1

September 2014

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 of 2012 (the “Reform Act”) and 14

C.F.R. Part 11, the City of Roswell Coalition (The Coalition) utilizing the Aeryon Labs’ SkyRanger small

Unmanned Aircraft Systems (“sUAS”) seeks an exemption from the Federal Aviation Regulations 

(“FARs”) listed below and discussed in Appendix A. The Coalition is a community based 

organization whose mission is to promote the responsible emergence of UAS 

industry in the area and encourage the preparation of the work force to attract 

this industry. Details of the SkyRanger sUAS and its OEM are described in Appendix B. A 

summary of this request is attached as Appendix C.

The Coalition members are comprised of Chaves County, NM, 4 municipalities including Roswell, NM, 

Roswell International Air Center, New Mexico Military Institute and Eastern New Mexico University –

Roswell (ENMUR). The New Mexico Attorney General has affirmed the coalition as a public entity 

(Appendix D). The mission of the coalition is to promote the growth of the UAS industry in their Central 

New Mexico location and foster professional preparation of that work force. To that end, the Coalition is 

working with Strategic-Aerospace International, INC, a contractor, and member ENMUR to conduct an 

Instructional System Design for a quad-copter and fixed wing curriculum (Strat-Aero will develop 

curriculum and the university will submit for NM university system approval and then collegiate 

accreditation). Strat-Aero will further develop the majority of these courses as web-based CBT. The 

courses will be packaged and delivered by ENMUR to award a technical certificate or an Associate’s 

degree in aviation science with a UAS specialty. ENMUR intends to deliver instruction of certain of these 

courses for credit hours with other academic institutions’ degree programs through articulation 

agreements. In addition, member New Mexico Military Institute intends to offer this curriculum to its junior 

college students. Further, the Coalition intends to create an educational Center of Excellence at Roswell 

dedicated to the responsible introduction of UAS operations into American industry. ENMUR has the 

infrastructure needed for this initiative to include the physical plant (classrooms, dormitories, dining 

facilities, etc.) and academic network (faculty, administration, organization – part of the state university 

system, Aviation Science department, etc.). Roswell, New Mexico provides an ideal location in terms of 

climate, available facilities, and perhaps most important broad-based, enthusiastic community support for 

the introduction of UAS industry activities.

The requested exemption would permit The Coalition operation of Aeryon’s SkyRanger (see details

in Appendix B), which weighs 6 lbs. with imaging payload, to perform research, development and 

validation of a formal UAS training curriculum that includes training in various mission applications of 
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sUAS vehicles to include 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. Applications for these sUASs include inspection of sensitive infrastructure including oil and

gas well heads, pipelines and flare stacks, power lines and towers, solar panel arrays, wind 

turbines, and surveying tasks such as precision agriculture, mining, transportation, and

forestry. Also , law enforcement agencies can apply these

technologies i f they are coupled with new approaches to the use 

o f data analysis to tactical situations . Use of the SkyRanger for these

inspection and surveying applications reduces the need to operate conventional aircraft, 

providing data more quickly, accurately, economically, safely, and with reduced environmental impact.

The requested exemption would address an insidious, imbedded problem with the current introduction of 

UAS activity into the NAS. The sales of UAV’s in the US have been quite robust and numerous different 

UAS models have been procured by a variety of new owners. Where have these new owners been 

trained and how comprehensive has their training been? Have they been trained to just maneuver the 

UAV or have they been educated properly using a well-developed, formal curriculum in the operation and 

application of the UAS in an operational context? A sampling of OEM training indicates that new owners 

are taught the very rudimentary elements of maneuvering the machine only, and from an ad hoc course of 

instruction. All of this suggests that latent accidents have already been introduced into the system. StratAero International Inc., the Coalition partner designated to provide UAS flying services operating the 

SkyRanger, has in depth experience with formal curriculum development in both PART 121 training 

environment to include major US air carrier Advanced Qualification Programs as well as the Part 141/142

and ICAO Ab Initio training arena to include Multi-Crew Pilot License programs. In the absence of 

regulatory guidance for training programs and in an effort to work with the FAA as it develops appropriate 

FAA guidance in this area, Strat-Aero and Eastern New Mexico University Roswell wish to formally 

develop a UAS training curriculum that meets the standards established for courses within the university 

system and that meets the accreditation requirements of regional educational accrediting bodies. Our 

intent would be to create a training program that would be certified as a Part 141 program as soon as 

available. In the meantime, we would develop a training program that is substantiated and would 

introduce safe, professional operators into the fledgling UAS industry in the US. Such a program could 

serve as a model for other such programs and an invaluable FAA resource. 

