November 20, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act, 49 U.S.C. § 

44701(t), and Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

"Reform Act"), Subsection (t) of 49 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 

("F ARs") 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 data taken by onboard sensors. Use of the Sky Ranger for these services reduces the 

need to operate conventional aircraft, providing more accurate data more safely, 

economically, and with reduced environmental impact. 

This exemption is derived from a request by Aeryon Labs Inc. ("Aeryon"), the developer 

ofthe SkyRanger sUAS. 1 Details of Aeryon 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 

1 See Aeryon Labs Inc., Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations, Docket No. FAA-2014-0642 (Aug. 25, 2014). ISW is aware of two other 

exemption requests to commercially operate the Aeryon SkyRanger. See VDOS Global LLC Exemption 

Request, Docket No. FAA-2014-0382 (Jun 9, 2014); City of Roswell Coalition, Exemption Request Under 

Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations, Docket No. FAA2014-0732 (Sept. 2014). 
for flying the sUAS, monitoring its status and flight dynamics while maintaining visual 

line of sight and keeping the flight within the manufacturer's specified limits in terms of 

wind, flight range, battery life, etc., to ensure safe operation of the vehicle. The observer 

is responsible for monitoring the airspace for other aircraft and hazards and advising the 

operator before and during flight of all such observed risks. ISW's sUAS operators will 

have passed an FAA approved or equivalent ground training exam and completed an 

authorized Aeryon training program for the Sky Ranger. 

Applicant Information: 

The name and address of the applicant is: 

123 Delaware, Inc. 

2711 Centerville Road, Suite 400 

Wilmington, Delaware 

19808 

The primary contact for 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. Part 21; 

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, ISW will operate under similar operating conditions as those required of the 

movie industry grants of exemption, in which exemptions for these FAR was deemed by the FAA as "not 

necessary." As a result, ISW is not requesting FAA exemption from FAR 45.23(b), 91.7(a), 91.9(b)(2), 

91.103, 91.109(a), and 91.203(a) and (b). 
Airworthiness of the Sky Ranger 

A critical element of the exemption application involves evidence of the 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 of New 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 of which 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 of pre-programmed control and various built-in technical 

capabilities that limit the potential for operation outside of the pre-established conditions. 

The SkyRanger sUAS also provides many built-in functional and safety features to assist 

the operator in safe and reliable operation. 

The SkyRanger provides two semi-autonomous flight modes using a point-and-click map 

and video interface. The user clicks on a map to direct the SkyRanger to fly to the point 

on the map where the operator is pointing, or programmed 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 

of sensors including sonar, barometric pressure, temperature, and wind speed to ensure 

high stability and reliability in challenging weather conditions. In the case of lost GPS, a 

manual user flight mode is enabled which allows the operator to provide manual 

navigation inputs to assist in landing the vehicle. At all times during flight operations, 

the operator can suspend a programmed flight and take immediate control of the 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 

of sight (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 (NOT AM). 

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-defined responses to a 

number of flight and system conditions, including: 

a. High winds with system and operator-defined safety thresholds; 

b. Low battery with system and operator-defined safety thresholds; 

c. High temperature safety thresholds; and 

d. Lost-link communication; and 

3) Pre-defined responses include attempting to re-establish radio communication, 

return to home position and hover, return to home position and land, or land in 

current position. 

Given these safety features, ISW proposes the Sky Ranger sUAS be operated by qualified 

operators and observers, rather than pilots. The operators should be required to: 

1) have successfully completed FAA private pilot ground instruction and passed the 

FAA Private Pilot written examination or FAA-recognized equivalents including 

commercial or private license and ground school issued from an ICAO country; 

and 

2) have completed Aeryon's authorized training program for operation and 

maintenance ofthe sUAS. 

