### July 28 , 2015

Exemption No. 12195 Regulatory Docket No. FAA

–20 15

– 1854

Mr. James Rodriguez Vice President Easy Drive 906 Ruiz Street San Antonio, TX 78207
Dear Mr. Rodriguez : This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and giv es you the conditions and limitations of the exemption, including the date it ends. By letter dated May 8, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Easy Drive (hereinafter petitioner or operator) for an exemption . The petitioner requested to operate an unmanned aircraft system (UAS) to conduct productivity demonstrations, aerial surveys, mapping, and inspections

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

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

. Airworthiness Certification The UAS proposed by the petitioner is an Aeryon Skyranger

. The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates

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

− 95 in reference to 49 U

. S

. C

. § 44704, and in

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consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21 , Certification procedures for products and parts, Subpart H

— Airworthin ess Certificates , and any associated noise certification and testing requirements of part 36, is not necessary. The Basis for Our Decision You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s . 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

− 20 14

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

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;
 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and
 A grant of exemption is in the public interest. Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Easy Drive is granted an exemption f rom 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

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

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

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Conditions and Limitations
In this grant of exemption, Easy Drive is hereafter referred to as the operator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.
1. Operations authorized by this grant of exemption are limited to the Aeryon Skyranger when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

. 2. Operations for the purpose of closed

- set motion picture and television filming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.
6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communi cate verbally at all times ; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the V O can perform the duties required of the VO.
7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the op erating documents, the conditions and limitations herein take precedence and must be followed.

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Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is th e operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.
8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. , replacement of a fli ght critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.
9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre

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

- flight inspection must account for all potential discrepancies, e.g. , inoperable components, items, or equipment. If the inspection reveals a con dition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.
11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
14. The operator may not permit any PIC to operate unles s the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be

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

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

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, un less a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement off icial upon request.
17. The UA may 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 PIC. 18. If the UAS loses communications or loses its GPS sign al, the UA must return to a pre - determined location within the private or controlled

- access property. 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast w eather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.
21. Air Traffic Organization (ATO) Certif icate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

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

. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification

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(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, v ehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protectio n. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.
27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

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

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29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption. 30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be used; e. Name and certificate number of UAS PICs invol ved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request ; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operati on. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption , the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

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This exemption terminates on July 31, 2017 , unless sooner superseded or rescinded. Sincerely, /s/ John S. Duncan Director, Flight Standards Service

Enclosures

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Date: 05/08/15

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Wa shington, DC 20590 Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of t he Federal Aviation Regulations

Dear Sir or Madam: Pursuant to Section 333 of t he FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Easy Drive seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in Appendix A. T his exemption is derived fro m a request by Aeryon Labs Inc. (“Aeryon”), the developer and operator of the Scout and SkyRanger small Unmanned Aircraft Systems (“sUAS”). D etails of

Aeryon a nd the SkyRanger sUAS are described in Appendix B. Attached as App endix C is a summary of this request. The requested exemption would permit Easy Drive commercial operation of Aeryon’s SkyRanger (see details in Appendix B), which we ighs 6 l bs. w ith imaging payload, to perform productivity demonstrations, aerial surveys, mapping, and inspections that consist of still photographs, video, and other data taken by onboard sensors. The SkyRanger produces high quality imagery and data that can be used independently

- or in the case of surveying and modelling, can be combined to produce precision digital point clouds, triangle models, and contour maps of the surveyed area. A pplications for these sUASs include inspection of sensitive infrastructure including oil and gas pipelines and flare stacks, power lines and towers, wind t urbines, and surveying tasks such as precision agriculture, mining, transportation, and forestry. Use of the SkyRanger for these inspection and surveying applications reduces the need to operate conventional aircraft, providing data more quickly, accuratel y, economically, safely, and with reduced environmental impact. Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level of safety to currently authorized operations using manne d aircraft and under conditions as may be modified by the FAA as required by Section 333. 

