August 10,2015 

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 and 

Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform 

Act") and 14 C.F.R. Part 11, Westar Energy, Inc. ("Westar Energy") the operator of an 

Aeryon SkyRanger and/or Altus UAS Delta X-8 ("sUAS" or "SkyRanger" or "Delta X8"), seeks an exemption from the Federal Aviation Regulations ("FARs") listed below 

and discussed in Appendix A. A summary ofWestar Energy's Section 333 Exemption 

Request is at Appendix B. Westar Energy's sUAS Operations and Safety Policy is at 

Appendix C. Aircraft manuals will be provided upon request. 

The requested exemption would permit Westar Energy to conduct commercial operations 

of the SkyRanger and/or Delta X-8, which weigh approximately 61bs. and 12 lbs., 

respectively, and are capable of capturing still imagery, video and other data collection. 

The application for the sUAS will be aerial data collection for inspection of utility 

infrastructure, property and features in furtherance ofWestar Energy's operations as an 

electric utility. 1 In particular, the use of sUAS will allow utility workers to conduct 

inspections without being in close proximity to high-voltage equipment or subject to the 

hazards of working height. The use of sUAS will also facilitate the safe inspection of 

hard-to-access or environmentally sensitive areas without the use of bucket trucks, 

helicopters, and other utility vehicles that have more environmental impact than sUAS. In 

addition, the use of sUAS will be more efficient and cost effective than traditional 

methods of inspection in many instances, which will reduce operations and maintenance 

costs and provide a means for faster resolution of problems on the electric system. In 

short, approval of this request will increase electric system reliability, decrease customer 

costs, and enhance worker safety. 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the sUAS. 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 sUAS. 

1 
Operations under the exemption will be subject to strict operating requirements and 

conditions to ensure at least an equivalent level of safety to currently authorized 

operations using manned aircraft. 

As described more fully below, the requested exemption would authorize commercial 

operations of remote sensing using the SkyRanger or Delta X-8, which at approximately 

6 lbs. and 12 lbs., respectively, are small in size. The SkyRanger or Delta X-8 will be 

operated under controlled conditions at low altitude in airspace that is limited in scope, as 

described more fully herein. It will have automated control features, as described below. 

The SkyRanger or Delta X-8 will be operated by a PIC with an airline transport, 

commercial, private, recreational, or sport pilot certificate who also holds a current FAA 

airman medical certificate or a valid driver's license. The PIC will also meet the flight 

review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated 

on his or her pilot certificate. See Appendix C. Finally, Westar Energy will comply with 

the airspace limitations contained within the blanket COA for sUAS in place for all Sec. 

333 exemption holders upon issuance of the exemption and will apply for a separate COA 

in the event it seeks to operate its sUAS beyond the parameters of the blanket COA. It 

will file NOTAMs in advance of sUAS operations as required by the exemption, 

applicable COA, regulation or the FAA. 

Westar Energy respectfully submits that because its sUAS, the SkyRanger and/or Delta 

X-8, 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 or greater level of safety. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the 

FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to 

"establish requirements for the safe operation of such aircraft systems in the national 

airspace system." 

The name and address of the applicant are: 

Westar Energy, Inc. 

Address: 818 S. Kansas Avenue PO Box 889 

Topeka, KS 6660 1 

Attn: Jason Klenklen 

Ph: 785-575-8187 

Email: J ason.klenklen@westarenergy.com 

The regulations from which the exemption is requested are as follows: 

14 C.F.R. 61.23(a) and (c); 

14 C.F.R. 61.10l(e) (4) and (5): 

14 C.F.R. 61.113(a) & (b): 

2 
14 C.P.R. 61.315(a); 

14 C.P.R. 91.7(a); 

14 C.F.R. 91.119(c); 

14 C.F.R. 91. 121 ; 

14 C.P.R. 91.151(a) (1); 

14 C.P.R. 91.405(a); 

14 C.P.R. 91.407(a) (1); 

14 C.F.R. 91.409(a) (1) and (2); 

14 C.P.R. 91.417(a) & (b). 

Appendix A discusses each rule listed above and explains why exemptions pursuant to 

the proposal set forth in this letter are appropriate, provide an equivalent level of safety, 

and are in the public interest. The FAA has previously granted Sec. 333 exemptions for 

commercial use of sUAS for utility and infrastructure inspection in exemptions 11185 