ISW notes that the FAA has found that safety factors permitted operation of sUASs by 

operators with these qualifications in the case of operations pursuant to public CO As 

when the mandatory operating conditions specified above were present (FAA Notice N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 

2013))_3 

Public Interest 

ISW respectfully submits that its use of the 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 of this 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 of surveying and inspection operations magnify the dangers of using conventional 

aircraft, as the aircraft fly in nonconventional operations under FAA waivers and at 

dangerous altitudes. By contrast the SkyRanger sUAS weighs 6lbs including its payload 

and uses a battery for power, is carried to and from the area of activity, 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 The FAA has the statutory authority to grant exemptions to the requirements for and privileges associated 

with the grant of airmen'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 of the SkyRanger 

sUAS poses no threat to national security. 

The grant of the 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 of safety of the 

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 exemption without delay. 

Lance T. Lehman 

4 The Federal Aviation Act ("FAAct") expressly grants the FAA the authority to issue exemptions: 

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection 

(a) or (b) of this section or any of sections 44702-44716 of this title if the Administrator finds the 

exemption is in the public interest. 49 U.S.C. § 4470l(t) 
APPENDIX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 

rsw requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the Sky Ranger: 

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

14 C.F.R. § 91.203(a)(1) 

Section 91.203(a)(l) requires all civil aircraft to have a certificate of airworthiness. Part 

21, Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR § 

91.203(a)(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 Part 21 Subpart H to achieve or exceed current safety levels. 

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

and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the 

Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the sUAS involved. 

In this case, an analysis of these criteria demonstrates that the SkyRanger operated 

without an airworthiness certificate, under the conditions proposed herein, will be at least 

as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an 

airworthiness certificate. The SkyRanger weighs 6 lbs. fully loaded. It will not carry a 

pilot or passenger, will not carry flammable fuel, and will operate exclusively within 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 of all operations through the filing of NOTAMs. Receipt of the prior permission 

of the landowner (or lessee), the size of the aircraft, the lack of flammable fuel, and the 

fact that the aircraft is carried to the location and not flown there all establish the 

equivalent level of safety. The SkyRanger provides at least an equivalent, and most likely 

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 of Sky Ranger 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 RP A 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, 

highlight the design intentions towards safety and reliability of the SkyRanger sUAS. 

14 C.F.R. §§ 61.3; 61.113(a) & (b); 61.133(a): Private Pilot Privileges and 

Limitations; Pilot in 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 of an 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 of others on board. ISW respectfully 

proposes that operator requirements should take into account the characteristics of the 

particular sUAS. The SkyRanger sUAS has a high degree of pre-programmed control 

and various built-in technical capabilities that strictly limit the potential for operation 

outside of the operating conditions set forth in the exemption application. 

The SkyRanger sUAS has an all-digital software platform with advanced features 

previously restricted to 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 in manual mode 

• Smart batteries and charger: Flight time and battery minutes are displayed at all 

times. The system will return home and land automatically if user-configurable 

limits are reached. 

Flight safety is a priority, no matter the operating environment or project. The SkyRanger 

offers superior safety over manned aircraft by removing the need for people to be 

onboard in potentially dangerous situations. With multiple built-in safety features, the 

Aeryon SkyRanger platform leads other sUAS manufacturers with respect to safety. 

• Intelligent fault handling: The system automatically detects potential issues - with 

configurable automated response behavior such as a return-home-and-land routine 

• Automatic pre-flight checks: The system self-calibrates all of its sensors and 

performs self-tests prior to takeoff to check for errors 

• No-fly zones: The system has the ability to set up 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 if user-configurable limits 

are reached. 

Additional automated safety functions and safety enhancing features of the SkyRanger 

include the following: 
• Auto-detection of lost GPS warns the pilot and initiates an immediate landing. 

• Low battery on the SkyRanger triggers a "Non Fatal Warning" alarm to return 

home, land and replace the battery. 

• Very low battery on the SkyRanger triggers a "Fatal Error" alarm and initiates an 

emergency high speed descent landing. 

• If the Sky Ranger detects a lost-link to the base-station the vehicle will perform its 

pre-defined Non-Fatal Condition Response. 

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 of sight (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 (NOT AM). 

Given these safety features and operating conditions, ISW proposes that operators of the 

SkyRanger sUAS should not be required to hold a commercial or private pilot 

certification. Instead, operators should be required to: 

• have successfully completed, at a minimum, FAA private pilot ground instruction 

and passed the FAA Private Pilot written examination or FAA-recognized 

equivalents including ICAO issued commercial, private license and ground 

school; and 

• have completed Aeryon's training program for operation of the sUAS. 