### While Easy

Drive is filing this exemption request on its own behalf, it anticipates that its customers, in the future, will file exemption applications to allow them to operate the SkyRanger in commercial operations at their own facilities, farms, mines, and other sites that require aerial data for inspections and surveys. Wherever possible, those filings will be substantially similar to this exemption application.
As described more fully below, the requested exemption would authorize Easy Drive to perform

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productivity demonstrations, aerial s urveys, mapping, and inspection operations that using the SkyRanger 1 , which at 6 lbs. is small in size and powered electrically by battery. The SkyRanger will be operated under controlled conditions at low altitude in airspace that is limited in scope, as described more fully herein; it will have automated control feature s, as described below. The Aeryon SkyRanger is designed to be operated by one person but flight operations generally involve two people: an operator and an observer. The operator is responsible for flying the sUAS, monitoring its status and flight dynamics while maintaining visual line of sight, and keeping the flight within the specified factory limits (in terms of wind, flight range, battery life, etc) to ensure safe operation of the sUAS itself. The observer is responsible for monitoring the airspace for other aircraft and hazards and instructing the operator before and during flight as necessary to ensure safe separation/de

- confliction with these aircraft and hazards. The operator also will be an individual who has passed an FAA approved or equivalent g round training exam and authorized Aeryon training program for the SkyRanger. Finally, the airspace in which the SkyRanger will operate will be disclosed to and approved, as needed, by the FAA in advance. Easy Drive respectfully submits that because this small, unmanned aerial system

– the SkyRanger

– will be used in lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft, the FAA can have confidence that the operations will achieve at least an equivalent level or greater level of safety. A pproval of this exemption would thereby enhance safety and ful fill the Secretary of T ransportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of s uch aircraft systems in the national airspace system.” The name and address of the applicant are: Easy Drive Attn: James Rodriguez Ph: 210

- 227

- 5975 Fax: 210

- 222

- 8316 Email: jr@easydrive.net Address: 906 Ruiz Street San Antonio, TX 782 07 

### The primary

contact for this application is: James Rodriguez , jr@easydrive.net , 210.227.5975 The regulations from which the exemption is requested are as follows: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b);

1 Aeryon and its customers have been granted ma ny flight operation certificate to operate the Aeryon Sk yR anger, and its predecessor the Aeryon Scout

- including Special Flight Operation Certificates in Canada for commercial use, and Certificates of Wa iver or Authorization (COA) in the US for public agency use.

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14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a). Appendix A discusses each rule listed above and explains wh y exemptions pursuant to the proposal set fo rth in this letter are appropriate, provide an equivalent level of safety, and are in the public interest

.

### 4 of 20 **THE AP**  **PLICA BLE LEGA**  **L STA NDA**  **RD UNDER SECTION 333** Easy Drive submits that grant of this exemption applicati on for use of the SkyRanger in productivity demonstrations, aerial surveys, mapping, and inspection operations that will advance the Congre ssional mandate in Section 333 of the Reform Act to accelerate the introduction of sUASs into the national airspace system (“NAS”) if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether certain sUASs may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of sUASs do not create a hazard to users of the NAS or the public or po se a threat to national security in light of the following:

● The sUAS’s size, weight, speed, and operational capability; ● Operation of the sUAS in close proximity to airports and populated areas; and ● Operation of the sUAS within visual line of sight of t he operator. Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of s uch aircraft in the national airspace system.” Id. §333(c) (emphasis added). 2
The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act, from the requirement that all civil aircraft mus t have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of t his 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. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1). The grant of

t he requested exemption is in the public interest based on the clear direction in Section 333 of t he Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations; and the significant public benef it, including enhanced safety and cost savings associated with transitioning to sUASs for aerial surveying, mapping and inspection appli cations. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay. **Ai rw**  **orthiness of the Sky Ranger**  A critical element of the exemption application involves evidence of the airworthiness of Aeryon sUAS inc luding the SkyRanger. Aeryon believes that it has shown compliance through a history of granted flight operations and successful flights

- including many operations with public agencies. T he list of granted applicants includes: Michigan State Police, US N avy Spawar, Ma ss Development (Joint Base Cape Cod), Unmanned Experts (NIJ Partnership), We stern Wa shington University, Aetos (v ia Northwest Michigan College), University of Alaska Fairbanks, University of New Me xico, Kansas State

2 Applicant submits that this provision places a dut y on the Adm inistrator to not only process applications for exem ptions under Section 333, but for the Adm inistrator, if he deems the conditions proposed herein require mo dification in order to allow approval, to supply conditions for the safe operation of the sUAS

. Aeryon welcomes the opportunity to consult with FAA staff in order to address any i ssues or concerns t hat this proposal ma y raise that they believe may require modification.

