August 12, 20 15 U.S. Department
of Tran spo rtation Docket Management System 1200 New Jersey Ave., SE Washington,

D

. C. 20590 

# ••• ,..Ill

• 

# ............ l1te&4 Re: Petition ofRaycom Media for Exemption from Certain Federal Aviation Regulations

to Operate Unmanned Aircraft Syst ems 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), 6 1.113(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 en ab le Raycom to operate wm1mm ed aircraft systems ("UAS") for aerial data collection. Specifically, Raycom seeks to operate UAS for newsgathering, commercial production, and facilities
in spection using the DJI Phantom
2, DJI Phantom
3, 3DR Solo, Yuneec Q500+, and the DJI In sp ir e 1. Becau se this petition is similar in all material respects
to previou

s ly-granted Section 333 petitions, Raycom request

s 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 broadca ste r s, owning and/or providing services for 53 television stations in 37 markets and 18 states. Raycom s tation

s cover 13

. 1 % ofU.S.
te le v ision hou se holds and employ over 4,000 individuals
in full and part-time posi tio n s . In addition
to televi sion 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
st rive s to keep
a udience

s informed with news of national significance

as well as content relating to i ssues that are important and unique to the specific communities served by its stations. UAS can provide

a safe and cost-effective way to achie ve this objective. Raycom seeks to use UAS to conduct aerial data collection that will serve
a variety of functions, including newsgathering, commercial production, and facili

t y 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

• 20 1 Monroe Street

• MontgomEfy,
AL 361 04 • (334

) 206- 14 0 0 • Fa x (334) 206-1555

### obtain key aerial footage for news stories and other content and operate its business more safely, efficiently, and effectively than ever before. Newsgathering

is a central component ofRaycom's intended use ofUAS. In times of need, journalists serve
a critical function, gathering news and reporting information

in a timely mmmer. The life-saving role of journalists

in the lead-up to a severe weather event iswelldocumented.

In but one recent example, on April28, 2014, with
a powerful tornado ripping 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 2

### of its UAS, and will adhere to stringent operating conditions
in confmmity with past grants of exemption. These conditions ensure that Raycom will operate safely in the national airspace, mi ligate the risks of harming other aircraft or people or prope1ty on the ground, and present no threat to national security. Adhering
to these parameters, Raycom will be able to safely and effectively operate its UAS to the benefit of its viewers, erewmembers and employees, and
the general public. 

## 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 grants

2 

## 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).



### 3

### 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)(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). 

## 47. Raycom's operating documents will be accessible during UAS operations and made available
to the Administrator upon request. 8. Prior to each flight, the PIC will conduct

a pre-flight inspection and determine the UAS is in a condition for safe flight. If the inspection reveals

a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed and the U AS is found to be in a condition for safe flight. 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.



### 5VII. SUMMARY TO BE PUBLISHED
IN THE FEDERAL REGISTER Should the FAA determine that publication

in the Federal Register
is required, Raycom offers the following summmy pursuant to section 11.81 of the FAA's rules:

7 Petitioner: Raycom Media 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).

6 Sincerely, David Burke Raycom Media