will be submitted as Enclosure (5) with this request. 

d u svuato,~, 

 rwdnol Aviatlon 

Arkninir4alWn 

niny 08,2014 

VIZldl 

I 1 ,0. Uox 129g? 1 

5mt nicgt,. CA, 92112 

Wedem-Pacifio @eglon 852S 6ibba Drive, Suite 120 

Fligh, Slendards Dfiuicl0fficc Sen Diego. CA 92123 

858-402-9882 x286 

Fdx: 858402-9985 

1)enr 

I Imvc completad rcviewcd and approved of your Inspeclion Manual dated May Ol, 2014 

Revision orittinal, attd lind na rcgulalory conflict with Tille 14 of Ihe Code ofFedera! 

kegufulions. 

flcn.se cnsure that mmtngemem, supervisory, and inspeelion personnel are familiar with the 

ncwly Implentcnlcd Mainlenance Munual policies and procedures. 

1'hc Federal Avialion Adlninislration rescrves lhe dght to require such changes, addilions, 

or clariflcoliotu as ntny prove necessnry, as n result of subscquent inspcctions and 

evnllultlons. lo ensurc conlihued complianee wilh the appropriate n:gulations. 

Sincercly, 

~~A ~ 

Kcvin U. lollnson 

12ritsipal Muintenance Inspcctor 

0. J 

0 

Page 7 of 12 
September 12, 2014 

5. Aircraft Configuration. InstantEye's performance characteristics Figure I shows a 

complete description of the aircraft. 

a. Three- vfew drawings or three-view dimensioned: 

Figure I- InstantEye Mk-2 Components 

b. Wing span. 22.5 cm (8.9 inches) (frame); 37.5 cm (14.8 inches) (frame + props) 

c. Length. 22.5 cm (8.9 inches) (frame); 37.5 cm (14.8 inches) (frame + props) 

d. Maximum gross takeoffweight. 453 g(<I Ib) 

e. Fuel capacity. N/A 

f. Payload capacity. 120 g(4.2 ounces) 

g. Maximum altitude. 12, 000 ft MSL 

h. Endurance. 20 min of battery life 

i. Maximum airspeed. 60 mph 

j. Description of ground support equipment. InstantEye Mk-2 uses 2000 mAh Li poly 

batteries and supplied charger. 

k. Description of launch and recovery equipment. N/A 

6. Ground Control Station System (GCS) Configuration. Description and a diagram (Figure 

2), of the GCS. 

Ground Control Station (GCS) Controllnterface 

The GCS control interface can be broken into three main groups, 2 joysticks, 8 primary control 

buttons, and 4 menu buttons, see Figure 2. 

1. .Ioysticks 

The joysticks are used to reposition the aircraft once it is airborne. Pushing the right joystick up 

and down causes the aircraft to clfmb and descend. Pushing it left and right rotates its heading 

(yaw). Pushing the left joystick up and down moves the aircraft forward and back. Pushing it left 

and right moves the aircraft left and right. 

2. Primary Control Buttons 

ALT, NAV, CAM, MOTOR, HOME, UTILl, and UTIL2 / IR 

3. Menu Buttons 

The menu buttons are just below the screen and are configurable based on context. The context 

menu can be brought up by pressing the menu button on the left. The other three buttons then 

perform the function described just above them on the screen. Pressing the left menu button a 

second time will brfng up a second context menu again defining the functton of the other three 

buttons. 

Page 8 of 12 
September 12, 2014 

~ 

~ 

ALr 

t o~~~~ ~ ~!i■ i ~ 

~ 

,vAV 

~ \® 

f YOt1'ER 

~ 

Gti ~ .Y/OI (7R 

I 1 

COIVTEXT AlGNU (3 ) 

AAENU 

Left Jqystick Right Joystick 

7ranslational Positioning Altiludc & Hcading (YaH•) 

Figure 2: GCS Button and Joystick Configuration 

7. Description of past flight history. There are in excess of 1500 hrs of test and evaluation 

time on the InstantEye Mk-2 systems and more than 2000 hrs of test and evaluation time on 

the systems it is derived from. Physical Science Inc. has already proven Airworthiness and 

has an Airworthiness Certification wfth US Army Special Operations Command. (AWR# 

IEM%220130521, attached.) In addition, As of June 25, 2014, after the FAA granted SDG&E 

a Special Airworthiness Certificate in the Experimental category, it has flown numerous 

sorties in support of operations and is always operated in a safe manner. 