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

ensure at least an equivalent level of safety to currently authorized operations using manned aircraft 

and under conditions as may be modified by the FAA as required by Section 333.

Aeryon has filed a similar exemption request on its own behalf. Aeryon has encouraged its 

customers to file exemption applications that would allow us to operate the SkyRanger in 

operations at our own facilities and other sites that require aerial data for inspections and surveys.

Wherever possible, those filings will be substantially similar to the Aeryon exemption application.

As described more fully below, the requested exemption would authorize The Coalition to perform

research, development and delivery of formally constructed training curricula to include applications 

like operations of aerial inspections and surveys using the SkyRanger1, which at 6 lbs., is small in

1 Aeryon and its customers have been granted many flight operation certificate to operate the

Aeryon SkyRanger, and its predecessor the Aeryon Scout - including Special Flight Operation Certificates in

Canada for commercial use, and Certificates of Waiver or Authorization (COA) in the US for public agency use.
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size and powered electrically by battery. The SkyRanger will be operated under controlled conditions at

low altitude in airspace that is limited in scope, as described more fully herein; it will have automated

control features, as described below. The Aeryon SkyRanger is designed to be operated by one person

but flight operations generally involve two people: an operator and an observer. The operator is 

responsible for flying the sUAS, monitoring its status and flight dynamics while maintaining visual

line of sight, and keeping the flight within the specified factory limits (in terms of wind, flight range, 

battery life, etc.) to ensure safe operation 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 ground 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.

The Coalition respectfully submits that because this small, unmanned aerial system – the SkyRanger

– will be used by competently trained operators 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. 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: 

The Roswell Coalition.

Attn: Mark Fischer

Ph: 575-740-72216

Fax: 519-347-2234

Email: mfischer@matrixgrp.net

Address: 122 Will Rogers Road, Bldg 1166

Roswell, NM 88203

The primary contact for this application is:

Jonathan Adams – jon@strat-aero.com, 518 224 5759

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);

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).
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THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

The Coalition and Aeryon submit that grant of this exemption application for use of the SkyRanger in

research and development of formally constructed training curricula to include applications like

surveying, mapping and inspection operations will advance the Congressional 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 pose 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 populated areas; and

● Operation of the sUAS within visual line of sight of the operator.

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such

aircraft in the national airspace system.” Id. §333(c) (emphasis added).

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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 must 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 this section or any of sections 44702-44716 of this title if the 

Administrator finds the exemption is in the public interest.

49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in Section

333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations; and the significant public benefit, 

including enhanced safety and cost savings associated with responsibly transitioning to sUASs for aerial

surveying, mapping and inspection applications. Accordingly, the applicant respectfully requests that

the FAA grant the requested exemption without delay.

Airworthiness of the SkyRanger

A critical element of the exemption application involves evidence of the airworthiness of Aeryon sUAS

including the SkyRanger. Aeryon believes that it has shown compliance through a history of granted

2 Applicant submits that this provision places a duty on the Administrator to not only process

applications for exemptions under Section 333, but for the Administrator, if he deems the conditions

proposed herein require modification in order to allow approval, to supply conditions for the safe operation of

the sUAS. Aeryon welcomes the opportunity to consult with FAA staff in order to address any issues or

concerns that this proposal may raise that they believe may require modification.
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flight operations and successful flights - including many operations with public agencies. The list of 

granted applicants includes: Michigan State Police, US Navy Spawar, Mass Development (Joint Base 

Cape Cod), Unmanned Experts (NIJ Partnership), Western Washington University, Aetos (via

Northwest Michigan College), University of Alaska Fairbanks, University of New Mexico, Kansas State 

University, and Virginia Tech University. The SkyRanger has also successfully completed the 

Department of Homeland Security RAPS Trial in 2013. In Canada, Aeryon has obtained 19 Special 

Flight Operations Certificates (SFOCs) from Transport Canada over 5 years and its customers have 

received multiple certificates to perform demonstration, research and development, public and 

commercial operations.The criteria set forth in the certificates granted specify the substantive

showings of the device’s safety and fitness for operation to ensure that the FAA has sufficient basis

to evaluate the aircraft’s safety

3. The SkyRanger also has a significant set of automated features to

ensure safe takeoff, flight and landing in many conditions, further details of operation can be found in

Appendix B.

