14-April-2015

U.S. DepartmentofTransportation Docket ManagementSystem 1200 NewJerseyAve., SE Washington, DC 20590 ·'::) ?l A r:. 

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### Sustainment Solutions Inc. 

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

Dear Siror Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (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 ofAeryon and the SkyRanger sUAS are described in Appendix B. Attached as Appendix C is a summaryofthis 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 ofstill photographs, video, and otherdata 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 SkyRangerfor 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 bythe FAAas 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 precautionwill be takento make sure thatthe sUAS nevercomes in any interferencewith 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 sUASfor inspection. As described more fully below, the requested exemption would authorize Sustainment Solutions Inc.

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### of19to 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 necessaryto 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 operatewill be disclosedto and approved, as needed, bythe FAA in advance. Sustainment Solutions Inc. respectfully submits that becausethis 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 thatthe operations will achieve at least an equivalent level or greater level ofsafety. 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 nameand 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 contactforthis application is: Scott

### L. Shinn · The regulationsfrom which the exemption is requested are asfollows: 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); 14C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103; 14C.F.R. 91.109(a); 14C.F.R. 91.119; 14 C.F.R. 91.151(a); 14C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14C.F.R. 91.407(a)(1); Aeryon and its customers have been granted many flight operation certificate to operate the Aeryon SkyRanger, and its predecessorthe Aeryon Scout

- including Special Flight Operation Certificates in Canada for commercial use, and CertificatesofWaiverorAuthorization (COA) in the US for publicagency use. 

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### of1914 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.

3of19THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 Sustainment Solutions Inc. submits that grant ofthis exemption application for use ofthe 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 ofthe NAS orthe public or pose a threat to national security in lightofthefollowing:

• The sUAS's size, weight, speed, and operational capability; • Operation ofthe sUAS in close proximityto 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 pilotsto operate aircraft in commercial service: TheAdministrator maygrantan exemptionfrom a requirement ofa regulation prescribed under subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the Administratorfindsthe 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 grantthe requested exemptionwithoutdelay. Airworthiness oftheSkyRanger 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 aduty on the Administratorto 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 consultwith FAA staff in orderto address any issues or concerns that this proposal may raise thatthey believe may require modification.

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### of19University, 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 ofthe device's safety and fitness for operation to ensure that the FAA has sufficient basisto 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 ofoperation 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 operationsto occurin Class G airspace. • Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts. • Operationsto be conducted over private orcontrolled-access property. • Permissionfrom land owner/controller required before commencing anyflight. • Operationsto occurduringVisual Flight Rules Meteorological Conditions (VMC). o Aircraftto remainwithin Visual Line ofSight (VLOS). • VLOS guaranteed with a cylinder of operation around operator of 

### Y2 nautical miles (NM). e Cylinderwalls may be expanded by observerwith abilityto control aircraft. • Operationsto occurduring daylight hours. o Above Ground Level (AGL) altitudeto be restricted to 400feet. • All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway centerline measuredfrom runwaythresholds. • Operatorwillfile a NOT AM foreachflight. • All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local lawenforcement, fire, orotherappropriategovernmental agencies. • All operations will include one pilot forflight control and one observerfor 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 potentialfor operation outside ofthe operating conditions setforth 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 forthe SkyRanger: 1) Aeryon SkyRanger UserGuide (Exhibit 1)which includes Safety and PreFlight Checklists; and 2) Training Manual (Exhibit2). 4As ofJuly2014, Aeryon staffand customers have performed over5681 flights, logging 623 hours offlighttime with the SkyRangerwith both developmentand release versions. The previous generation product, Scout, achieved over7197 flights and 839 hours offlighttime globally byAeryon and its customers. This is asignificant amountofflighttime 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 userclicks on a mapto directthe SkyRangertoflyto the point on the mapwhere 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 ofsensors including sonar, barometric pressure, temperature, wind speed and othersto ensure the high stability and reliability in challenging weather conditions. At all times during flight operations, the operatorcan intervene a programmedflight and take immediate control. Additional automated safety functions and safety enhancing features of the SkyRanger include the following: e Automated pre-flightsystem performance checks • User pre-flightchecklist • Automated condition or fault detection, warnings, and pre-defined responses to a number of flight and system conditions. Highwindswith system and userdefined safety thresholds

o Low batterywith system and userdefined safetythresholds

o Hightemperature orother system safetythresholds

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 inputsto 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 Pilotwritten examination or FAA-recognized equivalents including commercial or private license and ground school issuedfrom 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 ofoperations pursuantto public COAswhen the mandatory operating conditions specified above were present. See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) OperationalApproval, at 20-21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the requirements for and privileges associatedwith the grantofairmen's certificates. 49 USC §44701 (f).



