### June 25, 2015

Exemption No. 11903 Regulatory Docket No.FAA

–2015

–1217

Mr.Scott L. Shinn Sustainment Solutions Inc. 152 Pleasant Retreat Drive Lancaster, KY 40444

DearMr.Shinn: This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.
By letter datedApril 14, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf ofSustainment Solutions Inc. (hereinafter petitioner or operator) for an exemption

. The petitionerrequestedto operate anunmanned aircraft system (UAS) to conducttechnical inspection services that consist of still photographs, video, and other data taken by onboard

sensors

. See Appendix A for the petition submitted to the FAAdescribing the proposed operations and theregulations that the petitioner seeks an exemption

.
The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental tothe petitioner

.
Airworthiness Certification

The UAS proposed by the petitioner isan Aeryon SkyRanger

. The petitioner requested relief from 14 CFR part21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of Public Law 112

−95 in reference to 49 U

.S

.C

. § 44704, and in

### 2 consideration of the size, weight, speed, and limited operating area associated with the aircraftand its operation, theSecretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFRpart21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part36, is notnecessary.

The Basis for Our Decision
You have requested to use a UAS foraerialdata collection1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos

. 11062 to Astraeus Aerial (seeDocket No. FAA−2014−0352), 11109 to Clayco, Inc. (seeDocket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (seeDocket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision
In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore,pursuant to the authority contained in49 U.S.C. 106(f), 40113, and44701, delegated to me by the Administrator,Sustainment Solutions Inc. is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allowthepetitioner to operate a UAS to performaerial data collection

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3

Conditions and Limitations

Inthis grant of exemption,Sustainment Solutions Inc. is hereafter referred to as theoperator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to theAeryon SkyRanger whenweighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend thisexemption

.
2. Operations for the purpose of closed

-set motion picture and television filming are notpermitted.

3. The UA may not be operated at a speed exceeding 87 knots (100miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

-issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times;
electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must beaccessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.

### 4 Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and reviseddocuments if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flightcharacteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least500feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a conditionfor safe operation.

10. Prior to each flight, the PIC must conduct a pre

-flight inspection and determine the UAS is in a condition for safe flight. The pre

-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, orequipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraftcomponents.

12. Each UAS operated under this exemption must comply with all manufacturer safetybulletins.

13. Underthis grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be

### 5 operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500feet below or less than 2,000feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

-determined location within the private or controlled

-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attachedCOA

.
22. All aircraft operated in accordance with this exemption must be identified by serial

number, registered in accordance with 14 CFR part47, and have identification

### 6 (N−Number) markings in accordance with 14 CFR part45, SubpartC. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flightof the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least500feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.
The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within 24hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:www.ntsb.gov

. If this exemptionpermits operations for the purpose ofclosed

-set motion picture and television filming and production, the following additional conditions and limitations apply.

### 7

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;
c. Name and phone number of the person responsible for the on

-scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to beused;
e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permissionmust be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8 This exemption terminates onJune 30, 2017, unless sooner superseded or rescinded.
Sincerely,

/s/

John S. Duncan Director, Flight Standards Service

Enclosures14-April-2015

U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 ·'::) ?l A r:. 

## ?1**,~,:t~-** I .:.; t;• J 

### Sustainment
Solutions
Inc. 

# (0**I!:LUB7£.H.~:**

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, Sustainment Solutions Inc. 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 Inc. ("Aeryon"), the developer and operator of the Scout and SkyRanger small Unmanned Aircraft Systems ("sUAS"). Details of Aeryon and the SkyRanger sUAS are described in Appendix B. Attached as Appendix C is a summary ofthis request.

The requested exemption ·would permit Sustainment Solutions Inc.'s commercial operation ofAeryon's SkyRanger (see details in Appendix B), which weighs 6 lbs. with imaging payload, to perform technical inspection services 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 modelling, can be combined to produce precision digital point clouds, triangle models, and contour maps of the surveyed area. Applications for these sUASs 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, 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 underconditions as may be modified by the FAA as required by Section 333.
Operations will include technical inspection services such as inspection of roofs, electrical lines, railroad lines, and assisting engineers in theirfield surveys. High precaution will be taken to make sure thatthe sUAS never comes in any interference with otherflying objects.
Operations will primarily be in Kentucky. The main areas of inspection will be in rural and less populated regions. Sustainment Solutions Inc. believes that these operations are of a public good as time, human resources, and money can be saved when substituting current efforts with the use of sUAS for inspection.

As described more fully below, the requested exemption would authorize Sustainment Solutions Inc.

1

### of 19to perform technical inspection services using the SkyRanger1

, which at 6 lbs. is small in size and powered electrically by battery. The SkyRanger 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 ofthe 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.

