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 w 12

- 140 1200 New

Jersey Avenue, SE Washington, DC 20590

Re: Request for exemption from multiple regulatory provisions to allow the use of a sm all unmanne d aerial systems (sUAS) controlled by Baltimore Photo Bomb , LLC to assist with working company weddin g 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 sm all 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 com plying 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, w e 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 inspecti on procedures.

**Background Inform ation** 
Baltimore Photo Bomb , LLC is in the business of operating photo booths for our clients at small gatherings for w eddings 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 F AA 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 compl iance with the underlying regulation. In this case, approval of this exemption would allow our com pany 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 B om

b , LLC anticipates that use of sUAS will enhance our customers experience and by setting intoplace 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.

**Baltim ore Photo**  **B om** **b ,**  **LLC Safety Operations & Procedures Overview: Technology Considerations:**  Best

- in

- class, tried and proven technologies that are in adv anced 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 low er than nominal level. 3. Flights will be terminated at 25% battery pow er reserve. 4. Live video for operator gives real

- time positioning feedback. In oth er words, w e can monitor the scene from the vehi cle'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 i nformation to ascertain v ehicle health at all times: speed, altitude, number of GPS satellites (when available), heading and voltage. 7. GPS lock supplies for return

- to

- hom e (RTH). Should Command and Control (C2) link failures occur (highly improbable), vehicle returns automatical ly to the point of launch. 8. Altitude information will be provided to the sUA S 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 equipm ent 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 b y the pilot. **Mechanical/Physical:** 1. We will fly line

- of

- sight (LOS) only. The vehicle w ill 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 exem pt ion 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 f requencies 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 pe rsonnel 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 i nvolved 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 s UAS generally and received up

- to

- date information on the particular s UAS to be operated. **Operations:** 1. The sm all unmanned aerial system ( s UA S ) must weigh less than 30 pounds, including energy source(s) and equipment. Operations authorized by this petition of exemption are li mited 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 mo re 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 f eet 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 certificat e. 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 inc luded 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 conditi ons 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
am endment. If the operator determines that any update or revision wou ld 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) m ay 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 ne cessary 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 airc raft 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 mu st follow the manufac turer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/compo nent/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. Pow erplant (motors); d. Propellers; e. Electronic speed c ontroller; 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 em ergency. 11 . Regarding the distance from participating per sons, the operator’s manual has saf ety 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 perim eter and land or be recovered in accordance with the operator’s manual. 13 . The UAS must abort the flight in the ev ent of unpredicted obstacles or emergencies in accordance with the operator’s manual. 14 . Each UAS operation must be completed with 25% batte ry pow er rem aining.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 p rocedures 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 freque ncy spectrum used for operation and control of the UA must co mp ly with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 18 . The UA must remain clear and yield the r ight of way to all other manned operations and activities at all times (including, but not limi ted 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 un der special visual flight rules (SVFR) are not authorized. 2 0 . 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 fee t below or less than 2,000 feet horizontally from a c loud or when visibility is less than 3 statute miles from the PIC. 22 . The UA may not operate in Class B, C, or D ai rspace without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non

- towered airpo rt 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 manag ement must be made available to the Administrator upon request. 23 . Any incident, accident, or flight operation that trans gresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported t o 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 review ed 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 Inform ation:**  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**  **Baltim ore Photo Bomb**  **, LLC seeks an Exe**  **mption** 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 Exemp tion 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 on ly 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, w e request an exemption from any such regulatory provision s 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, w eight, speed, operational capability of the particular s UAS, 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 passeng er, 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 assi st 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 ris k 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 clie nts. Accordingly, the risk would be limited to Baltimore Photo Bomb , LLC personnel, who will be appropriately outfitted in safety gear, and Baltimore Photo Bom b , LLC c lient’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 yo u have any questions or concerns. Respectfu lly

submitted, Mike Canterbury CT O, Baltimore Photo Bomb , LLC