### David Burritt **15875 Quandary Loop BROOMFIELD, CO 80023** 
**T 303-810-9566**  **F 888-535-7265**  **Dave@dburritt.com**

**June 8, 2015 U.S. Department of Transportation, Docket Operations**  **Ground Floor, Rm. W12-140 1200 New Jersey Ave, SE**  **Washington, DC 20590** 

### Regarding: FAA Exemption Rulemaking Section 333 of the FAA Reform Act and Part 11- 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: Vintage Slots of Colorado, Inc., is requesting exemption from the Federal Aviation Regulations (“FARs”) listed below and pursuant to the FAA Modernization and Reform Act of 2012 and the proce

dures contained within 14 C.F.R. 11. in order to commercially op

erate a small ultra light unmanned aircraft system (“UAS”), spe

cifically the following UAS platforms will be used: DJI S900 DJI F550 DJI Phantom 3 Pro DJI Inspire Blade 350qx The Blade 350qx will only be used in drone awareness demonstra

tions and not used for filming activities. The 350qx does have the capability of transmitting the altitude and distance to the transmit

-ter so the PIC will know the altitude and distance at all times. In addition, this information can be automatically voiced to the PIC via the Spektrum DX9 transmitter so the PIC does not have to look down at the transmitter to get the information. Attachment 2 lists the technical specifications for each of the 5 UAS listed previously. The PIC will be David Burritt who is the CEO of Vintage Slots of Colorado, Inc. David Burritt received a Private Pilots Certificate in 1976 (see attachment 1). David Burritt has also been involved in the RC arena for over 20 years and has been flying small UAS multi-rotors extensively for the last 18 months. David Burritt is a member in good standing with the Academy of Model Aeronautics (AMA) and is also an IP (Introductory Pilot) instructor with the AMA (see attachment 1). David Burritt has never had an incident acting as either a pilot of a fixed wing aircraft or flying a UAS. Vintage Slots of Colorado, Inc., would like to expand its opera

tions, and wishes to add Residential and Commercial photography/ videography services. Specifically, it wishes to provide aerial im

aging to Homeowners, Real-Estate Agents and other entities in need of aerial photography/videography. With the advancement of Internet technology and consumer adoption of shopping for proper

ties online, the demand for high-resolution aerial graphics and video is unprecedented. As a Private Pilot, David Burritt and Vin

tage Slots of Colorado, Inc. understands the seriousness, necessity and importance of pre-flight and in-flight safety measures to en

sure public safety. All UAS pertinent safety and risk management measures as specified in the FAA’s Risk Management Handbook shall be complied with. In addition, the PIC would like to talk to school kids and others to explain how important UAS can be and clear up some of the misin

formation that is being said about UAS. That is why the Blade 350 QX is being added to the list of allowed UAS vehicles. The Blade350qx is a very lightweight UAS which has full return to home ca

pabilities just like the other UAS vehicles where listed earlier. A grant of the exemption request, by the FAA, would permit opera

tion of ultra lightweight and unmanned UAS to operate in prede

termined areas away from the general public, airports, heliports and vehicular traffic, primarily over individual properties/ communities for the purpose of recording real-estate listings (photo/video). All flights shall be logged and recorded to mini

mally include the date and time of flight, name of pilot (PIC) and Visual Observer (VO), address or location of flight, duration of flight, weather conditions and “flight notes” to include maximum altitude and speed along with signatures of the PIC and VO. A copy of the images shall also be retained for a minimum of 12 months from the date of flight. In summary and in accordance with this request of exemption re

quest as authorized and outlined by the FAA under Section 333(c) of the Reform Act specified for use of UAS’ for “Real Estate” pur

poses, Vintage Slots of Colorado, Inc. will adhere to all FAA regu

lations at all times and shall conduct all flight operations in strict compliance and safety protocols as mandated and required by regulations and best practices. Respectfully, we request the grant of exemption to operate ultra light weight, remote controlled UAS’s for commercial purposes as described in this request and as allow