Sustainment Solutions Inc. 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 ofthis 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 ofthe applicant are:

Sustainment Solutions Inc. Attn: Scott 

### L. Shinn Ph: 859-792-2000 Fax: 859-792-2005 Email: sshinn@ssi-worldwide.com Address: 152 Pleasant Retreat Drive, Lancaster, KY 40444

The primary contact forthis application is: Scott 

### L. Shinn ·

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. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.1 03; 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);

Aeryon and its customers have been granted many flight operation certificate to operate the Aeryon SkyRanger, and its predecessor the Aeryon Scout

- including Special Flight Operation Certificates in Canada for commercial use, and Certificates ofWaiver orAuthorization (COA) in the US for public agency use.



### 2

### of 1914 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.

3 of 19THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Sustainment Solutions Inc. submits that grant of this exemption application for use of the SkyRanger in technical inspection services will advance the Congressional mandate in Section 333 ofthe 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 ofthe following:

• The sUAS's size, weight, speed, and operational capability;
• Operation ofthe sUAS in close proximity to airports and populated areas; and
• Operation ofthe sUAS within visual line ofsight ofthe 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." /d. §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 §40101 ofthe 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 Administratorfinds the exemption is in the public interest.

49 U.S.C. §44701(f}. See also49 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 ofthe SkyRanger

A critical element ofthe exemption application involves evidence ofthe airworthiness ofAeryon 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 ofAlaska Fairbanks, University of New Mexico, Kansas State

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.



### 4

### of 19University, 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 safetl. 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 Sustainment Solutions Inc. will be subject to the following mandatory conditions, which are based upon operating conditions set forth for operation of sUAS by public entities pursuantto Certificates ofAuthorization, with additional restrictions:

• All operations to occur in Class G airspace.
• 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.

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

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

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

• VLOS guaranteed with a cylinder of operation around operator of 

### Y2 nautical miles (NM).

e Cylinderwalls may be expanded by observerwith ability to control aircraft.

• Operations to occur during daylight hours.

o Above Ground Level (AGL) altitude to be restricted to 400 feet.
• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway centerline measured from runway thresholds.
• Operatorwill file a NOT AM for each flight.
• All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, orother appropriate governmental agencies.
• All operations will include one pilot for flight control and one observer for VLOS enhancement ofsurrounding area nearthe aircraft
Operator Requirements

Sustainment Solutions Inc. respectfully proposes that operator requirements should take into account the characteristics of the particular sUAS. Certain sUASs, such as the Aeryon SkyRanger, are characterized by a high degree of pre-programmed control and various built-in technical capabilities that limitthe potential for operation outside ofthe operating conditions set forth above. The SkyRanger sUAS also provides many built-in functional and safety features to assist the operator in safe and reliable operation. 4

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). 4 As ofJuly 2014, Aeryon staff and customers have performed over 5681 flights, logging 623 hours offlight time with the SkyRangerwith both development and release versions. The previous generation product, Scout, achieved over 7197 flights and 839 hours offlight time globally by Aeryon and its customers. This is a significant amount offlight time collected to understand and refine the Aeryon sUAS products.

5 

### of 19The Aeryon SkyRanger provides two semi-autonomous flight modes using a point-and-click map and video interface. The user clicks on a map to direct the SkyRangerto fly to the point on the map where the operator is pointing, or programmed flight plans may be entered for a series ofwaypoints or gridbased area. Additional navigation aids including landing zones and flight areas may be designated to ensure the SkyRanger operates only within user-specified flight parameters. All flight operations are GPS controlled making the system easy to navigate, and the flight control system also employs a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure the high stability and reliability in challenging weather conditions. At all times during flight operations, the operator can intervene a programmed flight and take immediate control.

Additional automated safety functions and safety enhancing features of the SkyRanger include the following:
e Automated pre-flight system performance checks
• User pre-flight checklist
• Automated condition or fault detection, warnings, and pre-defined responses to a number of flight and system conditions. High winds with system and userdefined safety thresholds

o Low battery with system and user defined safety thresholds

o High temperature or other system safety thresholds

o Lost-link communication
o Pre-defined responses include behavior such as attempting to re-establish radio communication, return to home position and hover, return to home position and land, or land in current position

e In the case of lost GPS, a manual user flight mode is enabled which allows the operator to provide manual navigation inputs to assist in landing the vehicle.

Given these safety features, Sustainment Solutions Inc. proposes that operators of the SkyRanger should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:

o have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA-recognized equivalents including commercial or private license and ground school issued from an ICAO recognized country;
• have completed Aeryon's authorized training program for operation and maintenance of the sUAS.

Sustainment Solutions Inc. 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).



