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 WASHI NGTON, 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 FEDER AL AVIATION REGULATI** **ONS FROM TITLE 14 OF THE CODE OF FE** **DERAL 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 quilty ja@sofiaitc.com2



## Table of Contents **GLOSSARY OF ABBREVIATIONS**

........................................................................................................4 **EXECUTIVE SUMMARY**

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

............................................................5 **BACKGROUND**

.........................................................................................................................................6 **COMMERCIAL (MISSIO N, 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 Exemptio n 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 R**  **F70 UAS.**

.... 17 **3. Performing Aerial Video and Photography Operations With The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q5** **00 4K, Yuneec Tornado H920, and Roboflight RF70 UAS Will Benefit The Economy.** 

............................................................................................................................... 17 **4. There Are No Privacy Issues.**

............................................................................................................... 183

**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**  **M odernization and Reform Act of 2012 (FMRA) Section 333.** 

............................................................ 18 **a. The Specifications Of The RDASS Spyder HD Edition, RDASS Q1000, Yun eec Typhoon Q500**  **4K, Yuneec Tornado H920, and Roboflight RF70 UAS Demonstrate Its Safe Characteristics.**

....... 19 **i. Technical Specifica tions Of The RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon**  **Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS.**

............................................................. 19 **ii. Th e 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 Q 500 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**

.........................................................................................................................................294



### 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 System5



### 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 of2012 (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 commercialreal estate, civillandscapes 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 ofthe FAA Modernization and Reform Act of2012 (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 ofits 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 ofsuch aircraft systems in the national airspace system.” Section 333(c) ofthe Reform Act. This exemption will permit SofiaITC to operate an Unmanned Aircraft System (UAS) for the commercial and government purposes ofconducting 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 ofgovernmental, commercial, public, and residential uses, specifically targeting



### • Construction sites before and after



### • Appraisals



### • Real

-estate marketing



### • Economic development



### • Civic landmarks



### • Civil disasters6



### • 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 operatethe 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 takeoffand 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 of20mins 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 of25mins perbattery usage; a control Transmission Distance/Range of FCC Compliance up to 800M (2624.67ft.) / CE Compliance up to 200M (1312.34ft.); adjustable MaximumFlying Altitude of200ft

. **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 of25mins per battery usage; a control Transmission Distance/Range ofFCC Compliance up to 800M (2624.67ft.) / CE Compliance up to 200M (1312.34ft.); adjustable Maximum Flying Altitude of13,000ft. **5. Roboflight RF70** **:** EachUAV/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



### C**OMMERCIAL (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 ofutility 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 ofvarious sites, aerial video and live video feed to assist with search and rescue operations under the authority and support oflocal 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 of2012 (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 ofRDASS 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 ofFMRA 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 reliefis proper since an equivalent level ofsafety 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, andRoboflight 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 req

uirements 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 ofindustries 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, altitude9

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. Inaccordance 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 Tam pa, FL 33612 (813) 321

-5154 Office (877) 754

-0449 Fax quilty ja@sofiaitc

.com 

### B. T**he Specific Sections Of 14 C.F.R. From Which SOFIAITC**  **Seeks Exemption. 1. SOFIAITC**  **Seeks Exemption From Th e 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 ofa 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 ofthe 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 ofa 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, entitledFuel 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 windand forecast weather conditions) there is enough fuel to fly to thefirst point ofintended landing and, assuming normal cruising speed, tofly after thatfor 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) Ithas been approved for return to service by a person authorized under § 43.7 ofthis chapter[.] **9 .**  **SOFIAITC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).**  Section 91.409, entitledInspections, 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 ofan 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, entitledMaintenance 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; and12 (ii) The date of completion of the work performed; and (iii) The signature, and certificate number ofthe 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 ofthe 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 ofthe forms prescribed by § 43.9(d) ofthis 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 Reaso n**  **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 Privileg** **es 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 ofa 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 ofholding at present position; suspension ofmission; 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 includethe 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 of200 AGL. Given these safety features, SOFIAITC proposes that Operators ofthe 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 andpassed 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 ofUASs 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 N

