February 

### 2"d, 2016

Paul Wendler 2526 1041h LN SE, Olympia, WA 98501
RE: Federal Aviation Administration Petition ,-,'**~,** ! • {_,': .j

I, Paul Wendler, am writing pursuanttothe FAA Modernization of Reform Act of2012 and the procedures contained within 14 C.F.R. 11, To request that I, Paul Wendler, an owner and operator ofa small unmanned aircraft, be exempted from Federal Aviation Regulations (FARs") listed below so that I, Paul Wendler, may operate a n unmanned aircraft system ("UAS") commercially in airspace regulated by the Federal Aviation Administration ("FAA") in accordance with FAA UAS Regulations & Policies. Iwould like to formally submitfor 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), 14C.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 theTurbo Ace Matrix Quadcopter pursuantto the user manual and limitations outlined within. This proposed exemption would allow me operation of**ut:~manned** aircraft systems (UAS) forthe purpose ofaerial videography and photography services or as aservice to the public-interest. As found in exemption NO. 11138(Trudeau),The FAA has granted exemptions forvideo 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 LED's, failsafe mode for returning home and large prop size for superior stability. This will act to further safety precautions specificto lightweight UAS's used forvideo and photography. Iwill record flight data and other pertinent information to share with the FAA ordesired government agency to assist with future protocol and safety regulations.


### Specific section or sections of 14CFR which I seek relief and the reason I seek relief: 14C.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 ofan equivalentlevel ofsafety under Part 11 and**S~ction** 333 ofthe reform**Ac~.** In all 

### cases, an analysis ofthese criteria demonstratesthatthe UA operated without an airworthiness certificate, in the restricted environment and underthe_conditions proposed will be at least as safe, orsafer, than conventional aircraft operatingwith an airworthiness certificate without restrictions and conditions proposed.

14 C.F.R. 45.23: Display of marks: general The UAs will not have acabin, cockpit, pilotstation, fuselage, boom, or tail on which to mark certain words ofphrases. Further, the two inch lettering is difficultto place on such a small aircraftwith dimensions smallerthan 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 ofacommercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously issued exemptionsto 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. 919 (b)(2): Civil aircraftflight manual, marking, and placard requirements Requires an aircraftflight manual in the aircraft, howeverthere are no pilots or passengers on board this aircraft and given its size, this regulation in is inapplicable. An equivalent level ofsafety will be achieved by maintaining asafety/flight manual with the operator.

14 C.F.R. 91.119 (c): Minimum safe altitudes I, Paul Wendler, will ensure that any UAS does notoperate any higherthan 400 feet above ground level and notfly over congested areas containing people. Iwill plan operations before hand for properflight 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 sensdr. An equivalent level ofsafety will be achieved by using this.14 C.F.R. 91.151(a)(1): Fuel Requirements forflight in VFR conditions The UAS that Ifly is powered by electricity, using lithium polymer batteries thatcurrently have aflight time ofapproximately no more than 25 minutes. Therefore, due to the limitations ofthe batteries, it is currently impossible to comply with part 91.151.

14C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required Currently,there are no procedures for providing airworthiness certificates forthe Turbo Ace Matrix UAS. I, Paul Wendler, howeverwill always flywithin the guidelines ofall federal regulations and with extreme safety in mind.

14 C.F.R. 91.405(a): Maintenance Required, 14C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, oralteration, 14C.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 applyto aircraftwith an airworthiness certificate. However I, Paul Wendler, will perform preflight inspections ofthe UAS before each flight as outlined in the operating documents. I, Paul Wendler, will also follow manufacturer recommendations from said operating documents. 

### Public\nterest Aerial photography and videography as an available service tothe public allows for acheaper method to capturingaerial imagerythan 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 weight SOOOibs. or more, are operated by an onboard pilot and may carry otheronboard crewmembers, as well as 100gallons or more offuel. The petitioner's UAS weighs less than Sibs. The pilotand crew will be remotely located from the aircraft. The limitedweight reduces the potential for harm to persons ordamage to property in the eventofan incident oraccident. The risk ofan onboard pilotand crew duringan incidentoraccident is eliminated withthe use ofa UAS forthe proposed operation.Summary I, Paul Wendler, 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), 14C.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, 14C.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)(l) and {2), 14 C.F.R. 91.417 (a) and (b) With the exemptionsfrom the mentioned rules I, Paul Wendler, will be seeking to make my aerial photography/videography services available to the public. Historically, the public would seek helicopters and aircraftto achieve what Ioffer in asafer, more cost efficient manner. By not using combustible fuel, flying at safe heights and strictlyfollowing federal regulations and safety requirements myservices will aide to the public interest. I, Paul Wendler, promise to carefully abide by the following guidelines to ensure compliance and safety:
• Fly MatrixAce Turbo UAV cautiously and courteously • Maintain altitude below 400 feet • Perform propervisual inspection of UAS before all flights • Keeping mentioned UAS in visual sight at all times when in operation • Use an observerto assist ifneeded • Do not interfere with manned aircraft operations and avoid other aircraft • Not intentionallyfly over unprotected persons or movingvehicles • Contact the airport or control tower before flyingwithin 5 miles ofa n airport • Notflying in adverse weather conditions such as high winds or reduced visibility • Notflying underthe influence ofalcohol or drugs • Ensure the operating environment is safe • Notflying over sensitive infrastructure • Check and follow all local laws and ordinances before flying over private property • Do notconduct surveillance or photograph persons in areas where there is an expectation ofprivacy withoutthe individual's permission

Paul Wendler UAV Owner/Operator 2526 104th LN SE Olympia, WA 98501 Phone: {360)918-6495 ion,

Email: paulmwendler@yahoo.com