### 6

### of 19In summary, Sustainment Solutions Inc. seeks an exemption from the FARs set forth above and in Appendix Cto allow operations of a small unmanned vehicle in technical inspection services.
Approval of the exemption allowing commercial operations of the SkyRanger for technical inspection services 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 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 .technical inspection services 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 Sustainment Solutions Inc. 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 Sustainment Solutions Inc. commercial operation of the SkyRanger in technical inspection services.

Very truly yours,

Scott L. Shinn Sustainment Solutions Inc.



### 7

### of 19APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

Sustainment Solutions Inc. requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation ofthe SkyRanger:

14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR 

### § 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 ofthe 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 Hto achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe 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 ofthe aircraft, the lack offlammable 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 B and throughout this document highlight the design intentions towards safety and reliability on SkyRanger.

14 C.F.R. 

### § 45.23 

### &91.9(c): Marking ofthe Aircraft
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

An Aeryon internal report compares the crash kinetic energy dissipation rate ofa commercial airline versus the Aeryon SkyRanger. The report found the MTTF ofSkyRanger needs to only be > 2.3 hours to equal the energy dissipation ofthe gold standard commercial aircraft. Transport Canada, has issued a report on low energy RPA and determined the Aeryon Scour ro be well below the peak energy level of 12J/cm2 on impact, since the SkyRanger is similar in construction it could be considered robebelow this threshold as well.



### 8

### of 19registration 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 ofthis chapter.

The SkyRanger has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size ofthe sUAS, two-inch lettering will be impossible. Official marking systems for small UAS have not yet been established for operations inside the NAS. The SkyRanger is currently 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. Sustainment Solutions Inc. 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 ofthe sUAS.

The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 10167, 10167A and 10700.

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the SkyRanger in this case is remotely controlled with no passengers or property of others on board. Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in command of an aircraft for compensation or hire. Sustainment Solutions Inc. respectfully proposes that operator requirements should take into account the characteristics of the particular sUAS. Aeryon's SkyRanger has a high degree of pre-programmed control and various built-in technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exemption application.

The SkyRanger has an all-digital software platform with advanced features previously restricted to full size unmanned aircraft. Automated features and advanced fly-safe controls enable safe, reliable operation, as well as advanced networking capabilities and system extensibility.

e Plan your flight or fly ad-hoc: The system can autonomously fly a programmed flight path or fly in manual mode


### o Smart batteries and charger: Flight time and battery minutes are displayed at all times. The system will return home and land automatically if user-configurable limits are reached.
Flight safety is a priority, no matter the operating environment or project. The SkyRanger offers superior safety over manned aircraft by removing the need for people to be onboard in potentially dangerous situations. With multiple built-in safety features, the Aeryon platform leads other sUAS with respect to safety. · • Intelligent fault handling: The system automatically detects potential issues -with configurable automated response behavior such as a return-home-and-land routine



### 9

### of 19• Automatic pre-flight checks: The system self-calibrates all of its sensors and performs selftests priorto takeoffto check for errors
• No-fly zones: The system has the ability to set up visual no-fly zones
e Self-monitoring: Monitoring battery levels, in-flight wind speeds, and other system and environmental conditions are automatically handled by the system

o Battery communication: Battery minutes and flight time are displayed at all times. The system will return home and land automatically if user-configurable limits are reached.

Additional automated safety functions and safety enhancing features of the SkyRanger include the following:
• Auto detection of lost GPS warns the pilot and initiates an immediate landing.
• Low battery on the SkyRanger triggers a Non Fatal Warning alarm to return home, land and replace the battery

e Very low battery on the SkyRanger triggers a Fatal Error alarm and initiates an emergency high speed descent landing.
• If the SkyRanger detects a lost-link to the basestation the vehicle will perform its pre-defined Non-Fatal Condition Response.

Given these safety features, Sustainment Solutions Inc. proposes that operators of the SkyRanger should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:
• have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA-recognized equivalents including ICAO issued commercial, private license and ground school;
• have completed Aeryon's training program for operation ofthe sUAS.

Sustainment Solutions Inc. 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 where the mandatory operating conditions specified above are 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, granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the SkyRanger without a private pilot's certificate or a commercial pilot's certificate, under the conditions set forth herein.

The risks associated with the operation of the SkyRanger (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations ofthe sUAS as setforth above meets or exceeds the present level of safety provided under 14 C.F.R § 61.113(a) & (b) and does not rise to the level of requiring acommercial pilot to operate the aircraft under§ 61.133(a).

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 priorto each flight.



### 10 

### of 1914 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 ofsafety 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 offlight.

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 usedfor flight instruction unless that aircraft hasfully 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-and-click 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 preprogrammed 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 CFR 

### § 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



### 11 

### of 19

# --

closerthan 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the SkyRangerwill 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 Vllith 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 VFR 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 afterthat 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 longertime frame for flight in daylight VFR conditions is reasonable.