8. Flight Recovery and Lost Link Procedures. Aircraft lost link and emergency recovery 

questions/procedures. 

a. How is it determined that the UA is experiencinQ lost link and how is this displaved 

to the pilot? Signal strength or qualfty is determined by error rate or number of lost 

data packets which are monitored during communicatfons. When a threshold percent 

of data packets are lost the aircraft first switches frequency and if this is not better, 

the aircraft goes fnto "lost comms " mode. 

b. Operattonal procedures in the event of a lost link: During a lost link event the 

operator m6nitors the data and video until communications are restored, then 

control is regained. If for some reason communications are not restored the operator 

should wait by the last know location ofgood communications. The aircraft will 

return there and auto land. 

Describe how the aircraft will react during takeoff climb, cruise, descent, and 

landing in the event of a lost link. During startup each InstantEye air vehicle is 

"tethered " to a ground control station through its command and control 

communication system. After tethering has been achieved the air vehicle will 

respond to commands from that ground station only. In operation, due to radio 

interference or flight beyond communication range, the aircraft can lose command 

and control lock with the ground control station. In this event the aircraft will enter 

into its "lost comm " mode and will execute the following procedure: 

Page 9 of 12 
September 12, 2014 

i. Vehicle will immediately climbldescend to an altitude 300' Above Ground 

Level (AGL)above its launch altitude; 

ii. Vehicle will home toward last known location ofground control station (GPS 

position ofground control station is uploaded to air vehicle duringfight); 

iii. If command and control communication is reestablished, vehicle will stop 

and hover at current location. If command and control communication is not 

reestablished, vehicle will hover over last known location of ground control 

station ("home position') and land immediately. 

iv. If vehicle is at home position and command and control communication has 

not been reestablished, vehicle will autonomously descend and land. 

d. How is it determined that the lost link functionalit of the system is operational? The 

lost linkfunctionality has been extensively tested and is used operationally, please 

refer to Airworthiness Release: AWR# IEM%220130521. 

e. How does the UA navigate when in the lost link mode? The InstantEye Mk-2 is 

continuoarsly updated with the GCSs GPS location. When the aircraft goes into "lost 

comms" mode it then uses the last location of the GCS as its next waypoint. 

f. What parameters are used to define the lost link or return home point? How is this 

point selected? How is this point entered? What happens when the UA reaches this 

p int? The InstantEye vehicle will enter its lost communication control mode if the o

error rate increases above 18.75 failed transmissions per successful transmission or 

after receiving no data from the ground station for 7.5 seconds. Logic exists to 

prevent the vehicle from oscillating in and out of lost communication control. When 

the aircraft enters it "lost comms mode " the aircraft ascends or descends to 300 ft. 

AGL and then begins to navigate to the last known home position. If at any point 

communications are regained the operator can begin controlling again. 

g. Under what conditions is a return home mode both manually and automatically 

activated? The InstantEye Mk-2 either enters its return home mode in "lost comms 

mode " after the aircraft climbs/descends to an altftude 300' AGL above its launch 

altitude or when the "Home " button is pressed on the GCS. 

h. What do the control station displays indicate during lbst link? Is it clear that the data 

is stale or invalid? Lost link is known by the operator when the on-screen data stops 

updating and the "Home " mode is automatically highlighted on the GCS screen. 

i. Lost link emergencyprocedures: 

i. Weak Command and Control (C2) Link 

Indicator: "Warning.• Weak C2 link" is displayed on-screen. Aircraft OSD data, such as the 

heading and altitude graphics, have stopped updating. Often video reception is poor or nonexistent as well. 

Response action: In less than 10 seconds, the vehicle will enter lost communications mode. It will 

climb to an altitude of approximately 300 ft. AGL and then begin to fly back to the home location. 

If control communications are regained en route to the home location (indicated by the 

Page 10 of 12 
September 12, 2014 

disappearance of the "Weak C21ink" warning and resumption of aircraft OSD data updates) the 

operator may resume controlling the aircraft and redirect it by using the joysticks. 

ii. Loss of aircraft GPS fix 

Indicator: As GPS quality degrades, the color quality bar will shrink and change color and 

position hold will become less and less accurate. These effects are amplffied when operating in 

windy conditions, or with very heavy payloads. When the quality bar underneath GPS coordinate 

is empty (completely gray) for 4 continuous seconds, the vehicle has lost operational GPS and an 

indicator is displayed: "Warning: Vehicle lost GPS; NAV mode disabled " NAV mode is 

automatically exited without operator action. Aircraft ceases to automatically hold position. The 

last know GPS is displayed in the GPS Coordinate graphic. 

