Colorado Wedding Productions LLC
2900 Aurora Ave. Apt. 331 Boulder, CO, 80303

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 

### Regulatory

Docket Number _____________________________

To Whom It May Concern, Colorado Wedding Producti ons LLC (henceforth called CWP ) located at 2900 Aurora Ave. Apt. 331 Boulder, CO 80303 and Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("FAA Reform Act") and 14 C.F.R. Part 11, respectfull y requests exemptions from several provisions of the Federal Aviation Regulations ("FAR"), specifically 14 CFR Part 21 subpart H, Part 61, Part 91.103(b)(2), 91.105, 91.109, 91.119, 91.121, 91.151, 91.405, 91.407, 19.409, 91.417 to be able to operate unman ned air systems (UAS), specifically the models 3DR Solo, DJI Phantom 3, DJI Phantom 3 Professional, DJI Inspire 4k , and Yuneec Q500 4k, in NAS for primary commercial use of aerial filming and photography of weddings in Colorado and secondary commercial us e of mountain lake imaging for outdoor enthusiasts. CWP is a business which directly services members of the public and granting us these exemptions would serve public interest by increasing the quality of that service. As per the FAA recommendatio ns for filing a petition of this nature, CWP would like to address each point regarding the UAS, the UAS Pilot in Command (PIC), and the operation of the UAS.

Regarding the UAS 1. Each model which CWP seeks exemption to operate has been constructed to minimize the risk to the NAS as well as person s and property on the ground. These models, while technologically advanced, are limited by the manufactures for safety measures in compliance with the FAA. These limitations include for each model; maximum airspeed below 50 knots, maximum altitude below 400ft, and maximum weight (including aircraft weight) below 50 lbs. Each model has advanced GPS and operational modes designated for safety purposes. 2. CWP would implement inspection and maintenance on any UAS in accordance with the manual for that UAS before each flight. 3. The operating frequencies for the Solo, Phantom series, Inspire 4k, and Q500 4k are 2.4 GHZ, 5.7

- 5.85 GHZ, 5.7

- 5.85 GHZ, 2.4 GHZ (with 5.8GHZ video link) respectively. Thesefrequencies al l fall within the WIFI allocation band of the FCC’s radio communication allocation and are allowed by the FCC
Regarding the Unmanned Aircraft PIC 4. CWP would require any operator of the UAS who has under 50 hours of flight time to operate the UAS under its “safe” operation mode, which greatly slows the movement speed of the UAS and does not allow it to perform any maneuvers that would cause it to fall from the sky. Further, any operator of the UAS would not be allowed to operate the UAS around people withou t 10 hours of practice flight time. Typically CWP will only operate its UAS in “safe” mode regardless of the experience level of the PIC. All PIC’s will be required to read and familiarize themselves with the operating procedures of the UAS as described in the manual and will be tested for proficiency in both flight capability and knowledge of safe operating procedures by CWP’s founding member Shaun Piazza, who will have extensive practice and knowledge of each UAS model operated by CWP. 5. As these models are all small UAS operating at low elevation and speed CWP will not require operators to have any medical certifications . However the venues at which CWP typically engages in commercial activities have their own medical emergency procedure s.
Regarding the Operations of the UAS 6. CWP’s primary use of its UAS would be to shoot photo and video of weddings. This creates a unique situation of creating many people who are necessary to the shot (as the purpose is to capture a couple’s wedding and guests on digital media). The UAS would be launched and landed in an area clear of people besides the PIC in at least a 15ft radius. While flying above people, The UAS will not be operated within a 15ft radius of trees or any other aerial collision hazard, and the operational zone with be scouted for such hazards before the UAS is launched. The UAS will have a minimum altitude of 25ft when flying in the proximity of people. Further, CWP will make it policy to not ho ver directly above seated people (such as they would be at a wedding ceremony) and have all stationary filming shot from a clear location as is reasonably allowed by the location . While CWP seeks the maximum allowance of a 400ft altitude, a 50lb payload, and a 50 knot air speed, standard use of the UAS by CWP will be at less than half of these maximums. CWP will always operate the UAS under its “safe” operation mode unless the shot requires a faster movement speed, during which time the UAS will be taken out of “safe” operation mode and then immediately returned to that mode when the shot has been taken. CWP will also be mindful of weather conditions and w ill not operate any UAS when wind of temperature is outside of the manufacturer stated capability range of the UAS. Further, we will always operate the UAS in line of site. The launch and landing operations will be carried out at slow speed using the UAS’s auto mated systems for each maneuver in a zone clear of people besides the PIC. CWP’s secondary commercial use would be to provide imaging of mountain lakes. Under this operation each of the precautions stated above would still be followed by CWP, however the risk would be reduced even more because there would be less people and greater open space.7. As stated in item 6, the operational zone will be scouted for hazards and weather conditions will be taken into consideration. If fog, clouds, or snow pro hi bit line of site the UAS will not be flown past that threshold . Further, if any weather condition is advised against flying in by UAS’s manual then CWP will not operate the UAS. 8. The zones which the UAS will be used are large open spaces such as parks, g olf courses, and

m ountain event centers. The largest hazards will be weather, power lines, and trees, all of which will be looked for and considered before take off. 9. CWP does not intent to operate a UAS in the proximity of any airport. 10. The locations whic h CWP will primarily operate a UAS will not pose any issue to the line of sight regulation as the locations will be large open spaces filming a stationary scene which the PIC will be proximal to. If the operation zone creates line of site issues for secon dary use the UAS will be launched and landed multiple times to capture each piece of the desired image. The PIC will relocate him/herself during each repetition to be optimally located for line of site operation. 11. Preflight safety check of the UAS would fo llow the guidelines set forth in the operation manual for that model. 12. CWP will notify the FSDO when operating the UAS in any circumstance that requires notification to the FSDO.

**SUMMARY** Colorado Wedding Productions LLC seeks exemptions from the followin g regulations: 14 CFR Part 21 subpart H, Part 61, Part 91.103(b)(2), 91.105, 91.109, 91.119, 91.121, 91.151, 91.405, 91.407, 19.409, 91.417 to be able to operate unmanned air systems (UAS), specifically the models 3DR Solo, DJI Phantom 3, DJI Phantom 3 Professional, DJI Inspire 4k , and Yuneec Q500 4k, in NAS for primary commercial use of aerial filming and photography of weddings in Colorado and secondary commercial use of mountain lake imaging for outdoor enthusiasts. These exemptions will provide servic e to the public by allowing us to provide aerial photography and videography to the public and increasing the quality of the service provided by Colorado Wedding Productions. Colorado Wedding Productions will take the necessary steps to ensure a maximum l evel of safety when operating the UAS. Further, our UAS operations will primarily be with the UAS “safe” operation mode and at less than half of the maximum allowed speed, altitude, and weight the FAA imposes on similar exemptions, making this request a lower risk request.

Sincerely,
Shaun Piazza, Founding Member of Colorado Wedding Productions LLC