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