February 2nd, 2016

Lisa Wendler 2'526 104th LN SE, Olympia, WA 98501

RE: Federal Aviation Administration Petition I, Lisa Wendler, am writing pursuant tothe FAA Modernization of Reform Act of2012 and the

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### ~--procedure.scontained within 14C.F,R. 11, To requesHhatl, Lisa Wendler; an ownerand operatorofa small unmanned aircraft, be exempted from Federal Aviation Regulations (FARs") listed below so that I, Lisa 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), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1) 114 C.F·:R. 91.203(a)ancl (b), 14·£.F.R. 9·1AOS(a), 14 C.F.R. 91.407(a)(1), 14C.F.R. 91A09(a)(1)and (2), 14C.F.R. 91,4-l'?(a) ·and·(b).Tooperate theTurbo Ace Matrix Quadcopter pursuanttothe_ user manual and limitations.outlinecl within; :fhis proposed exemption would allow me operation of unmanne.d aircraft systems (UAS)forthe purpose ofaerial videography and photography services or as a service 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 specific to 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 14 CFR which Iseek relief and the reason I seek relief: 14 C.F.R. Part 21: Airworthiness Certificates ', I, Giventhe size and lirnited operating area associatedwith myservices; anexemption from Part 21 meets the requirements ofan equivalent l.evel ofsafety.under Part 11 and Section333 ofthe reform.Act. In all cases, an analysis ofthese criteriademonstratesthat**t~e** UAoperatedwithout an airworthiness certificate, in the restricted environment and und.er. the**condition~** pn;>posed 

### will.be atleast 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 acabin, cockpit, pilot station, fuselage, boom, or tail on which to mark certain words of phrases. Further, the two inch lettering is difficultto place on such asmall aircraft with 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 ofa commercially certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously issued exemptions tothis 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 aircraft flight 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, Lisa 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/orconflicts.

14 C.F.R. 91.121: Altimeter settings The UAS utilize electronic GPS with a barometricsensor. 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 that currently have aflight time ofapproximately no morethan 25 minutes. Therefore, due to the limitations ofthe batteries, it is currently impossible to complywith 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 forthe Turbo.Ace Matrix UAS. I, Lisa Wendler, howeverwill always flywithin the guidelines ofall federal regulations and with extreme safety in mind.

14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(l): Operation after maintenance, preventive maintenance, rebuilding, oralteration, 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 applyto aircraftwith an airworthiness certificate. However I, Lisa Wendler, will perform preflight inspections ofthe UAS before each flight as outlined in the operating documents. I, Lisa Wendler, will also follow manufacturer recommendations from said operating documents. Public Interest Aerial photography and videography as an available service tfrthe 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 50001bs. 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 5 lbs. The pilot and crew will be remotely located from the aircraft. The limited weight reduces the potential for harm to persons ordamage to property in the eventofan incident or accident. The risk ofan onboard pilot and crew during an incident or accident is eliminated with the use ofa UAS forthe proposed operation.

### Summary I, Lisa Wendler, am seeking exemption from the following rules: 14 C.F.R. Part 21, 14C.F.R. 45.23(b), 14C.F.R. 61.113(a), 14C.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), 14C.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, Lisa Wendler, will be seeking to make myaerial photography/videography services available tothe public. Historically, the public would seek helicopters and aircraftto achieve what I offer in a safer, 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, I, Lisa Wendler, promise to carefully abide by the following guidelinesto ensure compliance and safety: 

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# • • 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 otheraircraft Not intentionallyfly over unprotected persons or movingvehicles Contact the airport orcontrol tower before flying within 5 miles ofa n airport Notflying in adverse weather conditions such as high winds or reduced visibility Notflying underthe influence ofalcohol ordrugs 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 of privacy withoutthe individual's permission

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Lisa Wendler UAV Owner/Operator 2526 104th LN SE Olympia, WA 98501 Phone: (360)918-6495 Email: paulmwendler@yahoo.com