August 25, 2015

Exemption No. 12598

Regulatory Docket No. FAA−2015−2181

Mr. Robert Buhl

Star View Aerial

1839 256th Street

Lomita, CA 90717

Dear Mr. Buhl:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 19, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Star View Aerial (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

videography, cinematography, and photography to augment real estate listing videos.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Inspire 1 and DJI Phantom 3.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
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aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Star View Aerial is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Star View Aerial is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 and 

DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
May 19, 2015

U. S. Department of Transportation

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Docket Management System

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14

C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109;

119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

I, Robert Buhl dba “Star View Aerial.”, I am writing pursuant to the FAA

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R.

11, to request that I, Robert Buhl, an owner and operator of small unmanned aircraft, be

exempted from the Federal Aviation Regulations listed below so that I, Robert

Buhl, may operate my unmanned aircraft system (“UAS”) commercially in airspace

regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Robert Buhl, an insured member of the AMA (Academy of

Model Aeronautics) am experienced in flying hobby helicopters/planes for recreational

purposes. Currently using a DJI Inspire 1 Quadcopter and Phantom 3 with intent for aerial

videography/cinematography/photography and augment real estate listing videos; following 

exemption and approval by the FAA.

I have flown RC Helicopters/UAS for over five years without incident. Committed to safety

with each flight. My exemption request would permit operation of ultra light weight, UAS(s)

in tightly controlled and limited airspace. Predetermined in areas away from general

public, airports, heliports and vehicular traffic for community videos, and within property

boundaries for individual homeowner real estate listing videos/photos. Currently, similar

lightweight, remote controlled UAS's are legally operated by unmonitored amateur

hobbyists with no safety plan or controls in place to prevent catastrophe. 

1 Appendix A – Personal Protocols and Controls
1 Appendix B- DJI Inspire 1 Manual

Section 333 Exemption Petition

I Robert Buhl,have personally instilled safety

protocols and controls to avoid and prevent public hazard, as well as manned aircraft

hazards/catastrophe. This will act to further safety protocols exclusive to lightweight

UAS's specific to real estate video and photography usage as I, Robert Buhl protocols and controls3to avoid and 

prevent public hazard, as well as manned aircraft

hazards/catastrophe. This will act to further safety protocols exclusive to lightweight

UAS's specific to real estate video and photography usage as I, Robert Buhl,

record flight data and other information gained through permitted flight operations to

share with the FAA through any required FAA reports to assist with future protocol and

safety regulation.

Granting my request comports with the Secretary of Transportation’s (FAA

Administrator’s) responsibilities and authority to not only integrate UAS's into the

national airspace system, but to “...establish requirements for the safe operation of such

aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the

Reform Act specific to the use of UAS's for Cinematography/Photo purposes. Further I,

Robert Buhl, will conduct my operations in compliance with the protocols described

herein or as otherwise established by the FAA.

For the reasons stated below I, Robert Buhl, respectfully request the grant of an

exemption allowing me to operate ultra lightweight, remote controlled UAS’s 

to enhance real estate listing videos for homeowners who cannot afford

expensive manned aircraft. which will promote local

economic growth through increased employment and increased tax base. Both with

public safety in mind by keeping heavier manned aircraft containing combustible fuel

that that poses potential public hazard.

Name and Address of the Petitioner

Robert Buhl dba “Star View Aerial”
1839 256th st 

Lomita, CA 90717

Mobile: 310-877-2486

Email: starthome@sbcglobal.net

Regulations Petitioner Petitions for Exemption, If Such Regulations Apply to

SUAVs

14 CFR Part 21 14 C.F.R. 91.109 14 CFR 91.405 (a)

14 C.F.R. 45.23(b) 14 C.F. R. 91.119 14 CFR 407 (a) (1)

14 CFR 61.113 (a) & (b) 14 C.F.R. 91.121 14 CFR 409 (a) (2)

14 C.F.R. 91.7 (a) 14 CFR 91.151 (a) 14 CFR 417 (a) & (b)

14 CFR 91.9 (b) (2) 14 CFR 91.203 (a) & (b)

14 C.F.R. 91.103

The Extent of relief sought and the Reason He Seeks Such Relief:

I, Robert Buhl, submit this application in accordance with the Reform Act, 112 P.L.

95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent

me, Robert Buhl, to pursue commercial--cinematic, academic and other flight

operations within the national airspace system. The Reform Act in Section 332 provides

for such integration of civil unmanned aircraft systems into our national airspace system

as it is in the public’s interest to do so. My, Robert Buhl’s, ultra light weight UAS

meets the definition of “small unmanned aircraft” as defined in Section 331 and

therefore the integration of my ultra light weight UAS is expressly contemplated by the

Reform Act. I would like to operate my ultra lightweight UAS prior to the time period by

which the Reform Act requires the FAA to promulgate rules governing such craft.

