July 30, 2015

Federal Aviation Administration 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., ” 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

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

Attn: Rick McGee Sabrecross, Inc. P.O. Box 2241 3030 W. Champagne Court Eagle, ID 83616

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 30 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 aircra ft 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 91.103This 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, partia lly obscured, or impracticable for inspection by conventional means, such as physically walking the line, or utilizingairplane or helicopters for inspections. Access to assets can also be partially or completely blocked by environmental singul arities, 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 Tarot 680 is a hex rotor-type design that has six motors, manufactured by Sabrecross, Inc. 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, extr eme 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, 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 operati on of small Unmanned Aircraft Systems (UAS) for aerial surveillance and observation, cinematography, aerial photography, inspection focused on Construction and Technical Applications, surv eying, mapping, and other related services.

CONCLUSION

Satisfaction of the criteria provided in Secti on 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 ade quate justification for the grant of the requested exemptions allowing commercial operation of Sabrecross, Inc UAS for aerial surveys, cinematography and photography.