April 6, 2016

U.S. Department ofTranspmtation DocketManagement System 1200 NewJersey Ave., SE Washington, D.C. 20590 

# ••• ,..Ill •


# ............**~**

Re: Second Petition to Amend ExemptionNo. 14439; DocketNo. FAA-2015-5268

Dear Sir orMadam: Raycom Media ("Raycom") hereby petitions for an amendment to ExemptionNo. 14439, which the Federal Aviation Administration ("FAA") issued to Raycom on Januaty 14, 2016 to petmit unmatmed aircraft system ("UAS") operations for newsgathering, commercialproduction, and facilities inspection. Raycomrequests that the FAA make the following amendments to Exemption No. 14439: (1) revise the operating conditions and limitations to permit Raycom to operate above 400 feet above ground level ("AGL") for the purposes oftowerinspection; (2) waive the requirements of 14 C.F.R. § 61.56; and (3) revise the operating conditions and limitations to authorize the use ofany aircraft identified on the FAA's List ofApproved Unmanned Aerial Systems ("Approved List"). 1 Ifthe Approved List does not include the Yuneec Typhoon H at the time the FAA reviews this Petition, Raycom requests that the FAA authorize the use ofthis aircraft. 

### I. AUTHORIZATION TO OPERATE ABOVE 400 FEETAGL As explained in Raycom's initial petition for exemption, Raycom Media is one ofthe nation's largest broadcasters, owning and/or providing services for 53 television stations in 37markets and 18 states. Raycom stations cover 13

.1% ofU.S

. television households. To serve its viewers, Raycomdepends onaninfrastructure ofbroadcasttowers, many ofwhich are tallerthan400 feet. Raycom requests thatthe FAArevise ExemptionNo. 14439 to authorize Raycom to operate UAS above 400 feet AGL for the purpose ofinspecting its broadcast towers. Higher altitude operations for this limited purpose would not create an additional safety risk withrespect to manned aircraft because such aircraft are already precluded from flying in the vicinity ofthe towers. In addition, the operations will not present a heightened riskto persons on the ground
The Approved Listis available at regulatory docketFAA-2007-3330 atregulations.gov. R

S

A Tower 20't' Floor • 201 Monroe S treet • Montgomery, AL 36104 • (334) 206-1 400 • Fax (334) 206

- 1555 

### 1because the towers are generally in very remote locations, and Raycom would not inspect towers within 500 feet ofcongested areas. The presence ofguy wires will not create a heightened safety riskbecause, although such wires are difficult to see from the air, they are easily observable on the ground during daylight hours and canbe avoided without difficulty. Raycom will ensure the safety ofthese higher altitude operations by adhering to the following additional operating parameters: I. The UAS will operate in the immediate vicinity ofthe tower being inspected, at an altitude no higher than that ofthe tower being inspected. 2. Priorto commencing operations, the pilot-in-command ("PIC") and visual observer ("VO") will use visual capability as well as current weather conditions to determine the viability ofmaintaining VLOS. The PIC and VO will commence operations only if VLOS can be maintained for the duration ofthe flight. 3. Tower inspections will take place only when the PIC and VO are the only people within a potential debris fallout zone. 4. Tower inspections will only be conducted in locations farther than 500 feet from congested areas. 5. All tower inspections will be conducted during daylight hours and under visual meteorological conditions. No tower inspections will be conducted in high wind conditions, either on the surface or at altitude. 6. The PIC and VO will identify the location ofguy wires prior to commencing operations, and prepare a flight plan that takes into consideration these obstacles to ensure a safe flight. During flight, the PIC and VO will ensure thatthe UAS avoids the guy wires of the tower being inspected. In addition, Raycom will not undertake a higher-altitude tower inspection without prior FAA approval. To that end, Raycom will seek a Certificate ofWaiver orAuthorization for each tower location where Raycom intends to conduct aninspection. 

### II. WAIVER OF 14 C.F.R. § 

### 61.56 Raycom requests exemption from the flight review requirements ofSection 61.56 ofthe Federal Aviation Regulations. 2 Section 61.56 requires pilots to conduct flight review consisting ofat least one hour offlight training and one hour ofground training within two years ofacting as pilot in command ofan aircraft. Alternatively, pilots may satisfy flight review by accomplishing ce1iain pilotproficiency checks or practical examinations. Exemption No. 14439 requires each ofRaycom's PICs to meet the requirements ofSection 61.56 in an aircraft inwhich he or she is rated. As the FAA has not introduced a UAS rating for FAA-certifiedpilots, this requirement has

2 14 C.F.R. § 61.56.



### 2little ifany relevance to the safe operation ofUAS. This requirement overburdens Raycom's pilots while providing no cognizable safety benefit. In lieu ofthe flight review requirements ofSection 61.56, Raycom can achieve at least an equivalent level ofsafety byrequiring its pilots to complete appropriate UAS training, such as Auburn University's Unmanned Aerial Systems Flight Training Course. Raycom PICs would also conduct flight review using a model ofUAS that they operate pursuant to Raycom's exemption, and a certified flight instructor would endorse a logbook certifying that the pilothas satisfactorily completed UAS flight review. These procedures will ensure that Raycom's PICs have a curr-ent understanding ofthe applicable rules and conditions, and that they are capable of safely operating the aircraft that they actually use pursuant to Raycom's grant ofexemption. 

