### National Grid ’s Petition for Exemption

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

Applicant:

National Grid USA Service Company Inc. 40 Sylvan Rd. Waltham, MA 02451

Attn: Jac quelyn Mohl Attn: Mi chael Cooper

Phone: 781

- 907

- 1736 Phone: 781

- 907

- 2495

Email: jacquelyn.mohl@nationalgrid.com Email: michael.cooper@nationalgrid.com1 I. SUMMARY OF PETITION

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“Section 333”), National Grid USA Service Company, Inc. (“ National Grid ”) hereby respectfully requests expedited approval to use Small Unmanned Aircraft System (“sUAS”) under the terms and conditions described in this Petition for Exemption (“Petition”) to conduct inspections of energy

infrastructure

. Based on other utility grants of exemption (see Exemption Nos. 11185, 11224, 11239, 11258, 11326, 11389, 11538, 11868, and 11891), Natio nal Grid requests exemptions for the following regulations: 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b)

. In accordan ce with the grants of exemptions listed above , other regulations were either deemed not necessary or were not granted. National Grid also requests the exemptions t hat are necessary to grant such approval pursuant to 49 U .S.C. § 44701(f), and

14 C.F.R. § 11.81. 1

National Grid seeks to use sUAS to perform visual inspections of vital energy infrastructure,

such as transmission lines, sub

- transmission lines, distribution lines , power plants, substations

and other assets

, in order to further the public intere st in the safe and reliable delivery of electricity to customers

. Small UAS are ideally suited for inspection of energy infrastructure

— they can inexpensively, safely

, and quickly deliver high

- quality photo and video , which eliminates the need for physical inspection and thus speeds the process of trouble

- shooting, and ultimately increases the reliability of the electric grid. In particular, sUAS allow utility workers to conduct inspections without being in close pro ximity to high

- voltage equipment or subject to the hazards of working at height

. T hey can also facilitate the safe inspection of hard

- to

- access or environmentally sensitive areas without the use of bucket trucks or other utility vehicles that may have mor e impact than sUAS

. In addition, because of the small size of the craft, in many cases

sUAS can be more efficient and cost effective than traditional methods, which can help to reduce operations and maintenance costs and , perhaps most importantly, provide a means for faster

resolution of any problems on the electric system

. In short, approval of this request and the provision of the necessary exemptions will increase electric system reliability, decrease customer

costs

, and enhance worker safety.

Moreove r, approving the requested use would represent a significant step forward in the Federal Aviation Administration’s (“ Administration ”) efforts to integrate sUAS into the national airspace
system. National Grid ’s request provides the Administration with an opportunity to partner with a leading electric energy provider as it works to develop its rulemaking pursuant to the FAA

Reauthorization Act of 2012

— while doing so for a compelling public purpose and under strict operational and safety guidelines. Given the uniqueness of National Grid

— the company has a diverse geographical and environmental footprint and a distinctive resource mix

— it is ideally suited to help the Administration understand the potential utility applications for sUAS.

National Grid proposes to use sUAS that are rotorcraft , weigh ing 15 or fewer pounds ( 6.8 kg)

, operate at a speed of no more than 87 knots , and contain built

- in safety features

. In addition,

National Grid proposes to use the aircraft at low altitudes, not in proximity to densely populated

1 See Appendix A for description of requests of exemption2

areas, airports unless a Memorandum of Agreement (MOA) is first establi shed with the airport authority, or on property that is owned or operated with rights to patrol and inspect by National

Grid or is utility right of way

, within the vis ual line of sight of the operator, and under controlled

conditions

. Accordingly, the requested exemptions satisfy the applicable statutory criteria and policies, will serve the public interest, will not adversely affect safety, and will provide a level of safety at leas t e qual to the existing airworthiness and related regulations. Approval of this Petition is therefore consistent with Section 333’s directive to “establish requirements for the safe operation of [unmanned aircraft systems] in the national a irspace system” if the Secretary of Transportation determines that certain unmanned aircraft systems may operate safely in the national airspace system. 2

II. NATIONAL GRID BACKGROUND

National Grid Company PLC is an international investor

- owned electricity and gas network company based in the United Kingdom and Northeastern United States focused on transmission and distribution. The parent company is headquartered in London, England, while the US subsidiary, National Grid USA, is headquartered i n Waltham, MA.

