Docket Management System 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Petition of Southern Company Services, Inc. for an Exemption Pursuant to 

Section 333 of the FAA Modernization and Reform Act of2012 

Dear Sir or Madam: 

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

"FMRA"), 49 U.S.C. § 44701 and 14 C.F.R. Part 11, Southern Company Services, Inc. 

("Southern Company Services" or "Petitioner"), a subsidiary of The Southern Company 

("Southern"), hereby requests an exemption to permit limited small unmanned aircraft system 

("sUAS") operations as described herein. Southern Company Services requests the exemption in 

order to conduct research on the applicability of sUAS when assessing damage to power lines 

due to storm events and performing routine power line inspection. 

sUAS operations have the potential to assist utilities in providing safer and faster 

alternatives to manned ground and aerial inspections, and to increase customer benefits. 

Petitioner requests an exemption in order to conduct research on the application of sUAS in the 

power industry and to investigate the benefits of such technology compared to manned ground 

and aerial inspections. Petitioner will investigate benefits for various sUAS applications and 

evaluate the extent to which its customers could benefit through better service. Through its 

research, Petitioner will be in a position to establish best practices for using and operating sUAS 

within the power industry and share that information with the Department of Transportation (the 

"Department"), the Federal Aviation Administration ("FAA'') and other industry members. 

As described in detail below, Petitioner's proposed sUAS operations are in accordance 

with the principles and the requirements set forth at section 333 of the FMRA. They will also 

help implement the Department's and the FAA's policy to leverage authority granted under 

Section 333 for authorizing safe, civil operations of sUAS in the national airspace system 

("NAS"). 

Southern Company Services' proposed operations will also meet strict safety 

requirements. They will only take place in a privately owned, remote location, involve trained 

THOMPSON H IN E n r 

ATTORNEYS AT lAw 

1919 M Street, N.W. 

Suite 700 

Washington, D.C. 20036-3537 

www.ThompsonHine.com 

Phone: 202.331.8800 

Fax: 202.331.8330 

276208.<1 
pounds, far less than the FMRA's cut-offweight of 55 pounds to qualify as sUAS. 1 Reliance on 

sUAS would vastly reduce risks to crews responsible for power line inspections and significantly 

hasten power restoration in the event of storms, hurricanes, tornadoes and other weather events 

occurring in the southeast region of the United States. Southern Company Services' proposed 

operations will not have an impact on any citizen's privacy rights and will be in compliance with 

all privacy laws. In this regard, granting Southern Company Services' exemption request would 

be in the public interest. 

1 See FMRA, Pub. L. No. 112-95, § 331 (6), 126 Stat. II , 72. (20 12) (stating that "[t]he term 'small unmanned aircraft' means an 

unmanned aircraft weighing less than 55 pounds"). 
I. Description ofThe Southern Company and Southern Company Services, Inc ...................... 4 

A. The Southern Company ...................................................................................................... 4 

B. Southern Company Services, Inc ........................................................................................ 4 

II. Statutory and Regulatory Authority for Granting Petitioner's Request for an Exemption .... 5 

A. Section 333 ofthe FMRA ................................................................................................... 5 

B. 49 U.S.C. Sections 40109 and 44701 ................................................................................. 6 

C. 14 C.F.R. Part 11 ................................................................................................................. 7 

III. Southern Company Services' Proposed Operations ............................................................... 7 

A. Proposed sUAS Platform .................................................................................................... 7 

1. Southern Company Services will use a safe, proven sUAS platform ............................. 7 

2. Aircraft design and operational characteristics ............................................................... 9 

3. Aircraft inspection and maintenance ............................................................................ 1 0 

B. Pilot and Observer Qualifications ..................................................................................... 10 

C. Scope of Operations .......................................................................................................... 1 0 

1. Geographic Location ....................................... .............................................................. 10 

2. Flight Conditions .......................................................................................................... 19 

IV. Regulations from which Exemption is Requested ................................................................ 20 

V. Granting Southern Company Services' Petition is in the Public Interest.. ........................... 30 

VI. Privacy .................................................................................................................................. 31 

VII. Federal Register Notice ........................................................................................................ 32 

VIII. Summary ............................................................................................................................... 32 

IX. Request for Relief ................................................................................................................. 33 
A. The Southern Company 

Southern is a leading U.S. producer of clean, safe, reliable and affordable electricity. It 

owns electric utilities in four states (Alabama Power, Georgia Power, Gulf Power, and 

Mississippi Power), as well as a competitive generation company, Southern Power. Southern 

also owns a licensed operator of three nuclear generating plants, Southern Nuclear, as well as 

fiber optics and wireless communications entities-Southern Telecom and SouthernLINC 

Wireless. Southern brands are known for energy innovation, excellent customer service, high 

reliability and retail electric prices that are below the national average. With 4.4 million 

customers, over 100,000 miles of medium voltage power lines and nearly 46,000 megawatts of 

generating capacity, Southern is the premier energy company serving the Southeast. 

Southern has been recognized by the U.S. Department of Defense and G.l. Jobs magazine 

as a top military employer and listed by Diversitylnc as a top company for Blacks. The company 

received the 2012 Edison Award from the Edison Electric Institute for its leadership in new 

nuclear development, was named Platts' 2011 Power Company of the Year and is continually 

ranked among the top utilities in Fortune's annual World's Most Admired Electric and Gas 

Utility rankings. 

B. Southern Company Services, Inc. 

Southern Company Services, with offices in Birmingham, Alabama, is a shared services 

organization of Southern. As such, Southern Company Services provides administrative and 

operational services and support to Southern subsidiaries. Southern Company Services also 

provides engineering services to Southern subsidiaries. 

