Docket Ma

ag

y

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Re: Petition ofRaycom Media for Exemption from Certain Federal Aviation 

Regulations to Operate Unmanned Aircraft Systems Pursuant to Section 333 of 

the FAA Modernization and Reform Act 

Dear Sir or Madam: 

Pursuant to Section333 of the FAA Modernization and Reform Act ("FMRA") and 14 

C.F.R. part 11, Raycom Media ("Raycom") hereby petitions the Federal Aviation Administration 

("FAA") for exemption from 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(c), 91.121, 91.15l(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) and 

(2), and 91.417(a) and (b), and any other rules the FAA deems necessary, to enable Raycom to 

operate wm1mmed aircraft systems ("UAS") for aerial data collection. Specifically, Raycom 

seeks to operate UAS for newsgathering, commercial production, and facilities inspection using 

the DJI Phantom 2, DJI Phantom 3, 3DR Solo, Yuneec Q500+, and the DJI Inspire 1. Because 

this petition is similar in all material respects to previously-granted Section 333 petitions, 

Raycom requests expedited approval pursuant to the FAA's summary grant process. 

I. PROPOSED OPERATIONS AND PUBLIC INTEREST BENEFITS 

Raycom Media, an employee-owned company, is one of the nation's largest broadcasters, 

owning and/or providing services for 53 television stations in 37 markets and 18 states. Raycom 

stations cover 13.1% ofU.S. television households and employ over 4,000 individuals in full and 

part-time positions. In addition to television stations, Raycom owns Raycom Sports (a 

marketing, production and events management and distribution company), Tupelo-Honey 

Productions (a NY -based production company), Limerick Studios (a Charlotte, NC-based motion 

graphics design house), RTM Productions (a Franklin, TN-based automotive programming 

production and marketing solutions company), and Broadview Media (a post-production/digital 

signage company based in Montgomery, AL). 

Raycom strives to keep audiences informed with news of national significance as well as 

content relating to issues that are important and unique to the specific communities served by its 

stations. UAS can provide a safe and cost-effective way to achieve this objective. Raycom 

seeks to use UAS to conduct aerial data collection that will serve a variety of functions, 

including newsgathering, commercial production, and facility inspection. Grant of this petition 

will enable Raycom to better serve its viewers across the country, as Raycom will be able to 

RSA Tower 20''J Floor • 201 Monroe Street • MontgomEfy, AL 361 04 • (334) 206-1400 • Fax (334) 206-1555 
documented. In but one 

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through Tupelo, Mississippi, Matt Laubhan, the chief meteorologist for television station 

WTV A, instructed viewers to seek shelter before dramatically directing his own studio crew to 

the basement on live TV. After the storm had passed, many residents repmted that they did not 

hear the city's warning sirens and only took shelter because of Laubhan's coverage. In some 

instances, however, there are batTiers to collecting the infonnation and imagery needed to obtain 

and deliver breaking news. Safety risks of placing a crew in the thick of the action on the gronnd 

or in the air, physical obstructions, and cost can all prevent news outlets from repmting crucial 

information to the public. 

Permitting Raycom to use UAS will result in better news coverage and safer 

newsgathering, and will even facilitate emergency response. Through their geographic reach and 

unique views, UAS can provide a perspective that footage taken from the ground cannot, 

enhancing viewers' ability to gain information from news stories. Moreover, UAS can improve 

the accuracy and depth of information that Raycom can convey to the public during times of 

emergency or other breaking news situations. Authorization to operate UAS will enable Raycom 

to provide information and imagery to the public that is otherwise unavailable given existing 

barriers, such as those created by enviromnental hazards. Using UAS, Raycom can ensure the 

safety of its crewmembers while also gathering crucial information for its viewers. Grant of this 

petition will also lead to better emergency response on the first responder side, as the ability to 

use UAS will enable Raycom to assist public safety and local authorities that might not have 

immediate access to the same type of imagery (much in the same way that manned aircraft and 

other forms ofnewsgathering assist public safety and local authorities today). 

