April 30, 2015 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 

Dear Sir or Madam: 

I am writing concerning the FAA Modernization and Reform Act of 2012 (the "Reform Act") and the 

procedures contained in 14 C.F.R. 11. I am requesting that 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 by the Federal Aviation Administration ("FAA"). 

Primary uses will be low altitude aerial photography and video footage for educational, agricultural, 

research, promotional, entertainment, and marketing purposes. 

Sarra Ventures and Linda J Baurer have operated a UAS on many occasions non-commercially without 

incident. Sarra Ventures and Linda J Saurer also use an FAA certified Agricultural pilot for consultation 

if questions or concerns arise. 

The UAS utilizes battery power, not combustible fuels. Flight time ranges between five and twenty 

minutes. The UAS has GPS functionality to hover in place as well as a return to home function in case of 

loss of contact with the radio. It has an audible and visual warning system and will start to descend 

slowly if battery 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 comply with the FAA's 

current and forthcoming regulations. 

For the reasons stated below, Sarra Ventures respectfully request the grant of an 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 of Title 14 of the Code of Federal Regulations from Which We Request 

Exemption is: 

14CFR 21: 

14 C.F.R. 45.23 (b): 

14 CFR 61m113 (a) & (b): 

14 C.F.R. 91, et seq.: 

14 CFR 407 (a) (1): 

14 CFR 409 (a) (2): 

14 CFR 417 (a) & (b). 

U.S Dep't of Trans. 

3. The Extent of Relief Sarra Ventures Seeks and the Reason It Seeks Such Relief: 

Sarra Ventures submits this application in accordance with the Reform Act, 112 P.L. 

95§§ 331-334, seeking relief from 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 for such integration of civil unmanned aircraft systems into our 

National airspace system as it is in the public's interest to do so. Our lightweight UAS meets 

the definition of "small unmanned aircraft" as defined in Section 331 and therefore the 

integration of our lightweight UAS is expressly contemplated by the Reform Act. We 

would like to operate our lightweight UAS prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such craft. 

The Reform Act guides the Secretary in determining the types of UASs that may operate 

Safely in our national airspace system. Considerations include: 

• The weight, size, speed and overall capabilities of the UAS: 

• Whether the UAS will be operated near airports or populated areas: and, 

• Whether the UAS will be operated by line of sight. 

112 P.L. 95 § 333 (a). Each of these items militates in favor of an exemption for Sarra Ventures. 

Our UAS utilizes four counter-rotating propellers for extreme balance, control and stability. It weighs 

less than 5 pounds, including battery and all equipment. This small unmanned aircraft is designed to 

primarily hover in place and operate at less than a 50 knot maximum speed. It is capable of vertical and 

horizontal operation but operate only within the line of sight of the 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 of the aircraft at all times. 

Utilizing battery power and not combustible fuels, flights generally last between five and twenty 

minutes. We do not operate the UAS with less than twenty five percent battery capacity. Safety 
systems in place include a GPS mode that allows the UAS to hover in place or return to takeoff location if 

communication with the radio control pilot is lost and then slowly descend the UAS at twenty five 

percent battery capacity. Sarra Ventures does not operate the UAS near airports or near populated 

areas. To date, we have only operated the UAS in a non-commercial manner. 

Our operation of this small unmanned aircraft will not "create a hazard to users of the national airspace 

system or the public." 112 P.L. 95 § 333 (b). Given the small size and weight ofthe UAS, combined with 

its operation in cordoned off and well-controlled areas, this falls within Congress's contemplated safety 

zone when it promulgated the Reform Act and the corresponding directive to integrate UASs into the 

national airspace system. Indeed, our UAS will not pose any threat to the general public or national 

security. 

The FAA has the authority to issue the exemption sought by Sarra Ventures pursuant to the Federal 

Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 

4. How this Request Will Benefit the Public As A Whole: 

Granting this exemption request will benefit the public by promoting education, research, and 

promotional ideas within the agricultural communities. Sarra Ventures would like to use UAS to fly 

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 

better agricultural and resource management. Promotional and educational videos, photos, and images 

will be used to educate and train farmers to increase crop production and detect early problems within 

the farming operation. An example would be a UAS flying (and filming) a 100 acre field of newly 

emerging crops. By analyzing the imagery taken by the UAS an Agricultural specialist would be able to 

detect if the crop needs more nutrients or if the 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 their own yields. This crop increase would benefit the public as a whole. 

Not only would the farmer get higher income from increased production, but the public would get more 

food on the grocery shelves at lower costs. 

Sarra Ventures would also like to use UASs for cinematic and entertainment purposes. The videos and 

imagery captured would be put together in films that offer entertainment to the general public 

audience. Progression ofthe arts and sciences has been fundamental to our society 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 noteworthy and inevitable field. Permitting Sarra 

Ventures to immediately fly within the United States furthers these goals. 

