David Burritt

15875 Quandary Loop

Broomfield, CO 80023 Dave@dburritt.com

FAA 

June 30th, 2015 

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140 Washington, DC 20590 

Dear Exemption Manager, Re: Docket Number FAA-2015-0150 

I am submitting my Petition for Exemption for Unmanned Aircraft 

Systems operations. I have been an FAA licensed private pilot since 

1976. I take the skills and education for the safe operation of UAS, 

very seriously. These are UAS’s are not Toys. I am a member of the 

Academy of Model Aeronautics (AMA) and I frequent an AMA field 

frequently to always improve my skills as a UAS pilot. I also hold an 

AMA IP (introductory pilot) certificate which qualifies me to educate 

introductory pilots how to safely fly a UAS. 

My request is for a waiver of the sections identified below in an effort 

to operate a UAS in public. 

I reference the FAA announcement dated April 9th, 2015 http://

www.faa.gov/news/updates/?newsId=82485 which includes language 

that references the FAA’s experience in reviewing Section 333 

petitions and that they seem to be generally falling into two categories 

ie: film/television production and aerial data collection, and that most 

of the exemption requests in these categories will likely be handled 

through the new summary grant process. 

With my clear understanding of FAA rules, my awareness of 

operational and restricted airspace, my experience as a pilot license 

holder (even though The FAA is lowering the credential bar to include 

sport pilot certificates), and my attitude of safety first when it comes to 

flight operations, I believe I should be granted an exemption. 
My request for a waiver of the section is not for operations for the 

purpose of “closed-set motion picture and television filming” but are 

identified below. My request is to operate a UAS for commercial 

purposes. Primarily, to “record digital video data and other aerial 

photography data of privately owned fee simple real estate which will 

assist an owner in the promotion of their improved/unimproved parcel 

of land, for ultimate disposition and sale” or “other promotional 

purposes (i.e., a country club wanting to promote its facilities)”. Roof 

inspections could also be done because modern roofs commonly do 

not accommodate people walking on them so an inspection via UAS is 

very appropriate and is also safer than having a home owner walk on 

his or her roof and risk falling. Any complaint by a neighboring 

member of the public complaining of even a hint of invasion of privacy, 

founded in fact or not, and even within the private boundaries of the 

specific land parcel owner, and with the camera lens facing inward 

and focused only onto an owners parcel, will instantly be honored, 

resulting in immediate termination of aerial operations. 

I will also carry a minimum of $1,000,000.00 in liability insurance.

I also hope to operate the UAS to educate gifted middle school and 

high school kids so they may learn the positive aspects of UAS (aka 

drones).

I am currently seeking exemption of: 

Section of 14 CFR: parts 21 Subpart H, 27, 45.23(b), 45.27(a), 

61.113(a) and (b), 61.133(a), 91.7(a), 91.9(b)(2), 91.103, 91.109(a), 

91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.319(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). If I have erroneously 

omitted any other relevant section or, overstated any relevant section 

for my intended operations, please feel free to suggest the missing or 

overstated section(s). 

Suggested Public Federal Register Summary: 

“The petitioner is seeking an exemption to operate an unmanned 

aircraft system (UAS) under the new FAA “Summary Grant” approach, 

announced April 9th, 2015 http://www.faa.gov/news/updates/?

newsId=82485 that will help speed up Section 333 exemption 
approvals for many commercial UAS operators prior to finalizing the 

small UAS proposed rules published this past February. 

It is my understanding that the FAA will still review each Section 333 

petition individually. However, I am hoping that the agency will accept 

my particular petition, and include it in the next summary grant, and 

issue me an exemption on the presumption that the FAA has “already 

granted a previous exemption similar to this request”. 

Apparently, the new interim policy includes the granting of a Certificate 

of Waiver or Authorization (COA) for flights at or below 200 feet to any 

UAS operator with a Section 333 exemption for aircraft that weigh less 

than 55 pounds, operate during daytime Visual Flight Rules (VFR) 

conditions, operate within visual line of sight (VLOS) of the pilots, and 

stay certain distances away from airports or heliports such as 5 

nautical miles (NM) from an airport having an operational control 

tower; or 3 NM from an airport with a published instrument flight 

procedure, but not an operational tower; or 2 NM from an airport 

without a published instrument flight procedure or an operational 

tower; or 2 NM from a heliport with a published instrument flight 

procedure. It is also understood that the “blanket” 200- foot COA 

allows flights anywhere in the country except restricted airspace and 

other areas, such as major cities, where the FAA prohibits UAS 

operations. 

UAS Description: 

I am asking for an exemption for a UAS up to 55 pounds because I 

forecast I will be using a craft that will be flown operationally, weighing 

less than twenty pounds and more specifically a DJI S900, DJI FW 

550, DJI Phantom 3 series, DJI Inspire, and Blade 350 QX series and 

will be qualified as a UAS. I am currently flying the S900 and FW 550 

because they have six motors and can continue to fly if a motor fails. 

However, the Phantom 3 and or Inspire may be more appropriate in 

some situations. The Blade 350 QX series of craft are much smaller 

and will only be used in educational scenarios.

In the event a loss of communications occurs all of the craft will rise up 

vertically to a safe height before beginning an automatic return to 

home function. The control signal may be reconnected in flight and the 
pilot can take over safe operations again if communication is 

reestablished. However in the case of a GPS failure the craft will be 

able to be manually flown to a safe landing by the pilot. The craft 

operates electrically, carries no flammable fuel, has an integrated 

GPS pilot system,provides location information along with height AGL, 

speed, battery life. The DJI products have programmed no-fly zones 

for controlled airports, and provides direction of travel distance from 

the pilot. 

Additional Points: 

It is my hope that you find that the enhanced safety achieved using an 

unmanned aircraft with the specifications described by the petitioner 

which carries no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crew in addition to 

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

operation enabled by this exemption is in the public interest. 

Flight Operations: I am well aware of conducting safe flight 

operations and planning flight paths that minimize any overflight of 

crowds. Flights will end when battery reserve reaches 25 percent. 

Operations will not occur under IFR conditions. In addition, preflight 

and post-flight checklists and UAS examinations will help detect any 

abnormalities prior to flight and after flight. Any UAS unable to satisfy 

safety checklists will be removed from service until the issue can be 

resolved. 

Granting this request would not adversely affect safety since 

operations would be in accordance with current UAS rules. 

Section 333 Compliance and Appropriateness: Based on the size 

of the craft, experience of the pilot, and operational goals, this request 

appears to be well suited for approval using the current criteria 

outlined in Section 333 of the FAA Modernization and Reform Act of 

2012 (including new interim policies) 

Sincerely, 
David Burritt