April 30, 2015 United States DepartmentofTransportation Docket Management System 1200 NewJersey Ave., SE West Building Ground Floor Room W12-140 Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of2012 Dear Sir or Madam: Iam writing concerning the FAA Modernization and Reform Act of2012 (the "Reform Act") and the procedures contained in 14 C.F.R. 11. Iam requestingthat Sarra Ventures, owned and operated by Linda J Baurer be exempted from the Federal Aviation Regulations ("FARs") listed below so that Sarra Ventures may operate its small unmanned aircraft/lightweight unmanned aircraft systems "UAS" in commercial airspace regulated bythe Federal Aviation Administration ("FAA").

Primary uses will be lowaltitude aerial photography and video footage for educational, agricultural, research, promotional, entertainment, and marketing purposes.

Sarra Ventures and Linda JBaurer have operated a UAS on many occasions non-commerciallywithout incident. Sarra Ventures and Linda JSaurer also use an FAA certified Agricultural pilotfor consultation ifquestions orconcerns arise.

The UAS utilizes battery power, notcombustible fuels. Flight time ranges between five and twenty minutes. The UAS has GPS functionalityto hover in place as well as a return to home function in case of loss ofcontact with the radio. It has an audible and visual warning system and will startto descend slowly ifbattery power reaches 25%.

Sarra Ventures's exemption request would permit its operation of lightweight, unmanned (piloted by remote control) and comparatively inexpensive UASs in tightly controlled and limited airspace. As stated earlier, Linda J Saurer has UAS flight experience and is willing to abide and complywith the FAA's current and forthcoming regulations.

Forthe reasons stated below, Sarra Ventures respectfully requestthe grant ofan exemption allowing it to operate lightweight, remote controlled UASs.1. Contact Information: Linda 

### J Baurer Sarra Ventures 13643 Antioch Rd Tremont, IL 61568 (309)925-5980 e-mail: plajjd@gmail.com 2. The Specific Sections ofTitle 14ofthe Code of Federal Regulations from Which We Request Exemption is: 14CFR 21: 14C.F.R. 45.23 (b): 14CFR 61m113 (a) & (b): 14C.F.R. 91, et seq.: 14CFR 407 (a) (1): 14CFR 409 (a) (2): 14 CFR 417 (a) & (b). U.S Dep't ofTrans. 3. The Extent of Relief Sarra Ventures Seeks and the Reason It Seeks Such Relief: Sarra Ventures submitsthis application in accordance with the Reform Act, 112 P.L. 95§§ 331-334, seeking relieffrom any currently applicable FARs operating in cinematic, educational, promotional, agricultural, research, entertainment, and marketing flight operations within the national airspace system. The Reform Act in Section 332 provides forsuch integration ofcivil unmanned aircraft systems into our National airspace system as it is in the public's interestto do so. Our lightweight UAS meets the definition of"small unmanned aircraft" as defined in Section 331 and thereforethe integration ofour lightweight UAS is expressly contemplated by the Reform Act. We would like to operate our lightweight UAS priortothe time period by which the Reform Act requires the FAA to promulgate rules governing such craft. The Reform Act guides the Secretary in determiningthe types of UASs that may operate Safely in our national airspace system. Considerations include:

• The weight, size, speed and overall capabilities ofthe UAS:

• Whetherthe UAS will be operated nearairports or populated areas: and,

• Whetherthe UAS will be operated by line ofsight. 112 P.L. 95 § 333 (a). Each ofthese items militates in favor ofan exemption for Sarra Ventures. Our UAS utilizes four counter-rotating propellers for extreme balance, control and stability. Itweighs less than 5 pounds, including batteryand all equipment. This small unmanned aircraft is designed to primarily hover in place and operate at less than a50 knot maximum speed. It is capable ofvertical and horizontal operation but operate onlywithin the line ofsight ofthe remote control pilot. In addition to the remote control pilot, we use a spotter, such that, at minimum, two Sarra Ventures personnel govern the safe flight ofthe aircraft at all times. Utilizing battery powerand notcombustible fuels, flights generally last between five and twenty minutes. We do not operate the UAS with less than twentyfive percent battery capacity. Safetysystems in place include a GPS mode that allowsthe UAS to hover in place or return totakeoff location if communication with the radio control pilot is lost and then slowly descend the UAS attwentyfive percent battery capacity. Sarra Ventures does notoperate the UAS near airports or near populated
areas. To date, we have only operated the UAS in a non-commercial manner. Our operation ofthis small unmanned aircraftwill not "create a hazard to users ofthe national airspace system orthe public." 112 P.L. 95 § 333 (b). Given the small size and weight ofthe UAS, combined with its operation in cordoned offand well-controlled areas, this falls within Congress's contemplated safety
zone when it promulgated the Reform Act and the corresponding directive to integrate UASs intothe national airspace system. Indeed, our UAS will not pose anythreatto the general public or national security. The FAA has the authorityto issue the exemption sought by Sarra Ventures pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 4. Howthis Request Will Benefitthe Public As A Whole: Grantingthis exemption request will benefitthe public by promoting education, research, and promotional ideas within the agricultural communities. Sarra Ventures would like to use UAS tofly agricultural fields for scouting, educating, researching and promoting increased yields in crops and animal production. The information gathered by these flights will be used to educate and promote betteragricultural and resource management. Promotional and educational videos, photos, and images will be used to educate and train farmers to increase crop production and detectearly problems within the farming operation. An example would be a UAS flying (and filming) a 100acre field of newly emerging crops. By analyzing the imagerytaken by the UAS an Agricultural specialist would be able to detect ifthe crop needs more nutrients or ifthe field is being invaded by pests. Recommendations would be made and the farmer who could then adjust accordingly so maximum crop production is achieved. Educational and promotional films would be made to show additional farmers the benefit of using an UAS to help increase theirown yields. This crop increase would benefitthe public as awhole. Not onlywould the farmerget higher income from increased production, butthe public would get more food on the grocery shelves at lowercosts.