able by law. This grant of exemption will allow the company to of

fer such services to private entities, realtors and individual home

owners who have little to no experience piloting UAS’s but have a need to market their property in order to compete within an ever demanding technology driven real- estate market. Vintage Slots of Colorado, Inc. submits that this application has been prepared by David Burritt (CEO of Vintage Slots of Colorado, Inc.) and not an attorney using his personal knowledge of existing FARs as well as utilizing excerpts from other similar applications. Consequently, if David Burritt has unintentionally omitted any relative FARs, Vin

tage Slots of Colorado, Inc., humbly request an opportunity to submit to those accidental omissions. The essence of this applica

tion is to declare that, Vintage Slots of Colorado, Inc., and the PIC(David Burritt), meets and exceeds the FAA’s expected compe

tency for piloting the listed UASs for commercial purposes and that the UAS that we specified earlier meets and exceeds the safety requirements as set forth by the Secretary of Transportation thereby prompting the request for COA under Section 333.

**I. Contact Information:**  Vintage Slots of Colorado, Inc Attn: David Burritt 15875 Quandary Loop Broomfield CO 80023 303-810-9566 Dave@dburritt.com
**II. The Specific section(s) of 14 C.F.R. seeking an exemption**  **from are:** 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).
**III. The extent and reason of relief:**  Vintage Slots of Colorado, Inc., is seeking relief from exist

ing FARs that currently prohibit the use of UASs from oper

ating commercially for the purpose of aerial photography/ videography in accordance with the FAA Modernization and Reform Act of 2012 112 P.L. 95 § 331-334. The Reform Act Subtitle B: Unmanned Aircraft Systems – (Sec. 332) “Re

quires the Secretary to develop a plan to accelerate safely the integration by September 30, 2015, of civil unmanned air

craft systems (UASes, or drones) into the national airspace system.” Accordingly, the company attests that the PIC’s (David Burritt) personal qualifications as well as the list of the ultra lightweight UAS platforms meets the definition ofsuch approved drones (UAS) as defined in Section 331 and allows for exemption status consideration. Further, the com

pany humbly requests that it be allowed to commercially op

erate the listed UASs during the time period the FAA is fur

ther establishing rules and regulations governing the opera

tions of such craft. The Secretary of Transportation has been asked by Congress to, among other things, consider whether certain unmanned aircraft systems may operate safely in the national airspace system before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is re

quired to determine which types of UASs do not create a hazard to users of the National Airspace System or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight (VLOS) of the Pilot and VO Accordingly, all flights will be conducted by a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 “Op

erational Requirements for UASs” and with the following re

strictions:
a. All aircraft will be made with a UA Gross weight of less than 55 pounds b. All flights will occur only during daylight hours.
c. All flights will occur at or below 400 feet AGLd. 5 nautical miles from an airport having an operational control tower; or
e. 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or f. 2 NM from an airport without a published instrument flight procedure or an operation tower; or g. 2 NM from a heliport with a published instrument flight procedure. h. For safety, no flight with winds over 10 mph. i. Flight only in GPS mode that allows UAS to hover in place when radio controls are released. All operations to be conducted in GPS mode only. **IV. How the request will benefit the public as a whole:** Aerial photography is a critical component of marketing commer

cially available property. With today’s high-tech Internet market and ever demanding consumer, it is more important than ever for realtors and home sellers to have their listing appear near or at the top of Internet searches. The Multiple List Service (MLS) typically lists home searches in hierarchy based on number of “images” or “videos”. To grab the attention of the buyer, it is important for them to see the entire property and the area around it. All of these elements combine to have a tremendous impact on the outcome of a commercial real estate transaction. It is much too dangerous and expensive to hire a manned aircraft to take these aerial images thereby making the UAS option more cost effective and safer. There simply is not enough UAS Pilots to cover the demand for these images, which is leading to unlicensed UAS operators which ultimately results in untrained and unqualified operators.In addition, Vintage Slots of Colorado, Inc., hopes to offer educa

tion presentations to K - 12 students in order to dispel the myths around UAS which are commonly called drones and get very bad press in the news. **V. Reasons why the exemption would not adversely affect safety; or how the exemption would provide a level for safety at**  **least equal to the existing rule:** An exemption would not adversely affect safety because this ap

plication applies only to aircraft characteristics and applications within FAA specified limitations. These limitations provide for at least an equivalent safety standard. However, the experience of David Burritt as a certificated rated Private Pilot allows him to util