(Commonwealth Edison), 11238 (San Diego Gas & Electric Co.), 12040 (Burns & 

McDonnell Engineering Co., Inc.) and 11783 (Precision Design and Drafting, Inc.), and 

has approved Sec. 333 exemptions for the SkyRanger in exemptions 11112 and 11213 

and others, and for the Delta X-8 in exemption 11172A. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Westar Energy submits that granting of this exemption application for use of the 

SkyRanger and or Delta X-8 for aerial data collection will advance the Congressional 

mandate in Section 333 of the Reform Act to accelerate the introduction ofUASs into the 

national airspace system ("NAS") if it can be accomplished safely. This law directs the 

Secretary of Transportation to consider whether certain UASs 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 UASs 

do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 

• The UAS 's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual1ine of sight of the operator. 

The granting of the requested exemption is in the public interest based on the clear 

direction in Section 333 of the Reform Act; the additional authority in the Federal 

Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed 

operations; and the significant public benefit, including enhanced safety and cost-savings 

associated with transitioning to UASs for aerial data collection. Accordingly, the 

applicant respectfully requests that the FAA grant the requested exemption without delay. 

3 
The sUAS 

Each of the SkyRanger and Delta X-8 complies with the requirements set forth by 

Section 333 by its small size, weight, speed and limited operating area associated with the 

aircraft and its operations as set forth herein, in the proposed conditions of operation and 

the operating manual available upon request. As a result under this exemption the 

SkyRanger or Delta X-8 are not deemed airworthy by an airworthiness certificate, but 

rather they are deemed airworthy by the operator conducting a thorough preflight of the 

aircraft. The aircraft will also be registered in accordance to 14 CFR Part 4 7, marked in 

accordance to 14 CFR Part 45 Subpart C, and accompanied by a letter of alternative 

marking due to the unconventional design of a quadcopter. Markings will be as large as 

practicable. 

The SkyRanger is the same aircraft for which the FAA has already granted exemptions in 

exemptions 11112, 11209, 11213, 11239, 11259, and 11265, and the Delta X-8 is the 

same aircraft for which the FAA has already granted an exemption in exemption 11172A. 

Aircraft Make and Model: SkyRanger 

Configuration: Quadcopter 

Aircraft Performance/Specifications: 

• Ground Control Station (GCS): The aircraft will be primarily controlled through 

the use of a tablet via 900 MHz, 2.4 GHz, and 5.8GHz. 

• Lost Com: Aircraft will autonomously return to the launch location and safely 

land. 

• Emergency Procedure: Should the need arise the aircraft can be commanded by 

the pilot in command via the tablet GCS to safely land immediately or return and 

land at the launch location. 

• Power Supply: Lithium polymer batteries are self-contained high duration systems 

\Vith "S1-1ART" intelligence onboard. This includes cycle charge times, locations, 

GPS antenna, chemical management, and real-time data feeds to ensure maximum 

flight duration and subsystem safety processes. Charging is done in the included 

Aeryon Battery charger and can be charged via standard wall outlet, or via a 

vehicle. 

• Dimensions: 40 in (102 em) diameter, 9.3 in (24 em) height 

• Maximum Speed: 50 knots 

• Normal operating speed: Less than 30 knots 

• Weight without payload: 5.3 lbs. 

• Maximum weight with payload: 6.6 lbs. 

• Security: Secure network pairing, AES 256 bit encryption 

Aircraft Make and Model: Delta X-8 : 

Configuration: Quadcopter 

4 
Aircraft Performance/Specifications: 

• Wingspan (propellers fitted) 140cm (50") 

• Motors 8 x 400kV 

• Propellers 18" diameter 

• Battery type Lithium Polymer (LiPo) 6S, 22V, 16,000mAh, LiPo 6S, 22V, 

16,000/22,000mAh 

• Empty Weight 5.5kg (12lb) 

• Take Off Weight 9 .5kg (2llb) 

• Maximum Take OffWeight 22.5kg (49lb) 

• Flight Specifications (Under Autopilot at TOW) 

• Max climb rate 2 m/s 

• Max descent rate 2 m/s 

• Maximum speed 12 m/s 

• Endurance 12-15 minutes 

• Command and Control Frequency 

• • 2.4Ghz (Spectrum DSMX modulation) 

• Telemetry (Wi-Fi) 2.4Ghz (meets Directive 1999/5/EC specs) 

• Telemetry (Data link) 915-928Mhz FHSS (complies with AS/NZS 4268:2012) 

• Failsafe's 

• 1. Automatic Return to Home on C&C Failure Automatic Parachute deployment at 

70 degrees of roll 

• 2. Automatic Parachute deployment on violent shake state 

• 3. Dual AP, GPS and IMU for comparison checks X-8: Motor redundancy 

configuration 

Aircraft manuals will be provided upon request. 

