27 May 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave

. , SE Washington

, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pur suant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11, ISight RPV Services, LLC seeks an exemption from the Federal Aviation Regulations ("FARs") listed below and discussed in Appendix A. This exempt ion is derived from a request by Aeryon Labs LLC ("Aeryon"), the developer and operator of the Scout and SkyRanger small 8QPDQQHG$LUFUDIW6\VWHPVV8$6°

. Details of Aeryon and the SkyRanger sUAS are described in AppendixB. Attached as Appendix C is a s ummary of this request.

The requested exemption would permit ISight RPV Services, LLC commercial operation of Aeryon's SkyRange r (see details in Appendix B), which weighs 6 lbs. with imaging payload, to perform Market Research, Aerial Surveys, Mapping, Te sting

, and Inspections that consist of still photographs, video, and other data taken by onboard sensors. The SkyRanger produces high quality imagery and data that can be used independently

- or in the case of surveying and modeling, can be combined to pro duce precision digital point clouds, triangle models, and contour maps of the surveyed area

. Applications for these sUAS include inspection of sensitive infrastructure i ncluding oil and gas pipelines and flare stacks, power lines and towers, wind turbines, and surveying tasks such as precision agriculture, mining, transportation, cellular/radio frequency and other antenna inspections, sh i pping and receiving containers and logistics stations, ranch and cattle operations, snow skiing industry, search and resc ue , facility security

, Law Enforcement operations, and forestry. Use of the SkyRanger for these inspection and surveying applications reduces the need to operate conventional aircraft, providing data more quickly, accurately

, economically, safely, and with reduced environmental impact.

Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level of safety to currently authorized operations using manned aircraft
and under conditions as may be modified by the FAA as required by Section 333.

ISight RPV Services, LLC is requesting exemption to allow the commercial operation of the SkyRanger at our designated and approved facilities, farms

, mines, and other sites that require aerial
data a nd analysis for inspections and surveys

.

As described more fully below, the requested exemption would authorize ISight RPV Services, LLC to perform market research, analysis

, and commercial operations of aerial inspections and surveys using the SkyRanger 1

, which at 6 l bs. is small i n size and powered electrically by battery

. The SkyRanger

1 Aeryon and its customers have been granted many flight operations certificates to operate the Aeryon SkyRanger, and its predecessor the Aeryon Scout

± including Special Flight Operations Certificates in
Canada for comm ercial use, and Certificates of Waiver or Authorization (COA) in the US for public

agency use.will be operated under controlled conditions at low altitude in airspace that is limited in scope, as described more fully herein; it will have automated control features , as described below

. The Aeryon SkyRanger is designed to be operated by one person, but flight operations generally involve two people: an operator and an observer. The operator is responsible for flying the sUAS, monitoring its status and flight dynamics while maintaining visual line of sight, and keeping the flight within the specified factory limits (in terms of wind, flight range, battery life, etc) to ensure safe operation of the sUAS itself. The observer is responsible for monitoring the airspace for other aircraft and hazards and instructing the operator before and during flight as necessary to ensure safe separation/de

- confliction
with these aircraft and hazards. The operator also will be an individual who has passed an FAA approved or equivalent gr ound training exam and authorized Aeryon training program for the SkyRanger. Finally, the airspace in which the SkyRanger will operate will be disclosed to and approved, as needed, by the FAA in advance.

ISight RPV Services, LLC respectfully submits that because this small, unmanned aerial system

- the SkyRanger

- will be used in lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft, the FAA can have confidence that the operations will achieve at least

an equivalent level or greater level of safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish requirements for the safe operation of such aircraft systems in the national airspace system."

The name and address of the applicant are:

ISight RPV Services, LLC

. Attn: Mr. Nathaniel A. Leben and Mr. Adam D. Lingwall
Ph: 760.490.2597 Ph: 763.706.7945
Email: Nathan iel.Leben@isightrpv.com Email: Adam.Lingwall@isightrpv.com Mailing Address: 3816 Reserve Drive East, West Fargo ND 58078 Business Address: Center for Innovation, University of North Dakota, 4200 James Ray Drive, Grand
Forks ND 58203

The primary contac t for this application is: Mr. Nathaniel A. Leben and/or Adam D. Lingwall

The regulations from which the exemption is requested are as follows:

14 C

. F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103;

1 4 C.F.R. 91.109(a); 14 C.F.R. 91.119;
14 C.F.R. 91

. 151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2);

14 C.F

. R. 91.417(a).Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in this letter are appropriate, provide an equivalent level of safety

, and are in the public interest.