Response action: Ensure that ALT mode is engaged. The aircraft will matntain altitude while the 

operator can focus on controlling the lateral motion of the vehicle manually. When aircraft 

position has stabilized, climb to a safe height (above obstructions) and fly the aircraft towards 

the home location. Use the range/bearing graphic and video feed to assist in this. When over an 

optimal landing location, slowly decrease the aircraft's altitude while focusing on maintaining 

lateral position. At any point, if the GPS quality bar shows a signal quality of inedfum (yellow) or 

high (green), it is likely safe to re-enter NAV mode. 

9. Pilot Qualifications (14 CFR 61.3, Requirement for certificates, ratings, and authorizations, 

and 14 CFR 61.5, Certificates and ratings issued under this part). 

a. Pilot Qualifications: All pilots will be current rated pilots with current medical. 

b. Pilot Training. All pilots will be qualified in accordance with 14 CFR 61.3 and 61.5 

and will complete an internal training program. All pilots will follow SDG&E 

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

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

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

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

Sciences Inc, and approved by Army Special Operatfons Aviation Command. At the 

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

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

evaluations, the operator will receive a completion certificate authorizing them to 

operate the SDG&E InstantEye. 

Qualification and Training of Observers. If observers are not qualified pilots, 

observers will attend a ground school to understand the proper roles of an observer, 

communication procedures, proper visual scan techniques, operations at nontowered airports, and appropriate sections of the Aeronautical Information Manual. 

They will also understand the rules and responsibilities described in §§ 91.111 

(Operating near other aircraft), 91.113 (Right-of-way rules: Except water 

operatfons), and 91.155 (Basic VFR weather minimums). 

10. Flight areas 

San Diego Gas & Electric is requesting inspection Flights throughout SDG&E service 

Page 11 of 12 
September 12, 2014 

territory. SDG&E flights will always be conducted under VFR conditions and within line of 

sight 400 feet and below. This exemption will be submitted as Enclosure (6) with this request. 

11. Specifications and Operations for SDG&E 

a. The sUAS weighs 16 oz., much less than the weight of a Canada goose, and will 

operate under 400 ft. AGL. The aircraft internal software regulates the sUAS so that 

it will not fly above 400 AGL. The aircraft ground speed will be less than 25 mph. 

Impact to the public will be minimal. 

b. sUAS will operate in Class G, C& D airspace. Due to the height of SDG&E assets, 

the sUAS will fly in restricted airspace designated by 14 CFR 91.119. In general, 

SDG&E will operate in 14 CFR 91.119, airspace that requires civilian and 

commercial aircraft to have an exemption, and which is not normal operating 

airspace for civilian and commercial aircraft. 

c. Air Traffic Control Provisions. When operating in areas other than Class 'G' Airspace 

SDG&E will contact Los Angeles ARTCC MOS a minimum of one hour prior to 

operations. In addition, SDG&E will coordinate with the controlling agency of the 

appropriate airspace and always provide the planned operating details, NOTAM 

information, and cell phone number for the PIC. SDG&E will also monitor the 

required frequencies of the airspace we are operating in, so we can maintain direct 

two-way communications with the appropriate authority. 

12. Granting the exemption would be in the public interest and benefit the public as a whole. 

Enclosure (1) will include proprietary information/confidential material for this exemption 

and will be sent via a separate correspondence. and will be sent via a separate 

correspondence. 

13. Standard Operating Procedures 

Ground program folder will include all operating procedures. This information is 

proprietary/confidential and will be sent via a separate correspondence. 

14. FAA Order 8130.34C 

Approved Appendix C program letter for Unmanned Aircraft Systems; Experimental 

Certificate and Appendix D Safety Checklist. This information is proprietary/confidential and 

will be sent via a separate correspondence. 

Page 12 of 12 
Petition for exemption SDG&E Enclosure (1) sent via separate correspondence. 
~ 

U.S.Department 800 Independence Ave.. S.W. 

