November 20, 2015

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 Re: ExemptionRequest Under Section 333 ofthe FAA Reform Act, 49 U.S.C. § 44701(t), and Part 11 ofthe Federal Aviation Regulations Dear Sir orMadam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act"), Subsection (t) of49 U.S.C. § 44701 ("Section 333"), and 14 C.P.R. Part 11, 123 DELAWARE, INC. (which carries on business under the name and is hereinafter referred to as "ISW") seeks an exemption from the Federal Aviation Regulations ("FARs") listed below and discussed in Appendix A, to allow ISW to operate the SkyRanger sUAS to provide inspection support services for its. clients in the United States in the oil and gas pipeline, electricity transfer, mining, and roofing and building maintenance industries. These services include obtaining still photographs, video, and other datataken by onboard sensors. Use ofthe SkyRanger for these services reduces the need to operate conventional aircraft, providing more accurate data more safely, economically, and withreduced environmental impact. This exemption is derived from a request by Aeryon Labs Inc. ("Aeryon"), the developer ofthe SkyRanger sUAS. 1 Details ofAeryon and the SkyRanger sUAS are described in Appendix B. Operations under the exemption will be conducted under the limitations and conditions set forth in Appendix C and as may be modified by the FAA as required by Section 333. As more fully described below, the requested exemption would allow ISW to acquire photographs and other data using the SkyRanger, which at 6 lbs., is small in size and powered electrically by battery. The SkyRanger, which has extensive automated control features, will be operated under controlled conditions at very low altitudes in limited airspace, as described more fully herein. Although the SkyRanger can be operated by one person, flight operations carried on by ISW will involve two people: an operator and an observer. The operator is responsible

1See Aeryon Labs Inc., Exemption RequestUnder Section 333 ofthe FAA Reform Actand Part 11 ofthe Federal Aviation Regulations, DocketNo. FAA-2014-0642 (Aug. 25, 2014). ISW is aware oftwo other exemption requests to commercially operate the Aeryon SkyRanger. See VDOS Global LLC Exemption Request, DocketNo. FAA-2014-0382 (Jun 9, 2014); City ofRoswell Coalition, ExemptionRequestUnder Section 333 ofthe FAAReform Act and Part 11 ofthe Federal Aviation Regulations, DocketNo. FAA2014-0732 (Sept. 2014).for flying the sUAS, monitoring its status and flight dynamics while maintaining visual line ofsight and keeping the flight within the manufacturer's specified limits interms of wind, flight range, battery life, etc., to ensure safe operation ofthe vehicle. The observer is responsible for monitoring the airspace for other aircraft and hazards and advising the operator before and during flight ofall such observed risks. ISW's sUAS operators will have passed an FAA approved or equivalent ground training exam and completed an authorized Aeryontraining program for the SkyRanger. Applicant Information: The name and address ofthe applicant is: 123 Delaware, Inc. 2711 Centerville Road, Suite 400 Wilmington, Delaware 19808 The primary contactfor this application is: Lance T. Lehman 1678 Bloor St. W., Suite 302 Toronto, ON, Canada M6P 1A9 E-Mail: lance.lehman@industrialskyworks.com Ph: 416-993-8262 Exemptions Requested ISW requests exemptions from the following regulations:2

14 C.F.R. Part21; 14 C.F.R. 61.3; 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 61.133 (a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.151(a); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(1) and (2); 14 C.F.R. 91.417(a).

2 As set forth in Appendix C, ISWwill operate under similar operating conditions as those required ofthe movie industry grants ofexemption, inwhich exemptions for these FARwas deemedby the FAAas "not necessary." As a result, ISW is notrequesting FAA exemptionfrom FAR45.23(b), 91.7(a), 91.9(b)(2), 91.103, 91.109(a), and 91.203(a) and (b).Airworthiness ofthe SkyRanger A critical element ofthe exemption application involves evidence ofthe airworthiness of the SkyRanger sUAS. ISW and Aeryon believe that the vehicle has been shown to be airworthy and compliant through a history of granted flight operations and successful flights, including those by Michigan State Police, US Navy Spawar, Mass Development (Joint Base Cape Cod), Unmanned Experts (NIJ Partnership), Western Washington University, Aetos (via Northwest Michigan College), University of Alaska Fairbanks, University ofNew Mexico, Kansas State University. The SkyRanger also successfully completed the Department of Homeland Security RAPS trial in 2013. For additional safety, the SkyRanger sUAS is equipped with automated features which ensure safe takeoff, flight, and landing in many conditions, further details ofwhich are provided in Appendix 