Sustainment Solutions Inc. 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.

Sustainment Solutions Inc. believes that an equivalent level of safety can be achieved by maintaining 10 minutes of reserve fuel, which, allowing 40 minutes offlight 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.

14C.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



### 12 

### of 19by 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 ofthe Maintenance Schedule in the User Guide (see Exhibit 1).
Pre-flight checklist includes: 1.Visual inspection ofthe airframe 2.Visual inspections ofrotor integrity 3.Check charge ofall 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 SkyRangerwill 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 ofsafety 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 UAVto perform a Fatal Condition Response (FCR) or NonFatal Conditioned Response (NFCR), depending on the type offailure.



### 13 

### of 19APPENDIX 8

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

Sustainment Solutions Inc. Overview: Sustainment Solutions Inc. is a veteran-owned and HUBZone certified small business that focuses on providing equipment and facility services to worldwide customers. Services include: equipment installation, maintenance, and facility inspections. Current customers are the US Department of Army, Navy, State Department, NATO, in addition to, local Kentucky clients and international organizations. Sustainment Solutions Inc. has proven success with putting US military veterans to work, in fact, Sustainment Solutions Inc. is a recipient of two consecutive years (2014 & 2015) of being named 'Top 100 Small Businesses in US" by the US Chamber of Commerce, and the company president/CEO has been selected as "2015 KY Small Business Person ofthe Year" by the US Small Business Administration.

Aeryon Corporate Overview: Aeryon Labs, Inc. is a Canadian company located in Waterloo Ontario. Aeryon is focused on providing micro unmanned aerial system and is globally recognized as the market and technology leader in this space. Key customers range from military organizations such as Canadian Special Operations and US Special Operations; key government agencies such as NOAA, Environment Canada and the US Coast Guard; world leading universities in the unmanned space such as University of Alaska Fairbanks and Kansas State University; police agencies such as the RCMP and OPP; and global enterprises such as BP, UK Power Networks and Fortune 500 companies in the chemical, oil/gas and security markets. Aeryon systems have accumulated over 5000 hours in global flight operations. This number does not include military flight hours which increase the numbers further.
Aeryon 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 offeel' forwhat the impact ofthe wind is at the altitude the system is flying. The end result is a system capable ofgathering high quality aerial intelligence at much higherwind 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

14 

### of 19

# -

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 ofthe 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 SkyRangerthe 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-offautomated 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, 20x10" folded
Weight (without payload)- 2.4kg (5.3 lbs)

Fuel

- 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 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 -Autonomousvertical lift
Propulsion System
• Engines -The SkyRanger is powered by 4 electric brushless DC motors.

·o 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, orvia a vehicle.

Performance Characteristics
• Maximum Altitude

- 1500 ft.

e Maximum Endurance

- 50 minutes



### 15 

### of 19• Maximum Range

- 3 km

o Weather Minimums

- • Winds Maximum

- 40 MPH sustained, 55 mph gusts
• Minimum ceiling: 500ft
• Minimum visibility: 1 SM
• Icing conditions

- no icing conditions
• 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 priorto each flight.
Pre-flight checklist includes:
• Visual inspection ofthe airframe
• Visual inspections of rotor integrity

e 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 experience 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. Structural damage affecting flight characteristics will be detected by on-board sensors.

The UAV system detects numerous conditions which may make flying unsafe, such as reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, 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 offailure.

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:

o UAS Position 

# • Navigation Route 

# • UAS Tail Number 

# • UAS Position 

# • UAS Altitude

0 UAS Heading 

# • North Seeking Arrow 

# • Range to Target



### 16 

### of19e Calculated target position
• Date/time

o 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, orfrom the pilot to hover in place.
Frequency Allocations- 900 MHz, 2.4 GHz, 5.8 GHz, custom
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 ratherthan 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. Ifthe UAS becomes unstable due to sensorfailure, it will stop all four motors and free fall to avoid afly 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 similarto if an on-board flight instrumentfailed.
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



### 17 

### of 19degraded flight performance.

Low Battery Condition -Operatorwill be alerted of a low battery condition and will land the aircraft
as soon as able.

Low Battery Condition

- Operatorwill 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 ofthe pilot. Ifthe 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, orto land at the current position.
Security The system and communication links are encrypted by the manufacturers proprietary software.



### 18 

### of 19APPENDIX C

SUMMARY OF AERYON SECTION 333 EXEMPTION REQUEST

Sustainment Solutions Inc. hereby provides pursuant to Part 11 a summary of its exemption application to allow commercial operation of the SkyRanger small unmanned system in technical inspection services. 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. 61.113(a) & (b); 14 C.F.R. 61.133(a); 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).



### 19 

### of 19