Sofia Information Technology Consulting, Inc. 120 E. Logarto Cir. Ste. D-114, Tampa, FL 33612

www.sofiaitc.com 813-321-5154 Page 1

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Sofia Information Technology Consulting, Inc.

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 45.27(a); 61.113 (a) & (b); 91.7(a); 91.105 (a) & (b); 91.119 

(c); 91.121; 91.151(a); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT 

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on February 11, 2016 

Sofia Information Technology Consulting, Inc.

120 E. Logarto Cir. Ste. D-114

Tampa, FL 33612

info@sofiaitc.com

Mr. James A. Quilty

CEO

Sofia Information Technology Consulting, Inc.

120 E. Logarto Cir. Ste. D-114

Tampa, FL 33612

www.sofiaitc.com

quiltyja@sofiaitc.com
2

Table of Contents

GLOSSARY OF ABBREVIATIONS........................................................................................................4

EXECUTIVE SUMMARY ........................................................................................................................5

INTRODUCTION AND INTERESTS OF THE PETITIONER............................................................5

BACKGROUND .........................................................................................................................................6

COMMERCIAL (MISSION, OPERATION) PURPOSE: .....................................................................7

Regulations from which the Exemption Relief is requested:................................................................7

BASIS FOR PETITION.............................................................................................................................7

1. SOFIAITC Seeks Exemption From The Requirements Of Section 45.27(a).....................................9

2. SOFIAITC Seeks Exemption From The Requirements Of Section 61.113(a) And (b). ...................9

3. SOFIAITC Seeks Exemption From The Requirements Of Section 91.7(a).....................................10

4. SOFIAITC Seeks Exemption From The Requirements Of Section 91.105(a) And (b). .................10

5. SOFIAITC Seeks Exemption From The Requirements Of Section 91.121. ....................................10

6. SOFIAITC Seeks Exemption From The Requirements Of Section 91.151(b). ...............................10

7. SOFIAITC Seeks Exemption From The Requirement Of Section 91.405(a). .................................11

8. SOFIAITC Seeks Exemption From The Requirements Of Section 91.407(a)(1)............................11

9. SOFIAITC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

....................................................................................................................................................................11

10. SOFIAITC Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b)....11

14 C.F.R. § 45.27(a): Location of marks; nonfixed-wing aircraft; Rotorcraft;...................................12

14 C.F.R. § 61.113(a) & (b): Private Pilot Privileges and Limitations; Pilot in Command;..............13

14 C.F.R. § 91.7(a): Civil aircraft airworthiness....................................................................................14

14 C.F.R. § 91.105(a) and (b): Flight crewmembers at stations............................................................14

14 C.F.R. §91.121 Altimeter Settings ..............................................................................................15

14 C.F.R. § 91.151(a) & (b): Fuel Requirements for Flight in VFR Conditions .........................15

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance Inspections 16

1. The Public Will Benefit From Decreased Congestion Of The NAS. ................................................17

2. The Public Will Benefit From The Safety And Efficiency Of The RDASS Spyder HD Edition, 

RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS.....17

3. Performing Aerial Video and Photography Operations With The RDASS Spyder HD Edition, 

RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS Will 

Benefit The Economy................................................................................................................................17

4. There Are No Privacy Issues................................................................................................................18
3

1. Reasons Why The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, 

Yuneec Tornado H920, and Roboflight RF70 UAS Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333. ............................................................18

a. The Specifications Of The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 

4K, Yuneec Tornado H920, and Roboflight RF70 UAS Demonstrate Its Safe Characteristics. .......19

i. Technical Specifications Of The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon 

Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS..............................................................19

ii. The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado 

H920, and Roboflight RF70 UAS Global Positioning Modes Enable The UAS To Remain Within A 

Defined Operational Area. .......................................................................................................................19

iii. The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado 

H920, and Roboflight RF70 UAS Are Designed For Automatic Return To Home Point Or Hover In 

The Event Of Loss Of The Control Link Or Navigation.......................................................................20

iv. The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado 

H920, and Roboflight RF70 GCS And Its Operation. ...........................................................................20

b. Flight Operations Of RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, 

Yuneec Tornado H920, and Roboflight RF70 UAS Is Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer......................................................................20

c. Flights Of RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS Will Be Conducted Pursuant To Specific Operating 

Limitations.................................................................................................................................................20

1. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety. ...........................................................................................................................24

2. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely 

Affect Safety. .............................................................................................................................................25

3. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely 

Affect Safety. .............................................................................................................................................25

4. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely 

Affect Safety. .............................................................................................................................................26

CONCLUSION .........................................................................................................................................29
4

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

WGCS Wireless and/or Ground Control System
5

EXECUTIVE SUMMARY

Sofia Information Technology Consulting, Inc., dba. SOFIAITC hereafter referred to as SOFIAITC seeks 

exemption from the requirements of 14 C.F.R §§ 45.27(a), 61.113(a) & (b), 91.7(a), 91.105(a) & (b), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an 

