July 30, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Exemption Request under Section 333 - Small UAS 

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, 

provides a mechanism for seeking expedited FAA authorization of safe civil UAS 

operations in the NAS. Section 333(a) states that the FAA “shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace 

system before completion of the (comprehensive) plan and rule making 

required by section 332(b)(1) of this Act or the guidance required by 

section 334 of this Act.” In Section 332(b)(1), The Petitioner “ Sabrecross, Inc.,dba FLYING 

TARGETS” proposes the following exemptions and meets all 

requirements to permit FAA approval of commercial UAS operations. 

The proposed exemption, if granted, would allow Petitioner to conduct commercial 

operations of small unmanned aircraft systems (“UAS”) meeting or exceeding all of the 

operational and safety requirements Congress has set forth in Section 333. 

Petitioner is an aerial and technical photography company that plans to exploit the 

capabilities of Unmanned Aerial Systems to offer a multitude of services, including: 

- Aerial surveying 

- Agriculture 

- Aerial filmmaking and photography 

- Real Estate 

- Construction site inspections and monitoring 

- Educational and research operations

- Aerial target support for controlled events 

(a) The name and contact information of the applicant are:

Attn: Rick McGee 

Sabrecross, Inc. 

dba Flying Targets 

P.O. Box 2241 

Eagle, ID 83616 

Phone:(208)495-5031 

email: lovetofly_2000@yahoo.com

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 CFR 36 

14 CFR. 45.23(b), 45.27, 45.29 

14 CFR 61.113 (a) & (b) 
14 CFR. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR. 91.103 

14 CFR. 91.109 

14 CFR. 91.119 

14 CFR. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

(c) The extent of relief sought is for the duration of the Grant of Exemption, 

unless otherwise specified.

The reason to seek the relief is as follows:

I. 14 CFR 21 

i. The petitioner requests relief from 14 CFR part 21. The UAV is a small rotor craft 

weighing less than 25 pounds during operation. The UAV maximum speed is under 50 mph. 

The PIC will maintain VFR Rules flying at no more than 400 feet and will operate the UAV 

during the day in line-of-sight so as not to create a hazard to users of the National Airspace 

System or the Public or pose a threat to national security.

II. 14 CFR 36 

The Petitioner requests relief from any associated noise certification and testing 

requirements of part 36. As a note, according to the manufacturer’s specifications, the 

UAV operates below 40db within 50 meters. 

III. 14 CFR 45.23 

 The UAV does not currently display marks consisting of the Roman capital letter “N” 

followed by the registration number of the aircraft in compliance with 14 CFR 45.23 and 

14 CFR 45.27. The Petitioner will register the UAV with the FAA and ensure UAV is marked as 

appropriate before using the UAV in the NAS for commercial purposes. 

IV. 14 CFR 45.29 

The Petitioner request relief from the size requirements under this section due to the 

size limitations of the UAV. We propose to use marks as large as possible on the UAV 

as well as keep registration information with the PIC during operation. 

V. 14 CFR 61.113 

The Petitioner requests relief from 14 CFR part 61.113 The flight is only incidental to the 

proposed business or employment; and the aircraft does not carry passengers or property for 

compensation or hire. However, The applicant contact is a fixed wing S/ME IFR rated US 

airman with a second class medical. 

VI. 14 CFR 91.9 

Relevant materials shall be kept in a location accessible to the PIC in compliance with the 

regulations.
VII. 14 CFR 91.103 

This section does not apply to small UAV due to restrictions already imposed under 333. All 

flights are VFR. However, The PIC will follow all other applicable pre-flight actions as 

recommended by the manufacturer, including reviewing weather, flight requirements, and 

aircraft performance data before initiation a flight. 

VIII. 14 CFR 91.119(b,c) 

The Petitioner requests relief from this section because altitude restrictions are already 

provide within 333 and minimum vertical obstacle clearances are greater than currently 

approved for 333 UAS operations. The PIC will ensure the UAV is operated in controlled 

environment and as defined in section (d), If the operation is conducted without hazard to 

persons or property on the surface.

IX. 14 CFR 91.151 

The Petitioner requests exemption from this section due to the maximum flight time 

available from this UAV. The UAV total flight time is limited to 30 minutes and therefore 

the PIC would not be able to meet the minimum standards and still conduct the 

inspections. The UAS is equipped with a visual battery indicator that displays the battery 

levels at all time. 

Additionally, the UAS has a visual alarm that indicates when the battery reaches a state 

of 20% battery life, or approximately 7 minutes of flight time. These indicators, coupled 

with pilot awareness and the emergency return-to- station setting will supply ample time 

to land the UAV safely in the event of low battery.

X. 14 CFR 91.203 

The Petitioner requests relief from 14 CFR 91.203 as the appropriate airworthiness 

certificate does not exist for this UAS. Additionally, the certificate cannot be displayed in the 

aircraft due to the size and physical structure of the UAV. 