5. Reasons Why Sarra Ventures Exemption Will Not Adversely Affect Safety Or How The Exemption 

Will Provide a level of Safety 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 if needed. 
In addition we submit the following to represent the safety techniques we uphold when flying our UAS: 

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

• We only operate our UAS below 400 feet: 

• Our UAS only operates for 5-20 minutes per flight: 

• We land our UAS when it reaches 25% battery power: 

• Our remote control pilot operates the UAS by line of sight: 

• Our remote control pilot has video backup and GPS locator should he somehow lose Sight of the UAS: 

• We staff each flight with a remote control pilot and spotter with 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 if communication with the remote control pilot is lost or battery power 

Is below 25%: 

• We actively analyze electronic flight data and other sources of information to constantly 

Update and enhance safety protocols: 

• We conduct briefings prior to flight during which safety carries primary importance: 

• We have procedures in place to abort flights in the event of safety breaches or potential 

Danger. 

It is important to note that absent the integration of commercial UASs into our national airspace 

system, helicopters and manned airplanes are the primary means of aerial motion picture and 

agricultural imagery. While the safety record of such aircraft is remarkably astounding, it is far safer to 

operate a battery powered lightweight UAS. The potential loss of life is diminished because UASs carry 

no people on board and Sarra Ventures only operates them in specific areas away from mass 

populations. There is no fuel on board a UAS and thus the potential for fire or explosions is greatly 

diminished. The small size and extreme maneuverability of our UAS allows our remote control pilot to 

avoid hazards. Given their small 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. 14 C.F.R. 21 and 14 C>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 of Sarra Ventures UAS permits exemption from Part 21 because Sarra Venture's UAS 

meets an equivalent level of safety pursuant to Section333 of the Reform Act. The FAA is authorized to 

exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f) 

and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from the 

airworthiness certificate requirement in consideration of the weight, size speed, maneuverability and 

proximity to areas such as airports and dense populations. Sarra Ventures UAS meets or exceeds each of 

the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 

14 C.F.R § 91.9(b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UASs, this Regulation is inapplicable. An equivalent level of safety 

will be achieved by maintaining a manual at the flight operations center. The FAA has previously issued 

exemptions to their regulation in Exemption Nos 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10167A, 10602, 10700 and 32827. 

14C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as Sarra Ventures utilizes electronic 

global positioning systems and internal gyroscopes to provide spatial coordination. 

14 C.F.R. § 91.203 (a)) and (b) provides for the carrying of civil aircraft certifications and registrations. 

They are inapplicable for the same reasons described above. The equivalent level of safety will be 

achieved by maintaining such certifications and registrations at Sarra Ventures. 

B. 14 C.F.R § 45.23: Marking of the Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. 

Sarra Venture's UAS is, by definition, unmanned. It therefore does not have a cabin, cockpit or pilot 

station on which to mark certain words or phrases. Further, two-inch lettering is difficult to 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 that the pilot, 

technician, spotter and others working with the UAS will see the markings. The FAA has previously 

issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R.§§ 61.113 (a) & 

(b) private pilots are limited to non-commercial operations. Sarra Ventures can achieve an equivalent 

level of safety as achieved by current regulations because Sarra Ventures UAS does not carry any pilots 

or passengers. Furthermore, Sarra Ventures uses the wisdom and advice of a certified FAA Commercial 

pilot when there are any safety issues in question. The risks attendant to the operation of Sarra Venture 

UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R.§ 61, et seq. 

Thus, allowing Sarra Ventures to operate its UAS 
with a private pilot as the pilot in control will exceed current safety levels in relation to 14 C.F.R. § 

61.113 (a) & (b). 

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be 

operated at lower altitudes in certain conditions. Sarra Ventures will never operate at an altitude 

greater than 400 AGL. Given the size, weight, maneuverability and speed of Sarra Ventures UAS, an 

equivalent level of safety will be achieved. 

E. 14 C.F.R. 91.405 (a) (2); 417 (a) & (b): Maintenance Inspections. 

The above cited Regulations require, amongst other things, aircraft owners and operators to "have 

aircraft inspected as prescribed in subpart E ofthis part and shall between required inspection, except 

as provided in paragraph © ofthis section, have discrepancies repaired as prescribed in part 43 ofthis 

chapter .... " 

These Regulations only apply to aircraft with an airworthiness certificate. Therefore, they will not apply 

to Sarra Ventures should its requested exemption be granted. Sarra Ventures conducts a maintenance 

program that involves regular software updates and curative measures for any damaged hardware. 

Therefore, an equivalent level of safety will be achieved. 

F. Summary 

Sarra Ventures and Linda J Baurer seek an exemption from the following Regulations: 14 C.F.R. 21, 

subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.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; 14 C.F.R. § 91.121; C.F.R. § 91.151 (a); 14 C.F.R. 

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

91.409 (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, lighter and more maneuverable than conventional aircraft. Sarra Ventures UAS operates at 

lower altitudes and in controlled airspace. There are no people on board Sarra Venture's UAS and 

therefore the likelihood of death or serious bodily injury is significantly limited. Sarra Ventures operation 

of its UAS, weighing less than 5 pounds and travelling at speeds lower than 50 knots will provide at least 

an equivalent level of safety as that achieved under current FARs. 

Accordingly, Sarra Ventures respectfully requests that the FAA grant its exemption request without 

delay. The FAA has the authority to 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 important things that would benefit the general 

public. 1) the potential increase of crop production for farmers ... which in turn produces more food for 

the consumer at lower prices. 2) Entertainment and educational value for all public audiences. 

Respectfully submitted, 

Linda J Baurer 

Owner/Operator 

Sarra Ventures 

13643 Antioch Rd 

Tremont IL 61568