T H E A P P L I C A B L E L E G A L S T A N D A R D U N D E R S E C T I O N 3 3 3

ISight RPV Services

, LLC submits that grant of this exemption applic ation for use of the SkyRanger in market research, analysis, surveying, mapping and inspections, commercial and local government uses
that focus on safety, the reduction of overall costs of operations, and the ability to reduce the need for
actual "manned" aircraft, thus reducing potential risk to personnel. The SkyRanger would be utilized with a variety of interested parties in the commercial sector to include, but not limited to electrical power companies, oil/gas companies, railroad, precision agricultur e, forest industry, and Law Enforcement. Tower inspections can be conducted on antenna towers, electrical transmission lines, and wind turbine towers without having to have a manned aircraft fly over the top of a tower, because the SkyRanger can perform th at function, and it reduces the actual climbing of the tower by a technician to inspect the tower

. In the forest industry the SkyRanger can assist ranchers with locating cattle, utilize sensor equipment to locate too much undergrowth thus reducing forest f ire activity, uses in recreation with snow skiing locating skiers and identifying potential avalanche concerns

. Oil pipeline inspections and railroad inspections could reduce the amount of resources needed to conduct these inspections and identify at early stages potential hazards reducing risk. The SkyRanger would be used in law enforcement, large event venues, and physical security protection providing additional tools with the purpose of keeping the public safe will advance the Congressional mandate in S ection 333 of the Reform Act to accelerate the introduction of sUASs into the national airspace system ("NAS") if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether certain sUASs may operate safely in the NA S before completion of the rulemaking required under Section 332
of the Reform Act. In making this determination, the Secretary is required to determine which types of sUASs do not create a hazard to users of the NAS or the public or pose a threat to natio nal security in light of the following:

x The sUAS's size, weight, speed, and operational capability;

x Operation of the sUAS in close proximity to airports and populated areas; and

x Operation of the sUAS within visual line of sight of the operator.

Reform A ct § 333(a)(1). If the Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." I d

. §333(c) (emphasis a dded). 2

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §401 01 of the Act, from the requirement that all civil ai rcraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702

- 44716 of this title if the

2 Applicant submits that this provision places a duty on the Administrator to not only process applications for exemptions under Section 333, but for the Adminis trator if he deems the conditions proposed herein require modification in order to allow approval, to supply conditions for the safe operation of the sUAS . Aeryon welcomes the opportunity to consult with FAA staff in order to address any issues or concern s that this proposal may raise that they believe may require modification.Administrator finds the exemption is in the public interest.

49 U.S.C

. §44701(f). See a l s

o 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1). The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent
level of safety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to sUASs for aerial surveying, mapping and inspection applications. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay

.

A i r w o r t h i n e s s o f t h e S k y R a n g e r

A critical element of the exemption application involves evidence of the airworthiness of Aeryon sUAS including the SkyRanger. Aeryon believes that it has shown compliance through a history of granted flight operations an d successful flights

- including many operations with public agencies. The list of granted applicants includes: Michigan State Police, US Navy Spawar, Mass Development (Joint Base Cape Cod), Unmanned Experts (NIJ Partnership}, Western Washington University, Aetos (via Northwest Michigan College), University of Alaska Fairbanks, University of New Mexico, Kansas State University, and Virginia Tech University. The SkyRanger has also successfully completed the Department of Homeland Security RAPS Trial in 2013. In Canada, Aeryon has obtained 19 Special Flight Operations Certificates (SFOCs) from Transport Canada over 5 years and its customers have received multiple certificates to perform demonstration, research and development, public and commercial operations. The criteria set forth in the certificates granted specify the substantive showings of the device's safety and fitness for operation to ensure that the FAA has sufficient basis to evaluate the aircraft's safety 3

. The SkyRanger also has a significant set o f automated features to ensure safe takeoff, flight and landing in many conditions, further details of operation can be found in Appendix B.