### III. AUTHORIZATION TO USE ALL APPROVED UAS AND THE YUNEEC TYPHOONH Raycom requests that the FAA remove Condition #I in Exemption No. 14439 and replace it with the following: "The operator is authorized by this grant ofexemption to use any aircraft identified on the List ofApproved Unmanned Aerial Systems (UAS) under Section 333 at regulatory docket FAA-2007-3330 at www.regulations.gov, when weighing less than 55 pounds including payload." The FAAhas included this condition in several recent grants ofSection 333 petitions and amendment petitions.3 Increased flexibility with respect to the aircraft Raycom may operate pursuant to its Section 333 exemptionboth will enable Raycom to enhance its existing operations and will eliminate the need for future amendments, thereby alleviating administrative burdens on the FAA. Ifthe Yuneec Typhoon His not included on the Approved List at the time the FAA reviews this Petition, Raycomrequests that the FAA either add this UAS to the Approved List or otherwise authorize Raycom to use this aircraft under Exemption 14439. This reliefis wan-anted as the aircraft has specifications consistent with other aircraft models onthe Approved List and meets the requirements ofSection 333 ofthe FAA Modernization and Reform Act due to its weight, speed, and operational capability. Raycom has previously requested authorization to operate the Yuneec Typhoon H. 4 In its request, Raycom described the specifications ofthe Typhoon H, noting similarities to previous models inthe Typhoon product line, and explained that recent
See, e.g., Exemption No. 15241 to AeroVision Services, LLC, DocketNo. FAA-2015-5212 (issued Mar. 8, 2016); Exemption No. 111758 to State Farm Mutual Automobile Insurance Company, DocketNo. FAA-2014-0846 (issued Mar. 7, 2016); Exemption No. 15174 to Aero Image, LLC, DocketNo. FAA-20 15-4818 (issued Mar. 3, 2016). 4 See Petition ofRaycom to Amend Exemption No. 14439; Docket No. FAA-2015-5268 (filed Feb. 18, 2016).

3Section 333 petitions had requested authorization to operate this aircraft. 5 The FAA should proceed with adding the Yuneec Typhon H to the Approved List and/or authorizing Raycom to use this aircraft. Doing so will allow Raycom to realize the public benefits ofusing this aircraft for newsgathering, commercial production, and facilities inspection as described below. 

### IV. PUBLIC INTEREST BENEFITS OF GRANTING THIS PETITION FOR AMENDMENT Grant ofthis petition for amendment is in the public interest because it will enable Raycom to expand its mission to use UAS to conduct safer newsgathering and obtainbetter content. As Raycom explained in its initial petition for exemption, UAS enable Raycom both to improve the accuracy and depth ofinformation available to the public during breaking news situations, and to offer enhanced marketing and commercial content. In addition, the ability to use UAS allows Raycom to more safely and cost-effectively inspect its facilities, helping to ensure uninterrupted transmission ofimportant content to Raycom's viewers. Authorization to use any UAS on the Approved List will enhance Raycom's ability to provide all ofthese impottant benefits to the publicby affording Raycom flexibility in building its UAS fleet and expanding its operations. Authorization to operate above 400 feet AGL for tower inspectionpurposes will allow Raycom to broaden the scope ofthe facilities inspection it can conduct using UAS, thereby (i) promoting safety by minimizing the need to send an employee up onto the towers on foot; and (ii) serving the public at large by enhancing Raycom's ability to provide uninterrupted transmissions. Finally, waiver ofSection 61.56 is in the public interest because it will enable Raycom's pilots to focus on currency measures that are relevant to the UAS operations they conduct, thereby enhancing the safety ofRaycom's operations. 

### V. SUMMARY FOR THE FEDERAL REGISTER Should the FAA determine that the requests herein necessitate publication ofthis Petition inthe Federal Register, Raycom offers the following summary pursuant to section 11.81 ofthe FAA's rules: 6 Petitioner: Raycom Media Sections of 14 C.F.R. Affected: 14 C.F.R. § 61.56; 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.7(a). Description of Relief Sought: Petitioner seeks relieffromthe requirements of 14 C.F.R. 

### § 61.56 to operate unmanned aerial systems for newsgathering, contentproduction, and facilities inspection. In addition, Petitioner seeks revision ofterms and conditions in previous grant of exemption to authorize (i) operations at altitudes higher than 400 feet above ground level for the

Id. As ofthe date ofthis filing, the Approved List includes the following Yuneec models: the Tornado H920, Typhoon G, Typhoon H920, Typhoon Q500, Typhoon Q500+, and Typhoon Q500+ Pro. 6 14 C.F.R. § 11.81(1).

4pmpose oftower inspection; (ii) operation ofall aircraft included onthe Federal Aviation Administration's List ofApproved Umnanned Aerial Systems; and (iii) to the extentrequired, operation ofan aircraft not included onthe Approved List. 

### VI. CONCLUSION Based on the foregoing, Raycom respectfully requests that the FAA grant the reliefrequested herein. Please do nothesitate to contact Raycom's outside counsel, Kathleen A. Kirby ofWiley Rein LLP at 202-719-3360 orkkirby@wileyrein.com, and SaraM. Baxenberg ofWiley Rein LLP at 202-719-3755 or sbaxenberg@wileyrein.com, with any questions about this filing.

5 Sincerely,

David Burke VP, Technology Raycom Media