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U.S. Department of Transportation

December 31, 2014

Page Two

sd-654307

 14 C.F.R § 91.203 (a) & (b);

 14 C.F.R § 91.405(a);

 14 C.F.R § 91.407(a)(l);

 14 C.F.R § 91.409(a)(2);

 14 C.F.R § 91.417 (a) & (b).

This petition incorporates the material contained in the Consumers Energy Company

Operations, Inspection, and Maintenance Manual, the DJI S1000 User Manual, the A2 Flight

Control System User Manual, the Consumers Energy Company S1000 Pilot Operating

Handbook, and the Consumers Energy Company S1000 Training Manual (together, the

“Manuals”). The Manuals are submitted herewith as confidential under 14 C.F.R. § 11.35(b),

because they contain commercial and proprietary information that Consumers Energy

Company has not and will not share with others, is not available to the public, and is

protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.

II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS

This petition for exemption is submitted in accordance with Section 333 of the Reform Act.

Congress has directed the FAA “to safely accelerate the integration of civil unmanned

aircraft systems into the national airspace system.” Pursuant to Section 333 of the Reform

Act, the FAA Administrator is to permit operation of an unmanned aircraft system where it

does not create a hazard to users of the national airspace system (NAS) or the public or pose

a threat to national security based on the following considerations:

 The size, weight, speed and operational capability;

 Operation in proximity to airports and populated areas; and

 Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to

grant exemptions from the agency’s safety regulations and minimum standards when the

Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§

106(f), 44701-44716, et seq. A party requesting an exemption must explain the reasons why

the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect

safety or how it would provide a level of safety at least equal to the existing rules. 14 C.F.R.

§ 11.81.

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