8900.227, 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, andRoboflight RF70 Instruction Manual). SOFIAITC seeks the requested reliefbecause 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): Duringtakeoff 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; a nd (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 assignedduty 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 reliefbecause 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 ofa 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 ofunplanned 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 ofholding at present position; suspension ofmission; 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** Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe 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 ofthe 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 takeoffprohibits 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 afterthat 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 f lights 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. Petitionerbelieves 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 andproperty owners or official representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engender the type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Petitioner believes that an equivalent level ofsafety 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 itsplanned landing zone from anywhere in its limited operating area.16

Relieffrom 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 ofthe 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 d uration of23 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, andRoboflight 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 ofthe United States

. Additionally, use of theRDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Roboflight RF70 UAS will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits ofSOFIAITC’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 ofmanned 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 Spyde** **r 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 ofair 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, theRDASS 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 using18

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 ofthe U.S. economy. Improved financial performance ofU.S. companies, through commercial use ofthe 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 ofthe 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**  **Le ast**  **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 UA** **S 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 ofthe 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 ofthis subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion oftheplan and rulemaking required by section 332 ofthis 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 ofunmannedaircraftsystems, ifany, as a result oftheirsize, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line ofsight do not create a hazard to users ofthe 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 und

er section 44704 oftitle 49, United States Code, is requiredfor 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 aircraf t systems may operate safely in the national airspace system, the Secretary shall establish requirementsfor the safe operation ofsuch 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 ofthe 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 threatto 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 ofthe 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 Robof light 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 at20

pages 11 of the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, andRoboflight 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 Failsaf e 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, andRoboflight 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**  **RF 70**  **GCS And Its Operation.** A complete description ofthe operation and specifications ofthe 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 ofthe 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 operateRDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, andRoboflight 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 ofconducting aerial video and photography ofconstruction sites, residential and commercial real estate, civil landscapes and events as a service to the public/business interests, assist Law Enf orcement 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 of200 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 firstperson 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 mustbe 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. Ifa discrepancy exists between the conditions and limitations contained in the grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption 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. Itis 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 ifit petitions for extension or amendment to the grant ofexemption. Ifthe 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 ofexemption. 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. Ifthe inspection reveals a condition that affects the safe operation ofthe 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 the22

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 com ponents, 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 au

thorizedperson 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 certif

icate. 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). Ifflight at night is required, a special request will be made at the FAA office closest to proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles ofan 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. Ifthe 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 ofWaiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request aNotice 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 ofway 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 ofthe 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 ofthe 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 ofoperations, 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 relieffrom 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 of5 hours ofthose hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In25

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 flight

hour 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 experience

building f lights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. InExemption No. 11138 at page 15,Accordingly, SOFIAITC will ensure safe operations by not allowing any PIC to operate theRDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, andRoboflight RF70 UAS unless that PIC has demonstrated, by meeting minimum flight

hour and currency requirements, that the PIC is able to safely operate theRDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, andRoboflight 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 ofsight, at or below 500 feet AGL, will ensure a level ofsafety 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 establishedby the UAS at ground level. The FAA has previously granted relieffrom 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 ofthis 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 theRDASS SpyderHD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, andRoboflight RF70 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level ofsafety 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. Reliefhas 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 relieffrom 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

Inseeking 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, andRoboflight 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 ofthe RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, andRoboflight 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 ofsafety 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 reliefspecific 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 Prescr** **ibe 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 ofthe 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 willpermit safe operation of the UAS28

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 ofthe 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: Ifthe FAA finds that the airworthiness regulations ofthis 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**  **S ummary**  **That Can**  **Be Published**  **In The**  **Federal Register,**  **stating: The**  **Rules From Which**  **SOFIAITC Seeks Exemption:**  SOFIAITC seeks exemptionfrom the requirements of14 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 ofconducting aerial video and photography over certain areas ofthe 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 ofthe 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 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe 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 ofthe 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 ofthe public, by allowing SOFIAITC to safely, efficiently, and economically operate the RDASS Spyder HD Edition, RDASS Q1000, Yuneec Typhoon Q500 4K, Yuneec Tornado H920, andRoboflight 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 ofconstruction 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 Tam pa, FL 33612 (813) 321

-5154 Office (877) 754

-0449 Fax quilty ja@sofiaitc.com and Rick Cureton Chief Pilot, Sofia Information Technology Consulting, Inc.