M a n d a t o r y O p e r a t i n g C o n d i t i o n s

Grant of the exemption to ISight RPV Services, LLC will be subject to the followin g mandatory conditions, which are based upon operating conditions set forth for operation of sUAS by public entities pursuant to Certificates of Authorization, with additional restrictions:

x All operations to occur in Class G airspace.

x Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts. Operations to be conducted over private or controlled

- access property.

x Permission from land owner/controller required before commencing any flight.

x Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

x Aircraft to remain within Visual Line of Sight (VLOS).

o VLOS guaranteed with a cylinder of operation around operator of 1 /

2 nautical miles (NM).

o Cylinder walls may be expanded by observer with ability to contro l aircraft.

x Operations to occur during daylight hours.

x Above Ground Level (AGL) altitude to be restricted to 400 feet.

3 Aeryon can submit under confidentiality the following documents in support of this exemption application for the SkyRanger: 1) Aeryon SkyRanger User Guide (Exhibit 1) which includ es Safety and PreFlight Checklists; and 2) Training Manual (Exhibit 2).x All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway centerline measured from r unway thresholds.

x Operator will file a NOTAM for each flight.

x All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

x A ll operations will include one pilot for flight control and one observer for VLOS enhancement of surrounding area near the aircraft

O p e r a t o r R e q u i r e m e n t s

ISight RPV Services, LLC shall require that operators of the SkyRanger hold a commercial
certificati on and have completed Aeryon ' s authorized training program for operation and maintenance
of the sUAS. 4

ISight RPV Services, LLC notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the cas e of operations pursuant to public COAs when the mandatory operating conditions specified above were present. S e

e Federal Aviation
Administration

, Notice N

- 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20

- 21 (July 30, 2013). The FAA ha s the statutory authority to grant exemptions to the requirements for and privileges associated with the grant of airmen's certificates

. 49 USC §44701(f).

In summary, ISight RPV Services, LLC seeks an exemption from the FARs set forth above and in Appendi x C to allow market research and commercial operations of a small unmanned vehicle in surveying, mapping, inspections, and areas pertaining to commercial and government uses. Each industry has their own uses for this technology either by the use of cameras to obtain a visual inspection (i.e. electrical transmission lines, oil/gas pipelines, bridges, towers, law enforcement needs

, etc.), the use of various sensor equipment to identify certain chemicals in the air, certain biological identifiers in plants or animals, heat/cold sensors, radiation sensors, etc

., in order for the customer to collect data with the ability to analyze the information for their mission and tasking. As the small unmanned vehicle operator, we would work with the various commercial and government users on their goals and objectives based on their criteria and mission. ISight RPV Services, LLC would in turn work with the customer, create a plan to accomplish their mission, and establish the proper flight protocols following the FAA guide lines. This creates an environment of safe flight operations by a commercial pilot using the specific sUAS this exemption has identified

.

Approval of the exemption allowing commercial operations of the SkyRanger for surveying, mapping, and inspections ope rations will enhance safety by reducing risk

. Conventional aerial survey and inspection operations using manned aircraft involve very heavy aerial vehicles carrying significant quantities of combustible fuels, and a multi

- person crew in piloting and observ ation roles. These operations require transit to and from the location of the activity, and often take place in congested environments including proximity to physical obstacles and/or presence of the general public. By contrast, the Skyranger weighs 6 lbs including payloads and uses a battery for power, is carried to/from

4 As of July 2014, Aeryon staff and customers have performed over 5681 flights, logging 623 hours of flight time with the SkyRanger with both development and release versions. The pre vious generation product, Scout, achieved over 7197 flights and 839 hours of flight time globally by Aeryon and its customers. This is a significant amount of flight time collected to understand and refine the Aeryon sUAS products.the area of activity, removes the need for airborne pilots/observers

, and poses less risk to people and infrastructure on the ground. Additionally, no national security issue is raised by the grant of the requested exemptions. Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or other dangerous materials, the SkyRanger poses no threat to national security.

The operation of the S kyRanger for market research, surveying, mapping and inspection operations in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting ISig ht RPV Services, LLC from the requirements of Part 21.

The SkyRanger's satisfaction of the criteria set forth in Section 333 of the Reform Act

- size

, weight

, speed, operating capabilities, lack of proximity to airports and populated areas, operation within visual
line of sight, and national security

- and its showing of an equivalent level of safety as it may relate to the requirement for a pilot ' s license, provide more than adequate justification for the grant of the requested exemptions allowing ISight RP V Services, LLC commercial operation of the SkyRanger in market research, surveying, analysis, mapping and inspection operations.