Operator Requirements 

The PIC will have an airline transport, commercial, private, recreational, or sport pilot 

certificate and will also hold a current FAA airman medical certificate or a valid driver's 

license. The PIC will also meet the flight review requirements specified in 14 CFR § 

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate and will 

complete sUAS flight training as specified in Appendix C. 

Operations will be conducted in a manner consistent with this exemption, including 

evasive and emergency maneuvers while maintaining appropriate distances from persons, 

vessels, vehicles and structures. 

5 
Proposed Operating Conditions 

Westar Energy agrees to be bound by the following conditions for flight operations. 

• Operations will occur over utility right of way or permission from landowner will 

be obtained before commencing flights. 

• Operations will only occur during Visual Meteorological Conditions (VMC) under 

Visual Flight Rules (VFR). 

• Operations will not occur 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. 

• The sUAS will remain clear of manned aircraft and yield right of way. 

• A flight test will be conducted after any major repair or alteration. 

• A preflight check will be conducted before each flight to assure the sUAS is in a 

condition for safe flight. 

• Aircraft will remain within Visual Line of Sight (VLOS) of the operator. 

• All operations will be conducted with a Visual Observer (VO). 

• Operations will be conducted from sunrise to sunset. 

• Operations will be concluded \vith no less than 25% battery power remaining. 

• Operations will not exceed 400 feet AGL. 

• Operations will not occur within 5 nautical miles of any airport unless a letter of 

agreement with that airport's management is obtained. 

• Operations will take place under a COA. 

• The operator will be responsible for maintaining and inspecting the sUAS to 

ensure that it is in a condition for safe operation. 

• Operator will follow the sUAS manufacturer's maintenance, overhaul, 

replacement, inspection, and life limit requirements and safety bulletins for the 

aircraft and aircraft components. 

• The operator may not permit any PIC to operate unless the PIC meets the 

operator's qualification criteria and demonstrates the ability to safely operate the 

sUAS in a manner consistent with how the sUAS \Vill be 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 § 61.5l(b). The VO is also required to complete the operator's training 

requirements. A record of training must be documented and made available upon 

request by the Administrator. Flights for the purposes of training the operator's 

PICs and VOs (training, proficiency, and experience-building), are permitted 

under the terms of this exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the sUAS with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91 .119 

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• All non-participants will keep 500 feet away from operations unless there are 

adequate barriers to protect them. 

• All operations will be conducted according to the manufacturer's manuals. 

• All documents that will be kept at the GCS include but are not limited to: the 

aircraft manuals, maintenance logs, aircraft registration, grant of exemption, and 

COA. 

• sUAS will not be operated at a speed exceeding 87 knots (100 miles per hour) and 

in no case at airspeeds greater than the maximum operating airspeed 

recommended by the aircraft manufacturer. 

• The sUAS will autonomously return to the launch location and safely land in the 

event of loss of communication and control. 

• The sUAS will be registered in accordance to 14 CFR Part 47, marked in 

accordance to 14 CFR Part 45 Subpart C, and accompanied by a letter of 

alternative marking due to the unconventional design of a quadcopter. Markings 

will be as large as practicable. 

• The sUAS will not be operated by the PIC from any moving vehicle or device. 

• 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. 

Public Interest 

Consistent with the requirements of 14 C.F.R. §11.8l(d), Petitioner offers the following 

reasons why granting this petition for exemption is in the public interest, i.e., how 

granting it would benefit the public as a whole. 

Approval of this exemption allowing commercial operations of s U AS for aerial data 

collection benefits the public as a whole in the following ways: 

• It helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform 

Act, namely, the FAA Administrator's assessment of whether certain UAS may 

operate safely in the National Airspace System before completion of the 

rulemaking required under Section 332 of the Reform Act. 

• The operation significantly improves safety and reduces risk by alleviating human 

exposure to danger associated with current aerial remote sensing methods, namely, 

full size helicopters. Reducing human exposure to death or serious injury 

associated with manned aircraft performing these tasks furthers the public's 

interest. 

