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 procedures contained within 14 C.F.R. 11. in order to commercially operate a small ultra light unmanned aircraft system (“UAS”), specifically 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 demonstrations 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 operations, and wishes to add Residential and Commercial photography/

videography services. Specifically, it wishes to provide aerial imaging 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 properties online, the demand for high-resolution aerial graphics and 

video is unprecedented. As a Private Pilot, David Burritt and Vintage Slots of Colorado, Inc. understands the seriousness, necessity 

and importance of pre-flight and in-flight safety measures to ensure 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 misinformation that is being said about UAS. That is why the Blade 350 

QX is being added to the list of allowed UAS vehicles. The Blade 
350qx is a very lightweight UAS which has full return to home capabilities just like the other UAS vehicles where listed earlier. 

A grant of the exemption request, by the FAA, would permit operation of ultra lightweight and unmanned UAS to operate in predetermined 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 minimally 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 request as authorized and outlined by the FAA under Section 333(c) 

of the Reform Act specified for use of UAS’ for “Real Estate” purposes, Vintage Slots of Colorado, Inc. will adhere to all FAA regulations 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 allowable by law. This grant of exemption will allow the company to offer such services to private entities, realtors and individual homeowners 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, Vintage Slots of Colorado, Inc., humbly request an opportunity to 

submit to those accidental omissions. The essence of this application is to declare that, Vintage Slots of Colorado, Inc., and the PIC 
(David Burritt), meets and exceeds the FAA’s expected competency 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 existing FARs that currently prohibit the use of UASs from operating 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) “Requires the Secretary to develop a plan to accelerate safely the 

integration by September 30, 2015, of civil unmanned aircraft 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 of 
such approved drones (UAS) as defined in Section 331 and 

allows for exemption status consideration. Further, the company humbly requests that it be allowed to commercially operate the listed UASs during the time period the FAA is further establishing rules and regulations governing the operations 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 required 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 “Operational Requirements for UASs” and with the following restrictions: 

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 

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 commercially 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 education 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 application 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 utilize 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 services to the market place, there will be less of a demand for manned 

operations, which will provide for safer and quieter residential aerial 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 “Operational Requirements for UASs” and with the following restrictions: 

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 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. 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 manufacturer 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 airworthiness 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 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. 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 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 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 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 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 inapplicable for the same reasons described above. The equivalent 

level of safety will be achieved by maintaining any such required 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 lettering 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 required by 14 C.F.R. §45.29 (f) so that the PIC, or anyone assisting the PIC 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. 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 piloting 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 outlined 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 relation 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 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 the listed 

UASs. However, as a safety precaution the UAS which will 
be 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 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 the listed UASs permit exemption 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 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. 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 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. 

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 adhere 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 capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security – provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of the listed UASs for commercial purposes. Vintage Slots of Colorado, Inc. looks forward to support the 

FAA and UAS community in its quest to establish proper regulations 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 80023
Attachment 1
Attachment 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 active) 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)