ISW notes that the FAA has found that safety factors permitted operation of sUASs by 

operators with these qualifications in the case of operations pursuant to public COAs 

where the mandatory operating conditions specified above are present (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 SkyRanger before conducting operations. 

Given these conditions and restrictions, an equivalent or enhanced level of safety will be 

provided by allowing operation of the SkyRanger sUAS without a private pilot's 

certificate or a commercial pilot's certificate, under the conditions set forth herein. 

The risks associated with the operation of the SkyRanger (given its size, speed, 

operational capabilities, and lack of combustible fuel) are so diminished from the level of 

risk associated with private pilot operations or commercial operations contemplated by 

Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of 

the sUAS as set forth above meets or exceeds the present level of safety provided under 

14 C.P.R.§ 61.113(a) & (b) and does not rise to the level of requiring 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 of civil aircraft. Specifically, 

91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 

feet above the surface, except over open water or sparsely populated areas. In those cases, 

the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. 

As set forth herein, the SkyRanger will never operate at higher than 400 feet AGL. 

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 of safety will be achieved given the size, weight, speed, 

and material with which the SkyRanger is built. Also, no flight will be taken without the 

permission of the landowner or those who control the land. Because of the advance 

notice to the landowner (or lessee), all affected individuals will be aware of the 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 Qf the sUAS will 

maintain separation between these sUAS operations and the operations of conventional 

aircraft that must comply with Section 91.119. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

This regulation prohibits an individual from beginning "a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel 

to fly to the first point of intended landing and, assuming normal cruising speed - (1) 

During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for 

at least 45 minutes." 

The SkyRanger batteries provide approximately 50 minutes of powered 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 

longer time frame for flight in VFR conditions is reasonable. 

ISW believes that an exemption from 14 C.F.R. § 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 battery power, it would simply land. Given its weight and 

construction material, the risks are less than contemplated by the current regulation. 
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 of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter ... " Section 91.407 similarly makes reference to 

requirements in Part 43. Section 91.409(a)(2) requires an annual inspection for the 

issuance of an air worthiness certificate. Section 91.417(a) requires the owner or 

operator to keep records showing certain maintenance work that has been accomplished 

by certificated mechanics, under Part 43, or licensed pilots and records of approval of the 

aircraft for return to service. 

The SkyRanger is nearly maintenance free, it performs automatic pre-flight checks and 

the failure of any check will prevent take-off. Checks which cannot be done by the 

system will be performed by a qualified person prior to each flight and at predefined 

intervals as part of the maintenance schedule. 

Pre-flight checklist includes: 

1. Visual inspection of the airframe 

2. Visual inspections of rotor integrity 

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

station) 

An equivalent level of safety will be achieved because the sUAS is small in size, will 

carry no external payload, will operate only in restricted predetermined areas and is not a 

complex mechanical 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 of safety. 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 Sky Ranger. 

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 a 
Fatal Condition Response (FCR) or Non-Fatal Condition Response (NFCR), depending 

on the type of failure. 
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 behalf of ISW for N-registration. 

Aeryon systems have been approved by the FAA for research CO As and have 

demonstrated a safety track record. The Aeryon sUAS platforms were the first to 

officially fly at one of the FAA's UAS Test Sites (UAF Alaska). Many 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, monitor hostile 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 open pit mines. 

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 of feel' for what the impact of the wind is at the altitude at which the 

system is flying. The result is a system capable of gathering high quality aerial data at 

high wind thresholds, a trait that is imperative for many aerial inspection operations. 

The SkyRanger has a standard operational range of 3 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. 

At any point if the operator is not explicitly commanding the system to move, the system 

automatically holds its GPS position (i.e. GPS hold for reliable location hover). Camera 

positioning is also GPS controlled allowing for the most sophisticated camera targeting 

available. The flight control system employs not only GPS positioning but a variety of 

sensors including sonar, barometric pressure, temperature, wind speed, and others to 

ensure the most stability of any system in its class, regardless of the wind. 