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### of19In summary, Sustainment Solutions Inc. seeks an exemption from the FARs set forth above and in Appendix Cto allowoperations ofasmall unmanned vehicle in technical inspection services. Approval of the exemption allowing commercial operations ofthe SkyRangerfor 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 ofcombustible 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, removesthe needfor airborne pilots/observers, and poses less riskto people and infrastructure on the ground. Additionally, no national security issue is raised by the grant ofthe requested exemptions. Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or otherdangerous materials, the SkyRanger poses no threatto 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 ofthe criteria set forth in Section 333 of the Reform Act-size, weight, speed, operating capabilities, lack of proximityto airports and populated areas, operation within visual line ofsight, and national security

- and its showing ofan equivalent level ofsafety 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 ofthe SkyRanger in technical inspection services. Verytruly yours,

Scott L. Shinn Sustainment Solutions Inc.



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### of19APPENDIXA

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETYSHOWINGS UNDER APPLICABLE RULES SUBJECTTO EXEMPTION

Sustainment Solutions Inc. requests an exemption from the following regulations as well as any additional regulationsthat maytechnically applyto the operation ofthe SkyRanger: 14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14CFR 

### § 91.203(a)(1) Section 91.203(a)(1) requires all civil aircraftto have acertificate ofairworthiness. 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 unnecessaryto go through the certificate ofairworthiness process under Part 21 Subpart Hto achieve orexceed current safety levels. Such an exemption meets the requirements ofan equivalent level ofsafety 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 aircraftfrom 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, underthe conditions proposed herein, will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The SkyRangerweighs 6 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusivelywithin an area pre-disclosed and in compliancewith conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the conditions setforth above, and by local public safety requirements. The FAA will have advance notice of all operations through the filing of NOTAMs. Receipt ofthe prior permission ofthe land owner, the size ofthe aircraft, the lack offlammablefuel, and thefact thatthe aircraft is carried tothe location and not flown there all establish the equivalent level of safety. The SkyRanger provides at least an equivalent, and most likely exceeds5

, level ofsafety 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. 14C.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 ofacommercial airline versus the Aeryon SkyRanger. The report found the MTTF ofSkyRangerneeds to only be >2.3 hours to equal the energydissipation ofthe gold standard commercial aircraft. Transport Canada, has issued areport on low energy RPA and determined the Aeryon Scourro be well belowthe peak energy level of 12J/cm2 on impact, since the SkyRangeris similar in construction it could beconsideredrobebelowthisthreshold as well. 

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### of19registration number ofthe aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When marks include onlythe Roman capital letter"N" and the registration numberis 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 entranceto the cabin, cockpit, or pilot station, in letters not less than 2 inches nor morethan 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 unlessthat aircraft is identified in accordancewith part45 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 systemsfor small UAS have not yet been established for operations inside the NAS. The SkyRanger is currently marked with afixed label containing Aeryon Labs SkyRanger measuring 1.5" x0.5" as well as aserial number located underthe removable camera payload. SustainmentSolutions Inc. is preparedto 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, 10167Aand 10700. 14C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privilegesand Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations. Section 61.113(a) & (b) limit private pilotsto non-commercial operations. Unlike aconventional aircraft that carries a pilot, passengers, and cargo, the SkyRanger in this case is remotely controlled with no passengers or property ofothers on board. Section 61.133(a) requires an individual with acommercial 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 setforth 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, aswell as advanced networking capabilities and system extensibility.

e Plan yourflight orfly ad-hoc: The system can autonomouslyfly a programmed flight path orfly 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 ifuser-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 safetyfeatures, the Aeryon platform leads other sUAS with respectto safety. · • Intelligentfault handling: The system automatically detects potential issues -with configurable automated response behaviorsuch as a return-home-and-land routine 

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### of19• Automatic pre-flight checks: The system self-calibrates all of its sensors and performs selftests priorto takeoffto checkfor errors • No-flyzones: The system hasthe abilityto set upvisual no-flyzones e Self-monitoring: Monitoring battery levels, in-flight wind speeds, and other system and environmental conditionsare automatically handled bythe system o Battery communication: Battery minutes and flight time are displayed at all times. The system will return home and land automatically ifuser-configurable limits are reached. Additional automated safety functions and safety enhancing features of the SkyRanger include the following: • Auto detection oflost GPS warns the pilotand initiates an immediate landing. • Low battery on the SkyRanger triggers a Non Fatal Warning alarm to return home, land and replacethe 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 acommercial 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 operatorswith these qualifications in the case ofoperations pursuantto 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 requirementsfor commercial operations. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation ofthe SkyRangerwithout a private pilot's certificate oracommercial pilot's certificate, under the conditions setforth 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 orexceedsthe present level of safety provided under 14 C.F.R § 61.113(a) & (b) and does not rise to the level of requiring acommercial pilotto operatethe aircraft under§61.133(a). 14C.F.R. §91.7(a): Civil aircraftairworthiness. 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 forAeryon's Scout and SkyRanger, an equivalent level of safetywill be achieved by ensuring compliancewith the Aeryon manuals priorto eachflight.