One of Southern Company Services' areas of support is research and development. It is 

through its Research and Technology Management ("R&TM") office that Southern Company 

Services provides research and development services to Southern subsidiaries. Southern 

Company Services' R&TM will manage, coordinate and execute all sUAS activities for the other 

Southern subsidiaries in the geographic area designated in section III.C. of this petition. 

Southern Company Services, therefore, is the Petitioner requesting a section 333 exemption for 

limited sUAS operations as set forth herein. 

The Petitioner's name and mailing address are: 
Attn: Dexter Lewis 

600 North 18th Street, 14 N-8195, 

Birmingham, AL 35203 

Tel.: (205) 257-6854 

Email: dlewis@southernco.com 

All communications in connection with this petition should be sent to the undersigned 

and to the address listed above, to the attention of Mr. Dexter Lewis, who will be the point of 

contact at Southern Company Services. 

II. Statutory and Regulatory Authority for Granting Petitioner's Request for an 

Exemption 

A. Section 333 of the FMRA 

Section 333 of the FMRA provides that 

The Secretary of Transportation shall determine if certain unmanned 

aircraft systems may operate safely in the national airspace system before 

completion of the plan and rulemaking required by section 332 of this Act 

or the guidance required by section 334 of this Act? 

Section 333 also states: 

If the Secretary determines under this section that certain unmanned 

aircraft systems may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system. 3 

Based on the plain language of the statute, the Secretary is required to determine whether 

certain UAS operations should be permitted before issuance of the sUAS regulations required 

under section 332 of the FMRA. If the Secretary determines that the operations are safe, the 

Secretary must decide what the requirements will be for such operations. In other words, the 

2 FMRA § 333(a) (emphasis added). 

3 FMRA § 333(c) (emphasis added). 
the Secretary has determined that the system may operate safely in the NAS. The FAA has 

interpreted section 333, as a grant oflimited statutory flexibility to expedite requirements for the 

safe operation of certain aircraft systems in the NAS.4 

Section 333 further states that when the Secretary ofTransportation makes a 

determination under subsection (a), the Secretary must consider which types ofUAS would not 

create a hazard to others using the NAS or the public or pose a threat to national security. The 

Secretary is required to consider the following U AS specifications and operational factors: 

• Size. 

• Weight. 

• Speed. 

• Operational capability. 

• Proximity to airports and populated areas. 

• Operation with visual line of sight. 5 

If, upon consideration of the factors enumerated above, the proposed sUAS operations do 

not pose a threat to others using the NAS or to national security, the Secretary, acting through the 

FAA, may approve the proposed operations. As shown below, Southern Company Service's 

proposed sUAS operations will in no way create a hazard to the NAS or pose a threat to national 

security based on the factors set forth at section 333. 

B. 49 U.S.C. Sections 40109 and 44701 

Section 44701 requires the FAA Administrator to promote safe flight of civil aircraft by 

prescribing standards for aircraft and aircraft parts, inspecting, servicing and overhauling aircraft, 

maximum hours for airmen, and other practices or procedures necessary for safety and national 

security.6 However, subsection (f) states that the FAA Administrator "may grant an exemption 

4 See FAA, Section 333, https://www.faa.gov/uas/legislative_programs/section_333/ (last visited Oct. 2, 2014). 

5 FMRA § 333(b)(l). 

6 49 U.S.C. § 44701 (a)-(b) (2014). 
sections 44702-44716 of this title, if the Administrator finds the exemption is in the public 

interest."7 In addition, Section 40109 authorizes the Administrator to "grant an exemption from 

a [safety] regulation prescribed in carrying out sections 40103(b)(1) and (2), 40119, 44901 , 

44903,44906, and 44935-44937 of[49 U.S.C.] when the Administrator decides the exemption is 

in the public interest."8 Consequently, under the plain language of pertinent U.S. aviation law, 

the Administrator is expressly authorized to grant exemptions from the FAA's safety regulations where it would be in the public interest. As set forth in further detail below, granting Southern 

Company Services' petition for an exemption would be in the public interest.9 

C. 14 C.F.R. Part 11 

The FAA's regulations state that, using a petition for exemption, an entity may ask FAA 

to grant it relief from current regulations in title 14 of the Code of Federal Regulations.10 14 

C.F .R. Part 11 provides the bases for requesting exemptions. The petitioner is required to state 

(1) the specific sections of Title 14 from which it seeks an exemption, (2) the extent of relief it 

seeks and (3) the reasons why granting the request would be in the public interest and would not 

adversely affect safety (or how the exemption would provide a level of safety at least equal to 

that provided by the rule from which the petition seeks an exemption). 11 As set forth below, 

Petitioner has fulfilled each of these criteria by demonstrating that granting its exemption will 

serve the public interest and not adversely affect safety. 

III. Southern Company Services' Proposed Operations 

A. Proposed sUAS Platform 

1. Southern Company Services will use a safe, proven sUAS platform 

Petitioner seeks an exemption permitting operations of an Aeryon SkyRanger sUAS 

rotorcraft that weighs 6 pounds, including its imaging payload, to perform power line inspections 

7 49 U.S.C. § 4470l(f). 

8 49 U.S.C. § 401 09(b). 

9 See § V., infra. 

10 14 C.F.R. § 11.6 1. 

