Plum Consulting 

Flora A. Lloyd 

126 SW 148th St. 

Suite C100 Box 323 

Burien, WA 98166 

email: flora.lloyd@gmail.com 

January 13th, 2016 

U.S. Department of Transportation, 

Docket Management Systems, 

1200 New Jersey Avenue SE, 

Washington, DC 20590 

Dear Sir or Madam, 

This letter serves as a petition for exemption from specific rules contained in Title 14 of the 

Code of Federal Regulations 14 C.F.R., with regards to operation of a small, unmanned aircraft 

(sUAS} to allow In-Flight commercial operation in the industries listed below. This exemption 

will permit Plum Consulting to commercially operate an UAS for the purpose of conducting 

aerial video and photography within the following areas: 

• Aerial cinematography in video or still format for real estate, architectural, marketing, yacht 

sales or other legal businesses that require supplementary aerial footage 

• Aerial cinematography in video or still format for weddings & private events requiring 

supplementary aerial footage 

• Aerial surveying, inspections & mapping 

• Aerial cinematography in video or still format for sporting events, special events, film making 

I have been a licensed private pilot since 2006. In that time I have had the privilege of flying a 

twin engine aircraft around the world and have enjoyed both filming and flying sUAS(s) for the 

last 3 years. The skills I learned as a pilot I take in all seriousness, and believe that pilot 

education, procedure and and safety are key in the operation of a sUAS to prevent injury and 

accidents from occurring. With my understanding and awareness of operational and restricted 

airspace, my experience as a private pilot, and my awareness and attitude regarding safety 

standards in flight operations, I believe Plum Consulting should be granted an exemption. 

It is my understanding that the FAA will stilt review each Section 333 petition individually. 

However I am hoping that my petition may be included in the next summary grant on the 

assumption that the FAA has already granted a previous exemption similar to my request. 

Plum Consulting requests exemption for a sUAS up to 55 pounds. Specifically for my 

operations I would like the exemption to include the DJI Inspire 1 , DJI Phantom 2 & 3, and the 

DJI S-1 000. Plum Consulting seeks exemptions from the requirements of 14 C.F.R §§ 61.113(a) 

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b). 
Section 333 Compliance and Appropriateness: 

Based on the size of the craft, experience of the pilot, and operational goals, this request 

appears to be well suited for approval using the current criteria outlined in Section 333 of the 

FAA modernization and Refonn Act of 2012. The sUASs described in this petition meet the 

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance 

with 14. C.F.R. Part 21, Subpart H. Granting this request would not adversely affect safety 

since operations would be in accordance with current sUAS rules. Therefore Plum Consulting 

requests relief from Section 91. 7(a). Plum Consulting will ensure that the sUAS herein 

described will maintain an airworthy condition, prior to every flight, by determining that the 

sUAS are in compliance with the operating documents. 

In seeking this exemption, Plum Consulting submits that the DJI sUASs can operate safely in 

the NAS pursuant to FMRA Section 333, as demonstrated by it's characteristics, pilot 

verification requirements and the specific operating limitations. 

Plum Consulting requests relief from Sections 91 .405(a), 91.407(a)(1 ), 91.409(a)(1) & (a)(2), and 

91 .417(a) & (b), as these sections set forth requirements for maintenance that only apply to 

aircraft with an airworthiness certificate. Plum Consulting requests for relief is proper since an 

equivalent level of safety will be ensured. The use of experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the sUAS to insure 

airworthiness. Maintenance will be determined by the manufacture's recommendation of 

service and care. In addition, a standard maintenance log will be maintained. 

Relief from certain requirements of Section 61 .113(a) and (b) are requested, and the standards 

for our commercial operations will include: 

• PIC will possess an active private pilots license or other approved licenses by the FAA, and 

an active U.S. driver's license. The PIC will also have logged a minimum of five hours 

operating the make/model of the sUSA within the last 90 days. 

• Pre-flight inspection will take place prior to each flight to ensure sUAS is airworthy 

• Flights will never exceed 400 feet AGL 

• The designated flight area will not be less than 500 feet from nonparticipating persons, 

vehicles, vessels or structures unless approval is granted prior to flight 

• Flights will only occur within the VFR and VMC 

• All flights will only operate within a planned flight path delivered in a brief prior to flight. All 

participating parties will be in attendance who will be operating within the boundaries of the 

safety perimeter. 

• PIC will abort flight in the event of a sudden environmental, weather change or emergency 

• All flights will consist of at least one PIC and one visual observer to keep the sUAS within 

visual line of sight during the flight. 

• Verbal or written consent will be obtained from property owners, authorized representatives, 

territorial, state, county or city jurisdictions, including local law enforcement, fire or other 

appropriate governmental agencies . 

• The sUAS will not be operated by the PIC from any moving device or vehicle 

• Any incident, accident or boundary transgression will be reported within 24 hours to the 

FAA's UAS Integration Office and all accidents will be reported to the National Transportation 

Safety Board. · 

• The operator will also carry a minimum of $1 ,000,000.00 in liability insurance. 

Plum Consulting also seeks an exemption from the requirements of Section 91.121, as the DJI 

sUAS(s) will not have a typical barometric altimeter onboard. However, altitude information will 

be provided to the PIC via the display monitor, that will display data from the GPS equipment 
and radio communications telemetry data link. This information combined with maintained 

visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121 . 

Finally, Plum Consulting seeks an exemption from the requirements of Section 91.151(b). 

Safety will not be affected by operation of the DJI sUAS during daylight hours in VMC under 

VFR, with enough battery power to fly for a total duration of approximately 23 minutes. The 

PIC's monitor will display battery level, and flights will be terminated at no less than 25% 

battery life remaining. 

Additional Safety Feature$: 

The DJI sUAS(s) are equipped with many safety features, for example, if the DJI Phantom 2 

and its controller are disconnected during flight, the system's failsafe protection will activate, 

automatically telling and if the signal is good enough, the Phantom 2 to return home and land 

automatically. In order to increase flight safety and prevent accidental flights in restricted 

areas, the new firmware for the Phantom 2 series includes a No Fly Zone feature. If the 

Intelligent Flight Battery is running low, or if the Phantom loses the connection with the remote 

controller for any reason, the aircraft will automatically return to the takeoff point and land 

safely. In addition, the craft operates electrically, carries no flammable fuel, has an integrated 

GPS pilot system, provides location information along with height AGL, speed, battery life. In 

addition, a remote is equipped with a viewing screen to display the power levels and camera 

view for additional safety. 

Flight Operations: 

(see attached operational procedures) 

I am aware of how to conduct safe flight operations and planning flight paths that minimize any 

overflight of crowds. Flights will be terminated when battery reserve reaches 25%. Operations 

will not occur under IFR conditions, or any conditions that would render unsuitable for safe 

operation. The attached preflight, inflight and post flight checks will be carried out each flight 

and any pilots operating the sUAS will have a minimum of 1 0 hours flight time training before 

used for commercial purposes, and scheduled check flights will be preformed, logbooks 

maintained to insure that all PIGs are current on the sUAS. 

Benefit to the public: 

It is my hope that you find that the enhanced safety achieved using an unmanned aircraft as 

described above which carries no passengers or crew, rather than a manned aircraft of 

significantly greater proportions and cost, crew and flammable fuel, gives the FAA good cause 

to find that the sUAS operations enabled by this exemption is in the public interest. 

Sincerely, 

Flora Lloyd