Pursuant to this authorization, Raycom will conduct additional operations allowing it to 

bring content to its viewers more safely, efficiently, and effectively. First, several Raycom 

depmtments are involved in the production of commercial and marketing content. Raycom will 

use UAS to safely and efficiently obtain interesting aerial footage that will enhance this content 

and provide a unique perspective to viewers. Second, Raycom will use UAS to conduct 

inspections of its facilities, including towers. Obviating the need to send a person up to inspect 

the infrastructure, using UAS to gather aerial data is a safer and more cost-effective way for 

Raycom to confirm that its facilities remain operational and undamaged. These operations will 

help to ensure uninterrupted transmission ofimpottant content to Raycom's viewers. 

In addition to fostering significant public interest benefits, Raycom's operations will 

carry minimal risk. Using UAS for newsgathering and facility inspection will both eliminate the 

dangers associated with conducting these activities on foot or in manned aircraft and enable 

Raycom to efficiently and quickly deliver impmtant breaking news and other content to the 

viewing public. As discussed in more detail below, Raycom is committed to the safe operation 

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II. THEUAS 

Raycom requests an exemption to operate the DJI Phantom 2, DJI Phantom 3, 3DR Solo, 

Yuneec Q500+, and the DJI Inspire 1, all of which are well below 55 pounds including payload. 

Through the Section 333 exemption process, the FAA has authorized use of all UAS for which 

exemption is requested herein. 1 

III. REQUEST FOR SUMMARY GRANT 

Because this petition is similar in material respects to previous petitions the FAA has 

granted, Rayeom requests that the FAA issue a summary grant of exemption pursuant to the 

agency's expedited summary grant process. Specifically, the public interest and safety benefits 

Ray com's operations will achieve are materially similar to those recognized in Grants of 

Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), Ill 09 to Clay co, 

Inc. (see Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC (see Docket No. 

FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642). 

Ray com will adhere to a series of operating parameters that will offer the same level of safety as 

the conditions the FAA currently requires in its summary grants2 

IV. APPLICANT INFORMATION 

The name and contact information of the applicant is: 

David Burke 

VP, Teclmology 

Raycom Media 

201 Monroe Street 

RSA Tower, 20th Floor 

Montgomery, AL 36104 

' Regulations from which exemption is requested: 

See Exemption No. 11274A to United Services Automobile Association, Regulatmy Docket No. FAA2014-0796 (authorizing use of the 3DR Solo, DJI Phantom 3, and DJllnspire); Exemption No. 11875 to Green Bee 

Limited, Regulatory Docket No. F AA-20 15-0698 (authorizing use of the DJI Phantom 2); Exemption No. 12023 to 

William J. Henderson, Regulatory Docket No. FAA-2015-1518 (authorizing use of the Yuneec Q500 Typhoon). 

See, e.g., Exemption No. 12160 to Star Engineering Services LLC, Regulatmy Docket No. FAA-20 15-

1690 (Jul. 27, 20 15). 

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14 C.F.R. § 91.119(c); 

14 C.F.R. § 91.121; 

14 C.F.R. § 91.151(a)(l); 

14 C.F.R. § 91.405(a); 

14 C.F.R. § 91.407(a)(1); 

14 C.F.R. §§ 91.409(a)(l) and (2); 

14 C.F.R. §§ 91.417(a) and (b). 

V. OPERATING PARAMETERS 

Ray com will adhere to the following operating parameters when operating U AS pursuant 

to a grant of the requested exemption: 

1. Operations will be conducted using the DJI Phantom 2, DJI Phantom 3, 3DR Solo, 

Yuneec Q500+, and the DJI Inspire 1. 

2. The UAS will not be operated at a speed exceeding 87 knots (1 00 miles per hour), at an 

altitude greater than 400 feet above ground level, or, when visibility is less than 3 statute 

miles, less than 500 feet below or 2,000 feet horizontally from a cloud. All operations 

will be conducted during the day under visual meteorological conditions. 