11 14 C.F.R. § 11.81. Additional, non-substantive content is required. 
produces high quality imagery and data that can be used independently-or in the case of 

surveying and modeling-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 pipelines and flare stacks, power lines and 

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

and forestry. Use of the SkyRanger for these inspection and surveying applications reduces the 

need to operate conventional aircraft, providing data more quickly, accurately, economically, and 

safely, with reduced environmental impact. 

The SkyRanger is a safe, proven sUAS platform used by multiple governmental agencies. 

A critical element of this petition for an exemption is evidence of the Aeryon SkyRanger's 

airworthiness. Aeryon has demonstrated airworthiness of the Sky Ranger through a history of 

authorized flight operations and successful flights, including many operations with public 

agencies. The list of authorized SkyRanger operators 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 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, and public and commercial operations. The SFOCs and the operations by numerous public entities in the United States demonstrate the SkyRanger's 

safety and fitness for operations proposed in this petition. The criteria set forth in the certificates 

demonstrate the device's safety and fitness for operation and ensure that the FAA has sufficient 

basis to evaluate the aircraft's safety. 

The Sky Ranger also has a significant set of automated features to ensure safe takeoff, 

flight, and landing in many conditions. Details on such features are set forth at Attachment 1 

hereto and discussed below in this section liLA and section IV. (pertaining to an exemption from 

14 C.F.R. §61.113). This information provides the FAA with more than a sufficient basis for 

concluding that this particular sUAS does not present a hazard to the NAS or persons or property 

on the ground. 
The Aeryon SkyRanger is a 6-pound rotorcraft sUAS 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 in section III.C. It has the capability to 

hover and move in the vertical and horizontal plane simultaneously, and it provides many other 

built-in functional and safety features to assist the operator with safe and reliable operations. 

The flight control system of the Aeryon Sky Ranger contains two semi-autonomous flight 

modes that use a point-and-click map and video interface and a manual override mode. Under 

semi-autonomous modes, which are the primary modes for flight control, the operator exercises 

control by clicking the on a map the points to which the aircraft should fly or programming a 

flight plan comprising a series of waypoints or a grid-based area into the flight control system 

and executing it. The flight control system relies upon the GPS for navigation and employs a 

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

ensure high aircraft stability and flight control accuracy. Landing zones and flight areas may be 

designated to ensure that the SkyRanger operates only within user-specified flight parameters. 

At all times during flight, the operator can cancel the semi-autonomous flight modes and take 

immediate control of the aircraft. 

The SkyRanger employs a robust slate of automated safety functions and safety 

enhancing features, including the following: 

• Automated pre-flight system performance checks. 

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

of flight and system conditions, including: 

o High winds with system and user defined safety thresholds. 

o Low battery with system and user defined safety thresholds. 

o High temperature or other system safety thresholds. 

o Lost-link communication. 

• Pre-defined response behavior including attempting to re-establish radio communication, 

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

position. 

• In the case oflost GPS capability, a manual user flight mode that allows the operator to 

provide manual navigation inputs to assist in landing the vehicle. 
SkyRanger. A confidential aircraft manual will be submitted as soon as possible under separate 

cover and with a request for confidential treatment. 

3. Aircraft inspection and maintenance 

Attachment 1 provides information on SkyRanger inspection and maintenance 

requirements and procedures. The SkyRanger is nearly maintenance free, is capable of 

evaluating its health and functionality, and requires inspection before flight and after contact 

with other objects. 

B. Pilot and Observer Qualifications 

The pilot in command ("PIC") of the SkyRanger will be an FAA licensed airman with at 

least a private pilot's certificate and current third-class medical certificate. Prior to flying the 

SkyRanger, a PIC must complete Aeryon's authorized training program for operation and 

maintenance of the SkyRanger sUAS. 

The pilot and the visual observer will have been trained in general sUAS operations and 

received up-to-date information on the sUAS to be operated. 

C. Scope of Operations 

This section III.C identifies the standards under which Southern Company Services will 

operate the SkyRanger sUAS. At a minimum, Southern Company Services will operate the 

sUAS in conformance with the Model Aircraft Operating Standards set forth in Advisory 

Circular 91-57. The robust set of operating parameters described in this section ensures that 

Southern Company Services' proposed operation will "not create a hazard to users of the 

national airspace system or the public or pose a threat to national security."12 

1. Geographic Location 

Southern Company Services requests an exemption for sUAS operations and proposes 

training and research and development activities in a very limited geographical area. Petitioner 

initially proposes conducting sUAS operations within an existing power system training facility, 

12 See FMRA, Pub. L. No. 11 2-95, § 333(b), 126 Stat. II, 72. (2012). 
The Training Facility is situated on private property owned by Georgia Power Company, a 

Southern subsidiary, is surrounded by a secure chain link fence, and remains closed to the public 

at all times. The Training Facility is also greater than five miles from any airport and located in 

class G Airspace. (See Figures 1 and 2, below.) Thus, the Training Facility meets the Class G 

airspace and 5 statute-mile airport-distance requirements that Congress adopted for sUAS 

operations by public safety agencies. 14 

Klondike Training Facility 

lithonia, GA 

Figure I. The Training Facility is greater than 5 miles from any airport. This figure is difficult 

to read, but the distances are as follows: greater than 16 miles from A TL, greater than 7 miles 

from Berry Hill, greater than 16 miles from Covington, and greater than 11 miles from 

Whispering Pines. 

13 Southern Company Services may request COAs for additional locations in the future. 

14 FMRA § 334(c)(2)(C). 
g 

y 

lithonia, GA 

Figure 2. The Training Facility, as shown by the red star, is below ATL Class B airspace, which 

starts at 3,000 feet AGL, far above the altitude of Southern Company Services' proposed 

operations. Class G is from the surface to 1200 feet AGL. Operations below 400 feet AGL will 

be in class G airspace. 