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University, and Virginia T ech University. T he AkyRanger has also successfully completed the Department of Homeland Security RAPS Trial in 2013. I n Canada, Aeryon has obtained 19 Special Flight Operations Certificates (SFOCs) from Transport Canada over 5 years and its customers ha ve received multiple certificates to perform demonstration, research and development, public and commercial operations. T he criteria set forth in the certificates granted specify the substantive showings of

t he device’s safety and fitness for operation to ensure that the FAA has sufficient basis to evaluate the aircraft’s safety3

. T he SkyRanger also has a significant set of a utomated features to ensure safe takeoff, flight and landing in many conditions, further details of o peration can be found in Append ix B. **Mandatory**

**Operating Conditions** Grant of t he exemption to Easy Drive will be subject to the following mandatory conditions, which are based upon operating conditions set forth fo r operation of sUAS by public entities pursuant to Certificates of Aut horization, with additional restrictions:



### ● All operations to occur in Class G airspace. 

### ● Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts. 

### ● Operations to be conducted over private or controlled

- access property. 

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

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

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

### ● VLOS guaranteed with a cylinder of opera tion around operator of 1⁄2 nautical miles (NM). 

### ● Cylinder walls may be expanded by observer with ability to control aircraft. 

### ● Operations to occur during daylight hours. ● Above Ground Level (AGL) altitude to be restricted to 400 feet. ● All operations conducted in vicinity of airport to remain more than 2.5 NM fro m centerline azimuth of runway centerline measured from runway thresholds. ● Operator will file a NOTAM for each flight. ● All required permissions and permits will be obtained fro m territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. ● All operations will include one pilot for flight control and one observer for VLOS enhancement of surrounding area near the aircraft **Operator Requirements** Easy Drive respectfully proposes that operator requirements should take into account the characteristics of

t he particular sUAS. Certain sUASs, such as the Aeryon SkyRanger, are characterized by a high degree of pre - programmed control and various built

- in technical capabilities that limit the potential for operation outside of the operating conditions set forth above. The SkyRanger sUAS also provides many built

- in functional and safety features to assist the opera tor in safe and reliable operation. 4

3 Aeryon can submit under confidentiality the following documents in support of this exemption application for the Sk yRanger: 1) Aeryon Sk yRanger User Guide (Exhibit 1) which includes Safety and PreFlight Checklists; and 2) Training Manual (Exhibit 2). 4 As of July 2014, Aeryon staff and customers have performed over 5681 flights, logging 623 hours of flight time with the Sk yR anger with both development and release versions. The previ ous generation product, Scout, achieved over 7197 flights and 839 hours of flight time globally by Aeryon and its customers. This is a significant am ount of flight time collected to understand and refine the Aeryon sUAS products.

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The Aeryon SkyRanger provides two semi

- autonomous flight modes using a point

- and

- click map and video interface. The user clicks on a map to direct the SkyRanger to fly to the point on the map where the operator is poi nting, or programmed flight plans may be entered for a series of waypoints or grid

based area. Additional navigation aids including landing zones and flight areas may be designated to ensure the SkyRanger operates only within user- specified flight paramete rs. All flight operations are GPS controlled making the system easy to navigate, and the flight control system also employs a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure the high stability and reliabi lity in challenging we ather conditions. At all times during flight operations, the operator can intervene a programmed flight and take immediate control. Additional automated safety functions and safety enhancing fe atures of the SkyRanger include the fo llowing: 

### ● Automated pre

-flight system performance checks ● User pre

-flight checklist ● Automated condition or fault detection, warnings, and pre - def ined responses to a number of flight and system conditions.

