CENTRAL RURAL ELECTRIC COOPERATIVE

3304 S. Boomer Rd, PO Box 1809, Stillwater, OK 74076 405-372-2884

March 14, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: Request for exemption from multiple regulatory provisions to allow the use of small

unmanned aerial systems controlled by Central Rural Electric Cooperative to assist in the safe 

evaluation of infrastructure and operations.

Dear Sir or Madam:

Central Rural Electric Cooperative (‘CREC’) respectfully requests an exemption from several

provisions of Title 14 of the Code of Federal Regulations (CFR) to permit the use of small unmanned

aerial systems (sUAS) to assist in the evaluation, inspection and asset management of infrastructure 

owned and operated by Central Rural Electric Cooperative.

Background

Central Rural Electric Cooperative is an electrical utility headquartered in Stillwater, Oklahoma. 

Central Rural Electric Cooperative was formed to provide safe, reliable, affordable electric energy to 

its member owners both residential and commercial in north central Oklahoma. Central Rural 

Electric Cooperative is an electric distribution utility consisting of four thousand miles of overhead 

lines, poles, and electric apparatus such as capacitors, voltage regulators and electronic reclosers, all 

designed and coordinated to maintain power quality while supplying power to its member-owners.

The safety and efficiency of infrastructure operations is heavily dependent upon constant analysis of 

assets, right-of-way, infrastructure and other facilities. There are a wide variety of factors that can 

affect conditions and cause problems for infrastructure. Even relatively small objects or minor 

failures can lead to accidents or other incidents causing downtime of infrastructure or potential public 

hazards. Extreme weather, vegetation, natural disasters, theft and vandalism are among the many 

risks that modern infrastructure faces.

As such, employees routinely inspect the infrastructure, such as overhead lines, substations, electrical 

apparatus, poles, right-of-way and other similar structures. At present, this work is done primarily by

company personnel in motor vehicles, on foot or in specialized equipment. This is often a laborintensive and sometimes hazardous task.

While we do all we can to make these inspections as safe as possible, there is an irreducible element 

of risk involved whenever employees are required to go out on structures. Employees may need to 

climb over or onto structures, which can be slippery, rough, and/or exposed to the elements.

Some structures, such as bridges, are high above the ground. Equipment moving through inspection

zones can increase risk as well, especially in high-traffic areas. While the use of sUAS for

supplemental infrastructure and general asset evaluation would not eliminate these risks, it would 

minimize the risks to employees by allowing for remote aerial review.

Central Rural Electric Cooperative operates thousands of miles of utility infrastructure across 

portions of seven counties. The sheer amount of assets involved and the widely dispersed locations, 
in many instances across rural areas, means that visual inspection in all instances by company 

personnel leads to inefficiencies. 

By using sUAS for supplemental asset evaluation, Central Rural Electric Cooperative will be able to 

substantially upgrade its capacity to detect and address issues with the facilities, rights-of-way and 

other assets before they become a problem for safe operations. Thus, the use of sUAS has the 

potential to improve efficiency, resulting in faster and safer delivery of energy to residences and 

commercial businesses. 

Infrastructure Safety Inspection Operations

Overhead Line Inspections

Substation Inspections

Pole Inspections

Electrical Apparatus Inspections

Right-of-Way Inspections

Storm Damage Assessments

Solar Panel Inspection

Regulatory Basis for Exemption Request

This request is in accordance with Section 333 of the FAA Modernization and Reform Act of

2012 (Modernization Act) 1 through which Congress acknowledged the use of such systems prior to

the finalization of specific sUAS rules and regulations. Until such time as these regulations are

finalized, the Secretary of Transportation is required to make a determination whether certain

unmanned aircraft systems may operate safely in the national airspace system (NAS). As part of such 

determination the Secretary is to consider the following:

- The UAS’s size, weight, speed, and operational capability;

- Operation of the UAS in close proximity to airports and populated areas; and

- Operation of the UAS within visual line of sight of the operator.

In regards to specific requests the FAA has adopted requirements, providing that applicants of such 

requests shall explain why granting the exemption would not adversely affect safety or how the

exemption would provide at least an equivalent level of safety compliance with the underlying

regulation. In this case, approval of this exemption would advance the public interest by significantly

enhancing the safety and efficiency of infrastructure operations and by providing the

FAA with valuable user experience on sUAS in a context with appreciable economic and societal

benefits. As described more fully below, the requested exemption would permit the operation of

sUAS under tightly controlled conditions, thus ensuring that operations will not have an adverse

impact on safety to both public and worker. To the contrary, as explained below, Central Rural 

Electric Cooperative expects that use of sUAS will enhance safety in infrastructure operations. 

Granting an exemption is in the public interest. The safety and efficiency of infrastructure operations

is heavily dependent upon constant analysis of assets, right-of-way, infrastructure and other 

assets/facilities.

Provisions for which an exemption is sought

14 CFR Part 21

14 C.F.R. Part 61

14 CFR 61.113 (a)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)
14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

Explanation:

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

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

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

operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21

Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of

the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon

consideration of the size, weight, speed, operational capability, and proximity to airports and

populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the

UAS operated without an airworthiness certificate, in the restricted environment and under the

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or

rotorcraft) operating with an airworthiness certificate without the restrictions and conditions

proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a

secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will

be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, and

under the requirements and in compliance with local public safety requirements, to provide security

for the area of operation as is now done with conventional filming. The FAA will have advance

notice of all operations. These safety enhancements, which already apply to civil aircraft operated in

connection with motion picture and television production, provide a greater degree of safety to the

public and property owners than conventional operations conducted with airworthiness certificates

issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates

that there is no credible threat to national security posed by the UAS, due to its size, speed of

operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability

to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft & 14 C.F.R. Part 47. Aircraft Registration

These regulations require:

When marks include only the Roman capital letter "N" and the registration number is displayed on

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft,

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot

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

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

Central Rural Electric Cooperative will register all sUASs under the appropriate serial number in 

accordance with the referenced regulation.

