February 2"d, 2016 

Paul Wendler 

2526 1041h LN SE, 

Olympia, WA 98501 

RE: Federal Aviation Administration Petition 

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I, Paul Wendler, am writing pursuant to the FAA Modernization of Reform Act of 2012 and the 

procedures contained within 14 C.F.R. 11, To request that I, Paul Wendler, an owner and operator of a 

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. 

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 ut:~manned 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 LED's, 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 S~ction 333 of the reform Ac~. 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 of 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. 919 (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 in 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, Paul Wendler, 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 sensdr. 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 

time 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, Paul Wendler, 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, Paul Wendler, will perform preflight inspections of the 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 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 weight SOOOibs. or more, are operated 

by an onboard pilot and may carry other on board crewmembers, as well as 100 gallons or more of fuel. 

The petitioner's UAS weighs less than Sibs. 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, 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, 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)(l) and {2), 14 C.F.R. 91.417 (a) and (b) 

With the exemptions from 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 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, Paul Wendler, 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 a n 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 

Paul Wendler 

UAV Owner/Operator 

2526 104th LN SE 

Olympia, WA 98501 

Phone: {360)918-6495 

ion, 

Email: paulmwendler@yahoo.com