National Grid delivers electricity to approximately 3.5 million customers in Massachusetts, New

York and Rhode Island. National Grid own over 4,000 megawatts of contracted electricity generation, providing power to over one million Long Isla nd customers. We forecast, plan for, and procure 30 TWh of electricity annually across three states. We operate 105 miles of underground cable, 520 transmission su bstations and 644 distribution substations in New England and upstate New York. 8,920 miles o f electricity tra nsmission system are owned and operated by

National Grid in Massachusetts, New York, Rhode Island, and Vermont

. National Grid forecasts, plans for and procures 16bn standard cubic meters of gas , serving 3.6 million US gas customers in

New York (including New York City and Long Island), Massachusetts and Rhode Island. In the US,

National Grid o wns and operates Liquefied Natural Gas (LNG) storage and vaporization facilit ies, as well as an LNG storage facility in Providence , Rhode Island, wh ere they store gas for third part ies for a fee. We also buy gas directly from p roducers and LNG importers for resale to our customers. In the US, National Grid hold s a minor ity interest in two interstate pipelines: Millennium Pipeline Company and Iroquois Gas Transmission Sy stem.

National Grid is focused on providing safe, reliable electricity and gas to its customers, with an emphasis on efficiency and process excellence. It has instituted employee programs to reduce accidents, working toward 0.1 employee lost time injuries per 100,000 hours worked in a 12 month period. National Grid has also committed to improve the way it works to become more efficient, innovative, and r esponsible to its customers’ needs in end

- to

- end process that includes: meter to cash; emergency response; deliver, operate and maintain gas and electric. Consistent with its effort to provide safe and reliable electric and gas service, National Grid seeks to use sUAS to more efficiently and safely perform inspections of its energy infrastructure.

2 Section 333(c) of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112

- 95, 126 Stat 11.3 III. RELEVANT STATUTORY AUTHORITY

A. Section 333

Section 333(a) states that the Administration “shall determine if certain unmanned aircraft system before completion of the plan and rulemaking [to broadly integrate UAS into the national airspace] required by Section 332 of this Act.” Section 333 is also described as a pathway for “expedited operat ional authorization.” 3

Section 333 (b)(1) outlines the factors that the Administration shall use to determine whether UAS may be operated safely in the national airspace system: size , weight, speed, operational capability, proximity to airports and popu lated areas, and operation within visual line of sight. In addition, and importantly for this Petition, Section 333(b)(2) provides the Administration with the discretion to determine that a certificate of waiver, certificate of authorization, or

airworthi ness certification is not required to operate UAS that are found to be appropriate under Section 333(b)(1). Finally, Section 333(c) allows the Administration to establish requirements for safe operation of the UAS determined to be able to be operated safely in the national airspace
system.

B. Section 44701(f)

In addition to its specific authority related to authorizing UAS operation under Section 333, the

Adm inistration has general authority to grant exemptions from its safety requirements and

minimum standards if the Administration finds that the exemption is in the public interest. 4

Administration regulations set forth the information that must be included in the petition for exemption: (1) the applicant’s name and mailing address; (2) the regulations from which the applicant seeks exemption; (3) the extent of relief sought and why; (4) the reasons why granting the request would be in the public interest and how it would benefit the public as a whole; and (5) the reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to the rule from which the applicant seeks exemption. 5

IV. DISCUSSION

A. National Grid ’s Proposal Satisfies the Section 333 Criteria for Approval

.

As described above, Section 333(b)(1) outlines the factors that the Administration shall use to determine whether UAS may be operated safely in the national airspace system: size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight. Applying the criteria outlined in Section 333(b)(1 ) and other relevant criteria

to this case demonstrates that National Grid ’s proposed terms and conditions of operation will

result in the s UAS being operated safely in the national airspace system, consistent with Section

3 Section 332(b)(1).

4 49 U.S.C. § 44701(f).