◦ High winds with system and user defined safety thre sholds

◦ Low battery with system and user defined safety thresholds

◦ High temperature or other system safety thresholds

◦ Lost

- link communication 

### ● Pre

- def ined responses include behavior such as attempting to re - establish radio communication, return to home posi tion and hover, return to home position and land, or land in current position ● In the case of

l ost GPS, a manual user flight mode is enabled which allows the operator to provide manual navigation inputs to assist in landing the vehicle. Given these safe ty features, Easy Drive proposes that operators of the SkyRanger should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:



### ● have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA

- recognized equivalents including commercial or private license and ground school issued from an ICAO recognized coun try; 

### ● have completed Aeryon’s authorized training program fo r operation and maintenance of the sUAS. Easy Drive notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were present. See Federal Aviation Administration, Notice N

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

- 21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the requirements for and privileges associated with the grant of airmen’s certificates. 49 USC §44701 (f). In summary, Easy Drive seeks an exemption from the FARs set forth above and in Appendix C to allow operations of a small unmanned vehicle in productivity demonstrations, aerial surveys, mapping, and inspection operations.

. Approval of the exemption allowing commercial o perations of the SkyRanger for productivity demonstrations, aerial surveys, mapping, and inspections operations will enhance safety by reducing

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risk. Conventional aerial survey and inspection operations using manned aircraft involve very heavy aerial vehic les carrying significant quantities of combustible fuels, and a multi

- person crew in piloting and observation roles. These operations require transit to and from the location of the activity, and of ten take place in congested environments including proxim ity to physical obstacles and/or presence of the general public. By contrast, the Skyranger weighs 6 lbs including payloads and uses a battery for power, is carried to/from the area of activity, removes the need for airborne pilots/observers, and

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**AP PEND**  **IX A**

**EXEMPTION REQUEST A ND EQUIVA**  **LENT LEVEL OF SA FETY SHOWINGS UNDER** 

**AP PLICA**  **BLE RULES SUBJECT TO EXEMPTION**
Easy Drive requests an exemption fro m the following regulations as well as any additional regulations that may technically apply to the operati on of the SkyRanger: **14 C.F.R. Part 21, Subpart H: A irw**  **orthiness Certificates 14 CFR § 91.203(a)(1)**  Section 91.203(a)(1) requires all civil aircraft to have a certificate of a irworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, estab lishes the procedural requirements fo r the issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the aircraft (6 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels. Such an exemption meets the requirements of an equivalent level of s afety 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, we ight, speed, operational capability, and proximity to airports and populated areas of the s UAS 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 (f ixed wing or rotorcraft) with an airworthiness certificate. The SkyRanger we ighs 6 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an area pre

- disclosed and in compliance with conditions se t forth herein. Operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the conditions set forth above, and by local public safety requirements. The FAA will have advance notice of a ll operations through t he filing of N OTAMs. Receipt of

t he prior permission of the land owner, the size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level of safety. The SkyRanger provides at least an equivalent, and most likely exceeds 5 , level of safety to that of such operations being conducted with conventional aircraft that would be orders

- of

- magnitude larger and wo uld be carrying passengers, cargo, and flammable fu el. The automated safety features including redundant sensor systems as described in Appendix B and throughout this document highlight the design intentions towards safety and reliability on SkyRanger. **14 C.F.R. § 45.23 & 91.9(c): Marking of the A ircraft**  Regulation 45.23 provides:

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed by the

5 An Aeryon internal report compares the crash kinetic energy dissipation rate of a commercial airline versus the Aeryon SkyRanger. T he report found the MTTF of SkyRanger needs to only be > 2.3 hours to equal the energy dissipation of the gold standard co mmercial aircraft. T ransport 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 im pact, since the SkyRanger is similar in construction it could be considered to be below this threshold as well.

### 10 of 20 registration number of

t he aircraft. Each suffix letter used i n the marks displayed must also be a Roman capital letter. (b) W hen marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificat ed aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable. Regulation 91.9(c) provides:

No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter

. T he SkyRanger has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size of the sUAS, two

- inch lettering will be impossible. O f ficial marking systems for small UAS have not yet been established fo r operations inside the NAS. T he SkyRanger is currently marked with a fixed label containing Aeryon Labs SkyRanger measuring 1.5” x 0.5” as well as a serial number located under the removable camera payload. Easy Drive is prepared to mark the inspection system with the name of the organization and location or origin and ful fill any other request by the FAA to this topic in accordance to § 45.29(f) where the pilot, observer, and others working with the sUAS will see the id entification of the sUAS. The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 10167, 10167A and 10700. **14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial P**  **ilot Privileges and Limitations.** Section 61.113(a) & (b) limit private pilots to non

- commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the SkyRanger in this case is remotely controlled wit h no passengers o r p roperty of others on board. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. Easy Drive respectfully proposes that operator requirements should take into account t he characteristics of t he particular sUAS. Aeryon’s SkyRanger has a high degree of pre - programmed control and various built

- in technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exemp tion application. The SkyRanger has an all

- digital sof tware platform with advanced features previously restricted to full size unmanned aircraft. Automated features and advanced fly

- safe controls enable safe, reliable operation, as well as advanced netwo rking 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 o nboard in potentially dangerous situations. W it h multiple built

- in safety features, the Aeryon platform leads other sUAS with respect to safety. 

