Prepared for: Federal Aviation Administration

Docket Management Facility US Department of Transportation

Prepared by: Jerry Bruce /ADiversepov.com, Caesars Entertainment Services

PO Box 60332, Boulder City, NV. 89006

March 17, 2016

Contents

Petition for Exemption Letter

FAA UAS Civil COA Request

Location of proposed operation with VFR Chart 

UAS Certificate # FA3MY3XCP

Proof of Ownership
Petition for Exemption under section 333 of the FAA reform Act and Part 11 of

Aviation Regulations.

 I, Jerry Bruce, dba. ADiversePOV.com and an employee of Caesars Entertainment 

Corporation and holder of a Commercial Pilot Certificate hereby applies for an exemption 

from the listed Federal Aviation Regulation (FARs) to allow me to operate a small unmanned 

UAS (unmanned aerial system) seeks exemption from the requirements of.Specifically we 

request an exemption from part 21, subpart H; and Sections 45.23(b),61.113(a) and (b), 

91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91 .151 (a), 91 .203(a) and (b), 

91.405(a), 91.407(a)(1 ), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal 

Regulations (14 CFR). to operate an Unmanned Aircraft System (Turbo Ace Matrix) 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This 

exemption will permit ADiversepov.com operate an Unmanned Aerial Vehicle (UAV) for the 

commercial purpose of conducting aerial video and photography of the Cascata Golf 

Course in Boulder City, NV. 

Part 21 prescribes the procedural requirements for issuing and changing design approvals, 

productions approvals, airworthiness certificates, and airworthiness approvals.2

Section 45.23(b) prescribes that when marks include only the Roman capital letter "N" and 

the registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that 

aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental,n or "provisional," as applicable.

Because of the size of the aircraft we propose to install the "N" on the fuselage but do 

not think there is adequate space to also place any of the categories mentioned. 

However we have installed the N number in a location that is visible but on a smaller 

scale. N6789X

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by AdiversePOV.com to the extent 

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, 

as well as an airman medical certificate, and who has demonstrated, by meeting minimum 

flight hour and currency requirements, that the PIC is able to safely operate the Turbo Ace 

Matrix UAV in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures.

Since we will not be carrying any passengers or property for compensation my 

“limited” commercial pilot will carry out the responsibilities as PIC.
Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an 

airworthy condition.

An exemption is requested to 91.7(a) because the UAV does not have to receive an 

airworthiness certificate by the FAA.

Section 91.7 (b) prescribes that the pilot in command of a civil aircraft is responsible 

for determining whether that aircraft is in condition for safe flight and that the PIC 

shall discontinue the flight when an airworthy mechanical , electrical or structural 

conditions occur.

We will terminate any flight should the aircraft become un airworthy with mechanical, 

structural or electrical issues.

Section 91.9(b)(2) prohibits operation of US registered civil aircraft unless there is 

available in the aircraft a current approved Airplane or Rotorcraft Flight 

Manual,approved manual material , markings and placards or any combination 

thereof.

 There is no FAA approved manual for the Turbo Ace Matrix. We will submit a preflight check list and emergency procedure should there be a loss of signal to ensure a 

safe flight.

Section 91.103(b) prescribes that a pilot shall for any flight become familiar with 

runway lengths at airports of intended use, and takeoff and landing distance 

information.

 The Turbo Ace Matrix does not use any runway or fly anywhere near an airport.

Therefore we request exemption from the requirement.

Section 91.109(a) prescribes, in pertinent part, that no person may operate a civil 

aircraft (except a manned free balloon) that is being used for flight instruction unless 

that aircraft has fully functioning dual controls. 

The Turbo Ace Matrix does not have dual flight controls. It is flown by the one Radio 

control transmitter. We therefore request exemption from this requirement .

Section 91.119 prescribes that, except when necessary for takeoff or landing, no 

person may operate below the following altitudes.

(a)Anywhere an altitude allowing, if a power unit fails , an emergency landing without 

undue hazard to persons or property on the surface.

The Turbo Ace Matrix will not be flown near of around any power lines, lights poles or 

light fixtures.
(b) Over congested areas. Over any congested area of a city, town or settlement or 

any open air assembly of persons, an altitude of 1000 ft above the highest obstacle 

within a horizontal radius of 2,000 feet of the aircraft.

