### 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 A

viation 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



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### Product InformationProduct 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