• Petitioner's sUAS is battery powered and creates no emissions. If Petitioner's 

sUAS crashes, there is no fuel to ignite and explode. Any impact of Petitioner's 

7 
lightweight sUAS is far less than a full size manned aircraft. The public's interest 

is furthered by minimizing ecological impact of an accident and by reducing 

human exposure to potentially harmful emissions associated with manned aircraft. 

• Aerial data collection by sUAS is a valuable tool for mapping, real estate, 

insurance evaluations, and industrial inspection. However, problems with safety, 

cost, statistical integrity, and logistics impede aerial data collections from 

conventional manned aircraft. The use of sUAS addresses these problems and is a 

powerful tool for performing a wide-range of aerial data collection applications. 

The public as a whole will benefit from the safer and more cost-effective aerial 

data collection services that sUAS operations provide. 

Privacy 

Westar Energy will not operate sUAS in any way that may invade personal privacy and 

will comply with any federal, state, or local privacy laws that may apply in areas where 

Westar Energy operates sUAS. In addition, as a practical matter, flights will occur over 

utility property or utility right of way or with landowner permission, so privacy is 

unlikely to be a concern in relation to Westar Energy's proposed use. 

Conclusion 

Westar Energy seeks an exemption from the FARs set forth above and in Appendix A to 

allow commercial operations of sUAS to conduct aerial data collection. 

Approval of this exemption allowing commercial operations of the Sky Ranger and/or 

Delta X-8 for aerial data collection will enhance safety by reducing risk. Conventional 

aerial data collection operations, using turbine or piston-powered aircraft present risks 

associated with vehicles that can weigh 5,000 to 7,000 lbs., or more, carry large quantities 

of fuel, passengers, and, in some cases, cargo. In contrast, a Sky Ranger and/or Delta X-8 

weighing approximately 6 lbs. and 49 lbs., respectively, and powered by batteries 

eliminates a great portion of that risk given the reduced mass and lack of combustible 

fuel carried on board. The SkyRanger or Delta X-8 will carry no passengers or crew and, 

therefore, will not expose any individuals to the risks associated with manned aircraft 

flights. 

Additionally, no national security issue is raised by the grant of the requested exemptions 

due to all pilots being certified through the FAA. 

The operation of the SkyRanger and/or Delta X-8, weighing approximately 6 lbs. and 12 

lbs, respectively, for aerial data collection in accordance with the conditions outlined 

above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein. 

8 
The SkyRanger's and Delta X-8's satisfaction of the criteria set forth in Section 333 of 

the Reform Act-size, weight, speed, operating capabilities, lack of proximity to airports, 

operation within visual line of sight, and national security-and its showing of an 

equivalent level of safety strongly justifies the grant of the requested exemptions 

allowing commercial operation of the SkyRanger and/or Delta X-8 for aerial data 

collection. 

Jason 

~ Klenklen 

Supervisor, Transmission Maintenance 

9 
APPENDIX A: 

EXEMPTION REQUEST Al~D EQUIVALENT LEVEL OF SAFETY SHOWINGS 

UNDER APPLICABLE RULES SUBJECT TO EXENIPTION 

Westar Energy requests an exemption from the following regulations, all of \Vhich have 

been granted by every approved Section 333 exemption at the time of this submission. 

14 C.F.R. §§ 61.23(a) and (c), 61.10l(e) (4) and (5), 61.113(a) and 61.315(a): Pilot in 

command requirements. 

The FAA has recently determined that the PIC requirements for Section 333 exemptions 

for commercial operation of sUAS are met by a PIC who has an airline transport, 

commercial, private, recreational, or sport pilot certificate and will also hold a current 

FAA airman medical certificate or a valid driver's license. The PIC will also meet the 

flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is 

rated on his or her pilot certificate. See eg. Exemption No. 11238 (San Diego Gas & 

Electric Co.) and Exemption No. 12040, (Bums & McDonnell Engineering Co., Inc.) 

Westar Energy requests the same decision by the FAA with respect to its request for 

exemption of the above referenced FARs regarding the PIC requirements. 

Equivalent Level of Safety 

Currently, there are no applicable areas identified for sUAS in either the private or 

commercial sector and therefore an exemption is required to conduct commercial 

operations. As flight operations will be conducted in a restricted environment as 

described in the operations section, these strict guidelines will achieve an equivalent level 

of safety for each individual flight especially when compared to commercial flights 

identified in Part 61 when originally developed. 