### B.

Operator Requirements ISW respectfully proposes that operator requirements should take into account the characteristics of the particular sUAS. Certain sUASs, such as the SkyRanger, are characterized by a high degree ofpre-programmed control and various built-in technical capabilities that limit the potential for operation outside ofthe pre-established conditions. The SkyRanger sUAS also provides many built-in functional and safety features to assist the operator in safe andreliable operation. The SkyRangerprovides two semi-autonomous flight modes using apoint-and-click map and video interface. The user clicks on a map to direct the SkyRanger to fly to the point onthe map where the operator is pointing, orprogrammed flight plans may be entered for a series of waypoints or grid-based area. Additional navigation settings, including landing zones and flight areas, may be designated to ensure the sUAS operates only within operator-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, and wind speed to ensure high stability and reliability in challenging weather conditions. In the case oflost GPS, a manual user flight mode is enabled which allows the operator to provide manual navigation inputs to assist in landing the vehicle. At all times during flight operations, the operator can suspend aprogrammed flight and take immediate control ofthe vehicle. With pre-programmed flights and manual control, operators will be able to maintain separation from manned aircraft operations. All operations will remain within visual line ofsight (VLOS) and below 400 feet AGL. In addition, ISW will obtain a Certificate of Waiver or Authorization from the FAA Air Traffic Organization to address airspace requirements and provide notificationby aNotice to Airman (NOTAM). Additional automated safety functions and safety enhancing features ofthe SkyRanger include the following: 1) Automated pre-flight system performance checks;2) Automated condition and fault detection, warnings, and pre-definedresponses to a number offlight and system conditions, including: a. Highwinds with system and operator-defined safetythresholds; b. Low battery with system and operator-defined safety thresholds; c. Hightemperature safety thresholds; and d. Lost-link communication; and 3) Pre-defined responses include attempting to re-establishradio communication, returnto home position and hover, returnto home position and land, or landin current position. Given these safetyfeatures, ISWproposes the SkyRanger sUAS be operatedby qualified operators and observers, ratherthanpilots. The operators shouldbe requiredto: 1) have successfully completedFAAprivatepilot ground instruction and passed the FAA Private Pilotwritten examination orFAA-recognized equivalents including commercial orprivate license and ground school issued from an ICAO country; and 2) have completed Aeryon's authorizedtrainingprogram for operationand maintenance ofthe sUAS. ISW notes that the FAA has found that safety factors permitted operation ofsUASs by operators withthese qualifications inthe case ofoperations pursuantto public COAs whenthe mandatory operating conditions specified above were present (FAANotice N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013))_3 Public Interest ISW respectfully submits that its use ofthe SkyRanger sUAS in lieu of comparatively hazardous operations currently conducted with conventional fixed wing and rotary aircraft offers a net safety benefit and will achieve an enhanced level of safety, as mandated under Section 333(c) ofthe Reform Act. Approval ofthis application will also benefit the public interest by allowing better, safer, and more cost efficient information gathering for critical industries like oil and gas. Conventional aerial survey and inspection operations using manned aircraft involve very heavy aerial vehicles, transiting to the operational location, carrying significant quantities of combustible fuels, and a multi-person crew in piloting and observation roles. The nature ofsurveying and inspection operations magnify the dangers ofusing conventional aircraft, as the aircraft fly in nonconventional operations under FAA waivers and at dangerous altitudes. By contrastthe SkyRanger sUAS weighs 6lbs including its payload and uses a battery for power, is carried to and from the area ofactivity, removes the need for airborne pilots and observers, and poses less risk to people and infrastructure on the ground as well as other aircraft.

3 TheFAAhasthe statutory authorityto grant exemptions to the requirements for andprivileges associated withthe grant ofairmen's certificates (49 U.S.C. §44701(t)).