ize his experience in UAS operations thereby exceeding safety and improving airspace operations by allowing aerial imaging clients to choose an pilot that knows how to pilot an aircraft safely and within regulated limits. In addition, by providing unmanned serv

ices to the market place, there will be less of a demand for manned operations, which will provide for safer and quieter residential aer

ial photography. As previously stated, all flights will be conducted by a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 “Op

erational Requirements for UASs” and with the following restric

tions:
a. All aircraft will be made with a UA Gross weight of less than 55 pounds b. All flights will occur only during daylight hours.
c. All flights will occur at or below 400 feet AGL d. 5 nautical miles from an airport having an operational control tower; or
e. 3 NM from an airport with a published instrument flight pro

cedure, butnot an operational tower; or
f. 2 NM from an airport without a published instrument flight procedure or an operation tower; or g. 2 NM from a heliport with a published instrument flight pro

cedure. h. Extensive, pre-flight briefings are required between the PIC and the VO. i. A flight plan is required prior to each flight. j. All aircraft operations must be conducted within manufac

turer recommended specifications. k. All site permissions must be obtained prior to flight. **VI. 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 airwor

thiness certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of the listed UASs permit exemption from Part 21 because the listed UASs meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to ex

empt 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 require

ment in consideration of the weight, size, speed, maneuver

ability and proximity to areas such as airports and dense populations. The 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 with

out an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regu

lation is inapplicable. 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 such manuals on location with the Pilot. The FAA has previ

ously 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 inapplica

ble insofar as all 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 inappli

cable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such re

quired certifications and registrations with the Pilot.
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. The listed UASs 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 let

tering requirement. Regardless, Vintage Slots of Colorado, Inc., will mark its UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as re

quired by 14 C.F.R. §45.29 (f) so that the PIC, or anyone as

sisting the PIC as a spotter with the UAV will see the mark

ings. The FAA has previously issued exemptions to this regu

lation through Exemptions Nos. 8738, 10167, 10167A and 10700.c. 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. The PIC can achieve an equivalent level of safety as achieved by current Regulations because the listed UASs do not carry any pilots or passengers. Further, the PIC possess an FAA pilot certificate, which helps his remote control pi

loting skills and factors in his experience in assessing any flight risks. The risks attended to the operation of the listed UASs are far less than the risk levels inherent in the commercial activities out

lined in 14 C.F.R. § 61, et seq. Thus, allowing the PIC to operate the listed UASs and meet and exceed current safety levels in rela

tion to 14 C.F.R. §61.113 (a) & (b).
a. 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 helicopters to be operated at lower altitudes in certain conditions. The listed UASs will never operate at an altitude greater than 400 ft AGL. The PIC will also operate the listed UASs 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 the listed UASs, an equivalent or higher level of safety will be achieved.
b. 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 re

quired 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 airworthi

ness certificate. They will not, therefore, apply to the listed UASs. However, as a safety precaution the UAS which willbe used will be inspected 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 Cer

tificates, sets forth requirements for procurement of necessary air

worthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of the listed UASs permit ex

emption from Part 21 because the UASs 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 re

quirement 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 prox

imity to areas such as airports and dense populations. The listed UASs meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness cer

tificate. As no such certificate will be applicable in the form con

templated 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 is

sued 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. **In Summary:** Vintage Slots of Colorado, Inc., respectfully request that the FAA grant the exemption request and further volunteer any information gathered during flights in the event the FAA is interested in live field data. Vintage Slots of Colorado, Inc., agrees and attests to ad

here to any further limitations the FAA imposes, now or in the fu

-ture. Satisfaction of the current criteria provided in Section 333 of the Reform Act of 2012 – size, weight, speed, operating capabili

ties, proximity to airports and populated areas and operation within visual line of sight and national security – provide more than ade

quate justification for the grant of the requested exemptions allow

ing commercial operation of the listed UASs for commercial pur

poses. Vintage Slots of Colorado, Inc. looks forward to support the FAA and UAS community in its quest to establish proper regula

tions and protocols for the safe introduction of unmanned aircraft into the national airspace. Sincerely,

