Donald Ray Burritt

7931 Bayside Drive

Fort Collins, CO 80528

phone 970-631-7721

donburritt@gmail.com

June 22, 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:

I, Donald Ray Burritt, am 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 has

the capability of transmitting the altitude and distance to the

Spektrum DX9 transmitter so the Pilot in Command (PIC) will

know the altitude and distance of the UAS 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 3 lists the technical specifications for each of the 5

UAS listed previously in this document.

The PIC will be Donald Ray Burritt. Donald Ray Burritt received a

Private Pilots Certificate in 1975 (see attachment 1). Donald Ray

Burritt has been flying small UAS multi­rotors exclusively for the

last 18 months. Donald Ray Burritt is a member in good standing

with the Academy of Model Aeronautics (AMA).

Donald Ray Burritt has never had an incident acting as either a

pilot of a fixed wing aircraft or flying of a UAS.

Donald Ray Burritt would like to begin business operations as a

Residential and Commercial photography/videography service

provider. Specifically, I wish to provide aerial imaging to

Homeowners, Real­Estate 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 high­resolution aerial graphics and video is

unprecedented. As a Private Pilot, I, Donald Ray Burritt,

understand the seriousness, necessity and importance of pre­flight

and in­flight 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, I, the PIC, would like to talk to school children and

other persons to explain how important UAS can be and clear up

some misconceptions about UAS. The Blade 350 QX is being

added to the list of allowed UAS vehicles to help provide this

information to the general public. The Blade 350qx is a lightweight

UAS which has full return to home capabilities just like the other

UAS vehicles where listed previously in this document.

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. The operations would be primarily

over individual properties/communities for the purpose of

recording real­estate 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, Donald Ray Burritt 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, Donald Ray Burritt

requests 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 Donald Ray Burritt 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 a demanding technology­driven Real

Estate market. Donald Ray Burritt submits that this application has

been prepared by Donald Ray Burritt, and not by an attorney, using

his personal knowledge of existing FARs as well as utilizing

excerpts from other similar applications. Consequently, if Donald

Ray Burritt has unintentionally omitted any relative FARs, Donald

Ray Burritt request's the opportunity to submit corrections to those

accidental omissions. The essence of this application is to declare

that Donald Ray Burritt, the PIC, meets and exceeds the FAA’s

expected competency for piloting the listed UASs for commercial

purposes and that the UAS that are specified previously in this

document meet and exceed the safety requirements as set forth by

the Secretary of Transportation thereby prompting this request for

COA under Section 333.

I. Contact Information:

Donald Ray Burritt

7931 Bayside Drive

Fort Collins, CO 80528

970­631­7721 donburritt@gmail.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:

Donald Ray Burritt 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 §

331­334. 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, Donald Ray

Burritt attests that the PIC's (Donald Ray Burritt's) 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. Donald Ray Burritt humbly requests that

he 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 rule making 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 operational 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 high­tech Internet

market and ever demanding consumer, it is important 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 maximize the chance get the attention of the potential

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 private or commercial real estate

transaction. It is much too dangerous and expensive to hire a

manned aircraft to create these aerial images, thereby making the

UAS option more cost effective and safer than using manned

aircraft. There are not enough UAS Pilots to cover the demand for

these images, which is leading to use of UAS by unlicensed

operators. Unlicensed operators may be untrained and unqualified

for UAS services.

I, Donald Ray Burritt, desires to offer education presentations to K

­ 12 students in order to dispel misinformation about UAS, which

are commonly called drones, and get incorrect information from

the news services.

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
Donald Ray 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 operational tower; or

g. 2 NM from a heliport with a published instrument flight

procedure.

h. Extensive, pre­flight 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's 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 UASs 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 UASs, 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, two­inch lettering is difficult to place on

such small aircraft with dimensions smaller that minimal

lettering requirement. Regardless, Donald Ray Burritt will

mark his 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 non­commercial 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 does 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 above­cited 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 UASs 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 UASs, 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:

Donald Ray Burritt respectfully requests 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.
Donald Ray Burritt agrees and attests to adhere to any further

limitations the FAA imposes, now or in the future. 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.

Donald Ray Burritt looks forward to supporting 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,

Donald Ray Burritt

7931 Bayside Drive

Fort Collins, CO 80528

donburritt@gmail.com
Attachment 1
Attachment 2
Attachment 3

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 Naza­M V2

DJI S900 Specs

(http://www.dji.com/product/spreading­wings­s900/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/inspire­1?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/phantom­3/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/BLH7800­Man

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)