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U.S. Department of Transportation

December 31, 2014

Page Four

sd-654307

IV. DESCRIPTION OF PROPOSED OPERATIONS

Consumers Energy Company is requesting exemptions from applicable Federal Aviation

Regulations (FARs) pursuant to Section 333 of the Reform Act to perform research and

development using the DJI S1000 UAS. Key areas of focus for Consumers Energy

Company’s research and development are (i) public and worker safety; (ii) safe and timely

power restoration following storms; and (iii) new methods to effectively inspect power lines,

electrical facilities, vegetation and rights of way.

Consumers Energy Company is committed to improving power reliability for customers by

more safely and quickly restoring power to customers after storm related damage to the

electrical system. The Michigan Public Service Commission has emphasized to Consumers

Energy Company the importance of reducing outage response time, a critical component of

which is more accurate and timely storm damage assessment presently conducted by

employees in motor vehicles or on foot. Use of the S1000 will help to reduce power

restoration time and safety-related incidents involving employees working in adverse

weather conditions.

Additionally, current inspections of high voltage (HVD) power lines are done one to two

times a year by helicopter. Use of the S1000 will allow such inspections at considerable

savings, as well as reduce safety risks because the drone will not carry a flammable fuel

source. The S1000 will also allow better visual inspection of facilities installed on poles, as

helicopter inspection of a utility pole usually involves less than 5 seconds of visual

inspection.

Further, inspections of lower voltage power (LVD) lines are typically done by motor vehicle

or on foot. Due to visibility limitations based on the design of utility poles, a certain portion

of the pole and its facilities is never inspected. Using the S1000 to do LVD inspections will

increase their effectiveness, decrease their safety risks, and reduce the time needed for the

inspection cycle.

Thus, the research and development use proposed here will allow Consumers Energy

Company to determine the efficacy of the S1000 for increasing public safety, restoring

outages in a safe and timely manner, and creating new methods for inspecting electrical

facilities.

The research and development use will take place on six Michigan research and development

test sites (the R&D Sites) located in Jackson County, Tuscola County, and Mason County.

The sites are owned by Consumers Energy Company and have low nearby residential

populations. Two sites will focus on UAS research and development for power line

monitoring; four sites will focus on UAS research and development for wind turbine

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