November 1 7 , 2015

U.S. Department of Transportation , Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Ave., SE Washington, DC 20590

To Whom It May Concern :

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R., Part 11, Tribune Media Company (“Tribune Media ”) , operator of Small Unmanned Aircraft Systems (“ s UAS”) equippe d to conduct aerial videography and photography to support newsgathering

, requests a limited exemption from the below

- listed regulations to allow commercial operation of its s UASs, provided that the proposed sUAS operations comply with

the conditions outlined below or as established by the Federal Aviation Adminis tration (“FAA”)

under Section 333.

The name and address of the applicant is:

Hank Hundemer Sr. VP, TV Engineering Tribune Media Company 435 N. Michigan Ave. Chicago, IL 60611
Phone: 859

- 444

- 4265

Fax: 312

- 222

- 5981
hank@tribunemedia.com

Tribune Media makes this request under the “summary grant” process that the FAA announced in April 2015. 1 This request is similar in all material respects to a number of recent grants of exemption, including Grant of Exemption No. 12901 to Cox Media Group, LLC (FAA

Do cket No. 2015

- 2672 ) and Grant of Exemption No. 11488 to Advanced Aerial Cinematography, LLC (FAA Docket No. 2014

- 0090). 2

1 See FAA Summary Grants Speed UAS Exemptions, available at https://www.faa.gov/news/updates/?newsId=82485.

2 The use limitations and arguments in this application are nearly identical to those contained in Cox Media Group’s July 5, 2015 application and the FA A’s September 17, 2015 approval of that (continued...)U.S. Department of Transportation , Docket Operations

November 1 7 , 2015 Page 2

Regulations from which the exemption is requested:

14 C.F.R. §§ 61.23(a) and (c)

14 C.F.R. §§ 61.101(e)(4) and (5)

14 C.F.R. § 61.113(a)

14 C.F.R. § 61.315(a)

14 C.F.R. § 91.7(a)

14 C.F.R. § 91.119 (c)

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)(1)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a)(1)

14 C.F.R. §§ 91.409(a)(1) and (2)

14 C.F.R. §§ 91.417(a) and (b)

Tribune Media proposes tha t it receive an exemption to use s UAS to conduct aerial videography and photography for newsgathering purposes. Tribune Media would use the footage for the p roduction of news items for its broadcasting stations , studios, and digital

brands

.

Tribune Medi a would use the following UAS for operations under this exemption :

UAS Type Weight (including payload)

DJI Phantom 3 Pro Quad

- rotor 1280 grams

DJI Phantom 3 Advanced Quad

- rotor 1216 grams

DJI Phantom 2 Vision+ Quad

- rotor 1242 grams DJI Phantom Inspire 1 Standard Quad

- rotor 2939 grams DJI Phantom Inspire 1 Extended Quad

- rotor 3039 grams

application as well as Advanced Aerial Cinematography’s November 24, 2014 application and the FAA’s May 5, 2015 approval of that application.U.S. Department of Transportation , Docket Operations

November 1 7 , 2015 Page 3

Tribune Media does not require and is not seeking an exemption for operations for the purpose of closed

- set motion picture and television filming.

The proposed s UAS operation will be conducted safely to minimize risk to the national airspace system (“ NAS ”) or to persons and property on the ground. Tribune Media proposes that the exemption apply to civil aircraft that operate with in the limitations listed below. These

limitations were established in the FAA’s grant of Advanced Aerial Cinematography’s request for an exemption :

1. The sUAS will weigh less than 55 pounds, including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2. The s UAS may not be operated at a speed exceeding 87 knots (100 miles per hour). Tribune Media may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In n o case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

3. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude will be reported in f eet AGL.

4. The UA will be operated within visual line of sight (VLOS) of the Pilot in Charge (PIC) at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’ s FAA

- issued

ai rman medical certificate or U.S. driver’s license.

5. All operations will utilize a visual observer (VO). The UA will be operated within the VLOS of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always ma intains the VLOS capability. The VO and PIC will be able to communicate verbally at all times; electronic messaging or texting will not be permitted during flight operations. The PIC will be designated before the flight and cannot transfer his or her des ignation for the duration of the flight. The PIC will ensure that the VO can perform the duties required of the VO.