The Turbo Ace Matrix will not be flown over any congested areas, city, town, 

settlement or open air assembly of persons. 

(c) Over other than congested area. An altitude of 500 ft above the surface, except 

over open water of sparsely populated area. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle or structure.

The Turbo Ace Matrix will not be flown over any open water or sparsely populated 

area. 

Section 91.121 requires, in pertinent part, each person operating an aircraft to 

maintain cruising altitude by reference to an altimeter that is set..”to the elevation of 

the departure airport or an appropriate altimeter setting available before departure.

The Turbo Ace Matrix does not have a barometric altimeter but relies on GPS signal 

from the NAZA VM2 flight control system. This information is displayed to the PIC on 

the FPV screen. 

Section 91.151(a) prescribes that no person may begin a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing and assuming normal cruising 

speed, (1) during the day, to fly after that for at least 30 minutes

The Turbo Ace Matrix does not carry any liquid or solid fuels. It is powered strictly by 

1 8,000mah Lithium-Polymer (LIPO) battery which has a run time in normal conditions 

of around 26 minutes. the FPV system displays a low battery warning symbol. 

Request exemption from this requirement. 

Section 91.203(a) prohibits, in pertinent part, that no person may operate a civil 

aircraft unless the airworthiness certificate : and (2) an effective U.S. registration 

certificate issued to its owner or ,for operation within the United States, the second 

copy of the Aircraft registration Application as provided for in § 47.31(c)

An exemption is requested for the airworthiness requirement since the Turbo Ace 

Matrix does not have an airworthiness cert.
Section 91.203(b) prescribes , in pertinent part, that no person may operate a civil 

aircraft unless the airworthiness certificate or a special flight authorization issued 

under § 91.715 is displayed at the cabin or cockpit entrance so that is legible to 

passengers and crew.

Since there is no requirement for an airworthiness certificate for the Turbo Ace Matrix. 

We have registered the Turbo Ace Matrix with the N# N6789X. Though it does not meet 

the minimum size criteria we have registered it regardless. 

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall 

have that aircraft inspected as prescribed in subpart E of the same part and shall, 

between required inspections, except as provided in paragraph (c) of the same 

section, have discrepancies repair as prescribed in part 43 of the chapter 4

There is no scheduled or approved maintenance program for the Turbo Ace Matrix but 

the owner/operator has a maintenance facility to have repairs done as needed to 

ensure safety for both the aircraft and personnel.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft 

that has undergone maintenance, preventative maintenance , rebuilding, or alteration 

unless it has been approved for return to service by an authorized person under § 

43.7 of that same chapter.

After any routine maintenance or major repairs the turbo Ace Matrix will be test flown 

by the PIC in a remote area to ensure safe operation. 

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had an inspection for 

the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

After any routine maintenance or major repairs the turbo Ace Matrix will be test flown 

by the PIC in a remote area to ensure safe operation. 

Section 91.417(a) and (b) prescribes, in pertinent part, that-

(a) Each registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each engine, 

propeller, rotor, and appliance of an aircraft. The records must include-

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and

(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for 

return to service.

( 2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each

propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under

which the aircraft and its appliances are maintained.5

(v) The current status of applicable airworthiness directives (AD) and

safety directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves recurring 

action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods 

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the

work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service.

The Turbo Ace Matrix has a flight log in which we record all flight times and any 

maintenance performed on the aircraft. There is no built in airworthiness directives on 

the Turbo Ace Matrix. We will rectify any discrepancies should any arrive. 
Public Interest

Our intention is to film the golf course for advertisement purposes and apply the videos to 

our company website. The flights will be initiated from each and all 18 tee boxes and flown 

to all respective greens detailing yardages, hazards and obstacles. Altitude will be from the 

surface to 200ft. AGL.

Obtaining an exemption for this project will mean potential increase in our business allowing 

our current and future guests to view the course before and /or after they play it. Attracting 

more visitors to our site and viewing capabilities will bring an increase of interest to our golf 

course and therefore help our business to expand in conjunction with increased profits. 