Central Rural Electric Cooperative will mark the fuselage with a Registration Number as large as 

practicable in locations on the sUAS as feasible.
14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

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

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

current operations by requiring the PIC operating the aircraft to have at minimum a recreational

private pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a 

conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no 

living thing on board. The area of operation is controlled and restricted, and all flights are planned 

and coordinated in advance as set forth in the Manual. The level of safety provided by the 

requirements included in the Manual exceeds that provided by a single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The risks associated with the 

operation of the sUAS are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested 

with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) 

& (b).

14 C.F.R. Part 61, additional subparts

Central Rural Electric Cooperative requests the FAA to advise on the intended pilots licensing 

requirements. Central Rural Electric Cooperative intends to use employee(s) with a recreational 

pilot’s license but does have an employee with a commercial pilot certificate as well. When the FAA 

introduces sUAS specific regulations (such as 14 C.F.R. 107), Central Rural Electric Cooperative 

will transition to the appropriate licensure at that time

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

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

As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted,

no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft

and the requirements contained in the Manual for maintenance and use of safety check lists prior to

each flight an equivalent level of safety will be provided.

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

Section 91.9 (b) (2) provides:

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

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless

there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved

manual material, markings, and placards, or any combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on

the aircraft, not only because there is no pilot on board, but because there is no room or capacity to

carry such an item on the aircraft.

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

point where the pilot flying the sUAS will have immediate access to appropriate manuals.

14 C.F.R. § 91.103: Preflight action

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

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

exemption will be needed.
Central Rural Electric Cooperative can provide an equivalent level of safety as set forth in owner’s 

manual. The PIC will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon)

that is being used for flight instruction unless that aircraft has fully functioning dual controls.

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

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

radio communications. The FAA has approved exemptions for flight training without fully functional

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

The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried

in the aircraft and by the size and speed of the aircraft. Central Rural Electric Cooperative intends to 

provide flight instruction to be in accordance with the manufacturer’s guidelines and by utilizing the 

manufacturer’s ‘Beginner Mode’ function to instruct in-house pilots with the built-in flight simulator.

14 C.F.R. §91.119: Minimum safe altitudes

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

aircraft to be operated at less than the minimums prescribed. As this exemption is for a sUAS, the

exemption requests authority to operate at altitudes up to 200 AGL. As set forth herein, except for the 

limited conditions stated in the Manual, the UAS will never operate at higher than 200 AGL.

It will however typically be operated in a restricted area, where buildings and people will not be

exposed to operations without their pre-obtained consent. The equivalent level of safety will be

achieved given the size, weight, speed of the UAS as well as the location where it is operated. No

flight will be taken without the permission of the property owner or local officials. Compared to

flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed

herein and the lack of flammable fuel, any risk associated with these operations is likely less than

those presently presented with conventional aircraft. In addition, the low-altitude operations of the

sUAS will ensure separation between these small-UAS operations and the operations of conventional

aircraft that must comply with Section 91.119.

Central Rural Electric Cooperative also notes that the proposed operations covered under this 

exemption request are intended to be conducted near infrastructure for the purposes of their 

inspection. The operation of a sUAS so close to much larger structures would provide a negligible 

flight hazard to other aircraft compared to the tower or utility line itself.

14 C.F.R. §91.121 Altimeter Settings

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

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting

available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the

operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site

shown on the GPS altitude indicator before flight.

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

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

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

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

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”
Central Rural Electric Cooperative believes that an exemption from 14 CFR §91.151(a) falls within 

the scope of prior exemptions. Operating the small UAS, in a tightly controlled area where only 

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

less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was 

intended to alleviate given the size and speed of the small UAS.

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

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the

following:

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

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

(a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or

cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As 

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

on the sUAS.

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

point where the pilot flying the sUAS will have immediate access to them, to the extent they are

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation.

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

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

prescribed in subpart E of this part and shall between required inspections, except as provided in

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,”

and others shall inspect or maintain the aircraft in compliance with Part 43.

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

sections should not apply to Central Rural Electric Cooperative’s sUAS(s). Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating handbook as referenced in 

the Manual. An equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in restricted areas for limited periods 

of time. If mechanical issues arise the UAS can land immediately and will be operating from no 

higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in 

working order prior to initiating flight, 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.

Regulatory Relief from Other Sections as deemed appropriate by FAA

Central Rural Electric Cooperative requests additional relief, to the extent practicable, from 

provisions which the FAA has learned through the rulemaking process have proven impractical for 

the use of sUASs.

Exhibit A – Specific sUASs operated by Central Rural Electric Cooperative

DJI Inspire 1

DJI S1000

EXHIBIT B – FEDERAL REGISTER PUBLICATION VERBIAGE

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal
Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

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

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409

(a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs

or less) for the purposes of inspecting electrical and telecommunications infrastructure.

Approval of exemptions allowing these particular commercial operations of sUASs will enhance

safety by reducing risk. Conventional inspections require fixed wing aircraft, rotary winged aircraft

or qualified climbers to work on or around electrical and other hazards. In contrast, a sUAS weighing

fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced

mass and lack of combustible fuel carried on board as well as limiting risk to Central Rural Electric 

Cooperative personnel. 

The sUAS is transported or carried to the location and not flown. The sUAS will carry no passengers 

or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions outlined

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

herein, including exempting the applicant from the requirements of Part 21 and allowing commercial

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a controlled

environment and, as a result, are far safer than conventional operations conducted with manned

aircraft operating in close proximity to the ground and people.