Request	for	Amendment:	Exemption	No.	12593,	Docket	No.	FAA-2015-2412

September	18,	2015

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Attn:	Federal	Aviation	Administration	UAS	Integration	Office

RE:	Request	for	Amendment	to	Exemption	No.	12593	on	Behalf	of	Planet	Inhouse,	Inc.	(Regulatory	

Docket	No.	FAA-2015-2412)

Dear	Sir	or	Madam:

Planet	Inhouse,	Inc.	(hereinafter	“Operator”)	respectfully	requests	an	amendment	to	its	

existing	Section	333	Exemption	No.	12593,	to	include	authorization	to	conduct	Closed	Set	Motion	

Picture	and	Television	Aerial	Filming	Operations (“Closed	Set	Filming	Operations”),	and	to	add	

additional	aircraft	to	Operator’s	list	of	authorized	unmanned	aircraft	systems	(“UAS”).		The	

conditions	set	forth	in	Docket	No.	FAA-2015-2412	have	not	changed	since	Exemption	No.	12593	

was	granted	to	Operator	on	August	25,	2015.

In	support	of	Operator’s	request	to	amend	Exemption	No.	12593	to	include authorization	

to	conduct	Closed	Set	Filming	Operations,	Operator respectfully	submits	its	Motion	Picture and	

Television	Flight	Operations	Manual	(“MPTFOM”).		Operator’s	MPTFOM	is	attached	hereto	as	

Appendix A.		

Additionally,	Operator	respectfully	requests	an	amendment	to	its	exemption	authorizing	

the	operation	thereunder	of	the	following	UAS,	each	of	which	meets	the	size	and	performance	

characteristics	as	required	under	Operator’s	exemption	and	Section	333	of	the	2012	FAA	

Modernization	and	Reform	Act,	as	well	as	the	included	operations	manuals	submitted	in	support	

of	this	amendment	request:

1. FreeFly	Alta – The	Alta	is	a	small	(1126	mm	diameter)	and	lightweight	(maximum	takeoff	

weight	of	13.6kg	or	approximately	30	lbs.) multirotor	UAS	made	from	strong,	yet	

lightweight	materials	designed	for	professional	aerial	filming	operations.		The	Alta	is	highly	

reliable and	stable	aircraft	and	its	integrated	GPS and	flight	control	software	gives	the	Alta	

the	ability	to	make	emergency	“return-to-home”	and	automatic	landing	maneuvers	that	

ensure	the	highest	level	of	operational	safety. See	Appendix	B for	further	information	

regarding	the	airframe,	control	system,	and	electronics.		The	FAA	has	previously reviewed	

these	documents	and	has	approved	the	Alta	for	commercial	operations	in,	for	example,	

Exemption	Nos.	12830	and	12362.

2. DJI	Phantom	3– The	Phantom	3	is	a	small,	ultra-lightweight	(1280g)	multirotor	UAS	made	

from	strong	yet	lightweight	materials	designed	for	professional	aerial	filming	operations.		

The	Phantom	3	is	highly	reliable	and	safe	thanks	to	its	integrated	GPS	and	flight	control	

software	that	allows	the	Phantom	3	to	perform	several	emergency	maneuvers	such	as	

return-to-home	that	ensures	safe	operations.		See	Appendix	C for	further	information	

regarding	the	airframe,	control	system,	and	electronics.		The	FAA	has	previously	reviewed	
Request	for	Amendment:	Exemption	No.	12593,	Docket	No.	FAA-2015-2412

these	documents	and	has	approved	the	Phantom	3	for	commercial	operations	in,	for	

example,	Exemption	Nos.	11253A,	12844, and	11770A.

3. 3D	Robotics	Solo – The	Solo	is	a	small	(26cm	or	approximately	18	in	motor-to-motor)	and	

ultra-lightweight	multirotor	UAS	designed	for	professional	aerial	videography	and	

photography	operations.		The	Solo	is	highly	reliable	and	safe	thanks	to	its	integrated	GPS	

and	flight	control	software	that	allows	the	Solo	to	perform	various	emergency	and	safety	

maneuvers,	including	return-to-home	and	emergency	landing.		See	Appendix	D for	further	

information	regarding	the	airframe,	control	system,	and	electronics.		The	FAA	has	

previously	reviewed	these	documents	and	has	approved	the	Solo	for	commercial	

operations	in,	for	example,	Exemption	No. 12826.