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Petitioner seeks an exemption from 14 C.P.R.§ 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. Inasmuch there will be no airworthiness 

certificate issued for the sUAS, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. 

Equivalent Level of Safety 

Given the size of the SkyRanger and/or Delta X-8 and the preflight procedures including 

the review of maintenance logs and preflight check lists, an equivalent level of safety will 

be provided to assure the aircraft is in an airworthy condition. The FAA has previously 

determined that an operator ensures that its aircraft is in an airworthy condition based 

upon compliance with the operating documents. 

14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

10 
Petitioner requests an exemption from the minimum safe altitude requirements of 14 

C.F.R. § 91.119(c) which states that aircraft may not operate closer than 500 feet above 

the surface and away from any person, vessel, vehicle, or structure in non-congested 

areas. 

To provide the intended operations, the sUAS is operated below 400 feet AGL. 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the approximately 6 

lbs. and 12lbs. proposed herein, and given the lack of flammable fuel, any risk associated 

with these operations is far less than those that presently exist with conventional aircraft. 

An equivalent level of safety will be achieved given the size, weight, and speed of the 

UAS, as well as the location where it is operated. As set forth in the operations section of 

this exemption, the sUAS will be operated at least 5 nautical miles away from airports 

(unless a letter of agreement from the airport's management is obtained), where buildings 

and people will not be exposed to operations without their pre-obtained consent. Because 

of the advance notice to the property owners and participants, all affected individuals will 

be well aware of the planned flight operations. 

14 C.F.R. § 91.121: Altimeter Settings 

Petitioner requests an exemption from 14 C.F.R. § 91.121 which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an 

altimeter that is set to the elevation of the departure airport or barometric pressure. An 

exemption is required because the sUAS does not have a barometric altimeter, but rather 

a GPS altitude read out. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by the operator confirming the altitude of 

the launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will 

use the GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring 

operation at safe altitudes. 

14 C.F.R. § 91.151 (a) ( 1): Fuel Requirements for Flight in VFR Conditions 

Petitioner requests an exemption from 14 C.F.R. § 91.151(a)(l)'s fuel requirements for 

flight in VFR conditions during the day. Section 91.151(a)(1) states: 

(a) No person may begin 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; 

11 
Here, the battery powering the sUAS provides power lasting less than the 30 minutes 

reserve requirement in 14 C.F.R. § 91.151, and thus s U AS flights could not be conducted. 

Given the limitations on the sUAS's proposed flight area and the location of its proposed 

operations within a predetermined area, a safety margin based on a reserve amount of 

battery life is needed. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be conducted 

on-site without significant transit time by the sUAS. All flights will be planned to be 

terminated with no less than 25% reserve battery power still available. This restriction 

would be more than adequate to return the sUAS safely to the ground and its planned 

landing zone from anywhere in its limited operating area even in the event of an 

unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel 

does not include the type of risks that Section 91.151 (a)( 1) was intended to alleviate 

given the size and speed of the small sUAS, and the proximity of the flight operation to 

the landing zone. 

14 C.F.R. § 91.405(a), 91.407(a) (1), 91.409(a) (1) and (2); 91.417(a) and (b): 

Maintenance Inspections 

Petitioner also seeks an exemption from the maintenance inspection requirements 

contained in 14 C.P.R.§ 91.405(a), 91.407(a) (1), 91.409(a) (1) and (2); 91.417(a) and 

(b). These regulations specify maintenance and inspection standards in reference to 14 

C.P.R. Part 43. See, e.g., 14 C.P.R. § 91.405(a) (stating that each owner or operator of an 

aircraft " [ s ]hall have the aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections ... have discrepancies repaired as prescribed in part 43 of 

this chapter"). An exemption to these regulations is needed because Part 43 and these 

sections only apply to aircraft with an airworthiness certificate, which the sUAS will not 

have. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operator will ensure that the 

sUAS is in working order prior to initiating flight by following the preflight checklist, 

perform required maintenance, and keep a log of any maintenance performed. The 

operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition. 