Unmanned Aircraft System (RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, 

Yuneec Tornado H920, and Roboflight RF70) pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit SOFIAITC to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video and photography of construction 

sites, residential and commercial real estate, civil landscapes and events as a service to the public/business 

interests, assist Law Enforcement and/or Military in Search & Rescue and Emergency Services in 

coordination with local authorities over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

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, Sofia Information Technology Consulting, Inc., dba. (“SofiaITC”) Operator of Small 

Unmanned Aircraft Systems (UAS’s) equipped to offer on-demand commercial UAS operations for a 

host of industries and applications and to perform the purposes listed below, hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

sUAVs/UAS, so long as such operations are conducted within and under the conditions outlined herein or 

as may be established by the FAA in an exemption granted under either Section 333 or Section 49 U.S.C. 

§44701(f) 

As described more fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety 

enhancements in the fields in which it will operate, which now depend upon conventional aircraft or 

humans climbing high on dangerous structures, walking in insect laden swamps, and working adjacent to 

treacherous infrastructure. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements for 

the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform

Act. This exemption will permit SofiaITC to operate an Unmanned Aircraft System (UAS) for the 

commercial and government purposes of conducting aerial video and photography of construction sites, 

residential and commercial real estate, civil landscapes and events as a service to the public/business 

interests, assist Law Enforcement and/or Military in Search & Rescue and Emergency Services in 

coordination with local authorities over certain areas of the United States.

The objective of The SOFIAITC and our Unmanned Aircraft System aerial operations is to provide a 

more affordable, high-quality production system for a variety of governmental, commercial, public, and 

residential uses, specifically targeting

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Economic development

• Civic landmarks

• Civil disasters
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• Border/Coastal Patrol

• Special event coverage

• Law Enforcement and other protection industries

• Military

• Search & Rescue and Emergency Services

• Private and governmental training 

BACKGROUND

SOFIAITC seeks an exemption to operate the following UAS’s for compensation or hire within the NAS:

Description of Type, Make and Models of sUAV/UAS Requested:

The petitioner is seeking an exemption to commercially operate sUAVs makes and models as follows: 

1. RDASS Spyder HD Edition: The Rapidly Deployable Aerial Surveillance System (RDASS) 

Spyder Hi-Definition (HD) Edition is vertical takeoff and landing (VTOL) Unmanned Aircraft 

(UA) using GPS with a Ground Control Station (GCS) encryption system redundant at 900 MHz 

and 2.4 GHz. The RDASS Spyder HD Edition is deployable in less than three (3) minutes with a 

flight time of 20mins per battery usage; a range of one (1+) plus mile; payload maximum of 

1.5lbs; encrypted video feed; patented autopilot and fully autonomous for manual or automatic 

programmable flights. Critical Safety features include: “Return to Home” and “Intelligent 

Orientation” programs; is Extreme Weather Ready, patented engine management system. Stable 

in winds up to 35mph. Elevations up to 12,000ft. MSL with no loss of lift.

2. RDASS Q1000: The RDASS Q1000 is vertical takeoff and landing (VTOL) Unmanned Aircraft 

(UA) using GPS with a Wireless and/or Ground Control Station (WGCS) encryption system 

redundant at 900 MHz and 2.4 GHz. The RDASS Q1000 is deployable in less than three (3) 

minutes with a flight time of 20mins per battery usage; a range of one (1+) plus mile; payload 

maximum of 1.5lbs; encrypted video feed; patented autopilot and fully autonomous for manual or 

automatic programmable flights. Critical Safety features include: “Return to Home” and 

“Intelligent Orientation” programs; is Extreme Weather Ready, patented engine management 

system. Stable in winds up to 35mph. Elevations up to 12,000ft. WGS with no loss of lift.

3. Yuneec Typhoon Q500 4K: The Yuneec Typhoon Q500 4K is vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) system at 2.4 GHz using 

Android application. The Yuneec Typhoon Q500 has a flight time of 25mins per battery usage; a 

control Transmission Distance/Range of FCC Compliance up to 800M (2624.67ft.) / CE 

Compliance up to 200M (1312.34ft.); adjustable Maximum Flying Altitude of 200ft.

4. Yuneec Tornado H920: The Yuneec Typhoon Q500 is vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a Ground Control Station (GCS) system at 2.4 GHz using Android 

application. The Yuneec Typhoon Q500 has a flight time of 25mins per battery usage; a control 

Transmission Distance/Range of FCC Compliance up to 800M (2624.67ft.) / CE Compliance up 

to 200M (1312.34ft.); adjustable Maximum Flying Altitude of 13,000ft.

5. Roboflight RF70: 

Each UAV/UAS separately weighs 55 lbs. or less, with imaging payload and applicable equipment.