The Training Facility has multiple "training yards" with non-energized poles and wires 

that will be used to train field crew personnel. This infrastructure will serve as the perfect 

training facility for pilots learning to assess pole and line damage. Specific location details of 

the Klondike Training Site are shown in Figure 3 below. 
g 

y 

Training Areas 

• lls-TllOW>Q ..... 1 o.-r~ ..... z 

• ,..Y.,.Tr_ .... . T~S'*On TrJII'IIOgArU I T~ll"'l$:10"1 Tr~...ngAna 1 

Figure 3. Training Facility site in Lithonia, GA. The different colors represent different training 

yards for the Training Facility. There are two Distribution training areas, two Transmission 

training areas, and one pole yard. 
g 

y 

Pole Yard Training Area 

Figure 4. Pole Yard Training Area 

As shown in Figure 4, above, the Training Facility comprises an open area with multiple power 

poles. This section of the Training Facility is known as the Pole Yard Training Area. This area 

would serve as the first training area for the Aeryon SkyRanger. The poles represent vertical 

infrastructure that a pilot must avoid. Flights will not occur over the adjacent parking lot. 

Tabl e 1 L oca f 10n spec1 1c m orma 1on on "fi . £ f th e P oe I Y d T ar rammg · · Area. 

Point GPS Coords Length Segment Length (feet) 

1 33.639582,-84.126115 1-2 136 

2 33.639222,-84.126111 2-3 107 

3 33.639221,-84.125756 3-4 30 

4 33.639096,-84.125749 4-5 189 

5 33.639099,-84.125091 5-6 170 

6 33.639559,-84.125195 6-1 300 
Transmission Training Area 1. This area consists of large de-energized equipment used for 

training. This area will be used for applications training required for transmission line structures. 

Klondike Training Facility 

Transmission Tra ining Area 1 

Figure 5. Transmission Training Area 1 

Tabl e 2 L . fi . :6 ocat10n spec1 1c m ormatiOn on T ransmtsston T rammg Ar e a 1. 

Point GPS Coords Length Segment Length (feet) 

1 33.636143,-84.126646 1-2 273 

2 33.635645,-84.126086 2-3 380 

3 33.635557,-84.124828 3-4 190 

4 33.636121,-84.124814 4-1 577 
Transmission Training Area 2. This includes a test line that contains multiple types of structures 

used for training. This area will be used for applications training required for transmission lines. 

Klondike Training Facility 

Figure 6. Transmission Training Area 2 

Tabl e 3 L oca f ton spect tc m orma ton on . fi . fi t T ransmtsston T ramtng_ Ar e a 2. 

Point GPS Coords Length Segment Length (feet) 

1 33.635235,-84.122652 1-2 213 

2 33.634857,-84.122548 2-3 1,083 

3 33.636529,-84.120837 3-4 400 

4 33.637013,-84.121665 4-5 394 

5 33.636047,-84.121789 5-1 424 
Training Area 1. This is a distribution test line that contains multiple, installed pieces of 

distribution equipment. This area will allow a pilot to perform visual inspection on specific 

distribution equipment. 

Klondike Training Facility 

Distribut ion Training Area 1 

Figure 7. Distribution Training Area 1 

Tabl 4 L f "fi . £ e oca ton spect tc m orma f ton on D. IS t n u ·b r ton T rammg Ar e a 1. 

Point GPS Coords Length Segment Length (feet) 

1 33.637941,-84.129277 1-2 550 

2 33.636295,-84.129449 2-3 623 

3 33.636328,-84.127293 3-4 497 

4 33.637757,-84.127266 4-5 540 
Training Area 2. This test line crosses back and forth to represent a long distribution line. This 

area will be used for applications training required for distribution lines. 

Klond ike Training Facility 

Distribution Training Area 2 

Figure 8. Distribution Training Area 2 

Tabl 5 L f . fi . :6 e oca ton spect tc m ormation on D. ·b · T tstn utton rammg Ar e a2. 

Point GPS Coords Length Segment Length (feet) 

1 33.641214,-84.125662 1-2 475 

2 33.639955,-84.125512 2-3 650 

3 33.640008,-84.123183 3-4 1,293 

4 33.643322,-84.121875 4-5 640 

5 33.643465,-84. 124192 5-6 777 

6 33.641607,-84.124739 6-1 250 
As set forth in section 334(c) of the FMRA and shown above, the Training Facility's 

location meets the same statutory requirements that Congress adopted for sUAS operations to be 

conducted by public safety agencies. Specifically, it is within Class G airspace and outside of 5 

statute miles from any airport. 15 

Further, as shown above, safe sUAS demonstrations can be coordinated at the Training 

Facility to research the use of sUAS for different applications within the power generation and 

transmission industry. 

2. Flight Conditions 

In addition to operations within a limited geographic location only, Southern Company 

Services proposes sUAS operations under the conditions described below. These conditions will 

ensure that such operations will not adversely affect safety in the NAS and will provide a level of 

safety at least equal to that provided by each rule from which Petitioner seeks an exemption: 

(1) The sUAS will weigh less than 10 lbs. 

(2) All flights will be operated within visual line of sight of the PIC and at least one 

observer. 

(3) Flights will be operated within the Training Facility boundaries, as described in 

section III.C.1 . Additional COAs will be requested for any training and research 

and development operations outside of the Training Facility. 