Mandatory Operating Conditions

Grant of the exemption to The Coalition will be subject to the following mandatory conditions,

which are based upon operating conditions set forth for operation of sUAS by public entities 

pursuant to Certificates of Authorization, with additional restrictions:

● 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 operation around operator not to exceed the remain in 

sight of operator/observer distance and the boundaries of the authorized location.

● 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 within the boundaries of authorized 

location and so as to adhere to any conditions set forth in that authorization.

● Operator will file a NOTAM and/or notify ATC prior to each flight as per conditions of authorization.

● All required permissions and permits will be obtained from 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

Both The Coalition and Aeryon respectfully propose that operator requirements should take into

account the characteristics of the particular sUAS. Certain sUASs, such as the Aeryon SkyRanger,

are characterized by a high degree of pre-programmed control and various built-in technical

capabilities that 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 operator

3 The Coalition can submit under confidentiality the following documents in support of this

exemption application for the SkyRanger: 1) Aeryon SkyRanger User Guide which includes Safety and

Preflight Checklists; and 2) SkyRanger UAS Operating Manual.
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in safe and reliable operation.

4

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 pointing, 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 parameters (electric fence). 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 reliability in challenging weather conditions. At all times during

flight operations, the operator can intervene with a programmed flight and take immediate control.

Additional automated safety functions and safety enhancing features of the SkyRanger include the 

following:

● Automated pre-flight system performance checks

● User pre-flight checklist

● Automated condition or fault detection, warnings, and pre-defined responses to a number of 

flight and system conditions.

◦ High winds with system and user defined safety thresholds

◦ Low battery with system and user defined safety thresholds

◦ High temperature or other system safety thresholds

◦ Lost-link communication

● Pre-defined responses include behavior such as attempting to re-establish radio 

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

current position

● In the case of lost GPS, a manual user flight mode is enabled which allows the operator to 

provide manual navigation inputs to assist in landing the vehicle.

Given these safety features, The Coalition 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 country;

● have completed Aeryon’s authorized training program for operation and maintenance of the 

sUAS.

Aeryon 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).

4 As of July 2014, Aeryon staff and customers have performed over 5681 flights, logging 623 hours of 

flight time with the SkyRanger with both development and release versions. The previous generation 

product, Scout, achieved over 7197 flights and 839 hours of flight time globally by Aeryon and its 

customers. This is a significant amount of flight time collected to understand and refine the Aeryon 

sUAS products.
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In summary, applicant seeks an exemption from the FARs set forth above and in Appendix C to allow

research, development and delivery of a formal UAS training curriculum of a small unmanned

vehicle in surveying, mapping and inspection operations.

Approval of the exemption allowing research, development and delivery of a formal UAS 

training curriculum of the SkyRanger for surveying, mapping and inspection operations will 

enhance safety by reducing risk. Conventional aerial survey and inspection operations using manned 

aircraft involve very heavy aerial vehicles 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 often take place in congested environments including proximity to

physical obstacles and/or presence of the general public. By contrast, the SkyRanger weighs 6

lbs. including payloads and uses a battery for power, is carried to/from the area of activity,

removes the need for airborne pilots/observers, and poses less risk to people and infrastructure on

the ground. And the proper development of curricula through an instructional system design process 

will insure safe future operators of UAS for these tasks.

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

size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or 

other dangerous materials, the SkyRanger poses no threat to national security.

The operation of the SkyRanger by the Coalition for research, development and delivery of a

formal UAS training curriculum for surveying, mapping and inspection operations in accordance 

with the strict conditions outlined above, will provide an equivalent level of safety supporting

the grant of the exemptions requested herein, including exempting The Coalition from the requirements

of Part 21.

The Coalition utilizing the SkyRanger satisfies of the criteria set forth in Section 333 of the

Reform Act—size, weight, speed, operating capabilities, lack of proximity populated areas, operation

within visual line of sight, and national security – and its showing of an equivalent level of safety as it

may relate to the requirement for a pilot’s license, provide more than adequate justification for the

grant of the requested exemptions allowing The Coalition to proceed as requested.