Oi TranSportatlOn Washington. D C. 20591 

Federal Aviation 

Administration 

April 1, 2014 

Exemption No. 10968 

Regulatory Docket No. FAA-2013-1127 

Mr. Dallas Cormier, SD1173 

San Diego Gas & Electric, Sempra Energy 

101 Ash Street 

San Diego, CA 92101 

Dear Mr. Cormier: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letters dated December 20, 2013 and January 14, 2014, you petitioned the Federal 

Aviation Administration (FAA) on behalf of San Diego Gas & Electric (SDGE) for an 

exemption from §§ 91.9(b)(2) and 91.203(a) and (b) of Title 14, Code. of Federal Regulations 

(14 CFR). That exemption would allow SDGE to operate the InstantEye MK-2 N544L and 

N500VD unmanned aerial vehicles (UAVs) without carrying and displaying the airworthiness 

certificate, registration, flight manual, and any other required documentation onboard the 

aircraft. You requested that all required paperwork be located at the ground control station or 

within close proximity to the pilot in command. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Re ig ster because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to SDGE. 

The FAA has issued grants of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 8607 (copy enclosed), the FAA 

found it unnecessary to carry and display the airworthiness, certification, and registration 

documents in unmanned aircraft systems (UASs) and UAVs for the operations described by 

the petitioner. The original intent of the subject regulation was to display the airworthiness, 

AFS=14-084-E 

Petition for Exemption SDG&E Enclosure (2) 
2 

certification, and registration documents so they would be easily available to inspectors and 

passengers. 

Having reviewed your reasons for requesting an exemption, I find that— 

they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption No. 8607; 

the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 8607 

also apply to the situation you present; and 

a grant of exemption is in the public interest. 

Our Decision 

Under the authority contained in 49 U.S.C. §§ 106(f), 40113, and 44701, which the FAA 

Administrator has delegated to me, San Diego Gas & Electric is granted an exemption from 

14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) that allows SDGE to operate the InstantEye MK2 N544L and N500VD UAVs without carrying and displaying the airworthiness certificate, 

registration, flight manual, and any other required documentation onboard the aircraft, subject 

to the following conditions and limitations described below. 

Conditions and Limitations 

1. Compliance with the conditions and limitations stipulated in the Certificate of 

Waiver or Authorization (COA) for San Diego & Gas Electric UAS operations. 

Exemption No. 8607 was issued as a permanent exemption. The FAA, however, finds it in the 

best interest of safety to review this exemption every 2 years. This allows the FAA to ensure 

that there has been no change in circumstances or regulations from which the exemption is 

granted. 

This exemption terminates on Apri130, 2016, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 

Enclosure 

Petition for Exemption SDG&E Enclosure (2) 
0 

U.S. Department 

of Transportation - 

Federal Avfation 

Administratfan 

800 Independence Ave. SW 

Washington, DC 20591 

JAN 0 7 2014 

Mr. Dallas Cormier 

San Diego Gas & Electric 

Sempra Energy 

101 Ash St, 

San Diego, CA 92101 

Dear Mr. Cormier: 

Thank you for your letter dated December 28, 2013, requesting approval for a different 

nrarking procedure for San Diego Gas and Eleetric's InstantEye Mk-2 Gen 2 unmanned 

aircraft. "I'itle 14 of the Code of Federal Regulations 45.22(d), Exhibition, antique, and other 

airerafft: Speeial rules, permits persons to apply to the Administrator for a different marking 

proeedure if it is impossible to mark an aircraft per §§ 45.21 and 45.23 through 45.33. 

Your request for alternative rnarking has been reviewed. You are hereby authorized to identify 

yaur InstantEye Mk-2 Gen 2 unmanned aircraft with the following marking. Placce the word 

"EXPERIMENTAL" on the top of the main body of the aircrafk in lettering at least %2 inches 

high. 

This marking procedure applies to all San Diego Gas and Electric InstantEye Mk-2 Gen 2 

unmanned aircraft of the same configuration for which future certification may be requested. 

The following must be kept with the airworthiness certificate: 

• A copy of your original request letter; and 

• A copy of this responsb letter. 

If you have any questions, please contact the Airworthiness Certification Branch, AIR-230, at 

(202) 385-6346. 

Sincerely, 

James D. Seipel 

Manager, Production and Airworthiness Division 

Petition for Exemption SDG&E Enclosure (3) 
Petition for exemption SDG&E Enclosure (4) sent via separate correspondence. 


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