5 14 C.F.R. § 11.81.4

333. Based on the small size of the sUAS involved, the low altitude and restricted environment in which they will operate, and the fact that they will be operated within the visual line of sight of the operator, there is more than sufficient basis to find that the sUA S can be operated safely

under National Grid ’s proposal

.

Size , Weight, Speed, and Operational Capability

National Grid seeks an exemption permitting operations of a DJI Spreading Wings S1000, Aeryon SkyRanger, Aibotix Aibot X6 and Aero V ironment Shrike

. All sUAS proposed by National Grid are electric powered and will not be flown above 50 knots. Additional detailed information regarding the characteristics of each sUAS is provided in Appendix C . A Standard Operating Procedure (SOP) is provided for the D JI S1000 in Appendix D and the Aibot X6 in Appendix E as it pertains specif ically to DJI S1000 and Aibot X6 operation s

. All sUAS

oper ations w ill be modeled after th e s e SOP s

. Confidential treatment is requested for the

in formation provided in Appendix D and E, which were submitted separately via email

.

The sUA S proposed are ideally suited for inspe ction of power lines, generating plants, pipelines and other energy

- related infrastructure because the aircraft has the capability to deliver high quality photos and videos more efficiently and cost

- effectively than traditional methods. Using sUAS can

also be safer for utility workers because it will avoid putting utility workers in situations with potential hazards, eliminating the risk of injuries. They also allow the safe inspection of hard

- to

access or environmentally sensitive areas without the use of trucks and other utility vehicles. Overall, the sUAS can provide significant benefits to utility workers and customers over traditional energy infrastructure inspection methods

Proximity to Airports/Populated Areas

National Grid will avoid operating the sUAS over densely populated areas and will operate at
least five nautical miles away from the nearest airport. T he sUAS will be operated at low

altitudes of 400 feet or less

— much lower than the airspace in which manned vehicles operate

and often lower tha n the altitude at which hobby aircraft fly. Finally, operations will generally

occur over utility property or utility right of way

.

In addition, National Grid ’s flights will likely occur in airspace that is subject to a Notice to Airmen (“NOTAM”). The Administration has issued a standing notice to pilots to avoid loitering in the “airspace above, or in proximity to, sites such as nuclear power plants, power plants, dams, refineries, industrial complexes, military facilities, and other similar facilities .”

This NOTAM should further limit the potential interaction to for any flights near National Grid power generation facilities.

Visual Line of Sight

A trained operator will fly the sUAS during daylight hours, in good weather, and within the operator’s li ne of sight. In addition, the operator will be accompanied by a trained spotter, who also will be positioned in line of sight of the aircraft and will be in constant communication with

the operator to identify and alert the operator to any potential obsta cles. This eliminates the need5

for other “sense and avoid” capabilities during operation, as well as the need for any method of

air traffic control communications. 6

B. Applicant ’s Proposal Also Satisfies the Standard for Exemption under Section

44701 and 14 C.F.R. § 11.81.

Granting Applicant ’s Request Would Not Adversely Affect Safety and Would Provide a

Level of Safety at Least Equal to Existing Rules.

Granting National Grid ’s Petition will not adversely affect safety

, and National Grid ’s proposed terms and conditions of operation would provide a level of safety at least equal to existing rules. As discussed above with respect to Section 333(b)(1) criteria, the size, weight, sp eed, and operational capability of the sUAS that will be used in the proposed operations indicate that the aircraft can be operated safely in the national airspace system. Moreover, the aircraft will be operated at low altitudes, not in proximity to airpo rts or densely populated areas, and within the visual line of sight of the operator and spotter . In addition, National Grid proposes the following conditions to ensure that the requested exemption would result in a level of safety at least equal

to the ru les from which National Grid is seeking an exemption.

Safety Systems

The sUAS proposed by National Grid have a semi

- autonomous navigation and control system comprised of a Ground Control Station and auto

- pilot system. Automated safety functions and safety enhancing features of the sUAS include the following:

 Precision Flight and Stable Hovering : Integrated GPS autopilot system provides position holding, altitude lock

, and stable hovering to all field personnel to focu s on situational awareness and safely getting the job done

.