The RDASS Spyder HD Edition, RDASS Q1000, HSE Yuneec Tornado H920, Yuneec Typhoon Q500

and Roboflight RF70 that will be operated by SOFIAITC will be registered in accordance with 49 U.S.C. 

44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration Marking.
7

COMMERCIAL (MISSION, OPERATION) PURPOSE:

This exemption request, once granted would allow the petitioner to operate a small unmanned aerial 

vehicle (sUAV), unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack inspection, 

utility-power generation system inspections and patrolling, aerial inspection, photography and 

videography of residential and commercial real estate, weddings, aerial inspection, photography and 

videography of utility infrastructure including but not limited to electrical power lines, wind turbines and 

cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision 

agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial 

surveying, construction site inspection and monitoring, public entity support operations, Aerial imaging 

for safety, monitoring and comparing work efforts and completion percentages, and security of controlled 

environment of various sites, aerial video and live video feed to assist with search and rescue operations 

under the authority and support of local authority officials, aerial video and photography for public and 

private use including television, public events, and cinematography live feed and live newsgathering, 

training to persons individually or belonging to both private and public organizations to increase 

awareness and improve safety for current and future UAS operations within the NAS, special events: 

including high schools, colleges, professional sports, open air events and fairs, research, risk management 

and assessment, motion picture production1, surface mining, closed set filming2, disaster and catastrophe 

events.

Regulations from which the Exemption Relief is requested:

14 C.F.R. § 45.27(a)

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. § 91.105

14 C.F.R. § 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a)

14 C.F.R. § 91.405 (a)

14 C.F.R. § 91.407 (a) (1)

14 C.F.R. § 91.409 (a) (2)

14 C.F.R. § 91.417 (a) & (b)

BASIS FOR PETITION

Petitioner, SOFIAITC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) 

and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the RDASS 

Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight 

RF70, UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 

C.F.R §§ 45.27(a), 61.113(a)&(b), 91.7(a), 91.105(a)&(b), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated with the unmanned 

aircraft and its operation, SOFIAITC operation of RDASS Spyder HD Edition, RDASS Q1000, Yuneec 

 

1 Motion	Picture	and	Television	Flight	Operations	Manual	is	herein	attached	as	Appendix	G.

2 Motion	Picture	and	Television	Flight	Operations	Manual	for	closed	set	filming	is	herein	

attached	as	Appendix	G.
8

Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS meets the conditions of FMRA 

Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. 

Accordingly, SOFIAITC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with 

an airworthiness certificate. 

SOFIAITC submits that the requested relief is proper since an equivalent level of safety will be ensured. 

SOFIAITC will use experienced personnel or technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the 

operating documents (i.e., Monthly Maintenance Log, and RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 Instruction Manual). 

Furthermore, SOFIAITC will document and maintain all maintenance records for the RDASS Spyder HD 

Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS. 

SofiaITC seeks relief from Section 45.27(a), entitled Location of marks; nonfixed-wing aircraft; 

Rotorcraft, as the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS will not exceed the 200 AGL; thus not requiring any location 

“identifying” markers.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and 

limitations: Pilot in command, is requested by SOFIAITC to the extent necessary to allow a Pilot in 

Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, that 

the PIC is able to safely operate the DJI Phantom UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

SOFIAITC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the RDASS 

Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight 

RF70 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

As such, SOFIAITC submits that they will ensure that the RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS is in an airworthy 

condition, prior to every flight, by determining that the UAS are in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and RDASS Spyder HD Edition, RDASS Q1000, Yuneec 

Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 Instruction Manual), and that the 

aircraft are in a condition for safe flight. 

SofiaITC seeks relief from Section 91.105(a) and (b), entitled Flight crewmembers at stations, as the 

RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and 

Roboflight RF70 are unmanned sUAS, weighing less than 55 pounds with payload, for on-demand 

service to a host of industries and applications including: Flare stack inspections, utility-power generation 

system inspections and patrolling, pipeline inspection and patrolling, filmmaking, cinematography, 

videography, precision agriculture, wildlife and forestry monitoring, aerial surveying, construction site 

inspection and monitoring, and public entity support operations.

SOFIAITC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, 

as the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, 

and Roboflight RF70 UAS will not have a typical barometric altimeter onboard. However, altitude 
9

information of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the 

GCS for active monitoring of the flight path. This altitude information, combined with SOFIAITC’s 

operation of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS within visual line of sight, at or below 200 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. 