Thereby, providing direct experience and valuable information for formal regulation that

can be administered uniformly to all real estate related UAS aerial video and

photography. The Reform Act guides the Secretary in determining the types of UAS's

that may operate safely in our national airspace system. Considerations include: The

weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be
operated near airports or heavily populated areas; and, Whether the UAS will be

operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an

exemption for meRobert Buhl. My UAS's utilizes four (4) counter-rotating propellers

for balance, control and stability. My UAS's is equipped with GPS and auto return safety

technology. Weighing less than ten (10) pounds (far below the maximum 55 pound

limit); including camera with gimbal.

I, Robert Buhl, considers safety as foremost with each flight. My small unmanned

aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15

mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding

16 kph (20 mph). Built in safety systems include a GPS mode that allows my UAS to

hover in place when radio control inputs are released. With three modes to choose from, I

utilize the Smart Mode for aerial videography/photography. This is the safest, most

reliable and stable mode to prevent accident and hazard. When pilot communication is

lost UAS is designed slowly descend to point of take off. I do not operate my UAS near

airports, Hospitals nor Police heliports, and do not operate near areas where general

public is within fifty to one hundred (50-100) yards depending on location, conditions

and weather. I am constantly on alert for any manned aircraft (Police/Medical

helicopters, etc.) and prepared to land/abort immediately to the nearest and safest

ground point should a manned aircraft approach my location or I suspect manned

aircraft may approach near my location. My UAS is capable of vertical and horizontal

operations, and are flown only within my line of sight of me, as the remote control pilot.

Utilizing battery power rather than combustible fuels, flights generally last between

eighteen (18) to twenty (20) minutes, with an altitude under two hundred (200) feet.

4Smart Mode includes GPS Geofence radius for operation, position hold, self-leveling, altitude command, return 

home feature or land
in the event of communication interruption between RC transmitter and UAS. See Appendix Section 333 

Exemption Petition

I, Robert Buhl, utilize a fresh fully charged battery with each flight as a safety

precaution; full flight time limit for each battery is eighteen (18) to twenty (20) minutes

as tested. I do not operate my UAS at or below manufacturer recommended minimum

charge levels for operation; preferring to remain well within a safe operating range to

insure adequate communication between radio control and UAS to eliminate potential for

crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure

replacement for sufficient safe level of operation. I do not believe in taking risk that may

cause a crash, that could create hazard to the public/property/manned aircraft. I have

clocked over 200+ hours of hobby level flights for future commercial use to gain

familiarization with the characteristics of this specific UAS's performance under different

temperature and weather conditions. I also practice computerized simulated flights to

maintain adequate skills and response reflex time. I, Robert Buhl, am extremely

cautious when operating of my UAS/ultra light weight unmanned aircraft and will not

“create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333

(b). Given the small size and weight of my UAS it falls well within Congress’s

contemplated safety zone when it promulgated the Reform Act and the corresponding

directive to integrate UAS's into the national airspace system. The UAS, used in hobby

flight, has a demonstrable safety record and does not pose any threat to the general public

or national security.
How Robert Buhl’ Request Will Benefit the General Public:

Aerial videography for geographical awareness and for real estate marketing has been

around for a long time through manned fixed wing aircraft and helicopters. However, For

small budget real estate companies and average homeowners the expense of such aerial

videography is cost prohibitive. Only large companies and high end Realtors or luxury

homeowners can afford to absorb such expenses. Depriving non-luxury homeowners

and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat

to the public through potential catastrophic crash that the community has experienced in

the past with military, medical and news/tourism helicopter crashes within the cities. 

Resulting in loss of life and property damage. Each with combustible fuel that exploded

and burned on impact. Police helicopters have made emergency hard landings within

city limits. My UAS pose no such threat since size and lack of combustible fuel alleviates

any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate

commercially flown UAS's into the national airspace system, hence the passing of the

Reform Act. 

My ultra lightweight UAS is battery powered and creates no emissions that

can harm the environment. The consequence of my ultra light weight UAS crashing is far

less than a full size helicopter or fixed wing aircraft; which are heavy, contain

combustible fuel and can cause catastrophic devastation to the public

Section 333 Exemption Petition

The public’s interest is furthered by minimizing ecological and crash threat by permitting

aerial video/photo capture through my battery operated ultra lightweight UAS's.

Permitting me, Robert Buhl, to immediately fly within national air space furthers

economic growth through taxes and revenues generated. 

