September 4, 2015

Mr. James Williams 

Manager, Flight Standards Service 

Unmanned Aircraft Systems Integration Office 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591

U.S. Department of Transportation, Docket Operation 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590

Re: Request for exemption from multiple regulatory provisions to allow the use of a small unmanned aerial 

systems (sUAS) controlled by Baltimore Photo Bomb, LLC to assist with working company wedding 

events and filming ceremonies.

Dear Mr. Williams:

Baltimore Photo Bomb, LLC respectfully requests an exemption from several provisions of Title 14 of the 

Code of Federal Regulations (C.F.R.) to permit the use of a small unmanned aerial systems (sUAS) to 

assist in the filming of wedding ceremonies and events for our clients. This request is motivated primarily 

by the desire to maximize safety while complying with the current laws regarding the use of a sUAS to 

perform low altitude aerial footage for wedding and event ceremonies. 

Included in the attachment portion of the FAA exemption website, we have included the user manual for 

the aforementioned sUAS which provides the manufacturers information regarding the design, aircraft 

performance, and fail-safe features. We have provided manufacturer information related to operating 

limitations, normal and emergency procedures, and maintenance and inspection procedures. 

Background Information

Baltimore Photo Bomb, LLC is in the business of operating photo booths for our clients at small gatherings 

for weddings and other celebrations. We would like to extend our offerings to include the use of a sUAS 

for our clients. Baltimore Photo Bomb, LLC Clients look to us to provide fun and exciting new ways to 

capture their big day and the use of a sUAS has been a requested option from many of our clients to use at 

these gatherings to showcase these moments.

Regulatory Basis for Exemption Request

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA may grant an 

exemption under 49 U.S.C. §44701(f) if it has determined that such an exemption is in the public interest. 

The FAA has imposed a separate requirement in its procedural regulations, providing that the petitioner 

shall explain why granting the exemption would not adversely affect safety or how the exemption would 

provide at least an equivalent level of safety as compliance with the underlying regulation. In this case, 

approval of this exemption would allow our company to meet our client’s needs and provide an additional 

service that is unique in this fast paced event services industry. As described more fully below, the 

requested exemption would permit the operation of sUAS under tightly controlled conditions, thus ensuring 

that operations will not have an adverse impact on safety. To the contrary, as explained below, Baltimore 

Photo Bomb, LLC anticipates that use of sUAS will enhance our customers experience and by setting into 
place a series of safety procedures by the operators of the sUAS themselves, will equal a safe and 

controlled use that would not adversely interfere with any of the FAA’s prerogatives.

Baltimore Photo Bomb, LLC Safety Operations & Procedures Overview:

Technology Considerations:

Best-in-class, tried and proven technologies that are in advanced iterations. Software from highly-reputable

industry partners will include features -

1. Auto return home by GPS if communication signal were to be severed. If the sUAS loses 

communications, the sUAS will have capability to return to a pre-determined location within the Security 

Perimeter and land.

2. Auto descent (landing) if battery were to drop lower than nominal level.

3. Flights will be terminated at 25% battery power reserve.

4. Live video for operator gives real-time positioning feedback. In other words, we can monitor the scene 

from the vehicle's perspective for collision avoidance, and to maintain spatial orientation.

5. The sUAS will have the capability to abort a flight in case of unpredicted obstacles

or emergencies.

6. On-Screen-Display (OSD) contains operating information to ascertain vehicle health at all times: speed, 

altitude, number of GPS satellites (when available), heading and voltage.

7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2) link failures occur 

(highly improbable), vehicle returns automatically to the point of launch.

8. Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data feed, 

which downlinks from the aircraft to a ground-based on-screen display. This altitude information will be 

generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded 

barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude

initiation point will be established and confirmed for accuracy by the pilot.

Mechanical/Physical:

1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS to the pilot, thus 

eliminating the concern of signal severance (flying behind objects/walls).

2. The sUAS will weigh less than 10 lbs and travel at less than 5 m/s.

3. Batteries should far exceed the capacity required for actual flight time.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Fireproof bags for storage and charging of high capacity Lipo batteries on-site.

6. UA operated under this exemption will be marked in accordance with 14 CFR part 45 or as otherwise 

authorized by the FAA.

Personnel:

1. Spotters ensure safe operation and act as a redundant set of eyes for operators

(pilot, gimbal op, director)

2. Radio spectrum analysis for interference on the frequencies utilized for vehicle control/communication.

3. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s activities. It 

will be mandatory that all personnel who will be performing duties within the boundaries of the safety 

perimeter be present for this briefing.

4. The operator will obtain the consent of all persons involved in the sUAS operations.

5. Observer and pilot will at all times be able to communicate by voice.

6. Written and/or oral permission from the relevant property holders will be obtained.

7. Pilot and observer will have been trained in operation of sUAS generally and received up-to-date 

information on the particular sUAS to be operated.

Operations:

1. The small unmanned aerial system (sUAS) must weigh less than 30 pounds, including energy source(s) 

and equipment. Operations authorized by this petition of exemption are limited to the following aircraft 

described in Appendix B.
2. The UA may not be flown at a ground speed exceeding 5 m/s.

3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated 

by the procedures specified in the operator’s manual. All altitudes reported to ATC must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the 

PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the 

PIC’s FAA-issued medical certificate.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to 

communicate verbally at all times.