Very truly yours,

Mark Fischer

The City of Roswell Coalition
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APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER

APPLICABLE RULES SUBJECT TO EXEMPTION

Aeryon requests an exemption from the following regulations as well as any additional regulations that 

may technically apply to the operation of the SkyRanger:

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

14 CFR § 91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR § 91.203(a)(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 safety under Part 11 and Section

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

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas of the sUAS 

involved.

In this case, an analysis of these criteria demonstrates that the SkyRanger operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The SkyRanger weighs

6 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate 

exclusively within an area pre-disclosed and in compliance with conditions set 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 all operations through the filing of NOTAMs. Receipt of the 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

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, level of safety to that of such operations being conducted with 

conventional aircraft that would be orders-of-magnitude larger and would be carrying passengers, 

cargo, and flammable fuel. The automated safety features including redundant sensor systems as 

described in Appendix B and throughout this document highlight the design intentions towards safety 

and reliability on SkyRanger.

5 An Aeryon internal report compares the crash kinetic energy dissipation rate of a commercial airline versus the 

Aeryon SkyRanger. The report found the MTTF of SkyRanger needs to only be > 2.3 hours to equal the energy 

dissipation of the gold standard commercial aircraft. Transport Canada, has issued a report on low energy RPA 

and determined the Aeryon Scout, at a typical max kinetic energy of 1.45J/cm2, to be well below the 

recommended peak energy level of 12J/cm2 on impact, since the SkyRanger is similar in construction it could be 

considered to be below this threshold as well.
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14 C.F.R. § 45.23 & 91.9(c): Marking of the Aircraft

Regulation 45.23 provides:

(a) Each operator of an aircraft must display on that aircraft marks consisting of the 

Roman capital letter “N” (denoting United States registration) followed by the registration 

number of the aircraft. Each suffix letter used in the marks displayed must also be a 

Roman capital letter.

(b) When 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 certificated 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.

The 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. Official marking systems for 

small UAS have not yet been established for operations inside the NAS. The 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. Aeryon is prepared to mark the inspection 

system with the name of the organization and location or origin and fulfill any other request by the FAA 

to this topic in accordance to § 45.29(f) where the pilot, observer, and others working with the sUAS 

will see the identification 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 Pilot 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 with no 

passengers or property 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. Aeryon respectfully 

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

sUAS. Aeryon’s SkyRanger has a high degree of pre-programmed control and various built-in technical 

capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the 

exemption application.

The SkyRanger has an all-digital software platform with advanced features previously restricted to full 

size unmanned aircraft. Automated features and advanced fly-safe controls enable safe, reliable 

operation, as well as advanced networking capabilities and system extensibility.

● Plan your flight or fly ad-hoc: The system can autonomously fly a programmed flight path or fly

in manual mode

● Smart batteries and charger: Flight time and battery minutes are displayed at all times. The 

system will return home and land automatically if user-configurable limits are reached.
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Flight safety is a priority, no matter the operating environment or project. The SkyRanger offers 

superior safety over manned aircraft by removing the need for people to be onboard in potentially 

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

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

self-tests prior to takeoff to check for errors

● No-fly zones: The system has the ability to set up visual no-fly zones

● Self-monitoring: Monitoring battery levels, in-flight wind speeds, and other system and 

environmental conditions are automatically handled by the system

● Battery communication: Battery minutes and flight time are displayed at all times.The system 

will return home and land automatically if user-configurable limits are reached.

Additional automated safety functions and safety enhancing features of the SkyRanger include the 

following:

● Auto detection of lost GPS warns the pilot and initiates an immediate landing.

● Low battery on the SkyRanger triggers a Non Fatal Warning alarm to return home, land and 

replace the battery

● Very low battery on the SkyRanger triggers an Fatal Error alarm and initiates an emergency 

high speed descent landing.

● If the SkyRanger detects a lost-link to the basestation the vehicle will perform its pre-defined

Non-Fatal Condition Response.

Given these safety features, The Coalition 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 ICAO issued 

commercial, private license and ground school;

● have completed Aeryon’s training program for operation of the sUAS.