(4) All flights will be operated at an altitude of 400 feet or less AGL and in Class G 

atrspace. 

(5) The sUAS will not be operated above 50 knots. 

(6) All flights will be operated during daylight hours. 

(7) All flights will be operated at least 5 miles away from any non-private airport. 
interstates, or other public transportation rights of way unless traffic is restricted. 

(9) The minimum crew for each flight will consist of the sUAS pilot and a visual 

observer. 

(1 0) A safety briefing will be conducted before each flight, and it will identify adverse 

weather, the proposed flight path, the boundaries of the flight area, and any 

relevant hazards to the flight. 

( 11) The operator will obtain the consent of all persons involved in the research and 

ensure that only consenting persons will be allowed within 100 feet of the flight 

operation. 

(12) The visual observer and the pilot will at all times be able to communicate by 

voice and/or radio. 

(13) The maximum total flight time for each flight will only be 40 minutes or at such 

time as the sUAS reaches 20% battery power reserve, whichever is shorter. 

(14) Southern Company Services will not perform sUAS services for any 

organizations other than Southern and its operating subsidiaries. 

Southern Company Services notes that the FAA has found that safety factors permit 

sUAS flights by operators when the mandatory operating conditions specified above were 

present. 16 

IV. Regulations from which Exemption is Requested 

Petitioner requests an exemption from relevant provisions governing aircraft operations 

within Title 14 of the Code of Federal Regulations in order to conduct research on the 

applicability of sUAS when assessing damage to power lines due to storm events and conducting 

routine power line inspection. Exemptions are requested from provisions within Parts 21, 45, 47, 

49, 61 and 91 ofTitle 14. Petitioner addresses each relevant regulation below and provides a 

16 See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 

(July 30, 2013). 
safety that is either equal to, or greater than, the level of safety provided by the regulation from 

which an exemption is requested. In this regard, Southern Company Services meets the 

requirements at Part 11 for exemptions, and, as set forth at section V., below, granting these 

exemptions are in the public interest as required under 49 U.S.C. section 44701(f). 

14 C.F.R. Part 21 (Aircraft Certification). 

14 C.F.R. Part 21, Subpart H sets forth requirements for airworthiness certificates as 

required by 14 C.F.R. § 91.203(a)(1). As explained above at section liLA, the SkyRanger's 

airworthiness has been proven. Further, given the size of the aircraft, relatively low speed for 

operation, proposed limited location for flights in the Training Facility, and the previous COAs 

issued, an exemption from Subpart H meets the equivalent level of safety under section 333 of 

the FMRA and 14 C.F.R. Part 11, especially in light of the restrictive conditions proposed in this 

petition. The operations proposed in this petition will be as safe as, if not more safe than, 

operations involving manned aircraft or rotorcraft operating with an airworthiness certificate and 

without the restrictions that Petitioner has proposed in this petition. 

14 C.F.R. Part 45, subpart C and 14 C.F.R. 91.9 (Aircraft Marking). 

Section 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. 

Section 91.9(c) provides: 
is identified in accordance with part 45 of this chapter. 

The SkyRanger has no cabin, cockpit or pilot station, and, therefore, no entrance to any 

of these areas, on which the markings can be placed. Given the size of the sUAS, two-inch 

lettering will be impossible. The SkyRanger is currently marked with a fixed label stating 

"Aeryon Labs SkyRanger" that measures 1.5" x 0.5'', as well as a serial number located under 

the removable camera payload. Southern Company Services is prepared to mark the sUAS with 

its name and location (or origin) and fulfill any other request by the FAA concerning this issue in 

accordance with section 45.29(f) where the pilot, observer, and others working with the sUAS 

will see its identification. 

The FAA has previously issued exemptions to this regulation. 17 

14 C.F.R. Part 47 (Aircraft Registration) and Part 49 (Recordation of Aircraft Title and 

Security Documents). 

14 C.F.R. Part 47 sets forth various aircraft registration requirements. For example, 

section 47.3(b) states that no person may operate an aircraft eligible for registration unless the 

aircraft has been registered by its owner. 14 C.F .R. Part 49 requires recordation of any 

conveyances affecting title to, or interest in, aircraft. 

Petitioner seeks an exemption from the registration requirements at Part 47 and the title 

recordation requirements of Part 49 on the grounds that the Aeryon Sky Ranger will only be 

operated within the confines of the Training Facility and pursuant to the conditions proposed in 

this petition. Due to the limited nature of the flights proposed hereunder, registration and 

recordation of title and any security interests are not necessary to achieve an equivalent level of 

safety. 

14 C.F.R. § 61.3(d) (Requirement of Certificate for Flight Instruction). 

This regulation generally states that only those holding a flight instructor certificate 

issued under the FAA's regulations can give training required to qualify a person for solo flights. 

Aside from general training on the fundamentals of instruction, a person that possesses a flight 

instructor certificate is not especially qualified to provide the limited training on small unmanned 

17 See, e.g., Exemption Nos. 8738, 10167, 10 167Aand 10700. 
qualify for the certificate, a person must demonstrate an ability to instruct a person to fly a 

manned aircraft. 18 The training needed to operate the SkyRanger, however, is less rigorous than 

that required for manned aircraft; because of the SkyRanger's automation, the skills necessary to 

safely operate a manned aircraft are unnecessary for operating the SkyRanger. Second, the 

training necessary to conduct the proposed sUAS operations would be given to private pilots 

who already possess adequate aeronautical knowledge to operate sUAS. Third, qualified 

instructors will provide only the highest level of flight instruction. This level of training is 

equivalent to that required under the instruction certification requirements at 14 C.F .R. § 61.3( d). 