David Burritt CEO, Vintage Slots of Colorado, Inc. 15875 Quandary Loop Broomfield CO 80023Attachment 1Attachment 2 

### DJI F500 Specs ( http://wiki.dji.com/en/index.php/Flame_Wheel_F550_Sp ecifications ): Frame Weight : 478g Diagonal Wheelbase : 550mm Takeoff Weight : 1200g ~ 2400g Recommended Propeller : 10 × 3.8in ; 8 × 4.5in Recommended Battery : 3S~4S LiPo Recommended Motor : 22 × 12mm (Stator size) Recommended ESC : 30A OPTO Flight Computer: DJI Naza-M V2 DJI S900 Specs ( http://www.dji.com/product/spreading-wings-s900/spec ): Diagonal Wheelbase: 900mm Frame Arm Length:358mm Frame Arm Weight (Including Motor, ESC, Propeller): 316g Center Frame Diameter: 272mm Center Frame Weight (With Landing Gear Mounting Base, Servos): 1185g Landing Gear Size: 460mm(Length) × 450mm(Width) × 360mm(Height) Motor Stator Size: 41 × 14mm KV: 400rpm/V Max Power: 500W Weight (With Cooling Fan):158g ESC Working Current: 40A Working Voltage: 6S LiPo

### Signal Frequency: 30Hz ~ 450Hz Drive PWM Frequency: 8KHz Weight(With Radiators): 35g Foldable Propeller (1552/1552R) Material: High strength performance engineered plastics Size: 15 × 5.2inch Weight: 13g Flight Parameters Takeoff Weight: 4.7Kg ~ 8.2Kg Total Weight: 3.3Kg Power Battery: LiPo (6S 、 10000mAh~15000mAh 、 15C(Min)) Max Power Consumption: 3000W Hover Power Consumption: 1000W (@6.8Kg Takeoff Weight) Hover Time: 18min (@12000mAh& 6.8Kg Takeoff Weight) Working Environment Temperature: -10 °C ~ +40 °C DJI Inspire Specs ( https://store.dji.com/product/inspire-1?gclid=COKk9qzS gcYCFZaMaQoduLsAHg#/spec ) Model T600 Weight (Battery Included): 2935 g Hovering Accuracy (GPS Mode) Vertical: 0.5 m Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s Yaw: 150°/s Max Tilt Angle: 35° Max Ascent Speed: 5 m/s Max Descent Speed: 4 m/s

### Max Speed: 22 m/s (ATTI mode, no wind) Max Flight Altitude: 4500 m Max Wind Speed Resistance: 10 m/s Max Flight Time: Approximately 18 minutes Motor Model: DJI 3510 Propeller Model: DJI 1345 Indoor Hovering: Enabled by default Operating Temperature Range: -10° to 40° C Diagonal Distance: 559 to 581 mm Dimensions: 438x451x301 mm Gimbal Model: ZENMUSE X3 Output Power (With Camera) Static: 9 W In Motion: 11 W Operating Current Station: 750 mA Motion: 900 mA Angular Vibration Range: ±0.03° Mounting: Detachable Controllable Range Pitch: -90° to +30° Pan: ±320° Mechanical Range Pitch: -125° to +45° Pan: ±330° Max Controllable Speed Pitch: 120°/s Pan: 180°/s DJI Phantom 3 Pro Specs ( http://www.dji.com/product/phantom-3/spec ): Weight (Including Battery And Propellers): 1280 g Diagonal Size (Including Propellers): 590 mm Max Ascent Speed: 5 m/s

### Max Descent Speed: 3 m/s Hover Accuracy • Vertical: +/- 0.1 m (when Vision Positioning is ac
tive) or +/- 0.5 m • Horizontal: +/- 1.5 m Max Speed: 16 m/s (ATTI mode, no wind) Max Altitude Above Sea Level: 6000 m Operating Temperature: 0°C to 40°C GPS Mode: GPS/GLONASS Blade 350 QX Specs ( http://www.bladehelis.com/ProdInfo/Files/BLH7800-Man ual_EN.pdf ) Length: 18.30 in (465mm) Main Rotor Diameter: 22.80 in (580mm) Height: 5.43 in (138mm) Flying Weight: 24 oz (680 g)