Sarra Ventures would also like to use UASs for cinematic and entertainment purposes. The videos and imagery captured would be puttogether in films thatofferentertainmentto the general public audience. Progression ofthe arts and sciences has been fundamental to oursociety since its inclusion in the United States Constitution. Congress mandated the integration of UASs into our national airspace system, in part, to achieve progression in this noteworthyand inevitablefield. Permitting Sarra Ventures to immediatelyfly within the United States furthers these goals. 5. Reasons Why Sarra Ventures Exemption Will NotAdverselyAffect SafetyOr HowThe Exemption Will Provide a level ofSafety At Least Equal To Existing Rule: This exemption will not adversely affect safety. Since Sarra Ventures has experience with flying UASs,
we are quite aware (and follow) FAA safety protocols and airspace guidelines. Sarra Ventures also works closely with an FAA Commercial pilot, so it has valuable safety resources on hand ifneeded.In addition we submitthe followingto representthe safetytechniques we uphold when flying our UAS:

• Our UAS weighs less than 5 pounds complete with all mounted equipmentand battery:

• We only operate our UAS below 400 feet:

• Our UAS only operates for 5-20 minutes perflight:

• We land our UAS when it reaches 25% battery power:
• Our remote control pilotoperates the UAS by line ofsight:

• Our remote control pilot has video backup and GPS locatorshould he somehow lose Sight ofthe UAS:

• We staffeach flightwith a remote control pilotand spotterwith communication systems Enabling real time communication between them:

• Our UAS has GPS flight modes whereby it hovers, returns to takeoff position and then Slowly lands ifcommunication with the remote control pilot is lost or battery power Is below 25%:

• We actively analyze electronicflight data and othersources ofinformation to constantly Update and enhance safety protocols:

• We conduct briefings priorto flight duringwhich safety carries primary importance:

• We have procedures in place to abort flights in the event ofsafety breaches or potential Danger.

It is importantto note thatabsent the integration ofcommercial UASs into our national airspace system, helicopters and manned airplanes are the primary means ofaerial motion picture and agricultural imagery. Whilethe safety record ofsuch aircraft is remarkably astounding, it is farsaferto operate a battery powered lightweight UAS. The potential loss oflife is diminished because UASs carry
no people on board and Sarra Ventures onlyoperatesthem in specific areas awayfrom mass populations. There is no fuel on board a UAS and thus the potential forfire orexplosions is greatly diminished. The small size and extreme maneuverabilityofour UAS allows our remote control pilotto avoid hazards. Given theirsmall size and weight, even when close enough to capture amazing images,
our UAS needs not be so close to the objects it is focused on. Accordingly, our UAS has operated and will continue to operate at and above current safety levels.

### 6. Summary: A. 14C.F.R. 21 and 14C>F>R> 91: Airworthiness certificates and Manuals. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR§ 91.203(a)(1). The size, weight and enclosed operational area ofSarra Ventures UAS permits exemption from Part 21 because Sarra Venture's UAS meets an equivalent level ofsafety pursuant to Section333 ofthe Reform Act. The FAA is authorized to exempt aircraftfrom the airworthiness certificate requirement under both theAct (49 U.S.C. § 44701 (f) and Section 333 ofthe Reform Act. Both pieces oflegislation permitthe FAA to exempt UASs from the airworthiness certificate requirement in consideration ofthe weight, size speed, maneuverability and proximityto areas such as airports and dense populations. Sarra Ventures UAS meets orexceeds each of the elements. 14C.F.R. 91.7(a) prohibitsthe operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in theform contemplated bythe FARs, this Regulation is inapplicable. 14C.F.R § 91.9(b) (2) requires an aircraftflight manual in the aircraft. As there are no pilots or passengers, and given the size ofthe UASs, this Regulation is inapplicable. An equivalent level ofsafety will be achieved by maintaining a manual atthe flight operations center. The FAA has previously issued exemptionsto their regulation in Exemption Nos 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14C.F.R. § 91.121 regarding altimetersettings is inapplicable insofaras Sarra Ventures utilizes electronic global positioning systems and internal gyroscopes to provide spatial coordination. 14C.F.R. § 91.203 (a)) and (b) provides forthe carrying ofcivil aircraft certifications and registrations. They are inapplicable forthe same reasons described above. The equivalent level ofsafety will be achieved by maintainingsuch certifications and registrations atSarra Ventures. B. 14C.F.R §45.23: Marking ofthe Aircraft. Applicable Codes ofFederal Regulation require aircraftto be marked according to certain specifications. Sarra Venture's UAS is, by definition, unmanned. Ittherefore does not have a cabin, cockpit or pilot station on which to markcertain words or phrases. Further, two-inch lettering is difficultto place on such small aircraft. Regardless, Sarra Ventures will mark its UAS in the largest possible lettering by placing the word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. §45.29(f) so thatthe pilot, technician, spotterand others working with the UAS will see the markings. The FAA has previously issued exemptionsto this regulation through Exemptions Nos. 8738, 10167, 10167Aand 10700. C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuantto 14 C.F.R.§§ 61.113 