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

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

mandatory operating conditions specified above are present. 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 the SkyRanger (given its size, speed, operational 

capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with 

private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft 

(fixed wing or rotorcraft), that allowing operations of the sUAS as set forth above meets or exceeds the 

present level of safety provided under 14 C.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).
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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 the SkyRanger without an 

airworthiness certificate, no standard will exist for airworthiness of the SkyRanger. Given the size of 

the aircraft and the previous COAs issued 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.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

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, unless 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 the SkyRanger, it has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is no room or 

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., 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 flight. 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 Manual 

(exhibit 1) under the ‘Getting Ready to Fly’ section. The PIC will take all actions including reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft performance data 

before initiation 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 accomplished through the use of a control box that communicates with the aircraft via 

radio communications. The flight plan is either manually controlled through point-and-click touchscreen 

navigation or pre-programmed as way points or an AutoGrid into the auto pilot before or during flight 

and only in unusual circumstances will the pilot input control functions to alter the pre-programmed 

flight. If instruction is accomplished through a training program, as set forth in Exhibit 2, an equivalent 

level of safety will be assured. The FAA has approved exemptions for flight training without fully
12

functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See 

Exemption Nos. 5778K & 9862A. The equivalent level of safety will be achieved by the manufacturer 

providing the training as outlined, for example, in Exhibit 2 and through the use of experienced and 

qualified pilots familiar with the SkyRanger.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits 

aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure.

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

operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. 

Because aerial survey, mapping and inspection work must be accomplished at relatively low altitudes 

and at altitudes 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 is built. Also, no flight will be taken without the permission of the 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 conducted with aircraft or rotorcraft 

weighing far more than 6 lbs. and carrying flammable fuel, any risk associated with these operations 

will be far less than those currently allowed with conventional aircraft operating at or below 500 feet 

AGL. Indeed, the low-altitude operations 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 regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed – (1) During the day, to fly after that for at least

30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The SkyRanger batteries provide approximately 50 minutes of powered flight. Without an exemption 

from § 14 CFR 91.151, the sUAS’s flights would be limited to approximately 20 minutes in length. Given 

the limitations on its proposed operations and the location of those proposed operations, a longer time 

frame for flight in daylight VFR conditions is reasonable.

The Coalition believes that 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 not

engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at

which the sUAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its 

safety. Additionally, limiting SkyRanger flights to 20 minutes would greatly reduce their utility. In the

unlikely event that the SkyRanger should run out of fuel, it would simply land. Given its weight and

construction material, the risks are less than contemplated by the current regulation.

The Coalition believes that an equivalent level of safety can be achieved by maintaining 10 minutes of

reserve fuel, which, allowing 40 minutes of flight time, would be more than adequate to return the

sUAS to its
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planned landing zone from anywhere in its operating area.

The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and

10808.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft 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 

displayed at the cabin or cockpit entrance so that it is legible to passengers 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 equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the sUAS will have immediate access to them. The FAA has issued numerous 

exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos.

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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 this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...” 

Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an 

annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the 

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

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

return to service.

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

any check will prevent take-off. Checks which cannot be done by the system will be performed by a 

qualified person prior to each flight and at predefined intervals as part of the Maintenance Schedule in 

the User Manual (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
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keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar 

with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an 

equivalent level of safety.

The SkyRanger’s Maintenance guidelines ensure an equivalent level of safety to the maintenance 

requirements in Part 91. In addition, any component failure detectable by the system will be reported to 

the control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Non-Fatal 

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

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

Aeryon Corporate Overview: Aeryon Labs, Inc. is a Canadian company located in Waterloo Ontario. 

Aeryon is focused on providing micro unmanned aerial system and is globally recognized as the 

market and technology leader in this space. Key customers range from military organizations such as 

Canadian Special Operations and US Special Operations; key government agencies such as NOAA, 

Environment Canada and the US Coast Guard; world leading universities in the unmanned space such 

as University of Alaska Fairbanks and Kansas State University; police agencies such as the RCMP 

and OPP; and global enterprises such as BP, UK Power 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 officially fly at one of the FAA’s UAS 

Test Sites (UAF Alaska). Many customers from military, to education to police and even commercial 

operations have been given approval to fly in US, Canada, UK, Australia, Japan, and others airspaces.

