April 6, 2016 

U.S. Department of Transpmtation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

••• ,..Ill • 

............ ~ 

Re: Second Petition to Amend Exemption No. 14439; Docket No. FAA-2015-5268 

Dear Sir or Madam: 

Raycom Media ("Raycom") hereby petitions for an amendment to Exemption No. 14439, which 

the Federal Aviation Administration ("FAA") issued to Raycom on Januaty 14, 2016 to petmit 

unmatmed aircraft system ("UAS") operations for newsgathering, commercial production, and 

facilities inspection. Ray com requests 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 of tower inspection; (2) 

waive the requirements of 14 C.F.R. § 61.56; and (3) revise the operating conditions and 

limitations to authorize the use of any aircraft identified on the FAA's List of Approved 

Unmanned Aerial Systems ("Approved List"). 1 If the 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 of this aircraft. 

I. AUTHORIZATION TO OPERATE ABOVE 400 FEET AGL 

As explained in Raycom's initial petition for exemption, Raycom Media is one of the nation's 

largest broadcasters, owning and/or providing services for 53 television stations in 37 markets 

and 18 states. Ray com stations cover 13 .1% of U.S. television households. To serve its viewers, 

Ray com depends on an infrastructure of broadcast towers, many of which are taller than 400 

feet. 

Raycom requests that the FAA revise Exemption No. 14439 to authorize Raycom to operate 

UAS above 400 feet AGL for the purpose of inspecting its broadcast towers. Higher altitude 

operations for this limited purpose would not create an additional safety risk with respect to 

manned aircraft because such aircraft are already precluded from flying in the vicinity of the 

towers. In addition, the operations will not present a heightened risk to persons on the ground 

The Approved List is available at regulatory docket FAA-2007-3330 at regulations.gov. 

RSA Tower 20't' Floor • 201 Monroe Street • Montgomery, AL 36104 • (334) 206-1 400 • Fax (334) 206-1555 

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because the towers are generally in very remote locations, and Raycom would not inspect towers 

within 500 feet of congested areas. The presence of guy wires will not create a heightened safety 

risk because, although such wires are difficult to see from the air, they are easily observable on 

the ground during daylight hours and can be avoided without difficulty. 

Raycom will ensure the safety of these higher altitude operations by adhering to the following 

additional operating parameters: 

I. The UAS will operate in the immediate vicinity of the tower being inspected, at an 

altitude no higher than that of the tower being inspected. 

2. Prior to 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 of maintaining VLOS. The PIC and VO will commence operations only if 

VLOS can be maintained for the duration of the 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 of guy 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 that the UAS avoids the guy wires of 

the tower being inspected. 

In addition, Ray com will not undertake a higher-altitude tower inspection without prior FAA 

approval. To that end, Raycom will seek a Certificate of Waiver or Authorization for each tower 

location where Raycom intends to conduct an inspection. 

II. WAIVER OF 14 C.F.R. § 61.56 

Ray com requests exemption from the flight review requirements of Section 61.56 of the Federal 

Aviation Regulations. 2 Section 61.56 requires pilots to conduct flight review consisting of at 

least one hour of flight training and one hour of ground training within two years of acting as 

pilot in command of an aircraft. Alternatively, pilots may satisfy flight review by accomplishing 

ce1iain pilot proficiency checks or practical examinations. Exemption No. 14439 requires each 

ofRaycom's PICs to meet the requirements of Section 61.56 in an aircraft in which he or she is 

rated. As the FAA has not introduced a UAS rating for FAA-certified pilots, this requirement has 

2 14 C.F.R. § 61.56. 

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little if any relevance to the safe operation of UAS. This requirement overburdens Raycom' s 

pilots while providing no cognizable safety benefit. 

In lieu of the flight review requirements of Section 61.56, Raycom can achieve at least an 

equivalent level of safety by requiring 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 pilot has 

satisfactorily completed UAS flight review. These procedures will ensure that Raycom's PICs 

have a curr-ent understanding of the applicable rules and conditions, and that they are capable of 

safely operating the aircraft that they actually use pursuant to Raycom's grant of exemption. 

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 of exemption to use any aircraft identified on 

the List of Approved 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 FAA has included this condition in several recent grants of Section 333 petitions and 

amendment petitions. 3 Increased flexibility with respect to the aircraft Raycom may operate 

pursuant to its Section 333 exemption both will enable Raycom to enhance its existing operations 

and will eliminate the need for future amendments, thereby alleviating administrative burdens on 

the FAA. 

If the 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 relief is wan-anted as the 

aircraft has specifications consistent with other aircraft models on the Approved List and meets 

the requirements of Section 333 of the 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 of the Typhoon H, 

noting similarities to previous models in the Typhoon product line, and explained that recent 

See, e.g., Exemption No. 15241 to Aero Vision Services, LLC, Docket No. FAA-2015-5212 (issued Mar. 8, 

20 16); Exemption No. 111758 to State Farm Mutual Automobile Insurance Company, Docket No. FAA-2014-0846 

(issued Mar. 7, 2016); Exemption No. 15174 to Aero Image, LLC, Docket No. FAA-20 15-4818 (issued Mar. 3, 

20 16). 

4 See Petition ofRaycom to Amend Exemption No. 14439; Docket No. FAA-2015-5268 (filed Feb. 18, 

2016). 

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Section 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 Ray com to realize the public benefits of using this aircraft 

for newsgathering, commercial production, and facilities inspection as described below. 

IV. PUBLIC INTEREST BENEFITS OF GRANTING THIS PETITION FOR 

AMENDMENT 

Grant of this 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 obtain better content. As 

Raycom explained in its initial petition for exemption, UAS enable Raycom both to improve the 

accuracy and depth of information 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 of important content to Raycom's viewers. Authorization to use any UAS on the 

Approved List will enhance Raycom's ability to provide all of these impottant benefits to the 

public by affording Raycom flexibility in building its UAS fleet and expanding its operations. 

Authorization to operate above 400 feet AGL for tower inspection purposes will allow Raycom 

to broaden the scope of the 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 of Section 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 of this Petition in the 

Federal Register, Raycom offers the following summary pursuant to section 11.81 of the 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 relieffrom the requirements of 14 C.F.R. § 61.56 

to operate unmanned aerial systems for newsgathering, content production, and facilities 

inspection. In addition, Petitioner seeks revision of terms and conditions in previous grant of 

exemption to authorize (i) operations at altitudes higher than 400 feet above ground level for the 

I d. As of the date of this 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). 

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pmpose of tower inspection; (ii) operation of all aircraft included on the Federal Aviation 

Administration's List of Approved Umnanned Aerial Systems; and (iii) to the extent required, 

operation of an aircraft not included on the Approved List. 

VI. CONCLUSION 

Based on the foregoing, Raycom respectfully requests that the FAA grant the relief requested 

herein. 

Please do not hesitate to contact Raycom' s outside counsel, Kathleen A. Kirby of Wiley Rein 

LLP at 202-719-3360 or kkirby@wileyrein.com, and Sara M. Baxenberg of Wiley Rein LLP at 

202-719-3755 or sbaxenberg@wileyrein.com, with any questions about this filing. 

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Sincerely, 

David Burke 

VP, Technology 

Raycom Media