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M. Anne Swanson T

: +l 202 776 2534 aswanson@cooley.com June 25, 2015 Mr. William Crozier Unmanned Aircraft Systems Integration Office AFS-80 800 Independence Ave., S.W. Washington, D.C. 20591 Dear Mr. Crozier: Enclosed please find an amendment to the Section 333 exemption request that Media General, Inc. filed on June 3, 2015. That filing sought an exemption to various Federal Aviation Regulations under Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11 to allow commercial operations of unmanned aircraft. 1 If your staff or you have any questions, please contact me. I 

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. Anne Swanson MAS:vcd Enclosure cc (via e-mail): 333exemptions@faa. gov Andrew C. Carington, General Counsel, Media General, Inc. Henry R. Gola, Associate General Counsel, Media General, Inc.

1A confidential manual associated with this request, which is exempt from disclosure under the Freedom of Information Act, is being filed under separate cover.
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M . Anne Swanson +l 202 776 2534 aswanson@cooley.com June 25, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 RE: Amendment to Media General, Inc.'s Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: Media General, Inc. hereby seeks to amend its June 3, 2015 filing seeking an exemption, pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11, to allow use ofthe DJI Inspire 1 in various commercial aerial videography and aerial data collection operations. By this amendment, Media General seeks to add commercial closed-set motion picture and television filming as an additional permitted use. To accomplish this requested change, Media General specifically requests the addition of conditions related to the provision of closed-set filming. First, Media General proposes to insert the following condition in the list ofthose already requested in lieu ofthe similarly numbered condition: 2. Operations for the purpose of closed-set motion picture and television filming are permitted. Second, Media General requests that the following conditions be added at the end ofthose previously requested: 29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption. 30. At least 3 days before aerial filming, the operator ofthe UAS affected by this exemption must submit a written Plan ofActivities to the local Flight Standards District Office (FSDO) with jurisdiction over the area ofthe proposed filming. The 3-day notification may be waived with the concurrence ofthe FSDO. The plan of activities must include at least the following: a. Dates and times for all flights;

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June 25, 2015 Page Two b. Name and phone number ofthe operator for the UAS aerial filming conducted underthis grant of exemption. c. Name and phone number ofthe person responsible for the on-scene operation of the UAS; d. Make, model, and serial or N-Number of UAS to be used; e. Name and certificate number ofthe UAS PICs involved in the aerial filming; 

### f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list ofthose who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description ofthe flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder's MPTOM. Media General will conduct its closed-set motion picture and television filming and production operations in accordance with the separately filed MPTOM. 1 The additional operating conditions and limitations that Media General requests are identical to those in exemptions granted to Helicopters West, Inc. and other parties seeking to offer closedset filming services. 2 Helicopters West's exemption, in particular, proposes use ofthe same unmanned aerial vehicle (the DJI Inspire 1) specified by Media General. Since Media General
1 Media General requests that the MPTOM be maintained in confidence and not placed in the public docket or otherwise disclosed to the public. As the information included in the manual includes trade secrets and commercial information that is confidential and not made available to the public, it is exempt from disclosure underthe Freedom of Information Act, 5 U.S.C. 

### § 552(b), and 14 C.F.R. Part 11. Should the FAA receive a request for access to the manual, we ask for notification ofthat request prior to any action being taken by the FAA, as it may relate to that request. Media General has also made minor changes to the Flight Operations Manual ("FOM") that it confidentially submitted on June 3, 2015 to reflect this additional use case. Marked pages of the two amended sections of the FOM are included with the MPTOM in the separately submitted confidential filing. 2 See Helicopters West, Inc., FAA Exemption No. 11559, Regulatory Docket No. FAA-2015- 0430 (May 12, 2015). See a/so Integrated Media Technologies, Inc., FAA Exemption No. 11532, Regulatory Docket No. FAA-2015-0424 (May 11, 2015), and Shotwell Media, LLC, FAA Exemption No. 11280, Regulatory Docket No. FAA-2014-0885 (April1, 2015).

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June 25, 2015 Page Three will operate the aircraft in strict compliance with the conditions in existing exemptions previously granted by the FAA, or as they may be amended, notice need not be provided in the Federal Register nor public comment solicited. Media General reiterates that its UAS operations will be subject to strict operating requirements to ensure at least an equivalent level of safety to currently authorized operations using manned aircraft and under conditions specified by the FAA. Because the DJI Inspire 1will be used in lieu of comparatively hazardous operations that otherwise would have to be conducted with fixed wing and rotary conventional aircraft, the FAA can have confidence that the proposed closed-set filming operations will achieve at least an equivalent level or greater level of safety. As discussed in more length in Media General's exemption request filed on June 3, 2015, approval ofthis exemption would enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish requirements for the safe operation of such aircraft systems in the national airspace system."3 Please do not hesitate to contact me if you have any questions or need additional information . 

### , Ver .. truly you.rs,

r. )--- 

# \..( /I • ' • M.Anne Swanson Henry H. Wendel Counsel for Media General , Inc.

cc: William Crozier Robert Pappas Jake Troutman Dean Griffith , Esquire Thuy H. Cooper Andrew C. Carington , General Counsel, Media General, Inc. Henry 

### R. Gola, Associate General Counsel , Media General, Inc.

3 See Pub. Law 112-95, 126 Stat. 11 , 

### § 333 (2012) .
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