NextEra Energy, Inc.

700 Universe Boulevard, Juno Beach, FL 33408

February 26, 2015

Jake J. Troutman

Program Analyst – Rulemaking

FAA Office of Aviation Safety

Airmen and Airspace Rules Division

Re: Additional Information in Docket FAA-2014-0633

Dear Mr. Troutman:

Pursuant to your e-mail of February 12, 2015, NextEra Energy, Inc. (“NextEra”) provides the 

following additional information in support of its Petition for Exemption Pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012 (“Petition”) filed in Docket FAA-2014-0633 

on August 25, 2014: (1) description of aircraft make and model; (2) information regarding the 

radio frequency spectrum; (3) description of proposed pilot medical requirements; (4) pre-flight 

safety checklist; and (5) manufacturer’s user guide. 

NextEra is hopeful that the information provided in its Petition and with this letter provides an 

adequate basis to approve the Petition. For the reasons described in NextEra’s Petition, NextEra 

requests that the FAA finds that a grant of exemption is in the public interest. As the FAA has 

found in recent grants of exemption,1 “[t]he enhanced safety and reduced emissions achieved 

using a UAS with [appropriate specifications] and carrying no passengers or crew, rather than a 

manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, 

gives the FAA good cause to find that the UAS operation . . . is in the public interest.” If the 

FAA desires further information, please feel free to contact Mark Godwin at 561-694-4486 or

mgodwin@nee.com.

1. Description of Aircraft Make and Model

NextEra proposes to use the following three different models of small unmanned aircraft system 

(“sUAS”) for use in its proposed operations: DJI Phantom 2 Vision Plus;

2 DJI Inspire 1 (T600); 

and DJI S900. Appendix A provides descriptions and operating characteristics for three specific 

sUAS models proposed for use under this exemption. In addition, Appendix D provides user 

guides for the three models. All three craft are small (gross weight of 2.86 pounds, 7.49 pounds, 

and 18.07 pounds, respectively) and have speeds below 42 knots, significantly lower than the 87 

 1 See, e.g., Docket No. FAA-2014-0802, In the Matter of the Petition of Chevron USA, Inc. for an Exemption, Grant 

of Exemption at 13 (Feb. 13, 2015). 2 This is the same UAS for which the FAA approved a petition for exemption on behalf of Douglas Trudeau on 

January 5, 2015 in Docket FAA-2014-0481.
Additional Information in Docket FAA-2014-0633

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NextEra Energy, Inc.

700 Universe Boulevard, Juno Beach, FL 33408

knots recently proposed by the FAA.

3

 NextEra expects to conduct the vast majority of its 

operations with micro UAS of 4.4 pounds or less.

In addition to requesting a grant of waiver for use of to the three craft outlined in Appendix A, 

due to the low-risk proposed operating conditions under which NextEra will operate the UAS

(e.g. 400 feet above ground level maximum altitude, line of sight operations), NextEra requests 

authorization to use additional sUAS models that satisfy the following specific characteristics 

and performance criteria:

1. Propulsion: Electric 

2. Maximum Airspeed: 65 knots (75 mph)

3. Maximum Takeoff Weight: 19.84 pounds

4. All Communications in ISM (2.4 GHz or 5.8 Ghz) Bands that do not require an FCC 

license 

5. Other FAA Conditions to Ensure Safe Operations

Because sUAS technology is rapidly evolving, in order to achieve the benefits of the requested 

waiver over time, NextEra requests flexibility to upgrade to newer craft without burdening the 

FAA with amendments to the waiver. NextEra proposes that it be allowed to use craft that 

comply with the performance criteria outlined above and have at a minimum the same safety 

features as the three sUAS for which NextEra requests the waiver. This will allow NextEra to 

use sUAS with additional functionality, and most importantly enhanced safety technology, 

without requesting an additional waiver for each UAS model. NextEra would follow the same 

safety checklists, sUAS operator training, and other operating conditions that apply to the three 

craft specifically listed in this request.

2. Information Regarding the Radio Frequency Spectrum

Please refer to Appendix B for the information regarding radio frequency spectrum for the three 

sUAS described in Appendix A.

3. Description of Proposed Pilot Medical Requirements

In its Petition, NextEra proposed that in lieu of an airman medical certificate, NextEra’s UAS 

operators be required to hold a valid driver’s license.4

 NextEra will verify these drivers’ license 

numbers as part of the internal certification process, incorporate record driver license review into 

the pre-flight checklist, and maintain a log of sUAS Operators / Visual Observers’ driver’s

license numbers. As part of corporate procedures, any employee who is arrested or has a driver’s

license suspended must immediately notify their local management. NextEra will revoke all 

sUAS Operator or Visual Observer certification of any person reporting a non-valid driver’s

license.