SkyRanger Overview: Aeryon unmanned systems have been used to fight terrorism in Iraq, 

Afghanistan and Nigeria, monitor hostile borders between Saudi Arabia and Yemen, ensure the safety 

of world leaders at the G50 Nuclear Summit in Seoul, escort a fuel tanker and ice breaker into a remote 

Alaskan community, monitor wildlife on the Aleutian Islands, map remote communities in 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 40 M.P.H. for sustained winds and wind gusts up to 55 M.P.H.. What is unique about the 

Aeryon SkyRanger is the system automatically compensates for 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 commanding the system to move, the system automatically holds its GPS 

position (i.e. GPS hold for reliable location hover). Camera positioning is also GPS controlled allowing 

for the most sophisticated camera targeting available. The flight control system employs not only GPS 

positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed and 

others to ensure the most stability of any system in its class-regardless of the wind.

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

preplanned flight paths to fly in autonomous mode is as simple as clicking on the map to create a 

preplanned flight path. In semi-autonomous mode, the operator clicks on the map and the Aeryon 

SkyRanger automatically flies to the point on the map where the operator is pointing. Pre-mission 

waypoints, Landing zone points and flight area dimensions can all be entered during preflight ensuring 

the SkyRanger operates only within specified parameters.
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The Aeryon SkyRanger includes many advanced safety features that makes the SkyRanger the safest 

choice for both urban and non-urban environments. Built-in intelligent fault handling allows the 

SkyRanger to detect a system fault while in the air, and to automatically fly back to its take-off location 

and land. Faults that can be detected include: loss of communication; pre-set wind thresholds 

exceeded; and low battery levels. In addition, the operator can create no fly zones or maximum flight 

ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. And 

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

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

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.

SkyRanger UAS Operating Manual - System user manual available upon request.

Physical 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 “SMART” intelligence 

on-board. This includes cycle charge times, locations, GPS antenna, chemical management, and 

real-time data feeds to ensure maximum flight duration and sub-system safety processes. Charging is 

done in the included Aeryon Battery charger and can be charged via standard wall outlet, or via a 

vehicle.

Landing style/type – Autonomous vertical lift

Propulsion System

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

● Batteries – Lithium polymer batteries are self-contained high duration systems with SMART 

intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical 

management, and real-time data feeds to ensure maximum flight duration and sub-system 

safety processes. Charging is done in the included Aeryon Battery charger and can be charged 

via standard wall outlet, or via a vehicle.

Performance Characteristics

● Maximum Altitude – 1500 ft.

● Maximum Endurance – 50 minutes

● Maximum Range – 3 km

● Weather Minimums -

● Winds Maximum – 40 MPH sustained, 55 mph gusts

● 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
17

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

performed by a qualified person prior to each flight.

Pre-flight checklist includes:

● Visual inspection of the airframe

● Visual inspections of rotor integrity

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

Reliability – The system is designed for maximum reliability and to maintain performance over its life. 

The only components experience routine wear are rotors, batteries, motors, and legs. Battery and 

motor conditions are monitored by the system with deviations reported to the operator.

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

arms, to become damaged. Damaged components are likely to be detected during the full visual 

inspection of the airframe performed before each flight. Structural damage affecting flight 

characteristics will be detected by on-board sensors.

The UAV system detects numerous conditions which may make flying unsafe, such as reduced GPS 

accuracy, magnetic anomalies, low battery charge, battery cell imbalances, temperature fluctuations. 

Automatic pre-flight checks prevent the UAV from taking off if such conditions are present; or, if the 

condition is detected during flight, the system will trigger a Fatal Conditioned Response.

Fault Tolerance - The key feature of the UAV fault tolerance is its mechanical simplicity. It uses four 

fixed pitched rotors, each mounted on a separate motor. No control surfaces or other actuators are 

required for the 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 Systems

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

at least once per second.

Displayed on GCS:

● UAS Position

● Navigation Route

● UAS Tail Number

● UAS Position

● UAS Altitude

● UAS Heading

● North Seeking Arrow

● Range to Target

● Calculated target position

● Date/time

● Sensor heading and orientation relative to UAS

On-board Flight Instruments – The UAV is equipped with an Inertial Navigation System (3-axis 

gyroscope, 3-axis magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for 

precision AGL altitude measurement.
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On–board computer systems – The UAS is equipped on-board computer systems to monitor 

(sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, 

etc.).

On-board guidance and navigation equipment – The UAS can operate autonomously; it does not 

require any input from ground-based equipment, or from the pilot to hover in place.