An exemption from that provision is thus appropriate. 

14 C.F.R. § 61.31(d)(2) (Aircraft category, class, and type ratings). 

This provision requires the pilot in command of an aircraft to possess an appropriate 

category and class rating for the aircraft. In other words, it limits pilots to the aircraft types and 

operations for which they are licensed (e.g., airplane single engine land; instrument airplane). 

sUAS, however, are dissimilar from other categories and classes of aircraft for which pilots are 

rated. Indeed, the FAA does not issue licenses for pilots to fly sUAS. Thus, the existing category 

and class limitations do not apply to sUAS operations and exempting the SkyRanger pilots from 

the category and class requirement at section 61 .31 ( d)(2) would not adversely impact safety. 

Moreover, the special training that the pilots will obtain under Petitioner's proposed operation, as 

explained below regarding section 61 .113, will be rigorous, thorough, and more than sufficient to 

reach a level of safety that is equivalent to that achieved pursuant to section 61.31 ( d)(2) for 

manned aircraft, especially given the restrictive conditions for operations proposed hereunder 

and the limited geographic location for such flights in the Training Facility only. It is on these 

grounds that Petitioner respectfully requests an exemption from this provision. 

14 C.F.R. § 61.113(a) & (b) (Private Pilot Restrictions on Compensation). 

Section 61.113(a) and (b) prohibit private pilots from operating an aircraft for 

compensation or hir~, with a few exceptions. To avoid this prohibition, a person must possess a 

commercial pilot certificate, which requires additional aeronautical knowledge and airmanship 

competency.19 This additional competency is unnecessary, however, to operate the SkyRanger 

18 See, e.g., 14 C.F.R. § 61.187(b)(l )(iv) (requiring proficiency in providing a preflight lesson a maneuver "to be perfonned in 

flight"); 14 C.F.R. § 61.195(g) ("a flight instructor must perform all training from in an aircraft that meets the following 

requirements . . . . ")(emphasis added). 

19 14 C.F.R. §61.133(a). 
will obtain.20 Moreover, 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. Commercial pilot certification is also unnecessary because of the characteristics of the 

SkyRanger and the location for the proposed operations. 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 and geographic location proposed in 

this petition. 

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 ifuser-configurable 

limits are reached. 

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

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

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

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 

20 See In re Astraeus Aerial, F AA-20 14-0352, slip op. at 15-18 (Sept 25, 20 14) (granting an exemption from 14 C.F.R. 

§§61.113( a)&(b) for sUAS operations because private pilot aeronautical knowledge is sufficient and the additional airmanship 

skills of a commercial pilot do not necessarily provide an advantage in limited sUAS operations). 
system and environmental conditions are automatically handled by the system 

• Battery communication: Battery minutes and flight time are displayed at all times. 

The system will return home and land automatically ifuser-configurable limits 

are reached. 

Additional automated safety functions and safety enhancing features of the SkyRanger 

include the following: 

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

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

home, land and replace the battery 

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

emergency high speed descent landing. 

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

pre-defined Non-Fatal Condition Response. 

Given Petitioner's proposed conditions and restrictions, and given the SkyRanger's safety 

features, an equivalent level of safety will be attained by allowing operation of the SkyRanger 

with a private pilot's certificate, not a commercial pilot's certificate, under the conditions set 

forth herein. 

The risks associated with the operation of the Sky Ranger (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 ofthe 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). 

14 C.F.R. § 91.7(a) (Airworthiness Requirement). 

This regulation states that no person may operate a civil aircraft unless it is in an 

airworthy condition. As explained above at section liLA, the SkyRanger's airworthiness has 

been proven. Further, given the size of the aircraft, proposed limited location for operations, and 
conditions proposed in this petition. 

14 C.F.R. § 91.9(b)(2) (Flight Manual on Aircraft). 

This 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. Nor is there any pilot on board. The equivalent level of safety 

will be achieved by keeping the flight manual at the ground control point where the pilot flying 

the sUAS will have immediate access to it. As mentioned above, the SkyRanger User Guide, or 

aircraft manual, will be provided under separate cover with a request for confidential treatment 

as soon as possible. The FAA has issued to others the following exemptions to this regulation: 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, and 

10700. 

14 C.F.R. § 91.105 (Crewmembers at Stations; Seatbelts). 

Section 91.105 requires flight crew members to be at their stations with seatbelts fastened 

during landing and takeoff. The proposed operations do not involve flight crew members aboard 

the aircraft. An exemption from this provision is appropriate under the conditions proposed in this petition. 

14 C.F.R. § 91.109 (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 
an AutoGrid into the auto pilot before or during flight. Only in unusual circumstances will the 

pilot input control functions to alter the pre-programmed flight. Since instruction and training 

will be accomplished through a training program, an equivalent level of safety will be assured. 

Moreover, the instructor can easily assume control of the flight during training and instruction. 

The FAA has approved exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. (See Exemption Nos. 

5778K and 9862A.) The equivalent level of safety will be achieved by the manufacturer 

providing the training and through the use of experienced and qualified pilots familiar with the 

Sky Ranger. 

14 C.F.R. § 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. Nor 

will flights occur outside the designated geographic locations. Thus, there will be no flights near 

persons, vehicles or vessels. Rather, flights will be conducted outside of congested or populated 

areas. However, because aerial survey and inspection work must be accomplished at relatively 

low altitudes and at altitudes less than 500 feet AGL and within 500 feet of structures, an 

exemption from Section 91 .119(c) is needed. 