### 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 use ofthe SkyRanger sUAS poses no threatto national security. The grant ofthe requested exemption is in the public interest based on the clear direction in Section 333, the Federal Aviation Act,4 

### the high and equivalent level ofsafety ofthe proposed operations, and the significant public benefit, including enhanced safety and cost savings to be realized as a result of the use of sUASs for aerial inspection and mapping services. Accordingly, the applicant respectfully requests that the FAA grant the requested exemptionwithout delay.

Lance T. Lehman

4 The Federal Aviation Act ("FAAct") expressly grantsthe FAAthe authority to issue exemptions: The Administratormay grant an exemptionfrom a requirement ofa regulationprescribedunder subsection (a) or(b) ofthis section or any ofsections 44702-44716 ofthis title ifthe Administrator finds the exemption is inthe public interest. 49 U.S.C. §4470l(t)APPENDIXA EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDERAPPLICABLE RULES SUBJECT TO EXEMPTION 

## rsw requests an exemptionfrom the following regulations as well as any additional regulations thatmaytechnically apply to the operation ofthe SkyRanger: 14 C.F.R. Part21, SubpartH: Airworthiness Certificates 14 C.F.R. § 91.203(a)(1) 

### Section 91.203(a)(l) requires all civil aircraft to have a certificate 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)(l). Given the size of the aircraft (6 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part21 Subpart Hto achieve or exceed 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 aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximityto 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 a controlled area pre-disclosed and in compliance with conditions set forth herein. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the conditions set forth in Appendix C, the Operator's Manual, and local public safety requirements. The FAA will have advance notice ofall operations through the filing ofNOTAMs. Receipt ofthe prior permission ofthe landowner (or lessee), 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 ofsafety. The SkyRanger provides at least an equivalent, and most likely an enhanced5

, 

### 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

5 An Aeryon internal report compares the crash kinetic energy dissipation rate of a commercial airline versus the Aeryon SkyRanger. The report found the MTTF ofSkyRanger needs to only be> 2.3 hours to equal the energy dissipation of the gold standard commercial aircraft. Transport Canada, has issued a report on low energy RPA and determined the Aeryon Scout to be well below the peak energy level of 12J/cm2 on impact, since the SkyRanger is similar in construction it could be considered to be below this threshold as well.redundant sensor systems, as described in Appendix B and throughout this document, highlightthe design intentionstowards safety and reliability ofthe SkyRanger sUAS. 14 C.F.R. §§ 61.3; 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilotin Command; Commercial Pilot Privileges and Limitations. FAR Section 61.3 requires that civil aircraft pilots have a pilot certificate and a medical certificate issued under Part 67. Section 61.113(a) & (b) limit private pilots to noncommercial operations. And, Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in command ofan aircraft for compensation or hire. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the SkyRanger sUAS is remotely controlled with no passengers or property ofothers on board. ISW respectfully proposes that operator requirements should take into account the characteristics ofthe particular sUAS. The SkyRanger sUAS has a high degree ofpre-programmed control and various built-in technical capabilities that strictly limit the potential for operation outside ofthe operating conditions set forth inthe exemption application. The SkyRanger sUAS has an all-digital software platform with advanced features previously restrictedto full size unmanned aircraft. Automated features and advanced flysafe controls enable safe, reliable operation, as well as advanced networking capabilities and system extensibility.

• Plan your flight or fly ad-hoc: The system can autonomously fly a programmed flight path or fly inmanual mode • 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 apriority, no matterthe 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 SkyRangerplatform leads other sUAS manufacturers withrespectto safety.

