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 ofTransportation, 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 14of the Code of Federal Regulations 14 C.F.R., with regards to operation ofa 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 UASfor the purpose ofconducting aerial video and photographywithin thefollowing areas:

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

sales or other legal businessesthat 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 accidentsfrom occurring. With my understanding and awareness ofoperational 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 thatthe 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 thatthe FAA has already granted a previous exemption similar to my request. Plum Consulting requests exemption for a sUAS up to 55 pounds. Specificallyfor my operations I would like the exemption to includethe 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 andAppropriateness: Based on the size ofthe craft, experience ofthe pilot, and operational goals, this request appears to 

### be well suited for approval using the current criteria outlined in Section 333 ofthe FAA modernization and Refonn Act of2012. 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 thatthe 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 setforth requirements for maintenancethat only applyto aircraft with an airworthiness certificate. Plum Consulting requests for relief is proper since an equivalent level of safety will be ensured. The use ofexperienced personnel ortechnicians to perform maintenance, alterations, or preventive maintenance on the sUASto insure airworthiness. Maintenance will bedetermined bythe 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 orother 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 sUSAwithin the last 90 days. • Pre-flight inspection will take place priorto each flight to ensure sUAS is airworthy • Flights will never exceed 400 feet AGL • The designated flight area will not 

### be lessthan 500 feet from nonparticipating persons,

vehicles, vessels or structures unless approval is granted priorto flight • Flights will only occurwithin the VFR and VMC • All flights will only operate within a planned flight path delivered in a brief priorto flight. All

participating parties will be in attendance who will beoperating within the boundaries ofthe safety perimeter. • PIC will abort flight in the event ofa sudden environmental, weather change oremergency • All flights will consist ofat 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 cityjurisdictions, including local law enforcement, fire orother appropriate governmental agencies

. • The sUAS will not 

### be operated bythe PIC from any moving device or vehicle • Any incident, accident or boundarytransgression 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 operatorwill 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.

AdditionalSafetyFeature$: 

### The DJI sUAS(s) are equipped with many safetyfeatures, for example, ifthe DJI Phantom 2 and its controller are disconnected during flight, the system's failsafe protection will activate, automaticallytelling and ifthe 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 newfirmware forthe Phantom 2 series includes a No Fly Zone feature

. If the Intelligent Flight Battery is running low, or ifthe Phantom losesthe connection with the remote controller for any reason, the aircraft will automatically return tothetakeoff point and land safely

. In addition, the craft operates electrically, carries noflammable fuel, has an integrated GPS pilot system, provides location information along with heightAGL, 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 opera tions and planning flight paths that minimize any overflight of crowds

. Flights will 

### beterminated when battery reserve reaches 25%

. Operations will not occur under IFR conditions, orany 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 10 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 sa fety 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, givesthe FAA good cause tofind that the sUAS operations enabled bythis exemption is in the public interest.
Sincerely,

Flora Lloyd