The Aeryon SkyRanger can be operated in both semi and fully autonomous flight modes. 

Creating 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 dimensions 
can all be entered during preflight, ensuring the SkyRanger operates only within specified 

parameters. 

The Aeryon SkyRanger includes many advanced safety features that makes the 

SkyRanger the safest choice for both urban and non-urban environments. Built-in 

intelligent fault handling allows the SkyRanger to detect a system fault while in the air, 

and to automatically fly back to its take-off location and land. Faults that can be detected 

include: loss of communication; pre-set wind thresholds exceeded; and low battery levels. 

In addition, the operator can create no fly zones or maximum flight ranges and altitudes 

so the system cannot enter areas deemed unsafe or unnecessary to fly over. And before 

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

off. 

The Aeryon SkyRanger can be operated entirely by a touch-screen, map based interface. 

This means 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 connection required. 

SkyRanger Operating Manual- System user manual available upon request. 

Physical Characteristics 

Measurements- 40" diameter deployed, 20x10" folded 

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

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 can be charged via standard wall outlet, or via a vehicle. 

Landing style/type - Autonomous vertical lift 

Propulsion System - The SkyRanger is powered by 4 electric brushless 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 

• Minimum visibility: 1 SM 

• Icing conditions - no icing conditions 

• Precipitation- no visible moisture 
Maintenance - The UAS is nearly maintenance free, it performs automatic pre-flight 

checks and the failure of any check will prevent take-off. Checks which cannot be done 

by the system will be performed by a qualified person prior to each flight. 

Pre-flight checklist includes: 

• Visual inspection of the airframe 

• Visual inspections of rotor integrity 

• Check charge of all batteries (aerial vehicle, command station, radio repeater 

station) 

Reliability - The system is designed for maximum reliability and to maintain 

performance over its life. The only components that experience routine wear are rotors, 

batteries, motors, and legs. Battery and motor conditions are monitored by the system 

with deviations reported to the operator. 

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

and motor arms, to become damaged. Damaged components are likely to be detected 

during the full visual inspection of the airframe performed before each flight. Structural 

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

The 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 

off if such conditions are present. If such a condition is detected during flight, the system 

will trigger a Fatal Condition Response. 

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 on the type of failure. 

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 data to the operator. Telemetry data is transmitted to the command station 

at least once per second. 

Displayed on GCS: 

• U AS Position 

• Navigation Route 

• UAS Tail Number 

• UAS Position 
• UAS Altitude 

• UAS Heading 

• North Seeking Arrow 

• Range to Target 

• Calculated target position 

• Date/time 

• Sensor heading and orientation relative 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.) between the 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 in place. 

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

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

situation a flight termination link is available to the operator at the GCS. 

Takeoff and Landing - The SkyRanger has vertical lift autonomous launch and 

recovery. A Landing Zone "LZ" is designated by the operators and identified in the GCS 

software. For launch procedures the aircraft will takeoff and hover 3 meters directly 

above the LZ and hold until further 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 of sensors. 

Even though the data from all sensors is required for optimal system performance, a 

single sensor malfunction is likely to result in degraded performance rather than leading 

to a catastrophic failure. 

Emergency Procedures and System Failures 

Failure Handling - The 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 a Non-Fatal Condition Response (NFCR). 

Sensor Failure - Failure of on-board flight instruments or sensors will degrade the 

sUAS' performance and will result in either a FCR or a NFCR, depending on the severity 

of the failure. If the sUAS becomes unstable due to sensor failure, it will stop all four 

motors and free fall to avoid a fly away condition. 

Motor Failure- The sUAS flight performance will degrade significantly if one or more 

motors fails. 

Airframe Failure- If the airframe is damaged in a manner that 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 

FCR or NFCR 's depending on the nature of the failure. 

Power Failure- A complete battery failure which results in power loss to the sUAS will 

result in degraded flight performance. 

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

land the aircraft as soon as safely able. 