• Intelligent fault handling: The system automatically detects potential issues

- with configurable automatedresponse behavior such as areturn-home-and-land routine • Automatic pre-flight checks: The system self-calibrates all of its sensors and performs self-tests priorto takeoffto checkfor errors • No-fly zones: The system has the ability to setup visual no-fly zones • Self-monitoring: Monitoring battery levels, in-flight wind speeds, and other system and environmental conditions are automatically handled by the system • 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 ofthe SkyRanger include the following:• Auto-detection oflost 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. • Very low battery on the SkyRanger triggers a "Fatal Error" alarm and initiates an emergency high speed descent landing. • Ifthe SkyRanger detects a lost-link to the base-stationthe vehicle will perform its pre-definedNon-Fatal ConditionResponse. With pre-programmed flights and manual controls, operators will be able to maintain separation from manned aircraft operations. In the controlled operating environment, operations will remain within visual line ofsight (VLOS) and below 400 feet AGL. In addition, ISW will obtain a Certificate of Waiver or Authorization from the FAA Air Traffic Organization to address airspace requirements and provide notification by a Notice to Airman (NOTAM). Given these safety features and operating conditions, ISW proposes that operators ofthe SkyRanger sUAS should not be required to hold a commercial or private pilot certification. Instead, operators should be requiredto:

• 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; and • have completedAeryon'strainingprogram for operation ofthe sUAS. ISW notes that the FAA has found that safety factors permitted operation ofsUASs by operators with these qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above are present (FAA Notice N8900.227, 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. ISW will also require operators to have experience operating sUAS and the SkyRangerbefore conducting operations. Given these conditions and restrictions, an equivalent or enhanced level ofsafety will be provided by allowing operation of the SkyRanger sUAS without a private pilot's certificate or a commercial pilot's certificate, underthe conditions set forth herein. The risks associated with the operation of the SkyRanger (given its size, speed, operational capabilities, and lack ofcombustible 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 of the sUAS as set forth above meets or exceeds the present level ofsafety provided under 14 C.P.R.§ 61.113(a) & (b) and does not rise to the level ofrequiring a commercial pilot to operate the aircraft under§ 61.133(a) or have a pilot and medical certificate pursuant to§ 61.3.14 C.F.R. § 91.119(c): Minimum Safe Altitudes FAR Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of500 feet above the surface, except over open water or sparsely populated areas. Inthose cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. As set forth herein, the SkyRanger will never operate at higher than 400 feet AGL. Because aerial 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 or enhanced level ofsafety willbe 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 landowner or those who control the land. Because of the advance notice to the landowner (or lessee), all affected individuals will be aware ofthe flights. Compared to aerial inspection operations conducted with aircraft or rotorcraft weighing far more than 6 lbs. and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low-altitude operations Qfthe sUAS will maintain separation between these sUAS operations and the operations ofconventional aircraftthat must comply with Section 91.119. 14 C.F.R. § 91.151(a): FuelRequirements for Flight in VFR Conditions This regulation prohibits an individual from beginning "aflight 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) Duringthe day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The SkyRanger batteries provide approximately 50 minutes ofpowered flight. Without an exemption from 14 C.P.R. § 91.151, the sUAS's flights would be limited to approximately 20 minutes in length. Given the limitations on its proposed operations, a longertime frame for flight inVFR conditions is reasonable. ISW believes that an exemption from 14 C.F.R. § 91.151(a) is safe and within the scope ofa 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 ofbattery power, it would simply land. Given its weight and construction material, the risks are lessthan contemplatedbythe currentregulation.

### ISW believes that an equivalent or enhanced level of safety can be achieved by maintaining 10 minutes of reserve power which, allowing 40 minutes of flight time, would be more than adequate to return the sUAS to its planned landing zone from anywhere in its operating area. The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808. 14 C.F.R. §§ 91.405(a), 407(a)(l), 409(a)(2), and 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 ofthis part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 ofthis 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 ofapproval ofthe 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. Pre-flightchecklist includes: 1. Visual inspection ofthe airframe 2. Visual inspections ofrotor integrity 3. Check charge of all batteries (aerial vehicle, command station, radio repeater station) An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restricted predetermined areas and is not a complex mechanical device. The operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level ofsafety. Last, the operator manual will have instructions to develop and document maintenance, overhaul, replacement, and inspection requirements in the absence of Aeryon requirements, and procedures to document and maintain maintenance records for the SkyRanger. The SkyRanger's maintenance guidelines ensure an equivalent level of safety to the maintenance requirements in Part 91. In addition, any component failure detectable by the system will be reported to the control station and will cause the sUAS to perform aFatal Condition Response (FCR) or Non-Fatal Condition Response (NFCR), depending
onthe type offailure.

