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

- 20 1 4

- 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

- 063 3 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 t he FAA finds that a grant of exemption is in the pub lic 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 great er 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 mgod win@nee.com

.

1. Description of Aircraft Make and Model

NextEra proposes to use the following three different models of small unmanned aircraft system (“s UAS ”) for use in its proposed operations: DJI Phantom 2 Vision Plus ; 2 DJI Inspire 1 (T600) ; and DJI S900

. Appendix A provide s 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 M atter of the P etition 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 Page 2

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 condition s 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. A ll 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 s UAS 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

feature s as the three s UAS for which NextEra requests the waiver. This will allow NextEra to

use s UAS with additional functionality , and most importantly enhanced safety technology, without requesting an additional waiver for each UAS model. NextEra would follo w the same safety checklists, s UAS 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 r egarding 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 a n 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 certif ication of any person reporting a non

- valid driver ’s

license.

3 Federal Aviation Administration Docket FAA

- 2015

- 0150

, Operation and Certification o f 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 Page 3

NextEra Energy , Inc.

700 Universe Boulevard, Juno Beach, FL 33408 In addition, b ased on the FAA’s recent N PRM , 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 re ason 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 certific ate.

As the FAA has noted, t he “ 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 an d within visual line of sight

— significantly reducing t he impact of a subtle or sudden incapacitation of a sUAS Operator. Given the small size of the s UAS NextEra proposes to use and the low altitude and restricted environment in which they will operate, the traditional FAA medical

certification is not warran ted in this case. Moreover, r equiring 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 C hecklist

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

Please note that NextEra add ed 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 o f 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 a nd 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 Page 4

NextEra Energy , Inc.

700 Universe Boulevard, Juno Beach, FL 33408 5. Manufacturer’s User Guide

The follow ing user guides applicable to the three sUAS proposed for use by NextEra are provided in App endix 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 f or 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 g iven 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.

In stead, 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 licens e (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 NextE ra sUAS operators who meet requirements similar to those proposed by the FAA:

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

b e subject to the same background check as NextEra employees working around critical publ ic infrastructure ;Additional Information in Docket FAA

- 2014

- 0633 Page 5

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 o f 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 d amage to property ; and

o D emonstrate 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 imple ment 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 Next Era 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, s UAS 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 improvi ng 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 micr o 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

- describedAdditional Information in Docket FAA

- 2014

- 0633 Page 6

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

AttachmentsNextEra 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 438x451x301 mm

DJI S900 Rotorcraft 10.81 19.44 400 1000 Electric 15 10.8 0 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

- 5.825 GHz See Note 1 2412

- 2462MHz

5.725

- 5.825 GHz See Note 1

Notes: 1) DJI 900 r equires third

- p arty 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 interfer ence.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 co nducted 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 inte raction 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 pack ed 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 Ext inguisher 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

v icinity 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, en sure 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 imp act safe

operations

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

conditionsNextEra 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 pos ition

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 lin ks 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, r oles 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 ena ble 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 CoverNextEra 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