XI. 14 CFR 91.405, 407, 409, 417 

The Petitioner requests relief from 14 CFR 91.405, 407, 409, and 417 The above-cited 

regulations require, in general, aircraft owners and operators to inspect the aircraft “...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.” These regulations apply to aircraft with an Airworthiness Certificate. 

Therefore, these sections are not applicable to this UAS. Operators will adhere to 

requirements located within the operations manual.

(d) The reasons why granting this request would be in the public interest; that is, 

how it would benefit the public as a whole

I. Personnel Safety 

 Construction sites and land movements are areas of his risk for inspector and 

 any foot traveler. With the help of UAS more complete site inspections can be 

 performed without risking the life and safety of employees. 

II. Access to remote or Unreachable areas 
 Segments of Construction Sites, dams, farms, pipelines, and bridges may 

 currently be or become unreachable, partially obscured, or impracticable for 

inspection by conventional means, such as physically walking the line, or utilizing

airplane or helicopters for inspections. Access to assets can also be partially or 

completely blocked by environmental singularities, such as vegetation growth, or 

blocked by mechanical means such as vehicle accidents, new construction, or road 

maintenance. The use of our UAV will ensure access to remote or impassable areas on 

an as-needed basis as well as during or after uncontrolled singular events. 

III. Cost Effectiveness 

 Currently, multiple personnel consisting of agency officials, employees and/or 

 contractors are often required to conduct field inspections on large projects over 

 vast amounts of terrain in order to ensure public safety and meet regulatory 

 requirements. Inspections can require a substantial amount of person-hours and 

 persist for days or weeks at a time due to terrain and accessibility issues. 

 Factoring in engineering, planning & scheduling, safety meetings, mileage, 

 recovered man-hours, potential down time due to injury, potential worker’s 

 compensation savings, and the intangible consideration of keeping employees 

injury-free, the current system of inspecting these assets becomes cost prohibitive. 

UAV inspections in select areas are timelier, safer and more efficient 

 than the conventional methods for conducting these inspections. Our UAV 

 inspections will free up otherwise occupied employees, and provide a more 

 economic approach to the traditional inspection, thus lowering operational costs. 

 Lower overhead for corporations could lead to end-user savings such as 

 decreased utility bills.

(e) The reasons why granting the exemption would not adversely affect safety, or 

how the exemption would provide a level of safety at least equal to that provided 

by the rule from which the exemption is sought

The petitioner states that the unmanned aircraft (UA) to be operated under this 

request is less than 25 lbs. fully loaded, flies at a speed of no more than 44 knots, 

carries neither a pilot nor passenger and operates exclusively within a secured area as 

set out in the POH. 

The crafts are the Chroma, a Quad-rotor (with 4 motors), manufactured by Horizon 

Hobby. The Infinity-9 and Cinewing 8E crafts are an Octorotor-type design that has 

eight motors. All systems include GPS system, full autonomous autopilot capabilities, 

telemetry and manual ground control. 

 In addition, each craft has integrated safety features built into the design of the 

 UAS, as described in the POH, to ensure the safety of persons and property 

 within and surrounding the limited operating area. In the event of a 

 communication loss in manual control, the UAS switches to GPS control and 

 return to its takeoff coordinates to perform a “Fail Safe Landing” within the 

 Security Perimeter. It will also have the capability to abort a flight in the event of 

 unpredicted obstacles or emergencies. 

 II. The aircraft will be operated with both a PIC and a ground-based Visual 

 Observer (VO) in accordance with FAA Policy N 8900.227 Section 14, 
Operational Requirements for UAS. Operations will be conducted with the permission 

of the land owner. A Observer will be present during UAS flight operations The PIC will 

file a Notice to Airmen (NOTAM) providing location and a date/time of the flight.

III. This exemption will provide a greater level of safety to that provided by the rule 

from which the exemption is sought. Because UAS flights are not currently authorized 

for commercial use, methods for inspecting, surveying assets are limited to pedestrian 

or helicopter operations. Where helicopter operations are not feasible due to 

environmental or mechanical obstructions, and or Structural elements, utilizing the UAV 

will provide a safe alternative to the inherent dangers of walking through these regions 

to conduct the required inspections. The small size, extreme maneuverability and 

zoom capabilities on the camera allow for a safe, unimpeded inspection of critical 

infrastructure assets.

(f) Summary to publish in the Federal Register

Sabrecross, Inc, dba Flying Targets seeks exemption under §333 of the FAA 

Modernization and Reform Act of 2012 (Public Law 112-95) from 14 CFR 21; 14 CFR 36, 

45.23; 45.27, 45.29; 61.113; 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 

91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) II. 

The exemption would allow commercial operation of small Unmanned Aircraft Systems 

(UAS) for aerial surveillance and observation, cinematography, aerial photography, inspection 

focused on Construction and Technical Applications, surveying, mapping, Aerial target support 

for controlled events and other related services. 

CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security – provide more than adequate justification for the grant of the requested exemptions 

allowing commercial operation of Sabrecross, Inc dba Flying Targets UAS for aerial surveys, cinematography 

and photography.