Line-of-Sight Loss- All flight operations will be conducted with the sUAS within visual 

sight of the operator. If the operator's view becomes obstructed and line-of-sight is lost, 

the operator may instruct the sUAS to hover in place until line-of-sight is re-established, 

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

Security 

The system and communication links are encrypted by the manufacturer's proprietary 

software. 
APPENDIXC 

ISW OPERATING LIMITATIONS 

1) The sUAS must weigh less than 55 pounds (25 Kg), including energy source(s) 

and equipment. Operations authorized by the grant of exemption are limited to 

the following aircraft: Aeryon SkyRanger. Proposed operations of any other 

aircraft will require a new petition or a petition to amend the granted exemption. 

2) The sUAS may not be flown at a ground speed exceeding 25 knots; 

3) All operations shall occur in Class G airspace; the sUAS may not operate in Class 

B, C, or D airspace without written approval from the FAA. 

4) Operations shall avoid congested areas and sUAS must remain clear and yield the 

right of way to all other manned operations and activities at all times (including, 

but not limited to, ultralight vehicles, parachute activities, parasailing activities, 

hang gliders, etc.). 

5) Operations shall be conducted over private or controlled-access property; 

6) Operations shall occur during Visual Flight Rules Meteorological Conditions 

(VMC); sUAS operations may not be conducted during night, as defined in 14 

C.F .R. § 1.1; flights under special visual flight rules (SVFR) shall not be 

conducted. 

7) Aircraft shall remain within Visual Line of Sight (VLOS); 

a. VLOS guaranteed with a cylinder of operation around operator of Yz 

nautical miles (NM); 

b. Cylinder walls may be expanded by observer with ability to control 

aircraft; 

c. Operator must use human vision unaided 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 of a 5NM range of the geographic center 

of a non-towered airport as denoted on a current FAA-published aeronautical 

chart unless a letter of agreement with that airport's management is obtained, and 

the operation is conducted in accordance with a NOT AM as required by the the 

grant of this exemption. 

6 All altitudes reported to ATC shall be in feet AGL. 
10) Regarding the distance from authorized persons, the operator's manual has safety 

mitigations for authorized and consenting personnel. At all times, those persons 

must be essential to the operation. 

11) Regarding distance from non-authorized persons, the operator shall ensure that no 

persons are allowed within 500 feet of the area except those authorized and 

consenting to be involved and necessary for the operation. 

12) Operator shall file a NOT AM for each flight not more than 72 hours in advance, 

but not less than 48 hours prior to the operation. 

13) All required permissions and permits shall be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies. 

14) All operations shall include one operator for flight control and one observer for 

VLOS enhancement of surrounding area near the aircraft. 

15) The observer and operator must be able to communicate verbally at all times. 

16) Prior to the operation, the operator must have accumulated and logged a minimum 

of 100 flight cycles and 25 hours of total time as a UAS rotorcraft operator and at 

least ten hours logged as a UAS operator with a similar UAS type (single blade or 

multirotor).7 

17) Prior to the operation, the operator must have accumulated and logged a minimum 

of 5 hours as sUAS pilot operating the Sky Ranger and three take-offs and three 

landings within the preceding 90 days. 8 

18) Prior to operations, the operator and observer must have successfully completed a 

qualification process, as outlined in the Operator Training Manual.9 A record of 

completion of this qualification process must be documented and made available 

to the Administrator upon request. 

19) Prior to operations, a flight demonstration as set forth in the Operator's Training 

Manual, administered by a ISW-approved and qualified operator must be 

7 Prior documented flight experience that was obtained in compliance with applicable regulations may 

satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted 

under this grant of exemption to accomplish the required flight cycles and flight time. During training, 

proficiency, and experience building flights, all personnel not essential are considered nonparticipants, and 

the operator must operate the sUAS with appropriate distance from nonparticipants in accordance with 14 

C.F.R. § 91.119. 8 Training, proficiency, experience-building, and take-off and landing currency flights can be conducted 

under this grant of exemption to accomplish the required flight time and 90 day currency. During training, 

proficiency, experience building, and take-off and landing currency flights all persons not essential for 

flight operations are considered nonparticipants and the operator must operate the sUAS with appropriate 

distance from nonparticipants in accordance with 91 C.F.R. § 91.119. 9 The test must be developed and implemented by a qualified person designated at the sole discretion of the 

operator. 