### ● Intelligent fault handling: The system automatically detects potential issues

- with configurable automated response behavior such as a return

- home

- and

- land routine

### 11 of 20

● 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

-fl y 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 wi ll return home and land automatically if user

- conf igurable limits are reached. Additional automated safety functions and safety enhancing fe atures of the SkyRanger include the following: 

### ● Auto detection of lost GPS warns the pilot and initiates an immedia te landing. 

### ● Low battery on the SkyRanger triggers a Non Fatal Wa rning alarm to return home, land and replace the battery 

### ● Very low battery on the SkyRanger triggers an Fatal Error alarm and initiates an emergency high speed descent landing. 

### ● If the SkyRange r detects a lost

- link to the basestation the vehicle will perform its pre - def ined Non

- Fatal Condition Response. Given these safety features, Easy Drive proposes that operators of the SkyRanger should not be required to hold a commercial or private pilot c ertification. 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, pr ivate license and ground school; 

### ● have completed Aeryon’s training program for operation of the sUAS. Easy Drive notes that the FAA has found that safety factors permitted operation of sUASs by operators with these qualifications in the case of o peration s pursuant to public COAs where the mandatory operating conditions specified above are present. See Federal Aviation Administration, Notice N

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

- 21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial operations. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the SkyRanger without a private pilot’s certificate or a commercial pilot’s certificate, under the conditions set forth herein. The risks associated with the operation of t he SkyRanger (given its size, speed, operational capabilities, and lack of combustible fu el) are so diminished from the l evel of risk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (f ixed wing or rotorcraft), that allowing operations of the sUAS as set forth above meets or exceeds the present level of safe ty provided under 14 C.F.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). **14 C.F.R. § 91.7(a): Civil aircraft airworthiness.** This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of t he SkyRanger without an airworthiness certificate, no standard will exist for airworthiness of the SkyRanger. Given the size of the aircraft and the previous COAs issued for Aeryon’s Scout and SkyRanger, an equivalent level of safety will be achieved by ensuring compliance with the Aeryon manuals prior to each flight.

### 12 of 20

**14 C.F.R. § 91.9(b)(2): Civil A ircraft Flight Manual in the A** **ircraft.** The regulation provides:

No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unl ess there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Given the size and configuration of t he SkyRanger, it has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be achieved by keeping the flight manual ( see , e. g. , SkyRanger User Guide, Exhibit 1) at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. **14 C.F.R. § 91.103: Preflight action** This regulation requires each pilot in command to take certain actions before flight to insure the safety of f light. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in the SkyRanger User Guide (Exhibit 1) under the ‘Getting Ready to Fly’ section. The PIC will take all actions including reviewing weath er, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. **14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction** These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. The SkyRanger is a remotely piloted aircraft and by design, does not have fully functional dual controls. Flight control is ac complished through the use of acontrol box that communicates with the aircraft via radio communications. The flight plan is either manually controlled through point

- and

- click touchscreen navigation or pre - programmed as way points or an AutoGrid into the a uto pilot before or during flight and only in unusual circumstances will the pilot input control functions to alter the pre programmed flight. If instruction is accomplished through a training program, as set fo rth in Exhibit 2, an equivalent level of safe ty will be assured. The FAA has approved exemptions fo r flight training without fully functional dual controls for a number of a ircraft and fo r flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety wi ll be achieved by the manufacturer providing the training as outlined, fo r example, in Exhibit 2 and through the use of experienced and qualified pilots familiar with the SkyRanger. **14 CFR § 91.119: Minimum Safe A ltitudes**  Section 91.119 establishes safe altitudes fo r operation of c ivil 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.