Additionally, SOFIAITC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. SOFIAITC submits that safety will not be affected by 

operation of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS during daylight hours in visual meteorological conditions 

(VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of 

approximately 25 minutes. Battery power indicators are also able to show exactly how much battery 

power is left, as well as how much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, SOFIAITC provides the following information in support of its 

petition for exemption:

A. Name and Address of the Petitioner.

The name and address of the Petitioner and point of contact is:

James Quilty

CEO

Sofia Information Technology Consulting Inc, dba. SOFIAITC

120 E. Logarto Cir. Ste. D-114

Tampa, FL 33612

(813) 321-5154 Office

(877) 754-0449 Fax

quiltyja@sofiaitc.com

B. The Specific Sections Of 14 C.F.R. From Which SOFIAITC Seeks Exemption. 

1. SOFIAITC Seeks Exemption From The Requirements Of Section 45.27(a). 

Section 61.113, entitled Locatio of marks; nonfixed-wing aircraft: Rotocraft, subsections (a) 

prescribe the following, in relevant part: 

(a) Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces

of the cabin, fuselage, boom, or tail the marks required by § 45.23.

2. SOFIAITC Seeks Exemption From The Requirements Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) 

and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an 

aircraft that is carrying passengers or property for compensation or hire; nor may that person, 

for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with 

any business or employment if—
10

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

3. SOFIAITC Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

4. SOFIAITC Seeks Exemption From The Requirements Of Section 91.105(a) And (b).

Section 91.7, entitled Flight crewmembers at stations, subsection (a) and (b) prescribe the 

following, in relevant part:

(a) During takeoff and landing, and while en route, each required flight crewmember shall—

(1) Be at the crewmember station unless the absence is necessary to perform duties in 

connection with the operation of the aircraft or in connection with physiological needs; 

and 

(2) Keep the safety belt fastened while at the crewmember station. 

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during takeoff and 

landing, keep his or her shoulder harness fastened while at his or her assigned duty station. This 

paragraph does not apply if—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or 

(2) The crewmember would be unable to perform required duties with the shoulder 

harness fastened.

5. SOFIAITC Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure. 

6. SOFIAITC Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following: 
11

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at

least 20 minutes. 

7. SOFIAITC Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner 

or operator of an aircraft—

(a) 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[.] 

8. SOFIAITC Seeks Exemption From The Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or 

alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 of this 

chapter[.] 

9. SOFIAITC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter. 

10. SOFIAITC Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph (b) 

of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 

100-hour, annual, progressive, and other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance 

of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and 
12

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for 

return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each 

rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its 

appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, and 

appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service. 

C. The Extent Of Relief SOFIAITC Seeks And The Reason SOFIAITC Seeks The Relief. 

14 C.F.R. § 45.27(a): Location of marks; nonfixed-wing aircraft; Rotorcraft;

Relief from Section 45.27(a) requires each operator of a rotorcraft must display on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

SOFIAITC respectfully proposes that Operator will main the 200 AGL and below requirement for

SOFIAITCa sUAV platforms. When and if SOFIAITC decides to in the future, submit a subsequent 

exemption for operations above the 200 AGL, then all SOFIAITC aUAVs will become subject to 

displaying on each rotorcraft; horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks 

required by § 45.23.
13

14 C.F.R. § 61.113(a) & (b): Private Pilot Privileges and Limitations; Pilot in Command;

Relief from Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the SOFIAITC’s sUAV 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. 

SOFIAITC respectfully proposes that Operator requirements should take into account the characteristics 

of the particular UAS. SOFIAITC’s sUAV 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 SOFIAITC’s sUAV has navigation and control 

system comprised of a Ground Control Station (GCS) and auto-pilot system that can be pre-programmed 

to set operational boundaries. All flights are pre-programmed with precision GPS guidance. In the case of 

unplanned events, the Operator may input pre-programmed evasive maneuvers from the control unit, and 

the onboard autopilot executes those maneuvers. Pre-programmed Operator interventions include 

initiation of holding at present position; suspension of mission; fly back to launch point; abort mission 

and land immediately; and emergency power cut off and land (Flight Termination System). 

Additional automated safety functions and safety enhancing features of the SOFIAITC’s sUAVs may 

include the following:

1.1. Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate landing.

1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. Low 

power below 10% triggers an immediate landing.

1.3. If the auto-pilot detects a lost-link to the ground controller, the UAS will hold position at its 

current location for 5 seconds and if the signal is not restored, execute a return to home and 

land.

1.4. Redundant “kill switches” that enable completely shutting the aircraft down in flight in the 

event of a loss of control or un-commanded deviation from the flight path. 

1.5. The aircraft, weighs less than 55 lbs., fully loaded.

1.6. The motors are driven by pulse width modulated signals, not analog signals.

1.7. The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor above 

200 feet above the structure (imaging altitude) or a maximum of 200 AGL. 

Given these safety features, SOFIAITC proposes that Operators of the SOFIAITC’s sUAV 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; 

have completed the manufacturer’s or SOFIAITC’s training program for operation of the UAS.

