American Public Power Association

April 24, 2015 Federal Aviation Administration Docket Operations, M-30 US Department of Transportation 1200 New Jersey Avenue SE Room W12-140, West Buildings Ground Floor, Washington DC, 20590-001 To Whom It May Concern: The American Public Power Association (APPA), as part of this docket, joined in filing with the Edison Electric Institute (EEI) and the National Rural Electric Cooperative Association (NRECA) on the Federal Aviation Administrations (FAA) Proposed Rule governing the Operation and Certification of Small Unmanned Aircraft Systems. As noted in Note 3 of that joint filing, APPA is the national service organization representing the interests of non-profit, publicly-owned electric utilities. More than 2,000 public power systems provide over 15 percent of all kilowatt-hour sales to ultimate customers and operate in every state except Hawaii and provide electricity to U.S. territories such as Puerto Rico, Guam, and American Samoa. Collectively, public power utilities serve 48 million Americans. As state- and locally-owned entities, APPA members qualify as a government of a State, the District of Columbia, or a territory or possession of the United States or a political subdivision of one of these governments as described in 49 U.S.C. 40102(a)(41). Likewise, APPA members provision of utility services to residentsand provision of wholesale power to other public power utilitiesis a governmental activity and equipment used to conduct this activitysuch as routine inspection of electric power equipment or damage assessment of electric power equipmentis not being used for commercial purposes as defined under 49 U.S.C. 40125(b). As a result, APPAs comments filed jointly with EEI and NRECA on the FAA Proposed Rule for civil use of small UAS is based solely on the ability of APPA member utilities to opt to treat what would be public aircraft operations as civil aircraft operations. Conversely, APPAs joining in those comments should not be taken as in any way indicating that APPA believes its members use of aircraft would not qualify as public aircraft operations. As noted in our joint filing with EEI and NRECA, electric power reliability is critical to the economy, to life safety, and national security. Because UAS have such potential for the electric power utility sector, wethe electric sectorhope to work with the FAA to continue implementation of section 332 of the FAA Modernization and Reform Act (FMRA) by moving to integrate small UAS into the National Airspace System(NAS). Similarly, APPA hopes to work with the FAA as it continues to implement FMRA section 334 by expediting the issuance of certificates of authorization and expanding access to the NAS for public aircraft operations of UAS. Sincerely, Mike Hyland Senior Vice President, Engineering Services American Public Power Association