Safety 

 Safety being our primary goal we look to this operation as a safer alternative.Utilizing the 

UAV as opposed to a manned helicopter will greatly improve safety and costs due to the 

shear size and capability of the UAV. A helicopters weight and rotor wash at low altitude will 

adversely effect video quality. A manned helicopter can cost in upwards of $25,000 dollars a 

day when factoring in people ,equipment, noise pollution and risk of accidents and or death 

of flight crews. The UAV is quiet and almost undetectable when flying. The UAV in use 

weighs approximately 4 pounds. The UAV will be flown strictly with no players or spectators 

on the course during flight operations. 

 The UAV in use will be a Turbo Ace Matrix with GPS, NAZA VM2 flight control system

a three axis gimball with a GoPro 3+ camera mounted on the nose and a Futaba 14SG Long 

Range radio transmitter coupled with a R7008SB 2 way receiver and telemetry voltage 

sensor. The system includes a “Fail Safe” and “Go Home” feature in the event of loss of 

signal. It is powered by 1, 8000mah Lithium-Polymer (LiPo) battery along with 1, 2200mah 

Lithium-Polymer battery for the camera gimbal.It is constructed of a carbon fiber body and 

square aluminum tubular arms with four TA-Mat 13 balanced brushless motors. Flight time is 

approximately 26 minutes. The UAV weighs approximately 4 pounds.

All flights will be performed during DAYLIGHT operation only. There will be NO players or 

spectators at the time of flights for SAFETY concerns. The only buildings on the property are 

the golf pro shop and restaurant (one building) there are NO HOMES or other structures on 

the course. 
 The area of designated flight is the Cascata Golf Course located in Boulder City NV. The 

golf course is over 400 acres of PRIVATE PROPERTY (but is open to the public). Location is 

approximately 2.0 miles northwest of the city. Below is a list of all Latitude and Longitude 

specifications from the VFR sectional chart.

#1 Hole Tee Box Latitude 35.975106 -Longitude 114.895374 

#1 Green Latitude 35.977789 - Longitude 114.894826

#2 Hole Tee Box Latitude 35.978327 - Longitude114.894590 

#2 Green Latitude 35.981342 -Longitude 114.893770 

#3 Hole Tee Box Latitude 35.981189 -Longitude 114.892498

#3 Green Latitude 35.976615 -Longitude 114.892868

#4 Hole Tee Box Latitude 35.976898 - Longitude 114.893861 

#4 Green Latitude 35.975215 - Longitude 114.894118 

#5 Hole Tee Box Latitude 35.974608 - Longitude 114.893458

#5 Green Latitude 35.978310 - Longitude 114.891409 

#6 Hole Tee Box Latitude 35.978009 - Longitude 114.890524 

#6 Green Latitude 35.980581 - Longitude 114.888797

#7 Hole Tee Box Latitude 35.980557 - Longitude 114.887300

#7 Green Latitude 35.981177 - Longitude 114.886007

#8 Hole Tee Box Latitude 35.978488 - Longitude 114.882445

#8 Green Latitude 35.981471 - Longitude 114.883620 

#9 Hole Tee Box Latitude 35.981471 - Longitude 114.882499

#9 Green Latitude 35.978334 - Longitude 114.881099

#10 Hole Tee Box Latitude 35.978125 - Longitude 114.881705

#10 Green Latitude 35.974411 - Longitude 114.882172

#11 Hole Tee Box Latitude 35.974024 - Longitude 114.881115

#11 Green Latitude 35.976750 - Longitude 114.880562

#12 Hole Tee Box Latitude 35.977769 - Longitude 114.880482

#12 Green Latitude 35.978899 - Longitude 114.879624

#13 Hole Tee Box Latitude 35.979372 Longitude 114.877655

#13 Green Latitude 35.976431 - Longitude 114.878293

#14 Hole Tee Box Latitude 35.975989 -Longitude 114.879082

#14 Green Latitude 35.973110 - Longitude 114.880064

#15 Hole Tee Box Latitude 35.974043 - Longitude 114.881667

#15 Green Latitude 35.973251 Longitude 114.883604

#16 Hole Tee Box Latitude 35.974221 - Longitude 114.883604

#16 Green Latitude 35.977972 - Longitude 114.883229

#17 Hole Tee Box Latitude 35.979280 Longitude 114.886844

#17 Green Latitude 35.976081 - Longitude 114.889092

#18 Hole Tee Box Latitude 35.975271 Longitude 114.888550

#18 Green Latitude 35.973472 - Longitude 114.89315
The Cascata Golf Course is located at 1 