 3 Federal Aviation Administration Docket FAA-2015-0150, Operation and Certification of Small Unmanned 

Aircraft Systems Notice of Proposed Rulemaking at 14 (Feb. 15, 2015) (“NPRM”). 4 Petition at 11. 
Additional Information in Docket FAA-2014-0633

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NextEra Energy, Inc.

700 Universe Boulevard, Juno Beach, FL 33408

In addition, based on the FAA’s recent NPRM, NextEra proposes that its grant of exemption 

include a prohibition on a person acting as an operator or visual observer if he or she knows or 

has reason to know of any physical or mental condition that would interfere with the safe 

operation of a small UAS. As the NPRM notes, this provision is similar to FAA rule 14 C.F.R. § 

61.53(b), which applies to operations that do not require a medical certificate.

As the FAA has noted, the “primary reason for medical certification is to determine if the airman 

has a medical condition that is likely to manifest as subtle or sudden incapacitation that could 

cause a pilot to lose positive control of the aircraft, or impair the pilots ability to ‘see and 

avoid.’”5 While a medical certificate with vision test is critical to pilots of manned craft, under 

this proposal NextEra will conduct sUAS flight operations at a maximum height of 400 feet and 

within visual line of sight—significantly reducing the impact of a subtle or sudden incapacitation 

of a sUAS Operator. Given the small size of the sUAS NextEra proposes to use and the low 

altitude and restricted environment in which they will operate, the traditional FAA medical 

certification is not warranted in this case. Moreover, requiring prescriptive medical requirements 

would be unduly burdensome in light of the limited nature of NextEra’s proposed operations. 

The medical self-certification required in FAA’s proposed UAS rules are appropriate here.

NextEra will include a thorough understanding of the importance of health certification in 

internal training and will require demonstrated knowledge as part of a written test for internal 

training of operators and visual observers.

4. Pre-Flight Safety Checklist

Please refer to Appendix C for the safety checklists NextEra proposes to use in its operations. 

Please note that NextEra added the following requirements to the pre-flight safety checklist, 

consistent with the FAA’s NPRM:6 

(1) Assess the operating environment, considering risks to persons and property in the 

immediate vicinity both on the surface and in the air. This assessment must include:

(i) Local weather conditions;

(ii) Local airspace and any flight restrictions;

(iii) The location of persons and property on the surface; and

(iv) Other ground hazards.

(2) Ensure that all persons involved in the small unmanned aircraft operation receive a 

briefing that includes operating conditions, emergency procedures, contingency 

procedures, roles and responsibilities, and potential hazards;

(3) Ensure that all links between ground station and the small unmanned aircraft are 

working properly; and

(4) If the small unmanned aircraft is powered, ensure that there is enough available power 

for the small unmanned aircraft system to operate for the intended operational time and to 

operate after that for at least five minutes.

 5 NPRM at 115.

6 NPRM at 185-186.
Additional Information in Docket FAA-2014-0633

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NextEra Energy, Inc.

700 Universe Boulevard, Juno Beach, FL 33408

5. Manufacturer’s User Guide

The following user guides applicable to the three sUAS proposed for use by NextEra are 

provided in Appendix D:

• Appendix D-1: Phantom II Vision Plus User Guide (DJI 2014)

• Appendix D-2: Inspire 1 User Manual (DJI 2014)

• Appendix D-3: S900 Users Guide (DJI 2014)

• Appendix D-4: Smart Battery Safety Guide (DJI 2014)

6. Flight Operations Manual

In addition to requiring operators to follow the operating directives in the user guides for the 

relevant model, NextEra will require operators to comply with an sUAS Flight Operations 

Manual developed by NextEra. Please refer to Confidential Appendix E for a draft of the sUAS

Flight Operations Manual. NextEra will revise the Flight Operations Manual consistent with 

conditions imposed by the FAA in its grant of exemption.

7. Supplemental Pilot Certification Information

NextEra’s Petition proposed that given the significant differences between sUAS and piloted 

aircraft, the safety features inherent in the sUAS, and the strict operating conditions that will 

apply, operators of the sUAS will not be required to hold a commercial or private pilot license. 

Instead, NextEra proposed to train and internally certify operators and observers based on:

• Proven knowledge of NextEra 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

• A valid driver’s license (in lieu of health certification)

Now that the FAA has proposed a framework for issuing airman certificates specifically for 

sUAS operators, NextEra proposes that the FAA apply that framework in this case and issue 

temporary airmen certificates to NextEra sUAS operators who meet requirements similar to 

those proposed by the FAA:

• If Transportation Security Administration vetting is not yet available, operators would

be subject to the same background check as NextEra employees working around 

critical public infrastructure;
Additional Information in Docket FAA-2014-0633

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NextEra Energy, Inc.