Very Respectfully,

Mr. Nathaniel A. Leben ISight RPV Services, LLCA P P E N D I X A

E X E M P T I O N R E Q U E S T A N D E Q U I V A L E N T L E V E L O F S A F E T Y S H O W I N G S U N D E R
A P P L I C A B L E R U L E S S U B J E C T T O E X E M P T I O N

ISight RPV Services, LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the SkyRanger:

1 4 C

. F

. R

. P a r t 2 1

, S u b p a r t H : A i r w o r t h i n e s s C e r t i f i c a t e s 1 4 C F R § 9 1

. 2 0 3 ( a ) ( 1 )

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the pr ocedural requirements for the issuance of airworthiness certificates as required by FAR§ 91.203(a)(1). Given the size of the aircraft (6 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate

o f airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels

.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section

333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize
the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the
sUAS involved.

In this case, an analysis of these criteria demonstrates that the SkyRanger operated without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer

, than a conventional aircraft (fixed wing or rotorcraft) wit h an airworthiness certificate. The SkyRanger weighs 6 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an area pre

- disclosed and in compliance with conditions set forth herein.

O perations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the conditions set forth above, and by local public safety requirements. The FAA will have advance notice of all operations through the filing of NOTA Ms. Receipt of the prior permission of the land owner, the size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level of safety. The SkyRanger provides at least an equivalent, and most likely exceeds 5

, level of safety to that of such operations being conducted
with conventional aircraft that would be orders

- of

- magnitude larger and would be carrying passengers

, cargo, and flammable fuel. The automated safe ty features including redundant sensor systems as described in Appendix Band throughout this document highlight the design intentions towards safety and reliability on SkyRanger.

1 4 C

. F

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. § 4 5

. 2 3 & 9 1

. 9 ( c ) : M a r k i n g o f t h e A i r c r a f t

5 An Aeryon internal re port compares the crash kinetic energy dissipation rate of a commercial airline versus the Aeryon SkyRanger. The report found the MTTF of SkyRanger needs to only be >2.3 hours to equal the energy dissipation of the gold standard commercial aircraft. Trans port Canada has issued a report on low energy RPA and determined the Aeryon Scout to be well below the peak energy level of 12J/cm2 on impact, since the SkyRanger is similar in construction it could be considered to be
below this threshold as well.Regulation 45.23 provi des: (a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter "N" (denoting United States registration) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed m ust also be a Roman capital letter. (b) When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operat or must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicab le.

Regulation 91.9(c) provides: No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter.

The SkyRanger has no entrance to the cabin, cockpit, or pilot station on which the mark ings can be placed. Given the size of the sUAS, two

- inch lettering will be impossible. Official marking systems for VPDOO8$6KDYHQ¶WEHHQHVWDEOLVKHGIRURSHUDWLRQVLQVLGHWKH1$67KH6N\5DQJHULVFXUUHQWO\ marked with a fixed label containing Aeryon Lab s SkyRanger measuring 1.5" x 0.5" as well as a serial number located under the removable camera payload. ISight RPV Services, LLC is prepared to mark the inspection system with the name of the organization and location or origin and fulfill any other

reque st by the FAA to this topic in accordance to§ 45.29(f) where the pilot, observer, and others working with the sUAS will see the identification of the sUAS.

The FAA has issued the following exemptions to this regulation; see Exemption Nos. 8738, 10167,

101 67A and 10700.

1 4 C

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. § 9 1

. 7 ( a ) : C i v i l a i r c r a f t a i r w o r t h i n e s s

.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the SkyRanger wit hout an airworthiness certificate, no standard will exist for airworthiness of the SkyRanger. Given the size of the aircraft and the previous COAs issued for Aeryon's Scout and SkyRanger, an equivalent level of safety will be achieved by ensuring complianc e with the Aeryon manuals prior to each flight.

1 4 C

. F

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. § 9 1

. 9 ( b ) ( 2 ) : C i v i l A i r c r a f t F l i g h t M a n u a l i n t h e A i r c r a f t

.