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

with which the SkyRanger is built. It is also achieved through operations in the Training 

Facility, which is a very limited geographic area as described at Section III.C.1, above. 

Compared to current aerial survey operations conducted with aircraft or rotorcraft weighing far 

more than 6 lbs. and carrying flammable fuel, which are currently allowed at or below 500 feet 

AGL and within 500 feet of structures, the proposed SkyRanger operations will be far safer. 

Indeed, the low-altitude operations of the sUAS in the restricted geographic location will 

maintain separation between these sUAS operations and the operations of conventional aircraft 

that must comply with Section 91.119. 

14 C.F.R. § 91.121 (Altimeter Settings). 

14 C.F .R. § 91.121 requires persons operating aircraft to maintain certain cruising 

altitudes or flight levels by reference to an altimeter that is set "to the elevation of the departure 
exemption to this provision on the grounds that an equivalent level of safety, or greater, will be 

achieved by the Aeryon SkyRanger's use of a GPS system. The PIC will rely on the 

SkyRanger's GPS system in order to monitor the sUAS's altitude, thereby achieving an 

equivalent level of safety. 

14 C.F.R. § 91.151 (Fuel Requirements). 

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

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

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

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

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

an exemption from § 14 C.F .R. 91.151, the 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. 

An exemption from 14 C.F .R. § 91 .151 (a) would still result in safe operations and falls 

within the scope of a similar, prior exemption. 21 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, and given the limited geographic location 

for operations proposed in this petition. 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 and require a greater length of time to accrue data and information from the research 

to be conducted. In the unlikely event that the SkyRanger should run out of fuel, it would simply 

land within the Training Facility. Given its weight and construction material, the risks are less 

than contemplated by the current regulation and an equivalent, if not greater, level of safety 

would be achieved under the conditions proposed in this petition. 

An equivalent level of safety can be achieved by maintaining 10 minutes of reserve 

battery power, which would allow 40 minutes of flight time. The 10 minutes' worth of reserve 

battery power would be more than adequate to return the sUAS to its planned landing zone from 

anywhere in the Training Facility. 

21 See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.1 5l(a)). 
10673 and 10808. 

14 C.F.R. § 91.203(a) and (b) (Display of Certificates). 

Sections 91.203(a) and (b)requires all civil aircraft to have within them airworthiness and 

registration certificates, which are displayed at the cabin or cockpit entrance. These 

requirements were designed for manned aircraft which have a cabin and cockpit. Given the size, 

of the SkyRanger and its lack of a cabin or cockpit, airworthiness and registration certificates 

cannot be contained in and displayed in the SkyRanger in accordance with section 91.203. 

Moreover, operation of the SkyRanger will be conducted pursuant to an exemption to the 

airworthiness and registration requirements. For these reasons, compliance with Sections 

91.203(a) and (b) are unnecessary. 

14 C.F.R. § 91.213 (Inoperative Instruments and Equipment). 

This regulation prohibits taking off in an aircraft with inoperative instruments and 

equipment unless certain conditions are met. The SkyRanger operations proposed herein will be 

subject to restrictive conditions, occur within a restrictive area, and require extensive pre-flight 

checks and inspections. These conditions and requirements achieve the same, if not a greater, 

level of safety required under section 91.213. 

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

(Maintenance Inspections and Placarding). 

These regulations set forth various maintenance and inspection requirements and 

reference 14 C.F.R. Part 43. For example, 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 19.405(d) requires placards to be 

installed when discrepancies include inoperative instruments or equipment. 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 airworthiness 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. Pre-flight checks which cannot be performed by 
as part of the Maintenance Schedule in the User Guide. 

The pre-flight checklist includes: 

1. Visual inspection of the airframe 

2. Visual inspection of rotor integrity 

3. Checking the 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 the Training Facility and is not a complex 

mechanical device. As provided in the Aeryon User Guide (System Maintenance section), the 

SkyRanger operator will ensure that the sUAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance that is performed. Moreover, 

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

in an airworthy condition and to ensure an equivalent level of safety. 

The SkyRanger's Maintenance guidelines ensure a level of safety equivalent to these 

maintenance and inspection requirements in Part 91. In addition, any component failure 

detectable by the system will be reported to the control station and will cause the sUAS to 

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

depending on the type of failure. 

V. Granting Southern Company Services' Petition is in the Public Interest 

Southern Company Services' proposed sUAS operations will accord significant benefits 

to the public, Southern Company customers, its employees, and to the industry. Through its 

proposed research and development operations, Petitioner will generate best practices that can be 

applied across the industry and throughout the United States. Southern Company Services' 

operations will help devise ways to restore power for consumers more quickly after storm events. 

The best practices developed from Petitioner's research will result in lower restoration and 

maintenance costs and help provide safer, more affordable and more reliable power to all 

consumers in the United States. Petitioner is willing to share information gathered from its 

research and development efforts with others for this purpose, including the FAA. 
reduce risk. Traditional inspections are conducted with helicopters and bucket trucks. 

Helicopters are noisy, consume expensive energy resources in the form of fuel and can be 

dangerous in that there is a risk of accidents which can result in significant damages to property 

as well as injuries and fatalities for the crew. Bucket trucks are large, invasive and not always 

helpful in attaining hard-to-reach areas, and, thus, can be dangerous for inspection crews as well. 

In contrast, Petitioner's proposed operations would involve sUAS weighing less than 10 

pounds, operated at a very low altitude-i.e. under 400 feet AGL-and at relatively low speeds. 