SOFIAITC notes that the FAA has found that safety factors permitted operation of UASs by Operators 

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

operating conditions specified above were present. See, Federal Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). Likewise, 
14

SOFIAITC notes that the NPRM does not require that the Operator hold a private pilot license issued by 

the FAA.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing 

operation of the SOFIAITC’s sUAV 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 SOFIAITC’s sUAV (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 UAS 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): Civil aircraft airworthiness. 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to 

allow SOFIAITC to determine that the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon 

Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS are in airworthy condition prior to every 

flight by ensuring that the UAS is in compliance with the operating documents (i.e., SOFIAITC Aerial 

Operations Manual, Monthly Maintenance Log, and RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 Instruction Manual). 

SOFIAITC seeks the requested relief because the RDASS Spyder HD Edition, RDASS Q1000, Yuneec 

Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, SOFIAITC will ensure that the 

RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and 

Roboflight RF70 UAS are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and RDASS Spyder HD Edition, RDASS Q1000, Yuneec 

Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70) prior to every flight, and further, 

determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations 

below.

14 C.F.R. § 91.105(a) and (b): Flight crewmembers at stations. 

Relief from Section 91.7(a): During takeoff and landing, and while en route, each required flight 

crewmember shall— (1) Be at the crewmember station unless the absence is necessary to perform duties 

in connection with the operation of the aircraft or in connection with physiological needs; and (2) Keep 

the safety belt fastened while at the crewmember station; and (b): Each required flight crewmember of a 

U.S.-registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened 

while at his or her assigned duty station. This paragraph does not apply if— (1) The seat at the 

crewmember's station is not equipped with a shoulder harness; or (2) The crewmember would be unable 

to perform required duties with the shoulder harness fastened.

SOFIAITC seeks the requested relief because the RDASS Spyder HD Edition, RDASS Q1000, Yuneec 

Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS is remotely controlled with no 

passengers or property of others on board. SOFIAITC’s sUAV 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 SOFIAITC’s sUAV has navigation 

and control system comprised of a Ground Control Station (GCS) and auto-pilot system that can be pre-
15

programmed to set operational boundaries. All flights are pre-programmed with precision GPS guidance. 

In the case of unplanned events, the Operator may input pre-programmed evasive maneuvers from the

control unit, and the onboard autopilot executes those maneuvers. Pre-programmed Operator 

interventions include initiation of holding at present position; suspension of mission; fly back to launch 

point; abort mission and land immediately; and emergency power cut off and land (Flight Termination 

System).

14 C.F.R. §91.121 Altimeter Settings

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the 

RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and 

Roboflight RF70 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at the 

ground control station (GCS). Since the FAA requires that any altitude information concerning UAS 

operations be reported to air traffic control (ATC) in feet above ground level (AGL), SOFIAITC seeks the 

requested relief because the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, 

Yuneec Tornado H920, and Roboflight RF70 UA’s altimeter may be set on the ground to zero feet AGL, 

rather than the local barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the 

extent necessary to comply with the applicable conditions and limitations stated below. As more fully set 

forth herein, an equivalent level of safety will be maintained since the RDASS Spyder HD Edition, 

RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS are 

equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a 

ground level pressure setting will be established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display of the GCS. 

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

Section 91.151(a): During takeoff 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 battery powering the sUAS provides approximately 40 minutes of powered flight. To meet the 30-

minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 

minutes in length. Given the limitations on the UAS’ proposed flight area and the location of its proposed 

operations within a predetermined area, a longer time frame for flight is reasonable. 

Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 

91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners 

or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve 

fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size 

and speed of the small UAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 

25% of remaining battery power whichever happens first. This restriction would be more than adequate to 

return the sUAS to its planned landing zone from anywhere in its limited operating area.
16

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the 

extent required to allow flights of the battery powered RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23

minutes. SOFIAITC seeks the requested relief because without an exemption from Section 91.151(b), the 

flight time duration of the battery powered RDASS Spyder HD Edition, RDASS Q1000, Yuneec 

Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS will severely constrain the 

practicality of any aerial video or still photo flight operations that SOFIAITC proposes to conduct 

pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the RDASS Spyder HD Edition, RDASS 

Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS, the RDASS 

Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight 

RF70 operating documents, and SOFIAITC’s proposed operating limitations, ensure that SOFIAITC will 

safely operate the battery powered RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 

4K, Yuneec Tornado H920, and Roboflight RF70 UAS during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration 

of 23 minutes.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance Inspections

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft 

with an airworthiness certificate, SOFIAITC requests relief from these Sections because the RDASS 

Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight 

RF70 UAS do not require airworthiness certificates. As set forth more fully below, the RDASS Spyder 

HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70

UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, SOFIAITC will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating 

documents (i.e., the SOFIAITC Aerial Operations Manual, Monthly Maintenance Log, and RDASS 

Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight 

RF70 Instruction Manual). Furthermore, SOFIAITC will document and maintain all maintenance records 

for the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, 

and Roboflight RF70 UAS. 

