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

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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	Se t	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	c hanged	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	whic h	meets	the	siz e	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	submitte d	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	ha s	approved	the	Alta	for	commercial	operations	in,	for	example, Exemption	Nos.	12830	and	12362. 2. DJI	Phantom	3

– The	Phant om	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	th at	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	reviewedRequest	for	Amendment:	Exemption	No.	12593,	Docket	No.	FAA

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- 2412 these	docu ments	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. T arot	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	experien cing	certain	in

flight	failure s,	such	as	loss	of	GPS	signal,	and	perform	emergency	maneuvers	such	as return

- to

- home. See Appendix	E for	further	information	regarding	the	airframe,	con trol 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	Exemp tion	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

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- 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	Ex emption	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,

Nathan ial	C.	Brown Counsel	for	Operator Planet	Inhouse,	Inc.Request	for	Amendment:	Exemption	No.	12593,	Docket	No.	FAA

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## 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

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## 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

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## Appendix	C DJI	Phantom	3

– Operations	Documents
[

Due	to	file	size	limitations,	file	can	be	found	at http://download.dji

innovations.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

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## 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

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## 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’; ‘Appendi x	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’ ]