4. Tarot	Oct-Copter	X8 – The	Oct-Copter	X8	is	a	small	(1050mm	motor-to-motor)	lightweight	

(2.7kg)	multirotor	UAS	made	from	carbon	fiber	designed	for	professional	aerial	

videography	operations.		The	Oct-Copter	X8	is	highly	reliable	and	safe	and	is	equipped	with

redundant	safety	mechanisms	allowing	it to	operate	safely	after	experiencing	certain	inflight	failures,	such	as	loss	of	GPS	signal,	and	perform	emergency	maneuvers	such	as	

return-to-home. See	Appendix	E for	further	information	regarding	the	airframe,	control	

systems,	and	electronics.		The	FAA	has	previously	reviewed	these	documents	and	has	

approved	the	Tarot	Oct-Copter	X8	for	commercial	operations	in,	for	example,	Exemption	

No.	11178.

Operator’s	existing	safety	standard	and	procedures	as	outlined	it	Exemption	No.	12593 and	the	

attached	MPTFOM	will	apply	to	the	operation	of the	additional	aircraft.		Operator	will	follow	the	

recommended	maintenance	and	operations	parameters	set	forth	by	the	respective	UAS	

manufacturers.	

The	conditions	set	forth	in	Docket	No.	FAA-2015-2412	have	not	changed	since	Exemption	No.	

12593	was	granted	to	Operator	on	August	25,	2015.		Operator’s	Closed	Set	Filming	Operations	and	

the	additional	aircraft	listed	above	will	be	conducted	and	operated	within	the	parameters	set	forth	

by	Exemption	No.	12593	as	amended	hereby,	the	associated	COA,	and	Operator’s	MPTFOM.	

Please	do	not	hesitate	to	contact	me	at	303-910-6184,	or	by	email	at	n.c.brown51987@gmail.com	

should	you	have	any	questions	or	concerns.	

Respectfully	submitted,

Nathanial	C.	Brown

Counsel	for	Operator

Planet	Inhouse,	Inc.
Request	for	Amendment:	Exemption	No.	12593,	Docket	No.	FAA-2015-2412

Appendix	A

Planet	Inhouse,	Inc.

Motion	Picture	and	Television	

Flight	Operations	Manual

[File	uploaded	to	Docket	as	‘Appendix	A	– Planet	Inhouse	– MPTFOM.pdf’]
Request	for	Amendment:	Exemption	No.	12593,	Docket	No.	FAA-2015-2412

Appendix	B

FreeFly	Alta	– Operations	Documents

[Files	uploaded	to	Docket	as	‘Appendix	B	– Planet	Inhouse	– Alta	Manual.pdf’	and	

‘Appendix	B	– Planet	Inhouse	– Alta	Setup	Guide.pdf]
Request	for	Amendment:	Exemption	No.	12593,	Docket	No.	FAA-2015-2412

Appendix	C

DJI	Phantom	3	– Operations	Documents

[Due	to	file	size	limitations,	file	can	be	found	at	http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v

1.4_en_0915.pdf]
Request	for	Amendment:	Exemption	No.	12593,	Docket	No.	FAA-2015-2412

Appendix	D

3D	Robotics	Solo	– Operations	Documents

[File	uploaded	to	Docket	as	‘Appendix	D	- Planet	Inhouse	- 3DR	Solo	User	Manual.pdf]
Request	for	Amendment:	Exemption	No.	12593,	Docket	No.	FAA-2015-2412

Appendix	E

Tarot	Oct-Copter	X8 – Operations	Documents

[Files	uploaded	to	Docket	as	‘Appendix	E	- Planet	Inhouse	- TAROT	X8	Product	

Description	and	Specs.pdf’;	‘Appendix	E	- Planet	Inhouse	- 2.4G	Bluetooth	Datalink	&	

iPAD	Ground	Station	User	Guide.pdf’;	‘Appendix	E	- Planet	Inhouse	- 14sg-manual.pdf’;	

‘Appendix	E	- Planet	Inhouse	- Lightbridge	User	Manual.pdf’;	‘Appendix	E	- Planet	

Inhouse	- Woo-kong	flight	controller	user	manual.pdf’; and	‘Appendix	E	- Planet	

Inhouse	- Z15	User	Manual.pdf’]