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

Flight termination link – to prevent a “fly away” or other potentially dangerous situation a flight 

termination link is available to the operator at the GCS.

Takeoff and Landing – The SkyRanger has vertical lift autonomous launch and recovery. A Landing 

Zone “LZ” is designated by the operators and identified in the GCS software. For launch procedures the 

aircraft will takeoff and hover 3 meters directly above the LZ and hold until further operator instruction 

is given. The aircraft will automatically adjust for wind during this period.

Navigation System – Specific maps can be downloaded to the display screen (such as air sectional 

and geographic maps) which are overlaid with GPS positional data. Waypoints can be created before 

and during flight operation creating specific locations and sequences for the aircraft.

Redundant Systems – The UAS combines the input from a multitude of sensors. Even though the 

data from all sensors is required for optimal system performance, a single sensor malfunction is likely 

to result in degraded performance rather than leading to a catastrophic failure.

Emergency Procedures and System Failures

Failure Handling – The UAS has extensive failure detection and handling capabilities. All failures are 

deeded to be either fatal or non-fatal. Failures classified as fatal result in a Fatal Condition Response 

(FCR); and failures classified as non-fatal result in a Non-Fatal Condition Response (NFCR).

Sensor Failure – Failure of on-board flight instruments/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.

Airframe 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 System Failure – In a navigation system failure, degraded GPS will result in FCR or

NFCR ‘s depending on failures.

Power 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 as 

soon as able.

Low Battery Condition – Operator will be alerted of a low battery condition and will land the aircraft as
19

soon as able.

Line-of-Sight Loss – All flight 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.
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APPENDIX C

SUMMARY OF AERYON SECTION 333 EXEMPTION REQUEST

Aeryon hereby provides pursuant to Part 11 a summary of its exemption application to allow 

commercial operation of the SkyRanger small unmanned system in market research, precision aerial 

survey work, mapping and inspections. 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)
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APPENDIX D

NEW MEXICO ATTORNEY GENERAL LETTER OF AFFIRMATION

Attorney General of New Mexico General ALBERT J. LAMA

GARYK.KING Attorney Chief Deputy Attorney General

April 22, 2014

Sent via Electronic Mail: randy. willis@faa.gov byron.ctr.chew@faa.gov

Federal Aviation Administration

490 L 'Enfant Plaza, SW Suite 3200

Washington, DC 20024

Re: Public aircraft status of City of Roswell Unmanned Aerial Systems (UAS) Coalition unmanned 

aircraft systems

To the Federal Aviation Administration:

The New Mexico Attorney General hereby affirms that the City of Roswell Unmanned Aerial Systems 

(UAS) Coalition is a political subdivision of the State of New Mexico and that unmanned aircrafts 

systems operated by U AS, including those operated through the Roswell International Air Center, 

qualify as "public aircraft" under 49 USC 40102(a).

The pertinent portions of 49 USC 40102(a) that define public aircraft are as follows: (41) public aircraft 

means -

(C) An aircraft owned and operated by the government of a State, the District of Columbia, or a 

territory or possession of the United States or a political subdivision of one of these governments, 

except as provided in Section 40125(b).

(D) An aircraft exclusively leased for at least 90 days continuous days by the government of a 

State, the District of Columbia, or a territory or possession of the United States or a political 

subdivision of one of these governments except as provided in Section 40125(b).

The UAS membership consists entirely of municipalities, state educational institutions, and a county. It is 

well settled under New Mexico law that all such entities are political subdivisions of the state under 
22

applicable state statutes and constitutional provisions Further, we are aware of no case law or other 

authority that questions the status of the UAS or its membership organizations as political 

subdivisions of the state.

The unmanned aircraft systems operated by the Roswell UAS Coalition will either be owned outright or 

leased beyond 90 days, depending on the platform selected and duration of operations planned. 

Additionally, we understand that 40125(b) limits the scope of UAS operations for commercial 

purposes.

Thank you for your attention to this matter. Should the FAA need further information from the

New Mexico Attorney General’s Office, please feel free to contact the undersigned at 505-827-

7416. 

Sincerely,

Mark Reynolds 

Assistant Attorney General

 P.O. Drawer 1508 Santa Fe, New Mexico 87504 (505) 827-6000 www.nmag.gov