
U.S. Department of Transportation
December 31, 2014
Page Twenty-Two
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sd-654307
setting. An exemption is required to the extent that the S1000 does not have a barometric
altimeter setting. The altitude of the aircraft is monitored by the PIC on the ground control
station and by the visual observer.
Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be
achieved if the aircraft will be operated at or below 400 feet AGL and within visual line-of-
sight in addition to GPS based altitude information relayed in real time to the operator. See
Grant of Exemption No. 11062, p. 20-21. As the attached Manuals indicate, the S1000 will
be operated at or below 500 feet AGL and otherwise complies with the limitations in the
Grant of Exemption No. 11062.
K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR
Conditions
Consumers Energy Company requests an exemption from 14 C.F.R. § 91.151(a)’s fuel
requirements for flight in VFR conditions. Section 91.151 states:
(a) No person may begin 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.
Here, the technological limitations on S1000 battery power means that no meaningful flight
operations can be conducted while still maintaining a 30 minute reserve. The aircraft is
battery powered with a maximum flight time of 30 minutes. Consumers Energy Company
proposes that the maximum flight time for each operational flight will be 25 minutes. The
aircraft will be safely landed with no less than the greater of (a) 20% battery life remaining
or (b) five minutes of flight time remaining.
Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided
if the UAS flight is conducted under daytime VFR flight conditions using VLOS, and
terminated with at least 25% reserve battery power still available. See Grant of Exemption
No. 11062, p. 21-22. The Manuals providing an equivalent level of safety by safely landing
with no less than the greater of (a) 20% battery life remaining or (b) five minutes of flight
time remaining and otherwise complying with the flight restrictions above.
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