D. The Reasons Why Granting SOFIAITC Request Would Be In The Public Interest; That Is, How 

It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing SOFIAITC to safely, efficiently, 

and economically perform aerial video and photography of construction sites, real estate, events and civic 

landscape events as a service to the public/business interests, assist Law Enforcement and/or Military in 

Search & Rescue and Emergency Services in coordination with local authorities over certain areas of the 

United States.

Additionally, use of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of SOFIAITC’s proposed operation of 

the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and 

Roboflight RF70 UAS will be realized without implicating any privacy issues. 
17

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, 

and Roboflight RF70 UAS are battery powered and serve as a safe, efficient, and economical alternative 

to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial acquisitions, an exemption allowing the use of a RDASS Spyder HD 

Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS 

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 

increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The RDASS Spyder HD Edition, 

RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS do not 

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic control during the 

ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The RDASS Spyder HD Edition, 

RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS. 

Conducting aerial acquisitions with the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon 

Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS, instead of manned aircraft, will greatly 

benefit the public by drastically reducing the levels of air and noise pollution generated during traditional 

aerial video and still photography flight operations. By using battery power and electric motors, the 

RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and 

Roboflight RF70 UAS produce no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for 

aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation 

fuel. The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado 

H920, and Roboflight RF70 UAS, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an 

internal combustion engine. 

By using the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado 

H920, and Roboflight RF70 UAS to perform aerial acquisitions, the substantial risk to life and property in 

the air and on the ground, which is usually associated with traditional manned aircraft flight operations, 

will be substantially reduced or completely eliminated. Aside from the lack of flight crew members 

located onboard the aircraft, the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, 

Yuneec Tornado H920, and Roboflight RF70 UAS (weighing approximately 2.8 pounds at their 

maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less 

physical potential for collateral damage to life and property on the ground, and in the air, compared to the 

manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a 

wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The RDASS Spyder HD Edition, 

RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS Will 

Benefit The Economy. 

In addition to being safe and efficient, the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon 

Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS are also an economical alternative to using 
18

manned aircraft to conduct similar aerial operations. As such, operation of the RDASS Spyder HD 

Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS

will allow United States based companies, like SOFIAITC, to remain competitive and contribute to 

growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and 

operated companies must adopt new and alternative technology in order to remain competitive. Operating 

the battery powered RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without the high 

operational cost of a traditional manned aircraft. 

By operating the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS, companies such as SOFIAITC, can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately

contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through 

commercial use of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS, provides a stable workforce that increases consumer 

spending; improves local, state, and federal tax revenues; and allows companies to invest in research and 

development in order to remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

SOFIAITC’s proposed operation of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon 

Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS will not implicate any privacy issues. 

Specifically, the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS will be operated only in compliance with operating documents 

(i.e., SOFIAITC Aerial Operations Manual, Monthly Maintenance Log, and RDASS Spyder HD Edition, 

RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 Instruction 

Manual) which requires property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 

C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption 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 SOFIAITC Seeks Exemption. 

1. Reasons Why The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, 

Yuneec Tornado H920, and Roboflight RF70 UAS Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, SOFIAITC’s operation of the RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS meet the conditions of 

FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth 

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: 
19

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 

180 days after the date of enactment of this Act, 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. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight do not create a hazard to users of the national 

airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1). 

(c) Requirements for Safe Operation.--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. 

In seeking this exemption, SOFIAITC submits that the RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS can operate safely in the 

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the RDASS Spyder 

HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70

UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 

4K, Yuneec Tornado H920, and Roboflight RF70 UAS Demonstrate Its Safe Characteristics.

The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, 

and Roboflight RF70 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon 

Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS. 

The technical specifications of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 

4K, Yuneec Tornado H920, and Roboflight RF70 UAS are set forth by the RDASS Spyder HD Edition, 

RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 User Manual, 

attached hereto as Appendix A. 

ii. The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS Global Positioning Modes Enable The UAS To 

Remain Within A Defined Operational Area. 

The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, 

and Roboflight RF70 UAS may be operated in both manual and global positioning flight modes. A 

complete description of the flight and navigational modes of the RDASS Spyder HD Edition, RDASS 

Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS is provided at 
20

pages 11 of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 User Manual attached hereto as Appendix A. 

iii. The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS Are Designed For Automatic Return To Home 

Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 

4K, Yuneec Tornado H920, and Roboflight RF70 UAS will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, 

Yuneec Tornado H920, and Roboflight RF70 UAS does not reacquire control link data from the GCS, the 

UAS will assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) 

via GPS, and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS are set forth at pages 12

through 14 of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 User Manual, attached hereto as Appendix A.

iv. The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 GCS And Its Operation.