6. This exemption and all documents needed to operate the s UAS and conduct its operations in accordance with the condition s and limitations st ated in the grant of exemption, are hereinafter referred to as the operating documents. The operating documents will be accessible during s UAS operations and made available to the Administrator upon request. If a discrepancy exists between the

co nditions and limitations in the exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and will be followed. Otherwise, Tribune Media will follow the procedures as outlined in its operating document s. Tribune Media may update or revise its operating

documents. It is Tribune Media ’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. Tribune Media will a lso present updated andU.S. Department of Transportation , Docket Operations

November 1 7 , 2015 Page 4

revised documents if it petitions for extension or amendment to this grant of exemption. If Tribune Media determines that any update or revision would affect the basis upon which the FAA granted this exemption, then Tribune Media m ust petition for an amendment to its grant of exemption. The FAA’s UA S Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

7. Any UAS that has undergone maintenance or alterations that af fect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC

w

ith a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

8. Tribune Media is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

9. Prior to each flight, the PIC will conduct a pre

- flight inspection and determine
the s UAS is in a condition for safe flight. The pre

- flight inspection will account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the s UAS,
th e aircraft will be prohibited f r o m operating until the necessary maintenance has been performed and the s UAS is found to be in a condition for safe flight.

10. Tribune Media will follow the s UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limi t requirements for the aircraft and aircraft
components.

11. Each s UAS operated under this exemption will comply with all manufacturer safety bulletins.

12. Under this grant of exemption, a PIC will hold either an airline transport, commercial, private, recreation al, or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the
Federal Government. The PIC also will meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

13. Tribune Media will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the s UAS in a manner consistent with how the s UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and structures. PIC qualification flight hours and currenc y will be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-U.S. Department of Transportation , Docket Operations

November 1 7 , 2015 Page 5

building) and determining the PIC’s ability to safely operate the s UAS in a

manner cons isten t with how the s UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building f lights, all persons not essential for flight operations are considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

14. UAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations will be conducted under visual meteorological conditions (VMC).

Tribune Media will not operate f lights under special visual flight rules (SVFR).

15. The UA will not operate within 5 nautical miles of an airport ref erence point (ARP) as denoted in the current FAA Airport/Facility Director (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on
the current FAA

- published aeronautical chart, unless a letter of agreement with

that ai rport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management will be made available to the Administrator or any law enforcement official upon
request.

16. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

17. If the s UAS loses communications or loses its GPS signal, the UA will return to a

pre

- determined location wi thin the private or controlled

- access property.

18. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

19. The PIC will be prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enoug h available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

20. Air Traffic Organization (ATO) Certificate of Waiver or Authorization ( COA). All operations will be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.

21. All aircraft operated in accordance with this exemption will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

22. Docume nts used by Tribune Media to ensure the safe operation and flight of the

s UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will beU.S. Department of Transpor tation , Docket Operations

November 1 7 , 2015 Page 6

available to the PIC at the Ground Control Station of the s UAS any time the aircraft is operating. These docum ents will be made available to the Administrator or any law enforcement official upon request.

23. The UA will remain clear and give way to all manned aviation operations and
activities at all times.

24. The s UAS will not be operated by the PIC from any moving device or vehicle.

25. All f light operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures, unless:

a. Barriers or structures are present that sufficientl y protect nonparticipating persons from the UA and/or debris in the event of an

accident. Tribune Media will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objec ts and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees, essential persons, or individuals who have signed
consent forms are not co nsidered nonparticipating persons under this exemption.

26. All operations will be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

U nless otherwise specified, the s UAS operations will compl y with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. Tribune Media incorporates all arguments in support of the petition made in Advanced Aerial Cinematography’s November 24, 2014 application for exemption and in Cox Media Group, LLC’s June 5, 2015 application for exemption

.U.S. Department of Transportation , Docket Operations

November 1 7 , 2015 Page 7

Federal Register Notice

P ublication in the Federal Register is unnecessary because this application meets the FAA’s criteria for summary approval. To the extent that the FAA determines that p ublication is necessary, the following summary is provided:

Applicant seeks an exemption from the following rules: 14 C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119, 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to operate commercially a small unmanned vehicle (55 lbs or less) in videography and photography operations.

The Exemption is in the Public Interest

As demonstrated above, the proposed s UAS operations would mini mize the risk of harm

to individual safety or damage to the NAS and property. The operations proposed by Tribune

Media would provide tremendous public benefits by increasing news coverage of newsworthy
but difficult to re ach events, including weather even ts and disaster relief efforts. The s UAS operations as described in this application will be far safer and more efficient than use of helicopters or other aircraft to capture the required footage.

The conditions outlined in this petition clearly satisfy Section 333 ’s exemption criteria regarding “size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight,” and therefore the proposed operations would not

“create a hazard to users of the national airspace system or the public or pose a threat to national security.” As discussed above, Tribune Media agrees to use limitations that are substantially identical to those contained in the FAA’s recent grant of exemption for Advanced
Aerial Cinematography and for Cox Media Group, LLC . Accordingly, the proposed UAS operations of Tribune Media should not raise safety or national security concerns, and should receive summary approval.

Please do not hesitate to contact the undersigned if you need a dditional information.

Respectfully submitted,

Jack Schenendorf Stephen Kiehl