### APPENDIXB SMALL UNMANNED AERIAL SYSTEM DESCRIPTION ISW Corporate Overview: 

### ISW is a Delaware corporation with an office in Wilmington, Delaware. ISW is a wholly-owned subsidiary of 8681384 Canada Inc., which has its head office in Toronto, Canada. The sUAS will be held in a Non-Citizen Trust on behalfofISW for N-registration. Aeryon systems have been approved by the FAA for research COAs and have demonstrated a safety track record. The Aeryon sUAS platforms were the first to officially fly at one ofthe FAA's UAS Test Sites (UAF Alaska). Many entities from military, to education to police and even commercial operations have been given approval to fly in US, Canada, UK, Australia, Japan, and other airspaces. SkyRanger Overview: 

### Aeryon unmanned systems have been used to fight terrorism in Iraq, Afghanistan and Nigeria, monitorhostile borders between Saudi Arabia and Yemen, ensure the safety of world leaders at the GSO 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 openpitmines. The SkyRanger sUAS can carry payloads up to 600 grams. 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

.. The SkyRanger automatically compensates for wind rather than relying on the operator's 'sense offeel' for what the impact ofthe wind is at the altitude at which the system is flying. The result is a system capable ofgathering high quality aerial data at high wind thresholds, atraitthat is imperative for many aerial inspection operations. The SkyRanger has a standard operational range of3 

### km (1.6 

### NM) and up to 5 

### km (2.7 

### NM). All flight operations are GPS controlled making the system extremely easy to navigate. Atany point ifthe operator is not explicitly commanding the system to move, the system automatically holds its GPS position (i.e. GPS hold for reliable location hover). Camera positioning is also GPS controlled allowing for the most sophisticated camera targeting available. The flight control system employs not only GPS positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed, and others to ensure the most stability ofany system inits class, regardless ofthe wind. The Aeryon SkyRanger can be operated in both semi and fully autonomous flight modes. Creating pre-planned flight paths to fly in autonomous mode is as simple as clicking on the map to create a pre-planned flight path. In semi-autonomous mode, the operator clicks on the map and the Aeryon SkyRanger automatically flies to the corresponding point in space. Pre-mission waypoints, landing zone points, and flight area dimensionscan all be entered duringpreflight, ensuring the SkyRanger operates only within specified parameters. The Aeryon SkyRanger includes many advanced safety features that makes the SkyRanger the safest choice for both urban and non-urban environments. Built-in intelligent fault handling allows the SkyRanger to detect a system fault while in the air, and to automatically fly back to its take-offlocation and land. Faults that can be detected include: loss ofcommunication; pre-set windthresholds exceeded; and lowbattery levels. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. And before every take-off automated flight checks ensure the system is flight ready before it takes off. The Aeryon SkyRanger can be operated entirely by a touch-screen, map based interface. This means that the operator needs only 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 connectionrequired. SkyRanger OperatingManual- Systemuser manual available uponrequest. Physical Characteristics Measurements- 40" diameter deployed, 20x10" folded Weight (withoutpayload)- 2.4kg (5.3 lbs) Power

- 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 canbe charged via standard wall outlet, orvia a vehicle. Landing style/type

- Autonomous vertical lift Propulsion System

- The SkyRangeris powered by4 electricbrushless DC motors. Performance Characteristics • Maximum Altitude

- 1500 ft. • Maximum Endurance

- 50 minutes • Maximum Range- 3 

### km • Weather Minimums- None • Winds Maximum- 40 MPH sustained, 55 mph gusts • Minimum ceiling: 500ft • Minimumvisibility: 1SM • Icing conditions

- no icing conditions • Precipitation- no visible moistureMaintenance

- The UAS is nearly maintenance free, it performs automatic pre-flight checks and the failure ofany check will prevent take-off. Checks which cannot be done by the system will be performedby a qualified personpriorto each flight. Pre-flight checklistincludes:

• Visual inspection ofthe airframe • Visual inspections ofrotor integrity • Check charge ofall 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 that experience routine wearare 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 ofthe airframe performed before each flight. Structural damage affecting flight characteristics will be detected by on-board sensors. The sUAS system detects numerous conditions which may make flying unsafe, such as reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature fluctuations. Automatic pre-flight checks prevent the sUAS from taking offifsuch conditions are present. Ifsuch a condition is detected during flight, the system will trigger a Fatal ConditionResponse. Fault Tolerance

- The key feature of the sUAS 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 sUAS to fly. Any component failure detectable by the system will be reported to the control station and will cause the sUAS to perform a Fatal Condition Response (FCR) or Non-Fatal Condition Response (NFCR), depending onthe type offailure. Command and Control Systems

- The SkyRanger Ground Control Station (GCS) 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 datato the operator. Telemetry datais transmitted to the command station at least once per second. Displayed on GCS: • UAS Position • Navigation Route • UAS Tail Number • UAS Position• UAS Altitude • UAS Heading • North Seeking Arrow • Range to Target • Calculatedtargetposition • Date/time • Sensorheading and orientationrelative to sUAS On-board Flight Instruments

- The SkyRanger 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 SkyRanger is equipped with on-board computer systems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, etc.) betweenthe sUAS and the operator. On-board guidance and navigation equipment

- The SkyRanger can operate autonomously; it does not require any input from ground-based equipment, or from the pilot to hover inplace. 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 atthe GCS. Takeoff and Landing

- The SkyRanger has vertical lift autonomous launch and recovery. A Landing Zone "LZ" is designated by the operators and identified inthe GCS software. For launch procedures the aircraft will takeoff and hover 3 meters directly above the LZ and hold until further instruction is provided by the operator. 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 SkyRanger combines the input from a multitude ofsensors. Even though the data from all sensors is required for optimal system performance, a single sensor malfunction is likely to result in degraded performance rather than leading to a catastrophic failure. Emergency Procedures and System Failures Failure Handling

- The SkyRanger has extensive failure detection and handling capabilities. All failures are determined 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 aNon-Fatal ConditionResponse (NFCR). 

### Sensor Failure

- Failure of on-board flight instruments or sensors will degrade the sUAS' performance and will result in either a FCRora NFCR, depending onthe severity ofthe failure. Ifthe sUAS becomes unstable due to sensor failure, it will stop all four motors andfree fall to avoid a fly away condition. 

### Motor Failure- The sUAS flight performance will degrade significantly ifone or more motors fails. 

### Airframe Failure- Ifthe airframe is damaged in a mannerthat impacts flight characteristics, the sUAS will behave as though an on-board flight instrument has failed. 

### Navigation System Failure- In a navigation system failure, degraded GPS will result in FCRorNFCR 'sdepending onthe nature ofthe failure. 

### Power Failure- A complete battery failure whichresults in powerloss to the sUAS will result in degraded flight performance. 

### Low Battery Condition

- Operatorwill be alerted ofa lowbattery condition andwill land the aircraft as soon as safely able. 

### Line-of-Sight Loss- All flight operations will beconducted withthe sUAS within visual sight ofthe operator. Ifthe operator's viewbecomes obstructed andline-of-sightis lost, the operatormay instruct the sUAS to hover inplaceuntil line-of-sight is re-established, to return to the take-offposition, orto land atthe currentposition. 

### Security The system and communication links are encrypted by the manufacturer'sproprietary software.APPENDIXC ISW OPERATING LIMITATIONS 1) The sUAS must weigh lessthan 55 pounds (25 Kg), including energy source(s) and equipment. Operations authorized bythe grant ofexemption are limitedto the following aircraft: Aeryon SkyRanger. Proposed operations ofany other aircraft will require a newpetition ora petitionto amendthe granted exemption. 2) The sUAS maynotbeflown at a ground speed exceeding 25 knots; 3) All operations shall occur in ClassG airspace; the sUAS may not operate inClass B, C, or D airspace without written approval from the FAA. 4) Operations shall avoid congested areas and sUAS mustremain clear and yield the right ofwayto all other manned operations and activities at all times (including, butnot limitedto, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 5) Operations shall be conducted over private or controlled-accessproperty; 6) Operations shall occur during Visual Flight Rules Meteorological Conditions (VMC); sUAS operations may notbe conducted during night, as defined in14 C.F.R. § 1.1; flights under special visual flight rules (SVFR) shall not be conducted. 7) Aircraft shall remainwithin Visual Line ofSight (VLOS);