Cascata Dr. in Boulder City, NV. 89005 

Golf course is designed on 451 acres of 

rolling hillside land. 
Proof of Purchase

Order Information 

Order Number: 

131947 

Date: 

3/24/2014 12:44 PM 

Status: 

Shipped - Payment Completed 

Status Description: 

Net term 

Shipping Method: 

PICKUP ONLY- ITEM WILL NOT BE SHIPPED- SELECT Click here for rates BELOW FOR 

MORE SHIPPING OPTIONS 

Tracking Number(s): 

9400110200793196427395-RMA 07/21

Sales Rep: 

Customer Information 

Customer: 

Jerry Bruce 

Email: 

Jbruce081@gmail.com 

Ship To 

Jerry Bruce 

511 Lake Winnebago Lane 

Boulder City, NV 89005 United States 

Phone: 7024993904 

Bill To 

Jerry Bruce 

511 Lake Winnebago Lane 

Boulder City, NV 89005 United States 

Phone: 7024993904 

Additional Information 

Policy Agreement:

I have read and agree to the Shipping, Return, and Privacy policies. 

Product Information 
Product Name 

Item Number 

Quantity 

Item Price 

Total Price 

Turbo Ace Battery Meter: 16C Measures 1-6 Cell Lipo, Measures 2.8V-25.2V For 

All RC Helicopters 

TE-16C-BATTERY-METER 

1 

$6.95 

$6.95 

Turbo Ace Matrix-S Options: (Naza/A2, TX/RX/Telem, Gimbal & Vibration 

Isolation, FPV Monitor & Goggles, Battery, Charger, Training) 

Matrix Model Options: .Matrix-S + NAZA-M V2 + GPS + C4 Vibration Isolation Deck: Apply 

couponcode "Matrix300" at checkout for $300 off from $2,527.95 = (Matrix-S+NazaV2+GPS

+C4) 

Transmitter, Receiver & Telemetry Options: .Futaba 14SG Long Range Transmitter (14-

Channel) & R7008SB 2-Way Receiver (8-Channel) @ $599.97 + Telemetry Voltage Sensor 

Installed @ $88 = (14SG+R7008SB+VoltageSensorInstalled) 

Gimbal & Vibration Isolation: .Gyrox-3 Brushless Gimbal for Hero 3/3+ (Ultra Fast AutoStabilized Tilt-Axis & Roll-Axis, Pilot Controlled Tilt-Axis) + CNC Bracket + Installation 

(Gyrox3+MAT-06+Installation) 

Cameras: .None 

FPV Plug & Play with Monitor or Goggles: .FPV Plug & Play + TVL Camera: 8" FPV 

Monitor & Sunshield + Battery + Carbon Bracket for Futaba 14SG + VTX & VRX (ID: 

S29TX5803) (8"M+TVL+CT5535+2200-15C-D+CF-Bracket+VTXVRX) 

On Screen Display: .iOSD Mini: On Screen Display + Installation (Available for Naza-M V2) 

(DJI-IOSDMINI+Install) 

Free Batteries + Extra Batteries: .(1x) Free + (1x) Extra Turbo Ace Battery 8000mAh 6S 

(22.2V) 25C LiPo: For Turbo Ace Matrix (TA-8000M-6S-25C-XT90xQty2) 

Free Charger + Extra Charger: .(1x) Free + (1x) Extra CopterX 110V CX-B601 LiPo 

Balance Charger w/Power Supply + All-in-One Cable ((CX-B601 + Charger + All-in-One 

Cable)xQty2) 

Carrying Case: Matrix Industrial Grade Aluminum Case: Fits Matrix-S or Matrix-E 

Quadcopter + Gimbal + Transmitter + Batteries + Spare Parts + Tools (TA-Matrix-S/E-Case) 

Training Package: .None 

Matrix-S+Options 

1 

$4,960.67 

$4,960.67 
TA-MAT-01: A Pair of 15" Carbon Propellers (1 x Clockwise & 1 x Counter 

Clockwise) for Turbo Ace Matrix

TA-MAT-01 

1 

$49.95 

$49.95 

Subtotal:

Total $5,017.57 

Your assistance in this matter is greatly appreciated.! 

Sincerely 

Jerry Bruce dba ADiversepov.com

PO Box 60332

Boulder City , NV. 89006 < jbruce081@gmail.com> 702-499-3904