July 31, 2015

Casey Lee 6204 Oyster Bay Road Olympia, WA 98502 Phone: (360) 401

- 5088 Email: imkc5252@gmail.com

RE: Federal Aviation Administration Petition

I, Casey Lee, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Casey Lee, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Casey Lee, may operate an unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”) in accordance with FAA UAS Regulations &
Policies.

I would like to formally submit for an exemption from the following Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 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)(1) and (2), 14 C.F. R. 91.417(a) and (b). To operate the Turbo Ace Matrix Quadcopter pursuant to the user manual and limitations outlined within. This proposed exemption would allow me operation of unmanned aircraft systems (UAS) for the purpose of aerial videography and phot ography services or as a service to the public

- interest. As found in exemption No. 11138 (Trudeau), the FAA has granted exemptions for video and photography services using similar equipment

.

This device (Turbo Ace Matrix) was carefully selected for its pr oven reliable flying capabilities managed by gyro stabilized flight, ground detection, GPS aided navigation, a compass, blinking LEDs, failsafe mode for returning home and large prop size for superior stability . This will act to further safety precautions specific to lightweight UAS’s used for video and photography

. I will record flight
data and other pertinent information to share with the FAA or desired government a gency to assist with future protocol and safety regulations.Specific section or sections of 14 CFR which I seek relief and the reason I seek relief:

14 C.F.R. Part 21: Airworthiness Certificates

Given the size and limited operating area associated with my services , an exemption from Part 21 meets the requirements of an equiva lent lev el of safety under Part 11 and Section 333 of the reform
Act. In all cases, an analysis of these criteria demonstrates that the UA operated without an
ai rworthiness certificate, in the restricted environment and under the conditions proposed will b e at lea st as safe, or safer, than conventional aircraft operating with an airworthiness certi ficate without
restrictions and conditions proposed.

14 C.F.R. 45.23: Display of marks: general

The UAs will not have a cabin, cockpit, pilot station, fuselage, b oom, or tail on which to mark certain words or phrases. Further, the two inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement.

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitat ions: Pilot in command

The FAA has previously declared that additional manned airship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously issued exemptions to t h is regulation through Exemption Nos. 11062 and
11138.

14 C.F.R 91.7: Civil aircraft airworthiness

Currently, since there is no certificate applicable to the U As in question, this regulation is inapplicable.

14 C.F.R. 91.9 (b)(2): Civil aircraft flight m anual, marking, and placard requirements

Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on board this aircraft and given its size, this regulation is inapplicable. An equivalent level of safety will be
achieve d by maintaining a safety/flight manual with the operator.

14 C.F.R. 91.119(c): Minimum safe altitudes

I, Casey Lee
, will ensure that any UAS do es not oper ate any higher than 400 feet above ground level
and not fly over congested areas containing people

. I will plan ope rations before hand for proper
f light safety and proper height analysis as to avoid collisions and/or conflicts

.14 C.F.R. 91.121: Altimeter settings

The UAS utilize electronic GPS with a barometric sensor . An equivalent level of safety wi ll be achieved by using this.

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

The UAS that I fly is powered by electricity, using lithium polymer batteries that currently have a flight limit of approximately no more than 2 5 minutes. Therefore, due to the limitations of the batteries, it is currently impossible to comply with part 91.151.

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required

Currently, there are no procedures for providing air worthiness certif icates for the Turbo Ace Matrix UAS. I, Casey Lee , however will always fly within the guidelines of all federal regulations and with extreme safety in mind

.

14 C.F.R. 9 1.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation after maintenance, pre ventive maintenance, rebuil ding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance records

Maintenance inspections may be required and should b e granted since they only apply to aircraft
with an airworth iness certificate. However I, Casey Lee , will perform preflight inspections of the UAS before each flight as outlined in the operating documents. I, Casey Lee , will also follow manufacturer recommendations from said operating documents.

Public Interest

Aerial photography and videography as an available service to the public allows for a cheaper method to capturing aerial imagery than its alternative. Its alternative being aircraft and helicopters. They are expensive, create lots of noise, and are much mo re dangerous due to size and combustible
fuel. Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are operated by an onboard pilot and may carry other onboard crewmembers, as well as 100 gallons or more of fuel. The pe titi oner’s UAS weighs less than 5 lbs. The pilot and crew will be remotely located from the aircraft. The limited weight reduces the potential for harm to persons or damage to property in the event of an incident or accident. The risk of an onboard pilot a nd crew during an
incident or accident is eli minated with the use of a UAS for the proposed operation.Summary

I, Casey Lee , am seeking exemption from the following rules:

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C .F.R.91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 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)(1) and (2), 14 C.F.R. 91.417(a) and (b)

With the exemptions from the mentioned rul es I, Casey Lee, will be seeking to make my aerial photography/videography services available to the public. Historically, the public would seek helicopters and aircraft to achieve what I offer in a safer, more cost efficient manner. By not using
combustib le fuel, flying at safe he ights and strictly following federal regulations and safety requirements my services will aide to the public interest

. I, Casey Lee, promise to carefully abide by the following guidelines to ensure compliance and safety :

• Fly Matrix Ace Turbo UAV cautiously and courteously

• Maintain altitude below 400 feet

• Perform p roper visual inspection of UAS before all flights

• Keeping mentioned UAS in visual sight at all times when in operation

• Use an observer to assist if needed

• Do not in terfere with manned aircraft operations and avoid other aircraft

• Not intentionally fly over unprotected persons or moving vehicles

• Contact the airport or control tower bef ore flying within 5 miles of an airport

• Not flying in adverse weather conditions suc h as high winds or reduced visibility

• Not flying under the influence of alcohol or drugs

• Ensure the operating environment is s afe

• Not flying over sensitive infrastructure

• Check and follow all local laws and ordinances before flying over private property

• Do not conduct surveillance or photograph p ersons in areas where there is an expectation of privacy without the individual's permission

Thank you for your consideration,

Casey Lee UAV Owner/Operator 6204 Oyster Bay Road Olympia, WA 98502 Phone: (360) 401

- 5088 Email: imkc5252@gmail.com