### 13 of 20

As set fo rth herein, the SkyRanger will never operate at higher than 400 feet AGL. It w ill, however, be operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. Because aerial survey, mapping and inspection work m ust be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed. The equivalent level of safety will be achieved given the size, weight, speed, and material with which the SkyRanger i s built. Also, no flight will be taken without the permission of t he land owner or those who control the land. Because of the advance notice to the landowner, all affected individuals will be aware of the flights. Compared to aerial survey operations condu cted with aircraft or rotorcraft we ighing fa r 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 l ow- altitude operations of the sUAS will maintain separation between these sUAS operations and the operations of conventional aircraft that must comply with Section 91.119. **14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions** This regul ation prohibits an individual fro m beginning “a flight in an airplane under VFR conditions unless (considering wind and fo recast weather conditions) there is enough fuel to fly to the fi rst point of i ntended 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. Wi thout an exemption from § 14 CFR 91.151, the sUAS’s fl ig hts would be limited to approximately 20 minutes in length. Given the limitations on its proposed operations and the location of those proposed operations, a longer time frame for flight in daylight VFR conditions is reasonable. Easy Drive believes tha t an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operating the sUAS, without 30 minutes of reserve fuel does n ot engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at wh ich the sUAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting SkyRanger flights to 20 m inutes would greatly reduce their utility. In the unlikely event that the SkyRanger should run out of f uel, it would simply land. Given its weight and construction material, the risks are less than contemplated by the current regulation. Easy Drive belie ves that an equivalent level of safety can be achieved by maintaining 10 minutes of reserve fuel, which, allowing 40 minutes of f light time, would be more than adequate to return the sUAS to its planned landing zone from anywhere in its operating area. T he FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808. **14 C.F.R. § 91.203 (a) & (b): Carry ing Civil A** **ircraft Certification and Registration** This regulation provides as follows:

(a)

... no person may operate a civil aircraft unless it has

... an appropriate and current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is

### 14 of 20 displayed at the cabin or cockpit entrance so that it is legible to passenge rs or crew. The SkyRanger fully loaded weighs approximately 6 lbs. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. In addition, there is no pilot on board the aircraft. An equival ent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample of o ther exce ptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. **14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections** Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of t his 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 t he 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 quali fied person prior to each flight and at predefined intervals as part of the Maintenance Schedule in the User Guide (see Exhibit 1). Pre

- flight checklist includes: 1.Visual inspection of the airframe 2.Visual inspections of rotor integrity 3.Check charge of all batteries (aerial vehicle, command station, radio repeater station) An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restricted predetermined areas and is not a complex mechanical devise. As provided in the attached User Guide (System Maintenance section) , the operator of SkyRanger will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person most fa miliar with the aircraft an d is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety. The SkyRanger’s Maintenance guidelines ensure an equivalent level of safety to the maintenance requirements in Part 91. In addition, any comp onent failure detectable by the system will be reported to the control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Non

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

### 15 of 20

**AP PENDIX B**  **SMA LL UNMA**  **NNED AER**  **IA L SYSTEM DESCRIPTION**  **Easy D**  **rive Ov** **erview** : Easy Drive is a 65 year old US company based in Texas w ith offices in San Antonio and Austin. Easy Drive supplies the Surveying, Construction, Mapping, Engineering, Law Enforcement, and Agricultural industries with leading edge instrumentation and software fro m leading brands such as Leica, Trimble, Aeryon, Pix4d, Nikon, Pentax, and others. Easy Drive offers three full servi ce electro

- optical repair and service facilities, one of which is a certified N.I.S.T (National Institute of S tandards and Technology) traceable calibration system. In support of s ales, each of the three Easy Drive locations incorporates a modern multimedia training facility. **Ae ry** **on C**  **orporate Overview**  : Aeryon Labs, Inc. is a Canadian company located in W aterloo Ontario. Aeryon is focused on providing micro unmanned aerial system and is globally recognized as the market and technology leader in this space. Key customers range from milit ary organizations such as Canadian Special Operations and US Special Operations; key government agencies such as NOAA, Environment Canada and the US Coast Guard; world leading universities in the unmanned space such as University of

