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 photography 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 proven 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 agency 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 equivalent level 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 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than conventional aircraft operating with an airworthiness certificate 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, boom, 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 limitations: 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 this 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 UAs in question, this regulation is 

inapplicable.

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, 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 

achieved 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 does not operate any higher than 400 feet above ground level

and not fly over congested areas containing people. I will plan operations before hand for proper 

flight 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 will 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 25 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 airworthiness certificates 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. 91.405(a): Maintenance Required,

14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, 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 be granted since they only apply to aircraft 

with an airworthiness 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 more 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 petitioner’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 and crew during an 

incident or accident is eliminated 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 rules 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 

combustible fuel, flying at safe heights 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 proper 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 interfere with manned aircraft operations and avoid other aircraft 

• Not intentionally fly over unprotected persons or moving vehicles

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

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

• Not flying under the influence of alcohol or drugs

• Ensure the operating environment is safe

• Not flying over sensitive infrastructure

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

• Do not conduct surveillance or photograph persons 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