3. All operations will be conducted in accordance with a Cettificate of Waiver or 

Authorization ("CO A''). 

4. All operations will use a pilot-in-command ("PIC") and a visual observer ("VO"), and the 

UAS will remain within the visual line of sight of the PIC or the VO at all times. The 

PIC will maintain VLOS capability and the ability to communicate verbally with the VO 

at all times. 

5. The PIC will hold an airline transpmt, commercial, private, recreational, or sport pilot 

certificate, as well as an FAA aitman medical certificate or a valid U.S. driver's license. 

The PIC will meet the flight review requirements specified in 14 C.F.R. § 61.56 in an 

aircraft in which the PIC is rated on his or her pilot certificate. 

6. Raycom will ensure prior to operation that the PIC has demonstrated the ability to safely 

operate the UAS in a mmmer consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and stmctures. PIC qualification flight hours 

and currency will be logged in a mmmer consistent with 14 C.F.R. § 61.51(b). 

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been performed and the U AS is fou

g

9. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g., replacement of a flight critical component, will undergo a 

functional test flight prior to conducting futther operations under this exemption. 

10. Raycom will follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements, as well as safety bulletins, for the aircraft and 

aircraft components. 

11. The PIC will abmt the i1ight in the event of unpredicted obstacles or emergencies, and 

will yield to all manned aviation activities. 

12. Raycom will register and mark its UAS in accordance with 14 C.P.R. parts 47 and 45. 

VI. THE FAA'S AUTHORITY TO GRANT THIS PETITION 

The FAA has authority to grant the exemption requested herein under the FMRA and the 

Federal Aviation Act. Section 333 of the FMRA deals specifically with integrating UAS into the 

national airspace, and directs the Secretary of Transportation to determine which UAS, "as a 

result of their size, weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users of the national 

airspace system or the public or pose a tlu·eat to national security."3 Section 333 further directs 

the Secretary to "establish requirements for the safe operation of such aircraft systems in the 

national airspace system. "4 The Federal Aviation Act authorizes the Administrator of the FAA 

to grant exemptions from regulations prescribed under certain provisions of the Act where such 

exemptions are in the public interest. 5 Patt 11 of the Federal Aviation Regulations governs the 

FAA's exemption process and requirements.6 The FAA has granted more than 1,100 exemptions 

to date pursuant to its Section 333 and exemption authority, enabling commercial UAS 

operations in a wide variety of industries. 

Pub. L. No. 112-95, 126 Stat. 75-76 (codified as a Note to 49 U.S.C. § 40101). 

4 /d. 

5 49 U.S.C. § 44701 (f) ("The Administrator may grant an exemption fi·om a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the Administrator 

finds the exemption is in the public interest."). 

6 See 49 C.F.R. Part I I. 

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Sections of 14 C. FR. Affected: 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. § 91.15l(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 

C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b). 

Description of Relief Sought: Petitioner seeks relief from the requirements of 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); 14C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 

91.151(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(l) and 

(2); 14 C.F.R. §§ 91.417(a) and (b) to operate unmanned aerial systems for newsgathering, 

content production, and facilities inspection. 

VIII. CONCLUSION 

As demonstrated above, the UAS operations Raycom has proposed in this petition for 

exemption will garner significant public benefits while presenting minimal safety risks. 

Raycom's petition satisfies the criteria of Section 333 of the FMRA and is substantially similar 

to previous petitions the FAA has granted, meriting a summary grant of exemption. Raycom 

respectfully requests that the FAA grant this petition to enhance Raycom's ability to provide 

impmiant news and content to its large viewership. 

Please do not hesitate to contact Raycom's outside counsel, Kathleen A. Kirby ofWi1ey 

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

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

7 !d.§ 11.81(1). 

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Sincerely, 

David Burke 

Raycom Media