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. Sect ion 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may oper ate safely in the national airspace system before completion of the (c omprehensive) plan and rule making required by section 332(b)(1) of this Act or the guidance required by
section 334 of this Act.” In Se ction 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 Petiti oner to conduct commercial operations of small unmanned aircraft systems (“UAS”) meeting or ex ceeding all of the operational and safety requirements Congr ess has set forth in Section 333.

Petitioner is an aerial and technical photogra phy 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 th e 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 duri ng 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, accordi ng 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 num ber 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 informa tion 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 fi xed 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 follo w all other applicable pr e-flight actions as recommended by the manufacturer, including re viewing weather, flight requirements, and aircraft performance data before initiation a flight.

VIII. 14 CFR 91.119(b,c) The Petitioner requests relief from this sect ion because altitude restrictions are already provide within 333 and minimum vertical obsta cle 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 sect ion (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 fli ght 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 approxim ately 7 minutes of flight time. These indicators, coupled with pilot awareness and the emergency return-t o- 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 CF R 91.203 as the appropriate airworthiness
certificate does not exist for this UAS. Additio nally, the certificate cannot be displayed in the aircraft due to the size and ph ysical 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 owner s and operators to inspect the aircraft “...as prescribed in subpart E of this part and s hall 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 ar e not applicable to this U AS. Operators will adhere to requirements located withi n the operations manual.

(d) The reasons why granting this request w ould be in the public interest; that is, how it would benefit the public as a whole

I. Personnel Safety

Construction sites and land movements ar e areas of his risk for inspector and any foot traveler. With the help of U AS more complete site inspections can be performed without risking the lif e and safety of employees.

II. Access to remote or Unreachable areasSegments of Construction Sites, dam s, farms, pipelines, and bridges may currently be or become unreachable, part ially obscured, or impracticable for inspection by conventional means, such as physically walking the line, or utilizing airplane or helicopters for inspections. Acce ss to assets can also be partially or completely blocked by environmental singula rities, such as vegetation growth, or blocked by mechanical means such as vehi cle 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 consisti ng of agency officials, employees and/or contractors are often requi red 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 ti me due to injury, potential worker’s compensation savings, and the intangibl e 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 insp ection, thus lowering operational costs. Lower overhead for corporations coul d 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 provid e 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, f lies at a speed of no more than 44 knots, carries neither a pilot nor passenger and operat es 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 cra fts 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 ens ure the safety of persons and property within and surrounding the limited oper ating 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 al so have the capability to ab ort 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 wit h FAA Policy N 8900.227 Section 14,Operational Requirements for UAS. Operations will be c onducted 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) providin g location and a date/time of the flight.

III. This exemption will provide a greater leve l 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. W here helicopter operations ar e not feasible due to environmental or mechanical obstructions, and or Structural elements, utilizing the UAV will provide a safe alternative to the inher ent dangers of walking through these regions to conduct the required inspections. The small size, extreme maneuverability and zoom capabilities on the camera allow fo r 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 co mmercial operation of sma ll Unmanned Aircraft Systems (UAS) for aerial surveillance and observation, ci nematography, 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 ju stification for the grant of the requested exemptions allowing commercial operation of Sabrecross, Inc dba Flying Targets UAS for aerial surveys, cinematography and photography.