Lucas Bucholz

729 SE Manley

Bend, OR 97702

Cell (541) 480-0299

Email: Lucas.bucholz@gmail.com

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

Dear Sir or Madam,

In accordance with the FAA’s 

Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012, I Lucas Bucholz, 

referred to hereafter as the petitioner, request exemption from the following sections of 

Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 

91.409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial 

photography, cinematography, videography, and other flight operations that could be 

performed safely and more cost effectively with the use of small UAS at low altitude 

within the U.S. national airspace system as compared to a manned aircraft. Operations 

will be performed only at the request of and with the authorization and permission of clients or

their authorized agents in order to facilitate commerce and raise awareness of the beneficial 

uses of small unmanned air systems. 

So long as such operations are conducted within and under the conditions outlined herein 

or as may be established by the FAA as required by Section 333. 

The FARs 

The petitioner seeks exemption from the 

above-mentionedFARs for the following reasons; 

61.113(a) & (b);

The petitioner requests relief in order to facilitate the utilization of an FAA licensed

and current Private Pilot (Ty Baxter) with the addition of a Lucas Bucholz as the visual 

observer. All pre-flight inspection, maintenance and flight logs will be saved and made 

available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of 

safely integrating civil UAS operation in the National Airspace System. 

91.119(c) 

The petitioner requests waiver for this condition to allow reasonable and responsible 

operations in areas of subdivisions and neighborhoods if required. The petitioner will primarily

operate the UAS between ground level and 200 feet. The UAS will be operated over 
designated properties with the owner’s consent and while maintaining a safe distance from 

persons. The petitioner will compile flight data from the logs. This data may assist the FAA in 

development of regulations for commercial operations in low-risk, controlled environments.

91.121 

inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS 

with a barometric sensor for altitude information.

91.151(a) 

The UAS provides battery power remaining in percent to the PIC. The 

UA batteries provide approximately 25 minutes of powered flight. Information provided in the 

operating documents discusses procedures regarding remaining battery power management. 

Those documents contain a condition in which the PIC will initiate a landing procedure when 

battery remaining reaches a specified level. Given the limitations on proposed operations and 

the location of those proposed operations, The FAA found that a reduced minimum power 

reserve for flight in daytime VFR conditions was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b)

The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in 

accordance with the operating documents. The FAA found that adherence to the petitioner’s 

operating documents and the conditions and limitations specified, describing the requirements

for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would 

not be adversely affected. 

The UAS 

The S500 is a custom built quadcopter speciicaly for the use of filming and photography with 

a weight of less than 44 Ounces (1242g) designed primarily to carry aloft a high definition 

camera. The flight controler is a DJI naza MV2 which is the leader in uav technology. I have 

attached the manual for you to look at. The rest of the parts are also all DJI products. I 

wanted to have something built that was up to the standards of a commercial uav but with the 

extra features that will help in being safer as well as more options for the PIC and the 

observer to better help clients needs. It has an maximum speed of less than 30 knots (15m/s) 

and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four 

electric motors with a distance between motors of less than 18.7 inches (475mm). It utilizes 

an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with 

global positioning system (GPS) to maintain its geospatial orientation and position. It is 

controlled primarily through an FCC certified radio control (RC) unit. Real time video and 

telemetry information is transmitted back to a ground control station allowing the operator 

and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, 

camera imagery, and control camera angle. It has failsafe modes of operation for either loss 

of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum 

altitude can be preprogrammed by the PIC. Maximum altitude will always be programmed at 

200 ft. Battery life limits flight times to approximately 25 minutes. The onboard flight controller

will warn the pilot via telemetry and external lighting cues before reaching a low battery state. 

An automatic termination of flight and controlled automatic landing will be initiated when the 

battery reaches a predetermined low state. It is anticipated that flights will usually last less 
than 15minutes. 

Risk mitigation 

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations 

section and believes that the procedures specified therein are reasonable and will be 

utilized in order to manage and mitigate risk and ensure public safety. A preflight 

checklist will be developed and employed to ensure that the UA airworthiness will be 

verified before launch. Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance logs to record time on 

failure prone components. These documents will be made available to the FAA and SoT to 

assist in future implementation of safety standards and regulations. The petitioner will only 

operate the UAS over designated properties with the owner’s consent. Flight plans 

will be predetermined to limit the UASs flight time and limit safety concerns. The 

petitioner will take into account distance from persons and potential flight obstacles prior to 

operating the UAS. UAS operation will always be within VLOS of the PIC and the observer. 

Public interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft 

of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in 

order to facilitate commerce could lead to economic growth. Operations for this 

petition will enable service for property owners or their designees seeking an enhanced 

perspective for characteristics, amenities, and benefits of their desired photographic

subjects that cannot be displayed through ground level videography/photography. Aerial 

photography is a valuable marketing tool that can lead to increased commerce and 

enhance personal photography. Aerial surveying and inspections can increase work site 

efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients 

with photographic data for these purposes on a ‘for hire’ basis acting as an 

independent contractor. A visual observer will be utilized. Flight data including

A flight time, Control Unit operation time, incident, accident, and details concerning any 

deviations from normal operations will be available to FAA for use in collecting data 

regarding the use of UAS as part of this application. This data may be submitted to FAA 

via traditional means or other means as required. 

Conclusion 

The petitioner is requesting this exemption for the purposes of “aerial photography, 

cinematography, videography, inspections and surveying other flight operations”. The reason 

for such a general and broad based request is that the petitioner wishes to utilize a business 

strategy of horizontal integration and maximize economies of scope in order to capitalize 

on opportunities as they may arise in the future without the long turnaround time 

associated with additional exemptions. 

Lucas Bucholz