Petitioner's proposed operations do not involve the carriage of passengers or crew, and, thus, 

avoid risks involved with manned aircraft flights. Moreover, since Petitioner's sUAS will 

operate on battery power, the carriage and consumption of flammable fuels will not occur. Nor 

will fuel emissions. Petitioner's proposed operations will be significantly safer and more 

efficient than helicopters and bucket trucks. 

Petitioner's proposed sUAS operations also fulfill Congress' objective in adopting 

section 333 ofthe FMRA, and FAA's policy, to expedite the integration ofsUAS into the NAS 

and allow such operations where the FAA can determine that they will be accomplished without 

endangering others using the NAS or posing a risk to national security. As set forth above, 

Southern Company Services' operations will be conducted in accordance with strict conditions 

that ensure safety of the NAS and pose no threat to national security whatsoever. 

VI. Privacy 

Petitioner's proposed sUAS operations do not implicate any privacy concerns. All 

proposed sUAS training flights will be confined to the Training Facility, which is located on 

private property owned by Georgia Power Company, a Southern Company operating subsidiary. 

As shown in section III. C, above, the Training Facility is located far from residential areas and 

business centers. Moreover, the public is restricted from accessing the Training Facility. To the 

extent that Petitioner would seek additional CO As for training and research and development 

flights outside the Training Facility, the geographic area would be limited and public access will 

be restricted, thereby eliminating privacy concerns. In addition, Petitioner will remain in 

compliance with all applicable local, state and federal privacy laws. 
Pursuant to 14 C.F.R. Part 11, Petitioner provides the following Federal Register notice 

in the event that the FAA determines that publication of such a notice will be required: 

Southern Company, through its subsidiary, Southern Company Services, 

Inc. (Southern Company Services) has filed a petition with the Federal 

Aviation Administration requesting an exemption from the following 

provisions in connection with operating a small unmanned aircraft system 

(sUAS) weighing 6 pounds: 14 CFR Part 21; 14 CFR Part 45, subpart C; 

14 CFR Part 47; 14 CFR Part 49; 14 CFR § 61.3(d); 14 CFR § 

61.31(d)(2); 14 CFR § 61.113(a), (b); 14 CFR § 91.7(a); 14 CFR § 

91.9(b)(2);4 14 CFR § 91.105; 14 CFR § 91.109; 14 CFR § 91.119; 14 

CFR § 91.121; 14 CFR § 91.151; 14 CFR § 91.203(a), (b); 14 CFR § 

91.213; 14 CFR § 91.405(a), (d); 14 CFR § 91.407(a)(1); 14 CFR § 

91.409; and 14 CFR § 91.417(a), (b). 

Southern Company Services' proposed sUAS operations will occur less 

than 400 feet above ground level, over five miles from any airport, and in 

areas where public access will be restricted. The purpose of the operations 

is to conduct research on the use of sUAS when inspecting power lines for 

damage, especially after storm events. Southern Company Services 

requests that its sUAS operations be subject to the conditions and safety 

standards that are as set forth in its petition in order to ensure a level of 

safety that is equivalent to, or higher than, the level attained through 

regulations listed above. 

VIII. Summary 

In accordance with the factors to be considered under section 333 ofthe FMRA, 

Petitioner's proposed operations will not endanger others using the NAS or pose a threat to 

national security. The SkyRanger's size and weight are quite small at only 6 pounds, and its 

speed is relatively low at 50 knots. The SkyRanger's operational capabilities are quite 

sophisticated with numerous safeguards. Since it is currently widely used under public 

Certificates of Authorization, the SkyRanger's airworthiness has been proven. At all times, the 

flights will be operated within the pilot's and the visual observer's lines of sight. Flights will 

also occur in a remote area far from any airport and populated areas. Since equivalent levels of 
the regulatory provisions discussed above are appropriate. 

IX. Request for Relief 

Based on the foregoing, Petitioner hereby requests an exemption from the provisions 

discussed herein and such further relief that the Department deems appropriate for the operations 

proposed herein. 

Attachment 

cc: James Williams 

Robert Pappas 

Respectfully submitted, 

G. Brent Connor 

Jason D. Tutrone 

Thompson Hine LLP 

Counsel for Southern Company Services, Inc. 
Aeryon Corporate Overview: Aeryon Labs, Inc. is a Canadian company located in Waterloo 

Ontario. Aeryon is focused on providing micro unmanned aerial systems 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 CO As 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 of 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). 

THOMPSON HINE LLP 

ATTORNEYS AT lAw 

1919 M Street, N.W. 

Suite 700 

Washington, D.C. 20036-3537 

www. ThompsonHine.com 

Phone: 202.331.8800 

Fax: 202.331.8330 

276208.4 
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. 

The Aeryon SkyRanger includes many advanced safety features that make the SkyRanger the 

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

allows the SkyRanger to detect a system fault while in the air, and to automatically fly back to its 

take-offlocation and land. Faults that can be detected include: loss 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 Operating Manual - System user manual available upon request. 

Physical Characteristics 

Measurements - 40" diameter deployed, 20x 1 0" folded 

Weight (without payload) - 2.4kg (5.3 lbs.) 
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 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) 
its life. The only components that experience routine wear are rotors, batteries, motors, and legs. 

Battery and motor conditions are monitored by the system with deviations reported to the 

operator. 

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

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

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

characteristics will be detected by on-board sensors. 

The 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 U A V 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 • U AS Heading • North Seeking Arrow • Range to Target 

• Calculated target position 
• 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. 

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 
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 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.