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### of1914C.F.R. 

### § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. The regulation provides: No person mayoperate 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 combinationthereof. 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 capacityto 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 accessto it. The FAA has issuedto othersthefollowing exemptionstothis regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700. 14C.F.R. 

### § 91.103: Preflightaction This regulation requires each pilot in command to take certain actions beforeflightto insurethe safety offlight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level ofsafetywill be provided as setforth in the SkyRanger UserGuide (Exhibit 1) underthe '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. 14C.F.R. 

### § 91.109(a) & 91.319(a)(1): FlightInstruction These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being usedforflight instruction unlessthataircraft hasfullyfunctioning 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 pilotsfamiliarwith the SkyRanger. 14CFR 

### § 91.119: Minimum SafeAltitudes 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



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closerthan 500feetto any person, vessel, vehicle, orstructure. As set forth herein, the SkyRangerwill neveroperate at higherthan 400feet AGL. Itwill, 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 lessthan 500feetAGL, an exemptionfrom 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 ofthe land owner orthose 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 ofconventional aircraftthat must complywith Section 91.119. 14C.F.R. § 91.151(a): Fuel Requirementsfor 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 afterthatfor at least45 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 longertimeframeforflight in daylightVFR conditions is reasonable. Sustainment Solutions Inc. believesthat an exemptionfrom 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 lessthan contemplated bythe current regulation. Sustainment Solutions Inc. believes that an equivalent level ofsafety can be achieved by maintaining 10 minutes of reserve fuel, which, allowing 40 minutes offlight time, would be more than adequate to return the sUASto its planned landing zonefrom 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 AircraftCertification and Registration This regulation provides as follows: (a)

... no person may operate acivil aircraft unless it has

... an appropriate and current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required



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### of19by paragraph (a) ofthis section oraspecial flight authorization issued under §91.715 is displayed atthe cabin orcockpit entrance so that it is legibleto passengers orcrew. The SkyRangerfully 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. 14C.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) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

..." Section 91.407 similarly makes reference to requirements in Part43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the owneror operatorto 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 priorto each flight and at predefined intervals as part ofthe Maintenance Schedule in the UserGuide (see Exhibit 1). Pre-flight checklist includes: 1.Visual inspection ofthe airframe 2.Visual inspections ofrotor integrity 3.Check charge ofall batteries (aerialvehicle, command station, radio repeaterstation) An equivalent level ofsafety will be achieved becausethe 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 UserGuide (System Maintenance section), the operatorofSkyRangerwill 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 ofsafety. The SkyRanger's Maintenanceguidelines ensure an equivalent level ofsafetyto the maintenance requirements in Part 91. In addition, any componentfailure detectable bythe system will be reported tothe control station and will cause the UAVto perform a Fatal Condition Response (FCR) or NonFatal Conditioned Response (NFCR), depending on the type offailure.



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### of19APPENDIX 8 SMALL UNMANNEDAERIALSYSTEM 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" bythe US Small BusinessAdministration. Aeryon CorporateOverview: 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 Networksand Fortune 500 companies in the chemical, oil/gas and security markets. Aeryon systems have accumulated over 5000 hours in global flight operations. This numberdoes not include militaryflight hourswhich increasethe numbers further. Aeryon systems have been approved by the FAAfor research COAs and have a demonstrated safety track record. The Aeryon sUAS platforms were the first to officially fly at one ofthe 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, ensurethe 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 SouthAmerica, keep ourhighways clearand safe; and providevolumetricanalysisforopen pit mines. The Aeryon SkyRanger can carry payloads up to 600 g. The SkyRanger flies with a maximum wind threshold of40 M.P.H. for sustained winds and wind gusts upto 55 M.P.H

.. What is unique aboutthe Aeryon SkyRanger is the system automatically compensatesforwind versus relying on the operator's 'sense offeel' forwhatthe impactofthe wind is atthe altitudethe system is flying. The end result is a system capable ofgathering high quality aerial intelligence at much higherwind thresholds. Atraitthat is imperativefor many aerial inspection operations. The SkyRangerhas an operational range ofupto 