a. VLOS guaranteed with a cylinder ofoperationaround operator of

### Yz nautical miles (NM); b. Cylinder walls maybe expandedbyobserver with ability to control aircraft;

c. Operator mustuse humanvisionunaided by any device other than corrective lenses; 8) Above Ground Level (AGL) altitude to be restricted to 400 feet; 6 9) All operations will be conducted outside ofa 5NMrange ofthe geographic center ofa non-towered airport as denoted on a current FAA-published aeronautical chart unless a letter ofagreement withthat airport's management is obtained, and the operationis conductedinaccordance with aNOTAM as required bythe the grant ofthis exemption.

6All altitudes reported to ATC shall be in feet AGL.

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10)Regarding the distance from authorizedpersons, the operator'smanual has safety mitigations for authorized and consentingpersonnel. Atall times, those persons mustbe essential to the operation. 11)Regarding distance from non-authorized persons, the operator shall ensure that no persons are allowed within 500 feet ofthe areaexceptthose authorized and consenting to be involved and necessary for the operation. 12)Operator shall file aNOT AMfor eachflight not more than 72 hours in advance, butnot less than48 hours priorto the operation. 13)All requiredpermissions andpermits shall be obtained from territorial, state, county or cityjurisdictions, including local lawenforcement, fire, orother appropriate governmental agencies. 14)All operations shall include oneoperatorfor flight control and one observerfor VLOS enhancement ofsurrounding areanearthe aircraft. 15)The observer and operatormustbe able to communicate verbally at all times. 16)Priorto the operation, the operatormusthave accumulated and logged a minimum of 100 flight cycles and25 hours oftotal time as a UAS rotorcraft operator and at leasttenhours logged as a UAS operatorwith a similarUAS type (single blade or multirotor).7 17)Priorto the operation, the operator musthave accumulated and logged a minimum of5 hours as sUAS pilot operatingthe Sky Ranger and threetake-offs and three landings withinthe preceding 90 days.8 18)Priorto operations, the operator and observer musthave successfully completed a qualificationprocess, as outlinedinthe OperatorTraining Manual.9 A record of completion ofthis qualificationprocess mustbe documented and made available to the Administratoruponrequest. 19)Priorto operations, a flight demonstration as set forth in the Operator's Training Manual, administered by a ISW-approved and qualified operator mustbe

7 Priordocumented flight experience thatwas obtainedin compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under this grant ofexemptionto accomplishtherequired flight cycles and flight time. Duringtraining, proficiency, and experience building flights, all personnel notessential are considered nonparticipants, and the operatormust operate the sUAS with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 8 Training, proficiency, experience-building, and take-offand landing currency flights can be conducted underthis grant ofexemptionto accomplish the required flight time and 90 day currency. During training, proficiency, experience building, andtake-offand landing currency flights all persons not essential for flight operations are considerednonparticipants andthe operatormust operatethe sUAS with appropriate distance from nonparticipants in accordance with 91 C.F.R. § 91.119. 9 The test mustbe developed and implementedby a qualifiedperson designated atthe sole discretion ofthe operator.