 Auto Return

- To

- Home : Fail

- safe feature will automatically activate in case of signal loss with ground station, using GPS

- Enabled autopilot to automatically return and landing the craft at the ori ginal take

- off point

.

 Clearly Visible Battery and GPS Status : Battery and GPS Status will be available through airframe status lights clearly visible to the operator and available through the ground station display

.

 Controlled Airspace No

- Fly Zone : GPS c ontrolled autopilot will automatically enforce corporate policy and training prohibiting flights in proximity to airports and densely populated areas.

6 See Interim Operational Approval Guidance 08

- 01, Unm anned Aircraft Systems Operations in the U.S. National Airspace System at 4 (Mar. 13, 2008).6

Mandatory Operating Conditions

In addition to the safety features described above, National Grid proposes that its exemption be subject to the following mandatory conditions to ensure safe operation :

 Operations will avoid densely populated areas.

 Operations will be conducted over property that is owned or controlled by

National Grid or is utility ri ght of way

.

 Maximum total flight time for each flight will be 45 minutes. Flights will be
terminated at 25% batter y power reserve, should that occur before this time limit.

 Operations will occur during Visual Flight Rules Meteorological Conditions.

 Aircraft to remain within Visual Line of Sight ( “ VLOS ” ). VLOS will be guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles.

 Operations will occur during daylight hours.

 Flights will be operated at an altitude of no more than 400 fee t Above Ground

Level (“AGL”)

.

 All operations to remain more than three nautical miles from centerline azimuth of runway centerline measured from runway thresholds.

 Operators and spotters will meet the operator training and certification requirements propos ed below.

 Operators and spotters will be in communication at all times.

 Operator will perform required maintenance per the manufacturer’s recommendations and keep a log of any maintenance performed.

 Operator will perform any safety checks specified in the manufacturer’s user guide prior to each flight.

Operator Training and Certification

As discussed above

, the sUAS proposed are characterized by a high degree of control and built

in technical capabilities that limit the potential for operation outside the operating conditions set

forth in this Petition. Moreover, the mandatory operating conditions (maximum altitude, proximity to airfields, visual line of sight) minimize any potential weather impact and

interactions with other aircraft.

S i tuational awarene ss around high

- voltage equipment, a thorough working knowledge of the sUAS, and strict adherence to corporate sUAS flight policy are paramount to safe sUAS operations

. Given the significant differences between sUAS and piloted aircraft, the safety7

features inhe rent in the sUAS, and the strict operating conditions that will apply

, National Grid

proposes that operators of the sUAS will be required to hold at least a recreational or sport pilot
certificate as well as a valid driver’s license

. National Grid will also train and internally certify
operators and observers based on :

 Proven knowledge of National Grid sUAS flight policy (including Mandatory Operating Conditions specified in this P etition) ;

 P roven working knowledge of safe sUAS operations, flight chara cteristics, safety features, GPS/Battery Status indicators

, and emergency procedures ;

 U tility knowledge regarding safe operations around high voltage power lines, substation equipment, and power plants ; and

 At minimum, a valid driver’s license or a n FAA airman 3 rd class medical

certificate.

National Grid is receptive to future regulations and industry guidance on licensing sUAS pilots using training and testing that is relevant to operating sUAS in a limited flight area.

Privacy Considerations

Nat ional Grid will 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 National Grid operates sUAS . In addition, as a practical matter, flights will occur over utility property or utility right of way , so privacy is unlikely to be a concern in relation to National Grid ’s proposed use.

Granting Applicant ’s Request Would Be in the Public Interest and W ould Benefit the

Public as a Whole.

Allowing the requested use will provide significant benefits to the public, National Grid customers, and National Grid employees. Using sUAS to inspect energy infrastructure can be

safer and more efficient than traditio nal methods of infrastructure inspection, such as the use of helicopters and bucket trucks. The increased safety and efficiency of using sUAS to inspect infrastructure following significant weather events is especially important to National Grid

, which se rves millions of retail customers in [area]

, where storms occur with frequency. An

infrastr ucture inspection process that is safer and more efficient can help to lower operations and

maintenance costs and more quickly resolve problems in the delivery of electricity, both of

which will benefit customers

.