700 Universe Boulevard, Juno Beach, FL 33408

• Be at least 17 years old;

• Make available to the FAA, upon request, the small UAS for inspection or testing, 

and any associated documents/records required to be kept under the proposed rule; 

• Report an accident to the FAA within 10 days of any operation that results in injury 

or property damage; and

• Conduct a preflight inspection, to include specific aircraft and control station systems 

checks, to ensure the small UAS is safe for operation; and

• Pass knowledge testing on: 

o Roles/responsibilities of sUAS Operator and Visual Observer 

o Regulations applicable to small unmanned aircraft

o Classifications of specific airspace and requirements for operating in that 

airspace

o All operating limitations and conditions granted by the FAA for NEE sUAS 

flight operations

o Specific knowledge on sUAS model (must certify for each model used)

o Proficiency at performing safety checks (pre-field, pre-flight, and post-flight)

o Emergency procedures

o Reporting Requirements in case of injury to people or damage to property; 

and

o Demonstrate hands-on proficiency on basic, advanced, and emergency 

maneuvers on each model of small unmanned aircraft prior to certification for 

operational use of that craft.

NextEra maintains that the FAA has the authority to implement the temporary airmen certificates 

for sUAS operators pursuant to the FAA’s general waiver authority in 49 U.S.C. § 44701(f) and 

its Section 333 of the FAA Modernization and Reform Act of 2012 authority because the 

operating conditions proposed by NextEra would result in operations that would not adversely 

affect safety and would provide a level of safety at least equal to existing rules. As described in 

NextEra’s Petition, sUAS provide significant benefits for the power industry customers by 

improving reliability, managing costs, and reducing the risks associated with manned aircraft or 

the deployment of bucket trucks in close proximity to high-voltage equipment. In addition to 

improving worker safety, as the FAA discussed in the NPRM, sUAS provide less risk to person 

and property than comparable operations of manned craft, especially given that NextEra expects 

to conduct the vast majority of small unmanned aircraft operations with micro unmanned aircraft 

of 4.4 pounds or less. NextEra therefore requests that the FAA implement a temporary airmen 

certificate process to facilitate NextEra using sUAS operators meeting the above-described 
Additional Information in Docket FAA-2014-0633

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NextEra Energy, Inc.

700 Universe Boulevard, Juno Beach, FL 33408

qualifications to operate sUAS under the conditions outlined in NextEra’s Petition and in this 

letter.

I hope that you find the above information and appendices helpful in processing NextEra’s 

Petition. Please feel free to contact us or Mark Godwin (mgodwin@nee.com) should you need 

additional information or have any questions.

Best regards,

Charles Lande, Managing Attorney: charles.lande@nee.com

Amie Jamieson, Senior Attorney: amie.jamieson@nee.com

Attachments
NextEra Energy, Inc. Additional Information in Docket FAA-2014-0633

Appendix A Page 1

Appendix A: Description of Aircraft Make and Model

Model Aircraft

Type

Speed 

Cruise 

(knots)

Speed 

Max 

(knots)

Operating 

Altitude

(AGL ft)

Max

Altitude

(MSL ft)

Propulsion

Type

Endurance 

(min)

Payload 

Capacity 

(lbs)

Weight

Empty 

(lbs)

Weight

Max 

Gross 

(lbs)

Dimensions

Length x Width x 

Height 

DJI 

Phantom 

2

Vision 

Plus

Rotorcraft 15.76 29.16 400 1000 Electric 25 0.59 2.27 2.86 317x431x215mm

DJI 

Inspire 1

(T600)

Rotorcraft 15.76 42.76 400 1000 Electric 18(4500mah)

22(5200mah)

1.02 6.47 7.49 438x451x301mm

DJI S900 Rotorcraft 10.81 19.44 400 1000 Electric 15 10.80 7.27 18.07 460×450×360mm

Notes: 

1) Information provided by DJI

2) Max Altitude DJI S900 based on 2.4GHz control frequency

3) DJI Inspire 1 Endurance provided for 2 battery sizes (4500mah and 5200mah)
NextEra Energy, Inc. Additional Information in Docket FAA-2014-0633

Appendix B Page 1

Appendix B: Information Regarding the Radio Frequency Spectrum

Model Aircraft

Control

Video 

(Including Range Extender)

Operating

Frequency 

Transmitter

Power (EIRP)

Operating

Frequency

Transmitter

Power

DJI Phantom 2

Vision Plus

5.728 GHz-5.85 GHz 100mw 2412-2462MHz 20dBm

DJI Inspire 1

(T600)

5.725-5.825 GHz 13dBm@5.8G 2.400-2.483 GHz 20dBm@2.4G

DJI S900 2412-2462MHz

5.725-5.825GHz

See Note 1 2412-2462MHz

5.725-5.825GHz

See Note 1

Notes: 

1) DJI 900 requires third-party radio transmitters and receiver. NextEra would only use those operating on unlicensed 2.4GHz or 5.8GHz 

spectrum at FCC compliant power levels.