6. The operator’s manual included and this petition of exemption must be maintained and made available to 

the Administrator upon request. If a discrepancy exists between the conditions and limitations in this 

exemption and the procedures outlined in the operator’s manual, the conditions and limitations herein take 

precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its 

operator’s manual. The operator may update or revise its operator’s manual. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the Administrator upon 

request. The operator must also present updated and revised documents if it petitions for extension or 

amendment. If the operator determines that any update or revision would affect the basis for which the 

FAA grants this petition for exemption, then the operator must petition for amendment to their exemption. 

The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operator’s manual.

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the UAS is found to be in a condition 

for safe flight. The Ground Control Station, if utilized, must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight in 

accordance with the operator’s manual. The PIC who conducts the functional test flight must make an entry 

in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and 

aircraft record entry must be added to the operator’s manual.

9. The operator must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be 

established and identified in the operator’s manual. At a minimum, requirements for the following must be

included in the operator’s manual:

a. Actuators / Servos;

b. Transmission (single rotor);

c. Powerplant (motors);

d. Propellers;

e. Electronic speed controller;

f. Batteries;

g. Mechanical dynamic components (single rotor);

h. Remote command and control;

i. Ground control station (if used); and

j. Any other components as determined by the operator;

10. The UA may not be operated directly over any person, except authorized and consenting personnel, 

below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or 

emergency.

11. Regarding the distance from participating persons, the operator’s manual has safety mitigations for 

authorized and consenting personnel. At all times, those persons must be essential to the operations.

12. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined 

location within the security perimeter and land or be recovered in accordance with the operator’s manual.

13. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with 

the operator’s manual.

14. Each UAS operation must be completed with 25% battery power remaining.
15. The operator must develop procedures to document and maintain a record of the UAS maintenance, 

preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in 

service of the UAS. These procedures must be added to the operator’s manual.

16. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

17. Before conducting operations, the radio frequency spectrum used for operation and control of the UA 

must comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

18. The UA must remain clear and yield the right of way to all other manned operations and activities at all 

times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang 

gliders, etc.).

19. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must 

be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules 

(SVFR) are not authorized.

20. The UAS may not be operated by the PIC from any moving device or vehicle.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud 

or when visibility is less than 3 statute miles from the PIC.

22. The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA 

may not operate within 5 nautical miles of the geographic center of a non-towered airport as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s

COA. The letter of agreement with the airport management must be made available to the Administrator 

upon request.

23. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office 

(AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be 

conducted until the incident, accident, or transgression is reviewed by AFS-80 and authorization to resume 

operations is provided.

Support for Petition for Exemption 

In accordance with the procedural requirements of 14 C.F.R. §11.81, Baltimore Photo Bomb, LLC provides 

the following information: 

Contact Information: 

Mike Canterbury

CTO

Baltimore Photo Bomb, LLC

8 Brackenridge Ct

Baltimore, MD 21212

(443)-681-9162

mike.canterbury@baltimorephotobomb.com

info@baltimorephotobomb.com

Regulatory Provisions from which Baltimore Photo Bomb, LLC seeks an Exemption 

Baltimore Photo Bomb, LLC believes it may need an exemption from the following provisions to conduct 

the contemplated operations. In some instances, relief is needed because relief from another provision 

renders compliance with the regulation at hand infeasible. 

333 Aircraft Exemption Status 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a)(1)&(2) 
14 C.F.R. §91.417(a)&(b) 

Baltimore Photo Bomb, LLC believes an exemption is only needed from the above-listed regulatory 

provisions. To the extent that the FAA believes that additional relief is required for Baltimore Photo Bomb, 

LLC to conduct the operations described here, we request an exemption from any such regulatory 

provisions as well.

The Extent of Requested Relief and the Reasons Relief is Needed 

Section 333 Aircraft Exemption Status: 

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement for an 

airworthiness certificate based on a consideration of the size, weight, speed, operational capability of the 

particular sUAS, as well as its proximity to airports and populated areas. An analysis of these criteria 

demonstrates that the sUAS operated without an airworthiness certificate in the areas and under the 

conditions contemplated by Baltimore Photo Bomb, LLC will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

conditions proposed in this request. 

The sUAS is less than 10 lbs. fully loaded, carries neither a pilot nor passenger, and operates exclusively 

within a secured area not near airports or other government owned property. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by the operator and observer. 

Operations will be conducted in compliance with the FAA and with local public safety requirements. The 

application of the intended use demonstrates that there is no credible threat to national security posed by the 

sUAS, due to its size, speed of operation, location of operation, lack of explosive materials and inability to 

carry a substantial external load. 

Baltimore Photo Bomb, LLC anticipates initially using a cadre of specially trained staff to conduct 

the sUAS operations. While these individuals will not hold commercial pilot licenses. The sUAS will not 

carry property for compensation or hire since they will be used solely to assist in the filming of events for 

Baltimore Photo Bomb, LLC’s business. Without an exemption, the pilot would be required to hold a 

commercial pilot certificate under §61.133. However, the risk associated with the contemplated operations 

is less than the risk posed by a traditional aircraft. The sUAS will fly at altitudes well below the permissible 

limits for other civil aircraft, eliminating the risk to other aircraft, and within a geographical envelope under 

the sole control of Baltimore Photo Bomb LLC clients. Accordingly, the risk would be limited to Baltimore 

Photo Bomb, LLC personnel, who will be appropriately outfitted in safety gear, and Baltimore Photo 

Bomb, LLC client’s property on the ground. Requiring a commercial pilot certificate would provide no

appreciable safety benefit and would needlessly impose additional cost on Baltimore Photo Bomb, LLC. 

Please do not hesitate to contact me at the phone number or via the e-mail address provided above should 

you have any questions or concerns. 

Respectfully submitted, 

Mike Canterbury CTO, Baltimore Photo Bomb, LLC