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successfully completed and documented. This documentationmustbe available for reviewuponrequestbythe Administrator. 20)Any sUAS thathas undergone maintenance oralterations that affectthe sUAS operation orflight characteristics (e.g., replacement ofa flight critical component) mustundergo a functional test flight, whichis recorded inthe sUAS records. 21)ISW must follow the manufacturer's UAS aircraft/componentmaintenance, overhaul, replacement, inspection, and life limitrequirements. 10 22)The sUAS may notbe operated directlyover anyperson, except authorized and consentingindividuals, below an altitude thatis hazardous to persons orproperty onthe surface inthe event ofa sUAS failure or emergency. 23)Regarding authorized and consenting individuals, those persons mustbe essential to the operation. No further PSDO or aviation safety inspector approval is necessary for reductions to the distances specified inthe operator's manual. 24)Ifthe sUAS loses communications orloses its GPS signal, the sUAS mustreturn to a pre-determined location within the securityperimeter and land orbe recovered in accordance withthe operator's manual. 25)The sUAS must abortthe flight inthe event ofunpredicted obstacles or emergencies in accordance withthe operator's manual. 26)Each sUAS mustbe completed within40 minutes flight time. 27)The operatormust obtain anAir Traffic Organization (ATO) issued Certificate of Waiver orAuthorization (COA) priorto conducting any operation sunderthe requested grant ofexemption. This COA will also require the filing ofthe NOT AM as required above. 28)All aircraft operated in accordance withthe requested exemptionmustbe identifiedby serial number, registered in accordance with 14 C.P.R. Part47, and have identification (N-Number) markings in accordance with 14 C.P.R. Part45, Subpart C. Markings shall be as large as practicable. 29)The operator shall have proceduresto document and maintain a record ofthe sUAS maintenance, preventative maintenance, alterations, status of replacement/overhaul componentparts, andthetotal time in service ofthe UAS. 30)Each sUAS must comply with all manufacturer Safety Bulletins.

10 In the absence ofAeryonrequirements, the operators manual will have instructions to develop and document maintenance, overhaul, replacement, andinspectionrequirements and procedures to document andmaintain maintenance records for the Sky Ranger.



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31)Thepreflight inspectionrequired inthe operator's manual must accountfor all discrepancies (i.e., inoperable components, items, orequipment) not covered in the relevantpre-flightinspection sections ofthe manufacturer's operating manual. 32)The operator'smanual shall require the operatorto become familiar with all available information concerningthatflight before initiation ofthe flight, includingreviewing weather, flight battery requirements, landing andtakeoff distances, aircraftperformance data, relevant site specific conditions, and other reliable information appropriate to the aircraft and relating to aircraftperformance under expected values ofelevation, aircraft gross weight, andwind and temperature. 33)Theradio frequency spectrum used for operation and control ofthe sUAS must comply with Federal Communication (FCC) or other appropriate government oversight agency requirements. 34)Atleastthree days before scheduling a flight; the operator ofthe UASaffectedby this exemptionmust submit a Written Plan ofActivities to the local FSDO with jurisdictionoverthe area ofproposed operation. 11 Theplan ofactivities shall include at least the following:

a. Dates and times for all flights; b. Name andphonenumber ofthe operator ofthe sUAS operation conducted underthe exemptions;

c. Name and phone number ofthe personresponsible for the on-scene operation ofthe sUAS; d. Make, model and serial orN-numberofsUAS to beused;

e. Name ofthe sUAS operator and observerinvolved inthe operation; f. A statementthat the operatorhas obtainedpermissionfrom the property owners and/orlocal officials to conduct operations;12
g. Signature ofexemption-holder orrepresentative; and h. A description ofthe flight activity, including maps or diagrams ofany area, city, town, county and/or state overwhich operations will be conducted and the altitudes essential to accomplishthe operation. 35)The documents required under 14 C.P.R.§§ 91.9 and 91.203 mustbe available to the operator at the Ground Control Stationofthe sUAS any time the aircraft is operating. 13

II The 3-daynotification maybe waived with the concurrence ofthe FSDO. I2 The list ofthose who gave permission shall be made available to the FAA upon request.36)sUAS shall notbe operated from any moving device orvehicle. 37) sUAS shall notbe operated less than 500 feet beloworlessthan 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the operator. 38)Any incident, accident, orflight operationthattransgresses the lateral orvertical boundaries ofthe operational areaas defined bythe applicable COA shallbe reportedto the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents shall be reported to the National Transportation SafetyBoard (NTSB) perinstructions contained onthe NTSB Web site: www.ntsb.gov. Further flight operations shall notbe conducteduntil the incident, accident, ortransgression is reviewed by AFS-80 and authorizationto resume operations is provided. 39)The sUAS shall be operated during daytime hours only.

13 These documents shall be made available to the Administrator or any law enforcement official upon request. 

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