The regulation provides: No person may operate a U.S

. - registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manua l is not required by §21.5 of this chapter,
unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

Given the size and configuration o f the SkyRanger, it has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual ( s

e

e

, e

. g

. , SkyRanger User Guide, Exhibit 1) at the ground control point where the pilot flying the sUAS will have immediate

access to it. The FAA has issued to others the following exemptions to this regulation: Exemp tion Nos. 8607,8737,8738,9299, 9299A, 9565,95658,10167, 10167A, 10602,32827, and 10700.1 4 C

. F

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. § 9 1

. 1 0 3 : P r e f l i g h t a c t i o n

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA app roved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in the SkyRanger User Guide (Exhibit 1) under the 'Getting Ready to Fly' section. The PIC will ta ke all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

1 4 C

. F

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. § 9 1

. 1 0 9 ( a ) & 9 1

. 3 1 9 ( a ) ( 1 ) : F l i g h t I n s t r u c t i o n

These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

The SkyRanger is a remotely piloted aircraft and by design, does not have fully function al dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The flight plan is either manually controlled through point

- and

click touchscreen navigation or pre

- programmed a s way points or an AutoGrid into the auto pilot before or during flight and only in unusual circumstances will the pilot input control functions to alter the pre

- programmed flight. If instruction is accomplished through a training program, as set forth in
Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. S e

e Exemption Nos. 5778K & 9 862A. The equivalent level of safety will be achieved by the manufacturer providing the training as outlined, for example, in Exhibit 2 and through the use of experienced and qualified pilots familiar with the SkyRanger.

1 4 C F R § 9 1

. 1 1 9 : M i n i m u m S a f e A l t i t u d e s

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populate d areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the SkyRanger will never operate at higher than 400 feet AGL. It will, however, be operated to avoid congeste d or populated areas that are depicted in yellow on VFR sectional charts. Because aerial survey, mapping and inspection work must be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is ne eded.

The equivalent level of safety will be achieved given the size, weight, speed, and material with which the SkyRanger is built. Also, no flight will be taken without the permission of the land owner or those
who control the land. Because of the advan ce notice to the landowner, all affected individuals will be

aware of the flights. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more than 6 lbs. and carrying flammable fuel, any risk associated with these operatio ns will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low

- altitude operations of the sUAS will maintain separation between these sUAS operations and the operations of conventional aircra ft that must comply with Section 91.119.1 4 C

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. § 9 1

. 1 5 1 ( a ) : F u e l R e q u i r e m e n t s f o r F l i g h t i n V F R C o n d i t i o n s

This regulation prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast we ather 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."

The SkyRa nger batteries provide approximately 50 minutes of powered flight. Without an exemption from § 14 CFR 91.151, the sUAS's flights would be limited to approximately 20 minutes in length. Given the limitations on its proposed operations and the location of th ose proposed operations

, a longer time frame for flight in daylight VFR conditions is reasonable.

ISight RPV Services, LLC believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. S e

e Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151 (a)). Operating the sUAS, without 30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at which the sUAS op erates. The fact that it carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting SkyRanger flights to 20 minutes would greatly reduce their utility. In the unlikely event that the SkyRanger should run out of fuel, it would si mply land. Given its weight and construction material, the risks are less than contemplated by the current regulation.

ISight RPV Services, LLC believes that an equivalent level of safety can be achieved by maintaining 10 minutes of reserve fuel, which, a llowing 40 minutes of flight time, would be more than adequate to return the sUAS to its planned landing zone from anywhere in its operating area.

The FAA has granted similar exemptions to others, including Exemptions 2689F

, 5745, 10673 and

10808.

1 4 C

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. § 9 1

. 2 0 3 ( a ) & ( b ) : C a r r y i n g C i v i l A i r c r a f t C e r t i f i c a t i o n a n d R e g i s t r a t i o n

This regulation provides as follows: (a) ... no person may operate a civil aircraft unless it has an appropriate and current airworthiness
certificate. (b) No person may opera te a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The SkyRan ger fully loaded weighs approximately 6 lbs. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. In addition, there is no pilot
on board the aircraft.

An equivalent level of safety will b e achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos.
9565

, 9665,9789, 9789A

, 9797, 9797A, 9816A,and 10700.1 4 C

. F

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. § 9 1

. 4 0 5 ( a ) ; 4 0 7 ( a ) ( 1 ) ; 4 0 9 ( a ) ( 2 ) ; 4 1 7 ( a ) : M a i n t e n a n c e I n s p e c t i o n s

Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as prescribed in sub part E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter

... " Section 91.407 similarly makes reference to requirements in Part 43; S ection 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by
certificated mechanics

, und er Part 43

, or licensed pilots and records of approval of the aircraft for
return to service.