A complete description of the operation and specifications of the RDASS Spyder HD Edition, RDASS 

Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 GCS and flight control 

software is provided at pages 23 through 29 of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec 

Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 User Manual. RDASS Spyder HD 

Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 User 

Manual is attached hereto as Appendix A.

b. Flight Operations Of RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, 

Yuneec Tornado H920, and Roboflight RF70 UAS Is Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

SOFIAITC video production staff will be the only persons to act as a pilot in command (PIC) of the 

RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and 

Roboflight RF70 UAS. Additionally, a safety observer will assist him at all times during flight time. 

c. Flights Of RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS Will Be Conducted Pursuant To Specific Operating 

Limitations. 

In seeking this exemption, SOFIAITC proposes to commercially operate RDASS Spyder HD Edition, 

RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS for the 

special purpose of conducting aerial video and photography over certain areas of United States, pursuant 

to the following specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the following aircraft 

described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum 

gross weight: RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 Unmanned Aircraft Systems. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this grant. 
21

2. UAS operations under this exemption will be limited to conducting operations for the purpose 

of conducting aerial video and photography of construction sites, residential and commercial real 

estate, civil landscapes and events as a service to the public/business interests, assist Law 

Enforcement and/or Military in Search & Rescue and Emergency Services in coordination with 

local authorities over certain areas of the United States.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more above 200 feet above the structure (imaging 

altitude) or a maximum of 200 feet above ground level (AGL) when required and approved by 

Local and/or Federal Government Organizations, especially when pertaining to missions 

involving Law Enforcement and/or Military, as indicated by the procedures specified in the 

operating documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able 

to communicate verbally at all times. Electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding

other air traffic and other ground based obstacles/obstructions and is not permitted to operate the 

camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists between 

the conditions and limitations contained in the grant of exemption and the procedures outlined in 

the operating documents, the conditions and limitations contained in the grant of exemption take 

precedence and must be followed. Otherwise, the operator must follow the procedures as outlined 

in its operating documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. If the operator determines that 

any update or revision would affect the basis upon which the FAA granted the exemption, then 

the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration 

Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the 

operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft 

is prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. The Ground Control Station must be included in the 
22

preflight inspection. All maintenance and alterations must be properly documented in the aircraft 

records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional 

test flight. The PIC who conducts the functional test flight must make an entry in the aircraft 

records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the operating 

documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time 

in service, description of work accomplished, and the signature of the authorized person returning

the UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third- class 

medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of 

the exemption. However, training operations may only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building flights, all persons not essential 

for flight operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). If flight at night is 

required, a special request will be made at the FAA office closest to proposed area of operations. 

Flights under special visual flight rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operator’s COA. The letter of agreement with the airport management must be 

made available to the Administrator upon request. 
23

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

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

22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined 

location within the planned operating area and land or be recovered in accordance with the 

operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather

conditions) there is enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA 

will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation. All operations shall be conducted in 

accordance with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and control of 

the UA must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at

the Ground Control Station of the UAS any time the UAS is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons 

(persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and 

structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller 

of such vessels, vehicles or structures has granted permission and the PIC has made a 

safety assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard, and;
24

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present 

an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with permission 

from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

1. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety.

SOFIAITC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be 

maintained because no PIC will be allowed to operate the RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely 

operate the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado 

H920, and Roboflight RF70 UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Considering SOFIAITC’s proposed area of operations, and the operating limitations set forth-above; the 

parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot 

requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the 

RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and 

Roboflight RF70 UAS, SOFIAITC submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for SOFIAITC’s 

specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 

11160, 11161). 

SOFIAITC will not allow any PIC to operate the RDASS Spyder HD Edition, RDASS Q1000, Yuneec 

Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS unless that PIC has demonstrated, 

by meeting minimum flight-hour requirements or the RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS training and currency 

requirements, that the PIC is able to safely operate the RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS in a manner consistent 

with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a 

UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In 
25

addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in 

compliance with applicable regulations will ensure an equivalent level of safety during SOFIAITC’s 

proposed operations. The Administrator has held that prior documented flight experience that was 

obtained in compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion 

picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent 

with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged 

as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must 

also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and 

model of UAS to be used for operations under the exemption. For clarification, the FAA considers these 

minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may 

be included in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours of 

UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flighthour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills 

necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior 

documented flight experience that was obtained in compliance with applicable regulations would satisfy 

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

grant of exemption to accomplish the required flight time. During training, proficiency, and experiencebuilding flights the PIC is required to operate the UA with appropriate distances in accordance with 14 

C.F.R 91.119.