Moreover, the requested use presents a compelling case for the Administration moving forward with efforts to integrate sUAS into the national airspac e system as required by S ection 333. The public has a significant interest in efficient and safe inspection of energy infrastructure to ensure reliable delivery of power, and National Grid has proposed using sUAS to further this public interest in a way that is at least as safe a s operation of aircraft under existing regulations.

National Grid ’s request therefore provides the Administration a n appropriate vehicle to further Congress’ mandate to expedite integration of UAS. In addition, National Grid ’s operational experience resu lting from the use of sUAS in utility operations may be valuable to the

Administration in developing comprehensive rules governing sUAS for the electric industry

.8

C. Description of Relief Sought and Regulations from Which Exemption is Requested

Based on the foregoing, National Grid ’s proposal satisfies the criteria for approval under Section 333. In addition, National Grid ’s proposal meets the requirements and policies for exemptions

from Administration regulations. National Grid therefore resp ectfully requests that the

Administration grant exemptions from the regulations set forth in Appendix A to this Petition. 7

V. CONCLUSION

For the reasons discussed above, National Grid satisfies the relevant criteria for approval under

Section 333 and exem ptions from referenced regulations pursuant to Section 44701(f). Accordingly, National Grid respectfully requests that the Administration grant the relief requested in this Petition to allow the use of sUAS for the purposes and under the conditions set

fo rth herein. Granting this Petition will not only further Congress’ instruction to expedite the safe integration of UAS into the national airspace system , but will also further the significant public interest in the safe and reliable delivery of electricity to customers.

August 1 3 , 2015 Respectfully submitted,

Jac quelyn Mohl National Grid USA Service Company Inc. 40 Sylvan Rd. Waltham, MA 02451

Phone : 781

- 907

- 1736 Email: jacquelyn.mohl@nationalgrid.com

7 National Grid has attempted to identify the applicable regulations for which an exemption is required for the proposed use. To the extent that the Administratio n determines that any other safety regulations might apply to

National Grid ’s proposed use, Applicant further requests that this Petition be deemed to seek an exemption from those requirements.Appendix A to Applicant’s Petition for Exemption Page 1 Appendix A: Regulations from Which Exemption is Requested

National Grid has attempted to identify the applicable regulations for which an exemption is required for the proposed use. To the extent that the Administration determines that any other safety regulations might apply to National Grid ’s proposed use, National Grid fu rther requests that this Petition be deemed to seek an exemption from those requirements.

1. 14 C.F.R. § 61.23(a) and (c) : Medical Certificates: Requirements and Duration

Section 61.23 (a) and (c) require certain medical certificates based on the operations of the

aircraft. National Grid is proposing that its sUAS operators will have at a minimum a sport pilot or recreational pilot’s certificate. This certificate would re quire a valid driver’s license, but would not require FAA

- issued medical certificate.

National Grid respectfully requests exemption from th is requirement based on the particular

characteristics of the sUAS that will be used. The risks associated with th e operation of the sUAS described above (given the size, speed, operational capabilities, and lack of combustible fuel) are much lower than the risks associated with private pilot operations or commercial operations contemplated by Part 61 with conventiona l aircraft. In addition, National Grid will use sUAS with a high degree of control and various built

- in technical capabilities that strictly limit the potential for operation outside of the operating conditio ns set forth in this Petition.

Given the inhe rently lower

- risk nature of the sUAS and these safety features, National Grid proposes that operators be required to successfully complete the training described above. This training and the conditions and restrictions on operation proposed in this Petiti on will provide an equivalent level of safety as requiring operators to have a commercial or private pilot’s

certificate with an FAA

- issued medical certificate

. This exemption has been granted with limitations and considerations for other utility companies utilizing sUAS in similar forms (See FAA Exemption Nos. 11224, 11239, 11258, 11326, 11389, 11538, 11868, and 11891). See Appendix D for training and operatin g restrictions.Appendix A to Applicant’s Petition for Exemption Page 2

2. 14 C.F.R. § 61.101(e)(4) and (5) : Recreational Pilot Privileges and L imitations

Section 61.101(e)(4) and (5) state s that “a recreational pilot may not act as a pilot in com mand of an aircraft for compens ation or hire or in furtherance of a business.” As stated above, National

Grid proposes to use pilots with at least a recreational or sports pilot license to operate the sUAS. In this manner, National Grid respectfully requests exemption from this requirement based on the particular charac teristics and inherently lower

- risk nature of the sUAS and its safety features.