2) All craft to operate under ISM (Industrial, Scientific and Medical) radio bands reserved by the FCC for unlicensed communication. All 

devices proposed for NEE use are FCC compliant. Craft utilize frequency hopping within the designated range to avoid interference.
NextEra Energy, Inc. Additional Information in Docket FAA-2014-0633

Appendix C Page 1

Appendix C: NextEra Energy sUAS Safety Checklists

Note: NextEra Energy, Inc. (NextEra) proposes to require the use the following Daily Flight 

Planning, Pre-Takeoff , Post-Flight, and Emergency Checklists for sUAS operations conducted 

pursuant to its Petition for Exemption. NextEra requests permission to update checklists with 

additional equipment (e.g. hard hats, safety glasses) and process improvements to ensure the 

safety of our workers, customers, customer property and interaction with the national airspace. 

NextEra will also include other checklist items the FAA proposes. 

Daily Flight Planning

 sUAS Operator NextEra Energy Certified 

 Visual Observer NextEra Energy Certified 

 sUAS Operator and Visual Observer Possess Valid Driver’s Licenses

 SUAS Operator and Visual Observer wearing glasses or contact lenses if required by driver’s 

license

 No known medical condition (physical or mental) that could impact safe operations

 Toolkit packed for field with spare batteries, propellers, propeller wrenches, spare fuselage, 

spare controller batteries, charge cables for all batteries including range extender, and other 

field replacement parts to ensure craft is ready for safe operations

 Fire Extinguisher and First Aid kit packed for field

 Corporate Security notified of planned daily flight operations

Pre-Takeoff

 Daily Flight Planning Checklist complete

 Assess the operating environment, considering risks to persons and property in the immediate 

vicinity both on the surface and in the air. This assessment must include:

o Local weather conditions;

o Local airspace and any flight restrictions;

o The location of persons and property on the surface; and

o Other ground hazards.

 Propellers show no sign of damage or significant wear

 Propellers inspected and tightened as required

 Fuselage screws inspected and tightened as required

 Flight batteries show no sign of damage, physical distortion, or any signs of abnormality 

 If the small unmanned aircraft is powered, ensure that there is enough available power for the 

small unmanned aircraft system to operate for the intended operational time and to operate 

after that for at least five minutes

 Major vehicle components inspected for damage, or signs of wear that could impact safe 

operations 

 sUAS Operator & Visual Observer agree flight can be conducted safely and within operating 

conditions
NextEra Energy, Inc. Additional Information in Docket FAA-2014-0633

Appendix C Page 2

 Aircraft positioned in safe, level position for take-off

 All controller switches (S1 and S2 for DJI Phantom) are in the upper most position

 Both controller sticks placed into the neutral position

 Controller LED shows battery charged

 Range Extender LED shows battery charged

 Flight Battery is securely locked in place and LED indicator displaying a minimum of 75% charged

 Ensure that all links between ground station and the small unmanned aircraft are working 

properly 

 Ensure that all persons involved in the small unmanned aircraft operation receive a briefing that 

includes operating conditions, emergency procedures, contingency procedures, roles and 

responsibilities, and potential hazards

Post-Flight Checklist

 Stop all motors 

 Turn off battery, remove from aircraft

 Visually inspect craft for any sign of damage or unusual wear

 Log flight information

Emergency Checklist

Perform in case of injury to any person or property damage (except for minor aircraft 

damage)

 Contact Corporate Security

 Contact Local Authorities if Needed

 Record Complete Information about day, time, location, aircraft, the incident, and any other 

information that will enable NEE, local authorities and the FAA to understand the event and 

impact on people and property.
NextEra Energy, Inc. Additional Information in Docket FAA-2014-0633

Appendix D Page 1

Appendix D: 

User Guides

Provided Under Separate Cover
NextEra Energy, Inc. Additional Information in Docket FAA-2014-0633

Appendix E Page 1

Appendix E: 

NextEra Draft sUAS Flight Operations Manual

Provided Under Separate Cover

CONFIDENTIAL AND PROPRIETARY