### (a) 

### & (b) private pilots are limited to non-commercial operations. Sarra Ventures can achieve an equivalent level ofsafety as achieved by current regulations because Sarra Ventures UAS does not carry any pilots
or passengers. Furthermore, Sarra Ventures uses the wisdom and advice ofa certified FAA Commercial pilot when there are any safety issues in question.The risks attendantto the operation ofSarra Venture UAS is far less than the risk levels inherent in the commercial activities outlined in 14C.F.R.§ 61, et seq. Thus, allowing Sarra Ventures to operate its UASwith a private pilotas the pilot in control will exceed current safety levels in relation to 14C.F.R. § 61.113 (a) 

### & (b). D. 14C.F.R. 91.119: Minimum Safe Altitudes. 14C.F.R. § 91.119 prescribes safe altitudes forthe operation ofcivil aircraft. It allows helicoptersto be operated at lower altitudes in certain conditions. Sarra Ventures will never operate at an altitude greaterthan 400 AGL. Given the size, weight, maneuverability and speed ofSarra Ventures UAS, an equivalent level ofsafety will be achieved. E. 14 C.F.R. 91.405 (a) (2); 417 (a) 

### & (b): Maintenance Inspections. The above cited Regulations require, amongst otherthings, aircraftowners and operators to "have aircraft inspected as prescribed in subpart Eofthis partand shall between required inspection, except
as provided in paragraph 

### © ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

...." These Regulations only applyto aircraftwith an airworthiness certificate. Therefore, theywill not apply to Sarra Ventures should its requested exemption be granted. Sarra Ventures conducts a maintenance program that involves regular software updates and curative measuresforany damaged hardware. Therefore, an equivalent level ofsafety will be achieved. F. Summary Sarra Ventures and Linda 

### J Baurer seek an exemption from thefollowing Regulations: 14 C.F.R. 21, subpart H; 14C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) 

### & (b); 14C.F.R. § 91.7 (a); 14 C.F.R § 91.9 (b)(2); 14 C.F.R.§ 91.103(b); 14 C.F.R.§ 91.109; 14 C.F.R. § 91.119; 14C.F.R. § 91.121; C.F.R. § 91.151 (a); 14C.F.R. §§ 91.203(a) and (b); 14C.F.R. § 91.405 (a); 14C.F.R. § 91.407 (a) (1); 14 C.F.R. § 91.409 (a)(2);14 C.F.R. § 91.409 (a)(2);and 14 C.F.R.§§ 91.417 (a) 

### & (b) to commercially operate its lightweight unmanned aircraft in agricultural, educational, promotional, research, and motion picture or photography operations. Granting Sarra Ventures request for exemption will reduce current risk levels and thereby enhance safety. Currently aerial agricultural and motion picture image filming rely primarily on the use of larger aircraft running combustible fuel. Sarra Venture aircraft does not contain potentially explosive fuel, is smaller, lighterand more maneuverable than conventional aircraft. Sarra Ventures UAS operates at loweraltitudes and in controlled airspace. There are no people on board Sarra Venture's UAS and therefore the likelihood ofdeath orserious bodily injury is significantly limited. Sarra Ventures operation of its UAS, weighing less than 5 pounds and travelling at speeds lowerthan 50 knots will provide at least
an equivalent level ofsafety as that achieved under current FARs. Accordingly, Sarra Ventures respectfully requests thatthe FAA grant its exemption requestwithout delay. The FAA has the authorityto issue the exemption sought by Sarra Ventures pursuant to the Federal Aviation Act, 85 P.L. 726(1958), as amended (the "Act").

In closing, Sarra Ventures would like to state that by granting Sarra Ventures the exemption the FAA would be helping a small business accomplish two importantthings thatwould benefitthe general public. 1) the potential increase ofcrop production forfarmers

... which in turn produces morefood for the consumer at lower prices. 2) Entertainment and educational value forall public audiences.
Respectfully submitted, Linda 

### J Baurer Owner/Operator Sarra Ventures 13643 Antioch Rd Tremont IL 61568