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: Jacquelyn Mohl Attn: Michael Cooper 

Phone: 781-907-1736 Phone: 781-907-2495

Email: jacquelyn.mohl@nationalgrid.com Email: michael.cooper@nationalgrid.com
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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), National 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 accordance with the grants of exemptions listed above, other 

regulations were either deemed not necessary or were not granted. National Grid also requests 

the exemptions that 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 interest 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 proximity to high-voltage equipment or subject to

the hazards of working at height. They 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 more 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.

Moreover, 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, weighing 15 or fewer pounds (6.8kg),

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 exemption
2

areas, airports unless a Memorandum of Agreement (MOA) is first established 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 visual 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 least equal 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 airspace 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 in 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 Island customers. We forecast, plan for, 

and procure 30 TWh of electricity annually across three states. We operate 105 miles of 

underground cable, 520 transmission substations and 644 distribution substations in New England 

and upstate New York. 8,920 miles of electricity transmission 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 owns and operates Liquefied Natural Gas (LNG) storage and vaporization facilities, as 

well as an LNG storage facility in Providence, Rhode Island, where they store gas for third parties for 

a fee. We also buy gas directly from producers and LNG importers for resale to our customers. In the 

US, National Grid holds a minority interest in two interstate pipelines: Millennium Pipeline 

Company and Iroquois Gas Transmission System. 

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 responsible 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.
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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 operational 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 populated 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 

airworthiness 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 

Administration 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 sUAS 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 sUAS 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 AeroVironment 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 DJI S1000 in Appendix D and the Aibot X6 in 

Appendix E as it pertains specifically to DJI S1000 and Aibot X6 operations. All sUAS 

operations will be modeled after these SOPs. Confidential treatment is requested for the 

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

The sUAS proposed are ideally suited for inspection 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-toaccess 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. The 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 than 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 line 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 obstacles. This eliminates the need 
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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, speed, 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 airports 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 rules 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 focus 

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 original 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 controlled 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, Unmanned Aircraft Systems Operations in the U.S. National 

Airspace System at 4 (Mar. 13, 2008).
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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 right of way.

 Maximum total flight time for each flight will be 45 minutes. Flights will be 

terminated at 25% battery 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 feet 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 proposed 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 builtin 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.

Situational awareness 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 safety 
7

features inherent 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 Petition); 

 Proven working knowledge of safe sUAS operations, flight characteristics, safety 

features, GPS/Battery Status indicators, and emergency procedures; 

 Utility knowledge regarding safe operations around high voltage power lines, 

substation equipment, and power plants; and

 At minimum, a valid driver’s license or an 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

National 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 Would 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 traditional 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 serves millions of retail customers in [area], where storms occur with frequency. An

infrastructure 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 airspace system as required by Section 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 as operation of aircraft under existing regulations. 

National Grid’s request therefore provides the Administration an appropriate vehicle to further 

Congress’ mandate to expedite integration of UAS. In addition, National Grid’s operational 

experience resulting from the use of sUAS in utility operations may be valuable to the 

Administration in developing comprehensive rules governing sUAS for the electric industry.
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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 respectfully 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 exemptions 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 

forth 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 13, 2015 Respectfully submitted,

Jacquelyn 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 Administration 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 further 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 require a valid driver’s license, but 

would not require FAA-issued medical certificate. 

National Grid respectfully requests exemption from this 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) are 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 capabilities 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 successfully 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 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 operating 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 Limitations 

Section 61.101(e)(4) and (5) states that “a recreational pilot may not act as a pilot in command of 

an aircraft for compensation 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 characteristics 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 FAA Exemption Nos. 11224, 11239, 11258, 

11326, 11389, 11538, 11868, and 11891). See Appendix D for training and operating 

restrictions.

3. 14 C.F.R. §§ 61.113(a): Private Pilot Privileges and Limitations: 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 requests exemption from this 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) are 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 capabilities 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 successfully 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[...]in 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 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). 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 equivalent level 

of safety. 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 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): Minimum 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 operating 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 

associated 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 operations 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 barometric altimeter, 

but instead use GPS technology, National Grid requests an exemption from this requirement to 
Appendix 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 acquisition 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 

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

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

to fly after that for at least 30 minutes.” 

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 flights 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 shall have 

the aircraft inspected as prescribed in the rules and have discrepancies repaired 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 limited 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 initiating 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 55 pounds or less on property that is owned or 

controlled by National Grid or in 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 Petition in 

lieu of the above-referenced 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 Unmanned 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 Requested
Appendix E to Applicant’s Petition for Exemption Page 1

Appendix E: Aibot X6 Operating Manual

Submitted Separately

Confidential Treatment Requested