The SkyRanger is nearly maintenance free, it performs automatic pre

- flight checks and the failure of any check will prevent take

- off. Checks which cannot be done by the system will be performed by a qualified person prior to each flight and at predefined intervals as part of the Maintenance Schedule in the User Guide (see Exhibit 1).

Pre

- flight checklist includes:

1. Visual inspection of the airframe

2. Visual inspecti ons of rotor integrity

3. Check charge of all batteries (aerial vehicle, command station, radio repeater station)

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restricte d predetermined areas and is not a complex mechanical devise. As provided in the attached User Guide (System Maintenance section), the operator of SkyRanger will ensure that the sUAS is in working order prior to initiating flight

, perform required maintena nce, and keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety.

The SkyRanger 's Maintenance guidelines ensure an equivalent level of safety to the maintenance requirements in Part 91. In addition, any component failure detectable by the system will be reported to the control station and will cause the UAV to perform a Fatal Conditi on Response (FCR) or Non

- Fatal Conditioned Response (NFCR), depending on the type of failure.A P P E N D I X B

S M A L L U N M A N N E D A E R I A L S Y S T E M D E S C R I P T I O N

ISight RPV Services, LLC Corporate Overview: ISight RPV Services, LLC is a North Dakota

- based

Veteran

- owned Operations company. ISight RPV Services provides Operational Field Support (OFS) to the Intelligence Community, Law Enforcement, Search and Rescue, Government and Military entities. ISight RPV Services have supported worldwide UAS opera tions in the Middle East, as well as, Africa and Central/South America.

Aeryon sUAS systems have been approved by the FAA for research COAs and have a demonstrated safety track record. The Aeryon sUAS platforms were the first to officially fly at one of t he FAA's UAS Test Sites (UAF Alaska). Many customers from military, to education to police and even commercial operations have been given approval to fly in US, Canada, UK, Australia, Japan, and others airspaces.

SkyRanger Overview: Aeryon unmanned system s have been used to fight terrorism in Iraq, Afghanistan and Nigeria, monitor hostile borders between Saudi Arabia and Yemen, ensure the safety of world leaders at the G50 Nuclear Summit in Seoul, escort a fuel tanker and ice breaker into a remote
Alaskan community, monitor wildlife on the Aleutian Islands, map remote communities in South America, keep our highways clear and safe; and provide volumetric analysis for open pit mines.

The Aeryon SkyRanger can carry payloads up to 600 g. The SkyRanger flies wi th a maximum wind threshold of 40 M.P.H. for sustained winds and wind gusts up to 55 M.P.H

.. What is unique about the Aeryon SkyRanger is the system automatically compensates for wind versus relying on the operator's
'sense of feel' for what the impact of the wind is at the altitude the system is flying. The end result is a system capable of gathering high quality aerial intelligence at much higher wind thresholds. A trait that is imperative for many aerial inspection operations.

The SkyRanger has an opera tional range of up to 3 km (1.6 NM) with the standard offering and up to 5 km (2.7 NM).

All flight operations are GPS controlled making the system extremely easy to navigate. At any point if the operator is not explicitly commanding the system to move, th e system automatically holds its GPS position (i.e

. GPS hold for reliable location hover). Camera positioning is also GPS controlled allowing for the most sophisticated camera targeting available. The flight control system employs not only GPS positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure the most stability of any system in its class

- regardless of the wind.

The Aeryon SkyRanger can be operated in both semi and fully autonomous flight modes. Creating preplanned flight paths to fly in autonomous mode is as simple as clicking on the map to create a preplanned flight path. In semi

- autonomous mode, the operator clicks on the map and the Aeryon SkyRanger automatically flies to the point on the map where the operator is pointing. Pre

- mission waypoints, Landing zone points and flight area dimensions can all be entered during preflight ensuring the SkyRanger operates only within specified parameters.The Aeryon SkyRanger includes many advanced safety features that makes the SkyRanger the safest
choice for both urban and non

- urban environments. Built

- in intelligent fault handling allows the SkyRanger to detect a system fault while in the air, and to automatically fly back to its take

- off
locatio n and land. Faults that can be detected include: loss of communication; pre

- set wind thresholds exceeded; and low battery levels. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deem ed unsafe or unnecessary to fly over. And before every take

- off automated flight checks ensure the system is flight ready before it takes off.

