November 17, 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 (“sUAS”) equipped to conduct aerial videography and photography to support 

newsgathering, requests a limited exemption from the below-listed regulations to allow 

commercial operation of its sUASs, provided that the proposed sUAS operations comply with

the conditions outlined below or as established by the Federal Aviation Administration (“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 

Docket 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 FAA’s September 17, 2015 approval of that 

(continued...)
U.S. Department of Transportation, Docket Operations

November 17, 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 that it receive an exemption to use sUAS to conduct aerial 

videography and photography for newsgathering purposes. Tribune Media would use the 

footage for the production of news items for its broadcasting stations, studios, and digital 

brands.

Tribune Media 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 17, 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 sUAS 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 within 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 sUAS 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 no 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 feet 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 

airman 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 maintains 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 designation 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 sUAS and conduct its 

operations in accordance with the conditions and limitations stated in the grant 

of exemption, are hereinafter referred to as the operating documents. The 

operating documents will be accessible during sUAS operations and made 

available to the Administrator upon request. If a discrepancy exists between the 

conditions 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 documents. 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 also present updated and 
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November 17, 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 must 

petition for an amendment to its grant of exemption. The FAA’s UAS 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 affect 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 

with 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 sUAS 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 sUAS, 

the aircraft will be prohibited from operating until the necessary maintenance 

has been performed and the sUAS is found to be in a condition for safe flight.

10. Tribune Media will follow the sUAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components.

11. Each sUAS 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, recreational, 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 sUAS in a manner consistent with how the sUAS 

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 currency 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-
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November 17, 2015

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

manner consistent with how the sUAS 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 flights, 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 flights under special visual flight rules (SVFR).

15. The UA will not operate within 5 nautical miles of an airport reference 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 airport’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 sUAS loses communications or loses its GPS signal, the UA will return to a 

pre-determined location within 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 enough 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. Documents used by Tribune Media to ensure the safe operation and flight of the 

sUAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be 
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November 17, 2015

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available to the PIC at the Ground Control Station of the sUAS any time the 

aircraft is operating. These documents 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 sUAS will not be operated by the PIC from any moving device or vehicle. 

25. All flight operations will be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures, unless:

a. Barriers or structures are present that sufficiently 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 objects 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 considered 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.

Unless otherwise specified, the sUAS operations will comply 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 17, 2015

Page 7

Federal Register Notice

Publication 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 publication 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 sUAS operations would minimize 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 reach events, including weather events and disaster relief efforts. The sUAS 

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 additional information. 

Respectfully submitted,

Jack Schenendorf

Stephen Kiehl