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successfully completed and documented. This documentation must be available 

for review upon request by the Administrator. 

20) Any sUAS that has undergone maintenance or alterations that affect the sUAS 

operation or flight characteristics (e.g., replacement of a flight critical component) 

must undergo a functional test flight, which is recorded in the sUAS records. 

21) ISW must follow the manufacturer's UAS aircraft/component maintenance, 

overhaul, replacement, inspection, and life limit requirements. 10 

22) The sUAS may not be operated directly over any person, except authorized and 

consenting individuals, below an altitude that is hazardous to persons or property 

on the surface in the event of a sUAS failure or emergency. 

23) Regarding authorized and consenting individuals, those persons must be essential 

to the operation. No further PSDO or aviation safety inspector approval is 

necessary for reductions to the distances specified in the operator's manual. 

24) If the sUAS loses communications or loses its GPS signal, the sUAS must return 

to a pre-determined location within the security perimeter and land or be 

recovered in accordance with the operator's manual. 

25) The sUAS must abort the flight in the event ofunpredicted obstacles or 

emergencies in accordance with the operator's manual. 

26) Each sUAS must be completed within 40 minutes flight time. 

27) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operation sunder the 

requested grant of exemption. This COA will also require the filing of the 

NOT AM as required above. 

28) All aircraft operated in accordance with the requested exemption must be 

identified by serial number, registered in accordance with 14 C.P.R. Part 47, and 

have identification (N-Number) markings in accordance with 14 C.P.R. Part 45, 

Subpart C. Markings shall be as large as practicable. 

29) The operator shall have procedures to document and maintain a record of the 

sUAS maintenance, preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the UAS. 

30) Each sUAS must comply with all manufacturer Safety Bulletins. 

10 In the absence of Aeryon requirements, the operators manual will have instructions to develop and 

document maintenance, overhaul, replacement, and inspection requirements and procedures to document 

and maintain maintenance records for the Sky Ranger. 

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31) The preflight inspection required in the operator's manual must account for all 

discrepancies (i.e., inoperable components, items, or equipment) not covered in 

the relevant pre-flight inspection sections of the manufacturer's operating manual. 

32) The operator's manual shall require the operator to become familiar with all 

available information concerning that flight before initiation of the flight, 

including reviewing weather, flight battery requirements, landing and takeoff 

distances, aircraft performance data, relevant site specific conditions, and other 

reliable information appropriate to the aircraft and relating to aircraft performance 

under expected values of elevation, aircraft gross weight, and wind and 

temperature. 

33) The radio frequency spectrum used for operation and control of the sUAS must 

comply with Federal Communication (FCC) or other appropriate government 

oversight agency requirements. 

34) At least three days before scheduling a flight; the operator of the U AS affected by 

this exemption must submit a Written Plan of Activities to the local FSDO with 

jurisdiction over the area of proposed operation. 11 The plan of activities shall 

include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator of the sUAS operation conducted 

under the exemptions; 

c. Name and phone number of the person responsible for the on-scene 

operation of the sUAS; 

d. Make, model and serial or N-number of sUAS to be used; 

e. Name of the sUAS operator and observer involved in the operation; 

f. A statement that the operator has obtained permission from the property 

owners and/or local officials to conduct operations; 12 

g. Signature of exemption-holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any 

area, city, town, county and/or state over which operations will be 

conducted and the altitudes essential to accomplish the operation. 

35) The documents required under 14 C.P.R.§§ 91.9 and 91.203 must be available to 

the operator at the Ground Control Station of the sUAS any time the aircraft is 

operating. 13 

II The 3-day notification may be waived with the concurrence of the FSDO. 

I

2 The list ofthose who gave permission shall be made available to the FAA upon request. 
36) sUAS shall not be operated from any moving device or vehicle. 

37) sUAS shall not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

operator. 

38) Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA shall be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents shall be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight 

operations shall not be conducted until the incident, accident, or transgression is 

reviewed by AFS-80 and authorization to 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.