The Aeryon SkyRanger can be operated entirely by a touch

- screen, map based interface. This means the operator on ly needs to command the system where to go, and the system does all the flying for the operator. Maps can be saved and flight plans can be made or recalled with no Internet connection required.

S k y R a n g e r O p e r a t i n g M a n u a l

- System user manual available upo n request.

P h y s i c a l C h a r a c t e r i s t i c s

M e a s u r e m e n t s

- 40" diameter deployed, 20x1 0" folded

W e i g h t (without payload)

- 2.4kg (5.3 lbs)

F u e l

- Lithium polymer batteries are self

- contained high duration systems with 60$57 ́ intelligence

on

- board. This incl udes cycle charge times, locations, GPS antenna, chemical management, and real

time data feeds to ensure maximum flight duration and sub

- system safety processes. Charging is done in the included Aeryon Battery charger and can be charged via standard wall outlet, or via a vehicle

.

L a n d i n g s t y l e / t y p e

- Autonomous vertical lift

P r o p u l s i o n S y s t e m

x Engines

- The SkyRanger is powered by 4 electric brushless DC motors.

x Batteries

- Lithium polymer batteries are self

- contained high duration systems with SMART
in telligence on

- board

. This includes cycle charge times, locations, GPS antenna, chemical management, and real

- time data feeds to ensure maximum flight duration and sub

- system safety processes. Charging is done in the included Aeryon Battery charger and can be charged via standard wall outlet, or via a vehicle.

P e r f o r m a n c e C h a r a c t e r i s t i c s

x Maximum Altitude

- 1500 ft.

x Maximum Endurance

- 50 minutes

x Maximum Range

- 3 km

x Weather Minimums:

o Winds Maximum

- 40 MPH sustained, 55 mph gusts

o Minimum ceiling: 500ft

o M inimum visibility: 1 SM

o Icing conditions

- no icing conditions

o Precipitation

- no visible moistureM a i n t e n a n c e

- The UAS is nearly maintenance free, it performs automatic pre

- flight checks and the failure of any check will prevent take

- off. Checks which cannot be done by the system will be performed by a qualified person prior to each flight.

Pre

- flight checklist includes:

x Visual inspection of the airframe

x Visual inspections of rotor integrity

x Check charge of all batteries (aerial vehicle, command st ation, radio repeater station)

Reliability

- The system is designed for maximum reliab i lity and to maintain performance over its life

. The only components experiencing routine wear are rotors

, batteries

, motors

, and legs

. Battery and
motor conditions are m onitored by the system with deviations reported to the operator

.

Contact with other objects during flight may cause othe r components

, particularly rotors

, and motor

arms , to become damaged. Damaged components are likely to be detected during the full visu a l inspection of the airframe performed before each flight. On

- board sensors will detect structural damage affecting flight characteristics

.

The UAV system detects numerous conditions that may make f l ying unsafe

, such as reduced GPS

accuracy , magnetic ano ma l ies

, low battery charge

, battery cell imbalances

, and temperature fluctuations. Automatic pre

- flight checks prevent the UAV from taking off if such conditions are
present ; or , if the condition is detected during flight

, the system will trigger a Fatal C onditioned Response.

Fault Tolerance

- The key feature of the UAV fault tolerance is its mechanical simplicity. It uses four fixed pitched rotors

, each mounted on a separate motor. No control surfaces or other actuators are required for the UAS to fly. Any component failure detectable by the system will be reported to the
control stat i on and will cause the UAV to perform a Fatal Condition Response ( FCR ) or Non

- Fatal Conditioned Response (NFCR)

, depending on the type of failure

.

Command and Control Systems The SkyRanger Ground Control station allows the operator simultaneous control over aircraft and payloads. The touch screen control allows for quick navigation and data entry while the display screen provides all essential f l ight data to the operator

. Telem etry data is transmitted to the command station at least once per second. Displayed on GCS:

x UAS Position

x Nav i gation Route

x UAS Tail Number

x UAS Position

x UAS Altitude

x UAS Heading

x North Seeking Arrow

x Range to Target

x Calculated target position

x Date/ti mex Sensor heading and orientation relative to UAS

On

- board Flight Instruments

- The UAV i s equipped w i th an Inertial Navigation System ( 3

- axis

gyroscope , 3

- axis magnetometer

, GPS receiver

, and static pressure sensor) and a sonar sensor for

p r ecision AGL a ltitude measurement.

