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:

Pursuant 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 exemption 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 summary of this request.

The requested exemption would permit ISight RPV Services, LLC commercial operation of Aeryon's 

SkyRanger (see details in Appendix B), which weighs 6 lbs. with imaging payload, to perform Market 

Research, Aerial Surveys, Mapping, Testing, 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 produce 

precision digital point clouds, triangle models, and contour maps of the surveyed area. Applications for 

these sUAS include inspection of sensitive infrastructure including 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, shipping and receiving 

containers and logistics stations, ranch and cattle operations, snow skiing industry, search and rescue, 

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 and 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 SkyRanger1, which at 6 lbs. is small in 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 commercial 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 ground 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: Nathaniel.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 contact 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; 

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. 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 APPL IC AB L E L E G A L ST ANDARD UNDER SE C T ION 333

ISight RPV Services, LLC submits that grant of this exemption application 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 agriculture, 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 that 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 fire 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 Section 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 NAS 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 national 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 Act § 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." Id. §333(c) (emphasis added).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 aircraft 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 Administrator 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 concerns 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 also 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.

Airworthiness of the SkyRanger

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 and 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 safety3. The SkyRanger also has a significant set of automated features to ensure 

safe takeoff, flight and landing in many conditions, further details of operation can be found in 

Appendix B.

Mandatory Operating Conditions

Grant of the exemption to ISight RPV Services, LLC will be subject to the following 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 control 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 includes 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 runway 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 All operations will include one pilot for flight control and one observer for VLOS enhancement 

of surrounding area near the aircraft

Operator Requirements

ISight RPV Services, LLC shall require that operators of the SkyRanger hold a commercial 

certification 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 case of operations pursuant to public COAs when 

the mandatory operating conditions specified above were present. See Federal Aviation 

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

21 (July 30, 2013). The FAA has 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 

Appendix 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 guidelines. 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 operations 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 observation 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 previous 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 SkyRanger 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 ISight 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 RPV 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, LLC
APPENDIX A

E X E MPT ION RE QUEST AND E QUIV A L ENT L E V E L O F SA F E T Y SH O W INGS UNDER

APPL IC AB L E RUL ES SUBJE C T T O E X E MPT ION

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:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C FR § 91.203(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 procedural 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 

of 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) with 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. 

Operations 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 NOTAMs. 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 exceeds5, 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 safety features including redundant sensor systems as 

described in Appendix Band throughout this document highlight the design intentions towards safety 

and reliability on SkyRanger.

14 C.F.R. § 45.23 & 91.9(c): Marking of the Aircraft

 5 An Aeryon internal report 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. Transport 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 provides: (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 must 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 operator 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 applicable.

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 markings 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 Labs 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 

request 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, 

10167A and 10700.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

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 without 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 compliance with the Aeryon manuals prior to each flight.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:

No person may operate a U.S.-registered civil aircraft...

(2) For which an Airplane or Rotorcraft Flight Manual 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 of 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 (see, 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: Exemption Nos. 

8607,8737,8738,9299, 9299A, 9565,95658,10167, 10167A, 10602,32827, and 10700.
14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved 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 take all actions including reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

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 functional 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-andclick touchscreen navigation or pre-programmed as 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. See Exemption Nos. 5778K & 9862A. 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.

14 C FR § 91.119: Minimum Safe Altitudes

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 populated 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 congested 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 needed.

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 advance 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 operations 

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 aircraft that must comply with Section 91.119.
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in V FR Conditions

This regulation prohibits an individual from beginning "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."

The SkyRanger 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 those 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. See 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 operates. 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 simply 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, allowing 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.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

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 operate 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 SkyRanger 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 be 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.
14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart 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; Section 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, under 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 inspections 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 restricted 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 maintenance, 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 Condition Response (FCR) or Non- Fatal 

Conditioned Response (NFCR), depending on the type of failure.
APPENDIX B

SM A L L UNM ANNED A ERIA L SYST E M DESCRIPT ION

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 operations 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 the 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 systems 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 with 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 operational 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, the 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 

location 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 deemed 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 only 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.

SkyRanger Operating Manual - System user manual available upon request. 

Physical Characteristics

Measurements- 40" diameter deployed, 20x1 0" folded 

Weight (without payload)- 2.4kg (5.3 lbs)

Fuel - Lithium polymer batteries are self-contained high duration systems with 60$57 ́intelligence 

on-board. This includes cycle charge times, locations, GPS antenna, chemical management, and realtime 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.

Landing style/type - Autonomous vertical lift 

Propulsion System

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 

intelligence 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.

Performance Characteristics

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 Minimum visibility: 1 SM 

o Icing conditions - no icing conditions 

o Precipitation - no visible moisture
Maintenance - 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 station, radio repeater station)

Reliability- The system is designed for maximum reliability and to maintain performance over its life. 

The only components experiencing routine wear are rotors, batteries, motors, and legs. Battery and 

motor conditions are monitored by the system with deviations reported to the operator.

Contact with other objects during flight may cause other components, particularly rotors, and motor 

arms, to become damaged. Damaged components are likely to be detected during the full visual 

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 flying unsafe, such as reduced GPS 

accuracy, magnetic anomalies, 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 Conditioned 

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 station 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 flight data to the operator. Telemetry data 

is transmitted to the command station at least once per second.

Displayed on GCS:

x UAS Position 

x Navigation 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/time
x Sensor heading and orientation relative to UAS

On-board Flight Instruments - The UAV is equipped with an Inertial Navigation System (3-axis 

gyroscope, 3-axis magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for 

precision AGL altitude measurement.

On-board computer systems - The UAS is equipped on-board computer systems to monitor (sensors, 

battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, etc.).

On-board guidance and navigation equipment - The UAS can operate autonomously; it does not 

require any input from ground-based equipment, or from the pilot to hover in place.

Frequency Allocations - 900 MHz, 2.4 GHz, 5.8 GHz, custom 17 of20

Flight termination link - to prevent a "fly away" or other potentially dangerous situation a flight 

termination link is available to the operator at the GCS.

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

Zone "LZ" is designated by the 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 period.

Navigation System- 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 and sequences for the aircraft.

Redundant Systems - 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 performance rather than leading to a catastrophic failure.

Emergency Procedures and System Failures Failure Handling -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).

Sensor Failure- Failure of on-board flight instruments/sensors will degrade the UAS performance and 

will result in either 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.

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

Airframe Failure- If airframe is damaged in ways that impacts flight characteristics, the UAS will 

behave similar to if an on-board flight instrument failed.

Navigation System Failure- In a navigation system failure, degraded GPS will result in FCR or 

NFCR 's depending on failures.

Power Failure- A complete battery failure which results in power loss to the UAS will result in 
degraded flight performance.

Low Battery Condition - Operator will be alerted of a low battery condition and will land the aircraft 

as soon as able.

Low Battery Condition - Operator will be alerted of a low battery condition and will land the aircraft 

as soon as able.

Line-of-Sight Loss -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.

Security - The manufacturers proprietary software encrypts the system and communication links.
APPENDIX C

SUM M ARY O F ISIG H T RPV SERVIC ES SE C T ION 333 E X E MPT ION RE QUEST

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. 91.409(a)(2); 

14 C.F.R. 91 .417(a).