A laska Fairbanks and Ka nsas State University; police agencies such as the RCMP and OPP; and global enterprises such as BP, UK Power Networks and Fortune 500 companies in the chemical, oil/gas and security markets. Aeryon systems have accumulated over 5000 hours in global flight operations. This number does not include military flight hours which increase the numbers further. Aeryon systems have a been approved by the FAA for research COAs and have a demonstrated safety track record. The Aeryon sUAS platforms were the first to of ficially fly at one of

t he FAA’s UAS Test Sites (UAF Alaska). Many customers from military, to education to police and even commercial operations have been given approval to fly in US, Canada, UK, Australia, Japan, and others airspaces. **Sky Ranger**  **Overvie w**  : Aeryon unmanned systems have been used to fi ght terrorism in Iraq, Afghanistan and Nigeria, monitor hostile borders between Saudi Arabia and Yemen, ensure the safety of world leaders at the G50 Nuclear Summit in Seoul, escort a fuel tanker and ice break er into a remote Alaskan community, monitor wildlife on the Aleutian Islands, map remote communities in South America, keep our highways clear and safe; and provide volumetric analysis for open pit mines. The Aeryon SkyRanger can carry payloads up to 600 g. The SkyRanger flies with a maximum wind threshold of

4 0 M. P.H. for sustained winds and wind gusts up to 55 M. P.H.. W hat is unique about the Aeryon SkyRanger is the system automatically compensates fo r wind versus relying on the operator’s ‘sense of feel ’ for what the impact of the wind is at the altitude the system is flying. The end result is a system capable of gathering high quality aerial intelligence at much higher wind thresholds. A trait that is imperative for many aerial inspection operations. The SkyRanger has an operational range of up to 3 km (1.6 NM) with the standard offering and up to 5 km (2.7 NM). All flight operations are GPS controlled making the system extremely easy to navigate. At any point if the operator is not explicitly command ing 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.

### 16 of 20

The Aeryon SkyRanger can be operated in both semi a nd fully autonomous flight modes. C reating preplanned flight paths to fly in autonomous mode is as simple as clicking on the map to create a preplanned flight path. In semi

- autonomous mode, the operator clicks on the map and the Aeryon SkyRanger automatic ally flies to the point on the map where the operator is pointing. Pre

- mission wa ypoints, Landing zone points and flight area dimensions can all be entered during preflight ensuring the SkyRanger operates only within specified parameters. The Aeryon SkyRa nger includes many advanced safety features that makes the SkyRanger the safest choice fo r 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 b ack 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 sys tem cannot enter areas deemed unsafe or unnecessary to fly over. And before every take

- off automated flight checks ensure the system is flight ready before it takes off. The Aeryon SkyRanger can be operated entirely by a touch

- screen, map based interface. This means The operator only needs to command the system where to go, and the system does all the flying for the operator. Maps can be saved and flight plans can be made or recalled with no internet connection required. **Sky Ranger Operating Manual** 

- Syste m user manual available upon request. **Phy sical Characteristics**  **Measurements**

– 40” diameter deployed, 20x10” folded **Weight** (without payload)

– 2.4kg (5.3 lbs) **Fuel**

– Lithium polymer batteries are self

- contained high duration systems with “SM ART” intelli gence 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 ch arged via standard wall outlet, or via a vehicle. **Landing sty le/ty**  **pe** – Autonomous vertical lift **Propulsion Sy stem**  ● Engines

– The SkyRanger is powered by 4 electric brushless DC motors. ● Batteries

– Lithium polymer batteries are self

- contained high duration systems with SM ART 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 Ba ttery charger and can be charged via standard wall outlet, or via a vehicle. **Performance Characteristics** ● Ma ximum Altitude

– 1500 ft. ● Ma ximum Endurance

– 50 minutes ● Ma ximum Range

– 3 km ● We ather Minimums

- ● Wi nds Maximum

– 40 MPH sustained, 55 mph gusts

### 17 of 20

● Minimum ceiling: 500 ft ● 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

a ny 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 experience routine wear are rotors, batteries, motors, and legs. Battery and mot or 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 d uring the full visual inspection of

t he airframe performed before each flight. Structural damage affecting flight characteristics will be detected by on

- board sensors. The UAV system detects numerous conditions wh ich may make flying unsafe, such as reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, temperature fluctuations. Automatic pre -flight checks prevent the UAV fro m taking off if such conditions are present; or, if the condition is detected during flight, the system will trigger a Fatal Conditioned Response. **Fault Tolerance** 