On

- board computer systems

- The UAS is equipped on

- board computer systems t o monitor (sensors

, battery

, etc

. )

, control (speeds

, altitude

, position

, etc

. )

, and communicate ( control , t elemetry

, etc .)

.

On

- board guidance and navigation e quipment

- The UAS can operate autonomously ; i t does not

requ i re any input from g r ound

- based equipment

, or from the pilot to hover in p l ace

.

Frequency Allocations

- 900 MHz

, 2.4 GHz

, 5

. 8 GHz, custom 17 of20

F l i g h t t e r m i n a t i o n l i n k

- t o prevent a "fly away" or other potentially dangerous situation a flight termination link is available to the operator at the GCS.

T a k e o f f a n d L a n d i n g

- The SkyRanger has vertical lift autonomous launch and recovery. A Landing

Zone "LZ" is designated by th e operators and identified in the GCS software. For launch procedures the aircraft will takeoff and hover 3 meters directly above the LZ and hold until further operator instruction is given. The aircraft will automatically adjust for wind during this perio d.

N a v i g a t i o n S y s t e m

- Specific maps can be downloaded to the display screen (such as air sectional and geographic maps) which are overlaid with GPS positional data. Waypoints can be created before and during flight operation creating specific locations an d sequences for the aircraft.

R e d u n d a n t S y s t e m s

- The UAS combines the input from a multitude of sensors. Even though the data from all sensors is required for optimal system performance, a single sensor malfunction is likely to result in degraded perform ance rather than leading to a catastrophic failure.

E m e r g e n c y P r o c e d u r e s a n d S y s t e m F a i l u r e s F a i l u r e H a n d l i n g

- The UAS has extensive failure detection and handling capabilities. All failures are deeded to be either fatal or non

- fatal. Failures
classified as fatal result in a Fatal Condition Response (FCR); and failures classified as non

- fatal result
in a Non

- Fatal Condition Response (NFCR).

S e n s o r F a i l u r e

- Failure of on

- board flight instruments/sensors will degrade the UAS performance and
will result in e ither a FCR or a NFCR, depending on their severity. If the UAS becomes unstable due to sensor failure, it will stop all four motors and free fall to avoid a fly away condition.

M o t o r F a i l u r e

- The UAS flight performance will degrade significantly if one or more motors fails.

A i r f r a m e F a i l u r e

- If airframe is damaged in ways that impacts flight characteristics, the UAS will
behave similar to if an on

- board flight instrument failed.

N a v i g a t i o n S y s t e m F a i l u r e

- In a navigation system failure, degraded GPS wil l result in FCR or NFCR 's depending on failures.

P o w e r F a i l u r e

- A complete battery failure which results in power loss to the UAS will result indegraded flight performance

.

L o w B a t t e r y C o n d i t i o n

- Operator will be alerted of a low battery condition and will land the aircraft
as soon as able.

L o w B a t t e r y C o n d i t i o n

- Operator will be alerted of a low battery condition and will land the aircraft
as soon as able.

L i n e

- o f

- S i g h t L o s s

- All flight operations will be conducted with the UAS within visual sight of the pilot. If the pilot's view becomes obstructed and line

- of

- sight is lost, the pilot may instruct the UAS to hover in place until line

- of

- sight is reestablished, to return to the take

- off position, or to land at the current position.

S e c u r i t y

- The m anufacturers proprietary software encrypts the system and communication links.A P P E N D I X C

S U M M A R Y O F I S I G H T R P V S E R V I C E S S E C T I O N 3 3 3 E X E M P T I O N R E Q U E S T

ISight RPV Services

, LLC hereby provides pursuant to Part 11 a summary of its exemption application to allow commercial operation of the SkyRanger small

- unmanned system in market research

, analysis

, precision aerial survey work, mapping and inspections

. An exemption is requested from the following regulations:

14 C .F.R. Part 21 ; 14 C

. F.R. 45.23(b);

14 C

. F

. R. 91.7(a) ; 14 C.F

. R. 91.9(b)(2) & (c) ; 14 C.F.R. 91.103;
14 C.F.R. 91

. 109(a);

14 C.F.R. 91

. 119; 14 C.F.R. 91.151(a );

14 C.F.R. 91

. 203(a) & (b) ; 14 C.F.R. 91.405(a) ; 14 C.F.R. 91.407(a)(1);

14 C.F

. R. 9 1.409(a)(2);

14 C.F.R. 91

. 417(a)

.