CANDY FACTORY PRODUCTIONS 114 Middle Ave, Saratoga Springs, NY 12866 518-857-8468 candyfactoryflms.com

June 04, 2015

U.S Department of Transportation

Federal Aviation Administration

800 Independence Ave, S.W.

Washington, D.C. 20591

Dear Ms. Brenda Robeson,

Regarding public docket (No. FAA-2015-7059).

In accordance with §11.81, and per your written request dated May 20, 2015, Candy Factory 

Productions submits the following information in order to meet the exemption requirements for Section

333 of Public Law 112-95:

The specific section or sections of 14 CFR from which you seek relief, the extent of the relief you 

seek, and the reason you seek relief.

sUAS operator, Candy Factory Productions, LLC (CFP) seeks relief from CFR 14, part 21, 

Certification procedures for products and parts, Subpart H – Airworthiness Certificates, in accordance 

with Section 333 of Public Law 112-95, FAA Modernization and Reform Act of 2012 (FMRA). Based 

in Saratoga Springs, New York, CFP wishes to enter the services market for providing commercial, 

aerial photography and videography using small unmanned aircraft systems, using methods consistent 

with the FAA's exemption criteria. CFP seeks an exemption for the commercial use of the “Inspire 1” 

and “Phantom 3,” sUAS, manufactured by DJI. 

The reasons why granting the request would be in the public interest; that is, how it would benefit 

the public as a whole.

CFP is receiving sustained requests from clients in the electronic media and broadcasting industries for 

experienced and professional sUAS operators with knowledge of safety and regulatory requirements to 

provide aerial video capture for their associated projects, while using the least invasive technologies 

that do not require fueled and piloted aircraft to achieve the same results.

The reasons why the exemption would not adversely affect safety or how the exemption would 

provide a level of safety at least equal to that provided by the rule from which you seek an 

exemption.

Exempting CFP will in no way adversely affect safety for the following reasons:
CANDY FACTORY PRODUCTIONS 114 Middle Ave, Saratoga Springs, NY 12866 518-857-8468 candyfactoryflms.com

1. We are aware of the limitations imposed on this exemption and have already been operating in 

compliance with them recreationally. Namely, our sUAS (DJI Inspire 1) falls well under the 

maximum weight limit of 55 lbs (actual weight 6.5 lbs.), we fly under a maximum altitude of 

200 feet and always within visual range, and always stay beyond 5 miles of airports.

2. We are additionally aware of and adhere to community-based guidelines such a those of the 

Academy of Model Aeronautics (AMA).

3. CFP will conduct all sUAS activities on closed sets or rural locations with small population 

densities.

4. CFP has developed an additional protocol for enhanced launch, flight and landing safety, which 

includes regular sUAS inspections and calibrations prior to each flight, app (software 

application) performance checklists, and launch safety requirements for our immediate crew. 

Any additional information, views, or arguments available to support your request.

sUAS operators at CFP are mature and seasoned professionals within the film and television industries,

who have collectively logged over 100 hours of training and non-commercial flight-time working with 

sUAS in preparation for these emerging markets in a safe, responsible manner that respects the 

continued integrity and security of national air space. 

Please let me know if you require any additional information, which I am happy to provide.

Sincerely yours,

Jason Ward

CEO Candy Factory Productions

518-857-8468

jason@candyfactoryfilms.com