Reasons Why Robert Buhl’ Exemption Will Not Adversely Affect Safety And

How The Exemption Will Provide a Level of Safety At Least Equal To Existing
Rule:

My, Robert Buhl, exemption will not adversely affect safety. Quite the contrary,

for the reasons stated permitting me, Robert Buhl, to log more flight time in FAA

controlled airspace, with communication with the FAA, will allow me to contribute to the

innovation and implementation of new and novel, as of yet undiscovered safety

protocols for UAS Pilots that can be embraced for development in cooperation with the

FAA. In addition I, Robert Buhl, submit the following representations of enhancements

to current aerial videography and photography:

• My UAS weighs less than 10 pounds complete with a small ultra light weight

high camera

• I only operate my UAS below 200 feet (well within the 400 foot permissible

ceiling set by the FAA Modernization and Reform Act of 2012);

• my UAS only operate for 18-20 minutes per flight;

• I land my UAS prior to manufacturer recommended minimum level of battery

power;

• I pilot my UAS through remote control only by line of sight;

• My UAS has GPS a flight safety feature whereby it hovers and then slowly lands

if communication with the remote control pilot is lost;

• I actively analyze flight data and other sources of information to constantly

update and enhance safety protocols;

• I only operate in reasonably safe environment that are strictly controlled, are

away from power lines, elevated lights, airports and actively populated areas;

• I conduct extensive pre-flight inspections and protocol, during which safety

carries primary importance;

• I always obtain all necessary permissions prior to operation; and,

• I have procedures in place to abort flights in the event of safety breaches or

potential danger.

Section 333 Exemption Petition
My, Robert Buhl’, safety protocols provide a level of safety equal to or exceeding

existing rules. It is important to note that absent the integration of commercial UAS into

our national airspace system, helicopters are the primary means of aerial video and

photography for community awareness and real estate. While the safety record of such

helicopters is remarkably astounding, there has been local incident involving loss of life

as well as extensive property damage; it is far safer to operate a battery powered ultra

light weight UAS.

• First, the potential loss of life is diminished because UAS's carry no people on

board and only operated in specific areas away from mass populations.

• Second, there is no fuel on board a UAS and thus the potential for fire or

explosions is greatly diminished.

• Third, the small size and extreme maneuverability of my UAS allow me to

remotely pilot away from and avoid hazards quickly and safely.

• Lastly, given its small size and weight, even when close enough to capture

amazing images, my UAS need not be so close to the objects they are focused

on through the technology and use of post editing software allowing pan and

zoom.

Accordingly, my UAS has been experimentally operated for familiarization/competency

and will continue to operate at and above current safety levels.

A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 & 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth

requirements for procurement of necessary airworthiness certificates in relation to

FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, Robert Buhl

UAS permits exemption from Part 21 because my UAS meets (and

exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act.

The FAA is authorized to exempt aircraft from the airworthiness certificate

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the
Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the

airworthiness certificate requirement in consideration of the weight, size, speed,

maneuverability and proximity to areas such as airports and dense populations.

My, Robert Buhl, current and projected UAS's meet or exceed each of the

elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in the form contemplated by

the FARs, this Regulation is inapplicable.

Section 333 Exemption Petition

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there

are no on board pilots or passengers, and given the size of the UAS's, this

Regulation is inapplicable. An equivalent level of safety will be achieved by

maintaining a safety/flight manual delineating areas of where safety can be

defined.5 The FAA has previously issued exemptions to this regulation in

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A,

10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes

electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and

registrations. They are inapplicable for the same reasons described above. The equivalent

level of safety will be achieved by maintaining any such required certifications and

registrations by me, Robert Buhl.

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to

certain specifications. My UAS are, by definition, unmanned. They therefore do not

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further,

two-inch lettering is difficult to place on such small aircraft with dimensions smaller that
minimal lettering requirement. Regardless, I will mark its UASs in the largest possible

lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14

C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV

will see the markings. The FAA has previously issued exemptions to this regulation

through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial

operations. I, Robert Buhl, can achieve an equivalent level of safety as achieved by

current Regulations because my UAS does not carry any pilots or passengers. Further,

while helpful, a pilot license will not ensure remote control piloting skills. The risks

attended to the operation of my UAS is far less than the risk levels inherent in the

commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Luis

Cardenas, to operate my UAS meet and exceed current safety levels in relation to 14

C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows

Section 333 Exemption Petition

helicopters to be operated at lower altitudes in certain conditions. My UAS will never

operate at an altitude greater than 200 AGL; safely below the standard of 400 AGL. I,

Robert Buhl, will however operate my UAS in safe areas away from public and

traffic, providing a level of safety at least equivalent to or below those in relation to

minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS,

an equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft owners and

operators to “have [the] aircraft inspected as prescribed in subpart E of this part and

shall between required inspections, except as provided in paragraph (c) of this section,

have discrepancies repaired as prescribed in part 43 of this chapter. . . .”
These Regulations only apply to aircraft with an airworthiness certificate. They will not,

therefore, apply to my UAS. However, as a safety precaution I inspect my

UAS before and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14

C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H,

entitled Airworthiness Certificates, sets forth requirements for procurement of necessary

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and

enclosed operational area of my UAS permits exemption from Part 21 because my,

UAS meets an equivalent level of safety pursuant to Section 333 of

the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the

airworthiness certificate requirement in consideration of the weight, size, speed,

maneuverability and proximity to areas such as airports and dense populations. My

UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation

of an aircraft without an airworthiness certificate. As no such certificate will be

applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An

equivalent level of safety will be achieved by maintaining a manual. The FAA has

previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738,

9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software

updates and curative measures for any damaged hardware. Therefore, an equivalent

level of safety will be achieved.