These features are discussed in the justification for exemption of Section 61.23(a) and (c). The training, conditions and restrictions on operation proposed in this Petition will provide an equivalent level of safety as requiring operators to have a commercial or private pilot’s

certificate

. This exemption has been granted with limitations and considerations for other utility companies utilizing sUAS in similar forms (See F AA Exemption Nos. 11224, 11239, 11258, 11326, 11389, 11538, 11868, and 11891). See App endix D for training and operating

restrictions.

3. 14 C.F.R. §§ 61.113(a): Private Pilot Privileges and Limitation s: Pilot in Command

Section 61.113(a) limits private pilots to non

- commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the sUAS proposed for use by National Grid are remotely controlled with no passengers or cargo on board.

National Grid respectfully request s exemption from th is requirement based on the particular characteristics of the sUAS that will be used. The risks associated with the operation of the sUAS described above (given the size, speed, operational capabilities, and lack of combustible fuel) ar e much lower than the risks associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft. In addition, National Grid will use sUAS with a high degree of control and various built

- in technical capabil ities that strictly limit the potential for operation outside of the operating conditions set forth in this Petition.

Given the inherently lower

- risk nature of the sUAS and these safety features, National Grid proposes that operators be required to succ essfully complete the training described above. This training and the conditions and restrictions on operation proposed in this Petition will provide an equivalent level of safety as requiring operators to have a commercial or private pilot’s

certificate. See Appendix D for training and operating restrictions.Appendix A to Applicant’s Petition for Exemption Page 3

4. 14 C.F.R. §§ 61. 315(a): What are the privileges and limits of my sport pilot

certificate?

Section 61.315 (a) restricts those airmen holding a sport pilot certificate to being unable to act as pilot in command (PIC) of a light

- sport aircraft for “compensation or hire, in furtherance of a business[...]i n Class B, C, and D airspace.” As stated above

, National Grid proposes to use pilots with at least a recreational or sports pilot ’s certificate to operate the sUAS. In this manner,

National Grid respectfully requests exemption from this requirement based on the particular

characteristics and inherent ly lower

- risk nature of the sUAS and its safety features.

These features are discussed in the justification for exemption of Section 61.23(a) and (c). In addition, National Grid will not operate the aircraft within 5 nm of an airport, unless a Memorandum of Agreement (MOA) is first established with the airport authority. The training, conditions and restrictions on operation proposed in this Petition will provide an equivale nt level of safety

. This exemption has been granted with limitations a nd considerations for other utility companies utilizing sUAS in similar forms (See FAA Exemption Nos. 11224, 11239, 11258, 11326, 11389, 11538, 11868, and 11891). See Appendix D for training and operating

restrictions.

5. 14 C.F.R. § 91.7(a ): Civil Aircraft Worthiness

Section 91.7(a ) mandates that no person may operate a civil aircraft unless it is in airworthy

condition. If the Administration grants National Grid ’s request for exemption from the requirement to obtain an airworthiness certificate, no Administration regulatory standard will exist for determining airworthiness. National Grid will, however, maintain the sUAS as directed by the manufacturers and conduct any recommended safety checks prior to each flight.

6. 14 C.F.R. § 91.119 (c) : Minimu m Safe Altitudes

Section 91.119(c) prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in

non

- congested areas.

As described in the opera ting restrictions above, National Grid will operate the sUAS at altitudes up to 400 feet AGL , and therefore requests an exemption from the 500

- foot minimum altitude. Given the size, weight, and speed of the sUAS and the lack of flammable fuel, any risk

as sociated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the sUAS will ensure separation between these sUAS operations and the operation s of conventional aircraft that must generally operate above 500 feet.