- The key feature of the UAV fa ult 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 fo r the UAS to fly. Any component failure detectable by the system will be reported to the control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Non

- Fatal Conditioned Response (NFCR), depending on the type of failure

. **Command and Control Sy stems**  The SkyRanger Ground Control station allows the operator simultaneous control over aircraft and payloads. The touch screen control allows for quick navigation and data entry while the display screen provides all essential fli ght data to the operator. Telemetry data is transmitted to the command station at least once per second. **Display ed on GCS:**  ● UAS Position ● Navigation Route ● UAS Tail Number ● UAS Position ● UAS Altitude ● UAS Heading ● North Seeking Arrow ● Range to Target ● Calculated t arget position ● Date/time ● Sensor heading and orientation relative to UAS

### 18 of 20

**On -**  **board Flight**  **Instruments**

– The UAV is equipped with an Inertial Navigation System (3

- axis gyroscope, 3

- axis magnetometer, GPS receiver, and static pressure sensor) and a sonar sens or for precision AGL altitude measurement. **On**
**– board**  **computer systems** 

– The UAS is equipped on - board computer systems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, etc.). **On -**  **board gui**  **dance and**  **navigation equipment** 

– The UAS can operate autonomously; it does not require any input from ground

- based equipment, or from the pilot to hover in place. **Frequency**

**A llocations** 

– 900 MHz, 2.4 GHz, 5.8 GHz, custom **Flight termination**  **link**

– to prevent a “f ly 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 unti l further o perator instruction is given. The aircraft will automatically adjust for wind during this period. **Navigation Sy** **stem**

– Specific maps can be downloaded to the display screen (such as air sectional and geographic maps) which are overlaid with GPS positional data. Wa ypoints can be created before and during flight operation creating specific locations and sequences for the aircraft. **Redundant Sy** **stems**

– The UAS combines the input fro m a multitude of sensors. Even though the data fro m all sensors is required fo r optimal system performance, a single sensor malfunction is likely to result in degraded performance rather than leading to a catastrophic failure. **Emergency**

**Procedures and Sy stem Failures**  **Failure Handling** 

– The UAS has extensive failure detection and handling capabilities. All failures are deeded to be either fatal or non -fa tal. Failures classified as fatal result in a Fatal Condition Response (FCR); and failures classified as non

-fa tal result in a Non

- Fatal Condition Response (NFCR). **Sensor Failure** 

– Failure of on - board flight instruments/sensors will degrade the UAS performance and will result in either a FCR or a NFCR, depending on their severity. If the UAS becomes unstable due to sensor failure, it will stop all four motors and free fall to avoid a fly away condition. **Motor Failure**

– The UAS flight performance will degrade significantly if one or more motors fails. **Ai rframe Failure** 

– If airframe is damaged in ways that impacts flight characteristics, the UAS will behave similar to if an on - board flight instrument failed. **Navigation Sy stem Failure** 

– In a navigation system failure, degraded GPS will result in FCR or NFCR ‘s depending on failures. **Pow er Failure** 

– A complete battery failure which results in power loss to the UAS will result in degraded flight performance. **Low Battery** 

**Condition**

– Operator will be alerted of a low battery condition and will land the aircraft

### 19 of 20

as soon as able. **Low Battery** 

**Condition**

– Operator will be alerted of a low battery condition and will land the aircraft as soon as able. **Line -**  **of -**  **Sight Loss**

– All f light operations will be conducted with the UAS within visual sight of the pilot. If the pilot’s view becomes obstructed and line

- of

- sight is lost, the pilot may instruct the UAS to hover in place until line

- of

- sight is reestablished, to return to the take

- off position, or to land at the current position. **Security** The system and communication links are encrypted by the manufacturers proprietary software.

### 20 of 20

**AP PENDIX C**  **SUMMA RY OF A** **ERYON SECTION 333 EXEMPTION REQUEST** Easy Drive hereby provides pursuant to Part 11 a summary of its exemption application to allow commercial operation of the SkyRanger small unmanned system in productivity demonstrations, aerial surveys, map ping, and inspection operations, An exemption is requested from the following regulations: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a).