U.S. Department of Transportation, Docket Operations

Federal Aviation Administration

1200 New Jersey Ave., S.E.

Washington, DC 20590

Section 333 Petitioner:

Candeo Creative, LLC

146 Algoma Blvd., Ste. G

Oshkosh, WI 54901

Office: 920­252­8128

Email: sheng@candeocreative.com

January 14, 2016

Table of Contents:

Introduction

Request For Exemption

Small Unmanned Aircraft System (sUAS)

Operations and Safety

Conclusion
Introduction

Candeo Creative, LLC is a marketing and advertising agency interested in providing aerial

videography and photography to businesses and individuals in Northeast Wisconsin on a

for­profit basis. A prominent client of Candeo Creative is the Oshkosh Convention and Visitor’s

Bureau (OCVB), whose mission is to promote the city of Oshkosh as a premier destination for

corporate, sports and leisure groups and individual visitors. With the ability to utilize aerial

videography and photography in marketing service of the OCVB, Candeo Creative will aide in

the promotion of Oshkosh tourism and contribute to the state’s economic growth. (See 2015

Economic Impact of Tourism in Wisconsin attachment.)

Request For Exemption

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Candeo Creative,

LLC seeks exemption from the requirements of Title 14 C.F.R. Parts: 21, Certification

Procedures for Products and Parts; 61, Pilots, Lights Instructors, and Ground Instructors;

91.7(a), Civil aircraft airworthiness; 91.9(b)(2), Civil aircraft flight manual, marking, and placard

requirements; 91.109, Flight instruction, Simulated instrument flight and flight tests;

91.103(b)(2), Preflight action; 91.105, Flight crewmembers at stations; 91.119, Minimum safe

altitudes: General; 91.151(a), Fuel requirements for flight in VFR conditions; 91.203(a) and (b),

Civil aircraft: Certifications required; 91.405(a), Maintenance required; 91.407, Operation after

maintenance, preventive maintenance, rebuilding, or alteration; 91.409, Inspections; and

91.417(a) and (b), Maintenance records. This exemption will permit Candeo Creative, LLC to

operate a Small Unmanned Aircraft System (sUAS) for the commercial purpose of conducting

aerial videography and photography in service of businesses and individuals.

Small Unmanned Aircraft System (sUAS)

Candeo Creative will operate a DJI Phantom 2 with Zenmuse Gimbal for GoPro with

transportable controller stationed on the ground. The Phantom 2 Aircraft is equipped with a

built­in flight control system, used to control the aircraft’s functions in flight such as pitch, roll,

elevator and yaw. The flight controller contains the main controller, inertial measurement unit

(IMU), GPS, compass and receiver. The IMU has a built­in inertial sensor and a barometric

altimeter that measures both attitude and altitude. The compass reads geomagnetic information,

which assists the GPS to accurately calculate the aircraft’s position and height in order to lock

the aircraft in a stable hover. The receiver is used to communicate with the remote controller

and the main controller acts as the brains of the complete flight control system connecting and

controlling all the modules together. At takeoff, the Phantom 2 weighs less than three pounds.

Full specifications of the DJI Phantom 2 can be found at:

http://dl.djicdn.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf
Operations and Safety

A grant of Candeo Creative’s exemption request will not adversely affect public safety for the

following reasons:

1. LED flight indicators are used to show the aircraft’s current status such as, Ready to Fly,

Remote Controller Signal Lost, Low Battery Capacity Warning, Errors & Aircraft Cannot

Fly and Compass Data Abnormal to avoid safety risks.

2. Aircraft will be flown using only original DJI propellers. Aged, chipped or broken

propellers will be replaced before flight to avoid safety risks.

3. LED indicators on remote controller will notify pilot in control if remote controller needs to

be re­calibrated or is low on power to avoid safety risks.

4. The Phantom 2 is equipped with an “intelligent battery,” which balances the voltage of

each battery cell during charging, communicates with the main controller, automatically

stops charging when the battery voltage reaches 12.8V to prevent overcharging

damage, and automatically shuts off power supply when a short circuit is detected to

avoid safety risks.

5. Flights will be in conducted in the visual line of sight of the operator or visual observer

who will be in constant communication with the operator to avoid safety risks.

6. Flights will remain within a max radius. If the aircraft flies out of the max radius, it will fly

back within the limits range automatically if 6 or more GPS satellites have been found to

avoid safety risks.

7. If the Phantom 2 is in a special area or flies into a special area, the motor will not start, it

will automatically descend and land then stop its motors, or it will descend to less

restricted airspace and hover 5 meters below edge to avoid safety risks. All special

areas are listed on the DJI official website: http://www.dji.com/fly­safe/category­mc

8. Operators will be trained to safely operate the Phantom 2.

Conclusion

Candeo Creative respectfully requests the exemptions as described above be fully granted as

stated or modified in furtherance of public safety, necessity and convenience. Candeo Creative

stands ready to modify, augment or amend this request to satisfy any safety requirements

deemed necessary by the FAA.

Respectfully submitted,

Candeo Creative, LLC

By: Sheng Riechers, Director of Operations