Section 333 Exemption Petition

In summary, Robert Buhl seeks an exemption from the following

Regulations:
14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §

91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §

91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 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)(2); 14 C.F.R. §

91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my small

unmanned vehicle/lightweight unmanned aircraft vehicle in community

awareness, Cinematography, and to develop economic platforms for real .

Currently, area awareness and real estate aerial videography/photography relies

primarily on the use of larger aircraft running on combustible fuel. Posing potential risk

to the public. Granting my request for exemption will reduce current

risk levels and thereby enhance safety. My UAS craft does not contain potentially

explosive fuel, is smaller, lighter and more maneuverable than conventional video and

photographic aircraft with much less flight time. Further, I operate at lower

altitudes and in controlled airspace eliminating potential public risk flying to and from

established air fields. I, Robert Buhl, have been informally analyzing flight

information and have compiled safety protocols and the implementation of a flight

operations manual for UAS usage that exceeds currently accepted means and

methods for safe flight. Formal collection of information shared with the FAA will

enhance the FAA's internal efforts to establish protocols for complying with the FAA

Modernization and Reform Act of 2012. There are no personnel on board my UAS and

therefore the likelihood of death or serious bodily injury is significantly diminished.

Operation of my UAS, weighing less than 10 pounds and travelling at lower speeds

within limited areas will provide an equivalent level of safety as that achieved under

current FARs. Accordingly I, Robert Buhl, respectfully request that the FAA grant my

exemption request and am willing to cooperate in sharing information to benefit the FAA,

safety of manned aircraft, and the general public at large.

Respectfully submitted,

Robert Buhl, Photo/Cinematographer

Star View Aerial
1839 256th st 

Lomita CA,90717

Appendix A

Personal Protocols and 

Controls
Protocols and Controls

Aerial Community and Real Estate Videos

Safety for public on the ground as well as manned aircraft above is an essential and utmost

consideration for aerial videos and photography. As such, safety protocols and controls must be

implemented through pre-flight preparation and during flight.

Pre-Flight Protocol:

• Check batteries with voltage meter to insure fully charged and ready for use.

• Inspect batteries for damage or leakage that may affect proper operation.

• Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion

or

• unmanageable/uncontrolled flight.

• Check weather forecasts for wind advisory or other conditions that my impact flight.

• Consult five (5) mile radius map for airport vicinity.

o Contact respective airport to advise of estimated flight time, estimated flight

duration, estimated elevation of flight, and any other pertinent information.

• Inspect flight area for

o vicinity of public safety helipads/heliports

o vicinity of medical helipads/heliports

o vicinity of light poles

o vicinity or utility wires

o vicinity of trees

o flocks of birds that may cause interference and potential flight impact

o vicinity of any elevated obstructions that may pose potential flight hazard
o vicinity of roadways with moderate to heavy traffic that can be distracted

o public gatherings that may attract viewers

o optional point of control for best visual site of UAS while in flight

• Takeoff and landing

o inspect area for best and safest point of takeoff and landing

o if in a subdivision or area that is within 150 feet of a residential street, post

warning sign(s)/stand(s) "Attention Aerial Photography In Progress - Remain

Back 150 Feet"

Flight Protocol:

• Takeoff and land from same location

• Remain alert to birds, sound or aircraft, curious public, and approaching vehicles

• Do not allow anyone to engage in conversation or distract the remote control pilot

• Restrict flight to minimal elevation sufficient to acquire desired results

• Remain prepared for emergency landing at all times

• Pay attention to flight time

o If possible set a timer as a safety alert

• Land UAS and shut down propulsion immediately following landing

Protocols and Controls

Post flight:

a. Disconnect battery to prevent accidental activation of propulsion system

b. Secure UAS in a safe location

c. Remove all warning signs from public access areas

Emergency or Suspected Hazard:

• Immediate land UAS at safest and closet ground location in the event

o Manned aircraft is heard or seen in vicinity of flight
o There is a public gathering within established safety boundary wanting to observe

flight

o Pilot is being distracted from focusing on flight and safety

o Sudden change in weather (wind bursts)

o Sudden increase in vehicular traffic in vicinity of flight

o Birds enter into proximity of flight

o Any sudden unsafe event that can cause collision, distraction or interruption of

control

Appendix B

DJI Inspire

Owner's Manual