### 3 km (1.6 NM) with the standard offering and upto 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

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# -

forthe most sophisticated camera targeting available. Theflight control system employs not only GPS positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed and othersto ensurethe most stability ofany system in its class-regardless ofthewind. 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 SkyRangeroperatesonlywithin specified parameters. TheAeryon SkyRangerincludes manyadvanced safetyfeatures that makesthe SkyRangerthe safest choice for both urban and non-urban environments. Built-in intelligent fault. handling allows the SkyRangerto detect asystem faultwhile in the air, and to automaticallyfly backto itstake-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 sothe system cannot enterareas deemed unsafe or unnecessarytofly over. And before everytake-offautomatedflight checks ensurethe system is flight ready before ittakes off. The Aeryon SkyRangercan be operated entirely by atouch-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. SkyRangerOperating Manual

- System usermanual available upon request. Physical Characteristics Measurements-40" diameterdeployed, 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 PropulsionSystem • Engines-TheSkyRanger is powered by4 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 includedAeryon Battery chargerand can be charged via standardwall outlet, orvia avehicle. Performance Characteristics • MaximumAltitude

- 1500ft. e Maximum Endurance

- 50 minutes



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### of19• Maximum Range

- 3km o Weather Minimums

- • Winds Maximum

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

- no icing conditions • Precipitation

- novisible 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 aqualified person priorto each flight. Pre-flight checklist includes: • Visual inspection ofthe airframe • Visual inspections of rotor integrity e Checkcharge ofall batteries (aerial vehicle, command station, radio repeaterstation) Reliability- The system is designedfor maximum reliability and to maintain performance over its life. The only components experience routinewearare rotors, batteries, motors, and legs. Battery and motorconditions are monitored bythe 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 characteristicswill 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, ifthe condition is detectedduringflight, the system will triggera Fatal Conditioned Response. Fault Tolerance- The key feature ofthe UAVfault 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 thetype offailure. Command and Control Systems The SkyRangerGround Control station allowsthe operatorsimultaneouscontrol overaircraft and payloads. The touch screen control allows forquick navigation and data entrywhile the displayscreen provides all essentialflight datato the operator. Telemetrydata is transmittedto the command station at leastonce persecond. Displayed on GCS: o UAS Position 

# • Navigation Route 

# • UASTail Number 

# • UAS Position 

# • UAS Altitude 0 UAS Heading 

# • North Seeking Arrow 

# • RangetoTarget 

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### of19e Calculatedtarget position • Date/time o Sensor heading and orientation relativeto 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 precisionAGL 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 inputfrom ground-based equipment, orfrom the pilotto hoverin 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 availabletothe operatoratthe GCS. Takeoffand 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 aircraftwill automatically adjustforwind duringthis 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 duringflight operation creating specific locations and sequencesforthe 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 acatastrophicfailure. Emergency Procedures and System Failures Failure Handling -The UAS has extensive failure detection and handling capabilities. All failures are deeded to be eitherfatal or non-fatal. Failures classified as fatal result in a Fatal Condition Response (FCR); andfailures 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 dueto sensorfailure, itwill stopall four motors and free fall to avoid afly away condition. Motor Failure-The UAS flight performancewill degrade significantly ifone or more motorsfails. Airframe Failure- Ifairframe is damaged in waysthat impactsflight characteristics, the UASwill behave similarto ifan on-boardflight instrumentfailed. Navigation System Failure- In a navigationsystemfailure, degraded GPSwill result in FCR or NFCR 's depending on failures. Power Failure-A complete batteryfailurewhich results in powerlosstothe UAS will result in



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### of19degradedflight performance. Low Battery Condition -Operatorwill be alerted ofa low battery condition and will land the aircraft as soon as able. Low Battery Condition

- Operatorwill be alerted ofa low battery condition and will landthe aircraft as soon as able. Line-of-Sight Loss-Allflight operationswill be conducted with the UASwithin visual sight ofthe pilot. Ifthe pilot'sview becomes obstructed and line-of-sight is lost, the pilot may instructthe UASto hover in place until line-of-sight is reestablished, to return tothetake-offposition, orto land atthe current position. Security The system and communication links are encrypted bythe manufacturers proprietary software.



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### of19APPENDIX C SUMMARYOF 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 thefollowing regulations: 14C.F.R. Part 21; 14C.F.R. 45.23(b); 14C.F.R. 61.113(a) & (b); 14C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14C.F.R. 91.103; 14C.F.R. 91.109(a); 14C.F.R. 91.119; 14C.F.R. 91.151(a); 14C.F.R. 91.203(a) & (b); 14C.F.R. 91.405(a); 14C.F.R. 91.407(a)(1); 14C.F.R. 91.409(a)(2); 14C.F.R. 91.417(a).



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