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 Productions 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, respectfully 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 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. 

 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 recommendations 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 persons 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. These 
frequencies all 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 without 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 procedures.

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 hover 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 will 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 

automated 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 prohibit 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, golf courses, and 

mountain 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 which 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 secondary 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 follow 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 following 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 service 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 level 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