12 
APPENDIXB: 

SUMMARY OF WESTAR ENERGY SECTION 333 EXEMPTION REQUEST 

Westar Energy hereby provides pursuant to Part 11 a summary of its exemption application 

to allow commercial operation of the Aeryon SkyRanger and/or Altus UAS Delta X-8 

unmanned aircraft for aerial data collection in connection with utility and infrastructure 

inspection. An exemption is requested from the following regulations: 

14 C.F.R. 61.23(a) and (c); 

14 C.F.R. 61.10l(e) (4) and (5); 

14 C.F.R. 61.113(a) & (b); 

14 C.P.R. 61.315(a); 

14 C.F.R. 91.7(a); 

14 C.F.R. 91.119(c); 

14 C.F.R. 91.121; 

14 C.F.R. 91.15l(a) (1); 

14 C.P.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) & (b). 

Approval of the exemption requested by the petitioner will allow commercial operation 

of the SkyRanger and/or Delta X-8 for the purpose of utility and infrastructure 

inspections nationwide as conditioned by applicable COA. The requested exemption 

should be granted because operation of small sUAS, such as the SkyRanger or Delta X-8 

weighing approximately 6 pounds and 12lbs, respectively, conducted in the conditions 

outlined below will provide an equivalent level of safety, while still allowing commercial 

operations. The lightweight aircraft covered by the exemption is far safer than 

conventional operations conducted with manned aircraft weighing thousands of pounds, 

carrying highly flammable fuel, and operating in close proximity to the ground and 

people. The factors the FAA is required to consider when approving Section 333 

exemption petitions- size, weight, speed, operational capability, proximity to airports, 

proximity to populated areas, and operation within visual line of sight - each support the 

request. Both the Sky Ranger and Delta X-8 are small and operate at slow speeds, close 

to the ground. The increase in safety, decrease of risk to human life and property, 

coupled with the low risk use of sUAS to conduct these operations, weigh heavily in 

favor of granting the exemption. 

13 
APPENDIXC: 

WESTAR ENERGY's sUAS OPERATIONS AND SAFETY POLICY 

Operator Requirements 

To operate a UAS under this exemption, the pilot in command (PIC) PIC will have an 

airline transport, commercial, private, recreational, or sport pilot certificate and \Vill also 

hold a current FAA airman medical certificate or a valid driver's license. The PIC ·will 

also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in 

which the PIC is rated on his or her pilot certificate and training as defined below. 

Flight training to include, but not limited to: 

• 25 total hours as a UAS rotorcraft pilot including; 

• 10 hours logged as a UAS pilot-in-command of a multi-rotor UAS, 

• 5 hours in the specific make and model of the UAS, and 

• At least 3 take-offs and landings within the preceding 90 days 

Operating Procedures 

Preflight Checklist 

AREA CHECKS 

D DRecord Day, Date and Time: S M Tu \V Th F S , 20 at AM/PM 

D DCheck weather conditions (visually or via radar or \Vebsite) to confirm that no adverse 

weather conditions are expected 

0 D Record current weather conditions to best estimate: 

Rain in Area? YES or NO 

Current Temperature= F (must be between 20°F and 95°F) 

Current \Vind Conditions = mph (must not exceed 20 mph) 

Current \Vind Gusts= mph (must not exceed 25 mph) 

Current Visibility= miles (must be 1 mile or greater) 

D Cl Confirm that no other UAS are flying in vicinity that may create signal interference 

0 DRecord class of airspace from sectional chart or vfrmap.com: Class (no operations 

in Class B, C, or D w/out COA approval) 

0 DNote the proximity of nearest airport from sectional chart or vfrmap.com: _____ _ 

miles 

IJ CJ Visually survey the flight area, note any obstructions that could be hazardous during flight: 

o Trees o Cell Towers o Flags I Light Posts o Low Clouds o Birds 

o Power Lines o Sun Glare o High Voltage Lines o Wind Turbines 

o Other: 

CJ D PIC evaluation of whether candidate Area of Operation constitutes a congested area, a 

densely populated area, or an area over an open air assembly of persons: YES or NO (operations 

14 
cease if "yes ") 

0 0 Identification of alternate or emergency landing spots: 

UASCHECKS 

D 0 Ensure UAS is placed on a flat area for takeoff 

0 DEnsure battery has been inspected for signs of damage or leakage and considered satisfactory 

for flight 

0 DCheck that UAS battery is fully charged 

0 OVerify that the flight battery is fully installed 

0 0 Set up remote controls/monitoring devices 

LJ llRemove gimbal clamp and lens cap from UAS, if appropriate 

CJ [J Inspect propellers, gimbal, camera, and remote controller for any signs of damage 