7. 14 C.F.R. § 91.121: Altimeter Settings

Section 91. 121 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 sUAS may not have a ba rometric altimeter,

but instead use GPS technology

, National Grid requests an exemption from this requirement toAppendix A to Applicant’s Petition for Exemption Page 4

the extent it operates sUAS without a barometric altimeter. An equivalent level of safety will be achieved by the operator confirming the acqu isition of GPS signals and an initial ground level altitude of zero prior to take off

.

8. 14 C.F.R. § 91.151(a) (1) : Fuel Requirements for Flight in VFR Conditions

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

co nditions 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 minu tes. ”

National Grid requests an exemption from the 30 minutes of reserve fuel requirement. Given the limitations on flight locations and operations set forth in this Petition, a longer time frame for flight is reasonable. Operating the sUAS in a tightly controlled area 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 and speed of the sUAS.

National Grid proposes that an equivalent level of safety can be achieved by limiting flight s to 30 minutes or 25% of battery power, whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating

area.

9. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a) (1) and (2); 91.417(a) and (b):
Maintenance Inspections

These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part

43. Specifically , 14 C.F.R. § 91.405(a) states that the owner or operator of an aircraft s hall have

the aircraft inspected as prescribed in the rules and have discrepancies re paired as prescribed in part 43; 14 C.F.R. § § 407(a)(1) and 409(a) (1)& (2) requires that an aircraft be approved for return to service by a person authorized under 14 C.F.R. Section 43.7 after it has undergone

maintenance or receives an annual inspection; and 14 C.F.R. § 417 requires an owner or operator of an aircraft to maintain specific types of maintenance records, including signatures of the person authorized to approve the aircraft’ s return to service.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to National Grid ’s operation of sUAS . Maintenance will be accomplished by the operator pursuant to the manufacturer specifications. An equivalent level of safety to existing regulations will be achieved because these sUAS are very limited in size, operate only in restricted areas for limi ted periods of time, and carry no flammable fuel. If mechanical issues arise, the sUAS can land immediately and will be operating from no higher

than 400 feet AGL . As described above, the operator will ensure that the sUAS is in working order prior to in itiating flight, perform a preflight safety checklist, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator 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.Appendix B to Applicant’s Petition for Exemption Page 1 Appendix B: Summary Suitable for Publication in the Federal Register

National Grid petitions the Federal Aviation Administration for relief from compliance with 14

C

. F

. R . §§ 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.7(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b) for

purpose of operating small unmanned aircraft 5 5 pounds or less on property that is owned or controlled by National Grid or i n utility right of way , in order to inspect energy infrastructure and identify problems in the delivery of electricity to customers. National Grid proposes that its operation be subject to the operating conditions and safety standards set forth in its P etition in

lieu of the above

- refer enced regulations in order to provide a level of safety equivalent to those regulations.Appendix C to Applicant’s Petition for Exemption Page 1 Appendix C : National Grid Proposed U nmanned Aerial Systems

No Make Model Type Description Weight

w/o Payload* Max

Flight

Endurance

1 DJI S1000 Rotorcraft (Octocopter) VTOL,

retractable gear 4.2 kg

(9.26 lb) 15

- 20

minutes

2 AeroVironment Shrike Rotorcraft (Quadcopter) VTOL,

retractable gear 2.49 kg

(5.5 lb) 40 minutes

3 Aeryon SkyRanger Rotorcraft (Quadcopter) VTOL,

retractable gear 2.4 kg

(5.3 lb) 50 minutes

4 Aibotix Aibot X6 Rotorcraft (Hexacopter) VTOL 3.4 kg (7.5 lb) 30 minutes

* All indicated weights are taken from publicly available specifications and are without payload.Appendix D to Applicant’s Petition for Exemption Page 1

Appendix D : National Grid UAS Standard Operating Procedure for DJI S1000

Submitted Separately

Confidential Treatment RequestedAppendix E to Applicant’s Petition for Exemption Page 1 Appendix E : Aibot X6 Operating Manual

Submitted Separatel y

Confidential Treatment Requested