In Exemption No. 11138 at page 15, Accordingly, SOFIAITC will ensure safe operations by not allowing 

any PIC to operate the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the RDASS Spyder HD Edition, 

RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS in a 

manner consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

2. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely 

Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every 

flight, SOFIAITC will ensure that the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon 

Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS is in an airworthy condition based upon the 

UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

3. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely 

Affect Safety.
26

The equivalent level of safety established by Section 91.121 will be maintained because the altitude 

information of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of 

the flight path and altitude. This altitude information, combined with SOFIAITC’s operation of the 

RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and 

Roboflight RF70 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety

equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed 

onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the 

UAS at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in 

all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely 

Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of (1) the technical specifications of the RDASS Spyder HD Edition, RDASS 

Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS; (2) the 

limitations on the proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, SOFIAITC will ensure that it will safely operate the battery powered RDASS Spyder HD 

Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS

during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 23

minutes. 

Here, as in Exemption No. 11109, the technical specifications of the RDASS Spyder HD Edition, RDASS 

Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS; the limitations on 

the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level 

of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the RDASS 

Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight 

RF70 UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low 

battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at 

approximately 10% remaining battery power. At the critically low battery level, the RDASS Spyder HD 

Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS 

will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the UAS are 

considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed 

in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously 

granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

5. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect 

Safety. 
27

In seeking this exemption, SOFIAITC submits that the equivalent level of safety with regard to the 

regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because SOFIAITC will use trained technicians to 

perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 

and practices prescribed in the operating documents (i.e., SOFIAITC Aerial Operations Manual, Monthly

Maintenance Log, and RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 Instruction Manual). Furthermore, SOFIAITC will document and 

maintain all maintenance records for the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon 

Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS. 

Since the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado 

H920, and Roboflight RF70 UAS will be inspected as prescribed by the operating documents, SOFIAITC

will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). A copy of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, 

Yuneec Tornado H920, and Roboflight RF70 User Manuals are attached hereto as Appendix A and B; a 

copy of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado 

H920, and Roboflight RF70 UAS Maintenance LOG is attached hereto as Appendix C. 

Likewise, the exemption sought will not adversely affect safety because SOFIAITC will use trained 

technicians to perform maintenance, alterations or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 

91.407, 91.417(a) and 91.417(b), because all maintenance of the RDASS Spyder HD Edition, RDASS 

Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS will be performed 

by trained technicians. Maintenance will be documented and maintained utilizing the monthly

maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are considered. 

In consideration of SOFIAITC’s proposed operating limitations, the operating documents, and the 

technical aspects of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec 

Tornado H920, and Roboflight RF70 UAS, SOFIAITC submits that safety will not be adversely affected 

by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 

91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

6. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.F.R. § 21.16 entitled Special Conditions, SOFIAITC requests that the FAA prescribe special conditions 

for the intended operation of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 

4K, Yuneec Tornado H920, and Roboflight RF70 UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 

21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS
28

for the limited purpose of conducting aerial video and photography over certain areas of the United States 

for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS 

will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification in accordance 

with any requirements that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, 

Yuneec Tornado H920, and Roboflight RF70 UAS, since the airworthiness regulations of 14 C.F.R. Part 

21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of 

the aircraft. Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or 

unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions 

and amendments thereto for the product. The special conditions are issued in accordance with 

Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special 

conditions for Leading Edge’s intended operation of the RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS, which contain such 

safety standards that the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which SOFIAITC Seeks Exemption: 

SOFIAITC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption SOFIAITC Seeks: 

This exemption will permit SOFIAITC to commercially operate an Unmanned Aircraft System 

(UAS) for the purpose of conducting aerial video and photography over certain areas of the 

United States.

• Any Additional Information, Views, Or Arguments Available To Support 

SOFIAITC’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, SOFIAITC’s request for exemption may be granted pursuant to the 

authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 
29

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to 

users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, SOFIAITC will operate the RDASS Spyder HD Edition, RDASS Q1000, 

Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS safely in the NAS, 

without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national 

security. 

CONCLUSION

As set forth herein, SOFIAITC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the RDASS 

Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight 

RF70 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting 

aerial video and photography over certain areas of the United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 

2012, while also advancing the interests of the public, by allowing SOFIAITC to safely, efficiently, and 

economically operate the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, 

Yuneec Tornado H920, and Roboflight RF70 UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and 

Reform Act of 2012, Section 333, SOFIAITC respectfully requests that the Administrator grant this 

Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge 

to operate the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado 

H920, and Roboflight RF70 UAS commercially for the purpose of conducting aerial video and 

photography of construction sites, residential and commercial real estate, civil landscapes and events as a 

service to the public/business interests, assist Law Enforcement and/or Military in Search & Rescue and 

Emergency Services in coordination with local authorities over certain areas of the United States.

Dated: February 11, 2016

Respectfully submitted,

James Quilty

CEO

Sofia Information Technology Consulting Inc, dba. SOFIAITC

120 E. Logarto Cir. Ste. D-114

Tampa, FL 33612

(813) 321-5154 Office

(877) 754-0449 Fax

quiltyja@sofiaitc.com

and 

Rick Cureton

Chief Pilot,

Sofia Information Technology Consulting, Inc.