0 D Verify that the micro SD card has been properly installed into memory slot, if appropriate 

POWERING UP 

0 OFollow respective user manuals for powering, linking, calibrating, and takeoff procedures of 

the UAS 

STARTING MOTORS 

0 DAnnounce "CLEAR!" and make sure no one is within 5 ft ofUAS before it is powered up 

D OConfirm all propellers are spinning smoothly and at approximately the same rotational speed 

0 DIs UAS deemed safe for flight by the PIC? YES or NO (operations cease if "no '') 

c::J CGPS position set 

END OF FLIGHT 

DOLand UAS 

0 OTum off power to the UAS 

0 DPlace gimbal clamp back onto camera, and lens cover on camera lens, if appropriate 

0 OTum off power to remote control 

0 DRecord time that motors were turned off on copter: ______ _ 

0 0 Record maximum height during flight: feet 

D 0 Secure the UAS in a case, vehicle, or structure 

Flight Conditions 

• The UAS will weigh less than 55 lbs. 

• The speed of the UAS will not exceed 87 knots, or the manufacturer's suggested maximum 

speed, whichever is less. 

• All operations will be conducted with aVO. 

• The UAS will be operated in PIC's and/or VO's VLOS at all times. 

• PIC and VO will be in direct verbal contact during flight. 

• The UAS will not be operated at night. Operations will only occur during daytime VMC. 

• The UAS will not be operated from a moving vehicle or device, except as permitted from a 

boat or other water craft. 

• Flights will be operated at an altitude of no more than 400 feetAGL. 

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• Landowner consent prior to flight ifWestar Energy does not own or have rights of access to 

property. 

• Operations will not occur less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 1 statute mile from the PIC. 

• The UAS will remain clear of manned aircraft and yield right of way. 

• A flight test will be conducted after any major repair or alteration. 

• Operations will be concluded, and the UAS will be safely landed, with no less than 10% 

battery power remaining or the manufacturer's recommended battery power remaining, 

whichever is more. 

• Minimum operational standoff distances for nonparticipating persons, vehicles, and 

structures will be kept. 

• Operations will not occur within 5nm of any airport unless a letter of agreement with that 

airport's management is obtained or otherwise permitted by a COA issued to the exemption 

holder. 

• Operations will take place under and in accordance \vith an applicable COA. 

• The operator will be responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

• Operator will follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements and safety bulletins for the aircraft and aircraft 

components. 

• All non-participants will keep an appropriate distance from operations unless there are 

adequate barriers to protect them. 

• All operations will be conducted according to the manufacturer's manuals. 

• All documents that will be kept at the Ground Control Station include but are not limited to; 

the aircraft manuals, maintenance logs, aircraft registration, grant of exemption, and COA. 

• The UAS will be registered in accordance to 14 C.F.R. Part 47, marked in accordance to 14 

C.F.R. Part 45 Subpart C, and accompanied by a letter of alternative marking due to the 

unconventional design of a quadcopter. Markings will be as large as practicable. 

• A GPS receiver will be used to determine and set altitude. 

• Takeoff and landing procedures will be conducted based on stipulations in U AS's User 

Manual. 

• A preflight checklist will be completed in order to ensure the conditions are safe for flight. 

• A NOTAM will be filed prior to flight, as required. 

Logs and Records 

• PICs will maintain a flight logbook to record all flights, including training. 

• A flight logbook will be kept to record all flight time for each aircraft. 

• Maintenance logbook will be kept for each UAS. 

• Maintenance and inspections w·ill be completed based on manufacturer's recommendation. 

• All maintenance performed will be logged in this Maintenance Log. 

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Emergency Procedures 

• In the event of an emergency, immediately land UAS at location that does not create an 

additional hazard. Examples of possible emergencies: loss of communication, loss ofVLOS, 

critically low battery, battery fire, wind gusts, motor failure. 

• Utilize return to home feature in the event of an emergency or unpredicted obstacle, if necessary and 

available. 

• Any damage or injury must be reported to the PIC's immediate manager within 12 hours of event. 

Safety Procedures 

• Report unplanned events, including near misses, hazard observation, or accidents that could or did 

harm personnel, equipment, property or environment. Report within 12 hours of incident. 

• 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 

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