I 

cool ex 

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 

v: true: ~}~ //( / . Anne Swanson 

MAS:vcd 

Enclosure 

cc (via e-mail): 

333exem ptions@faa. gov 

Andrew C. Carington, General Counsel, Media General, Inc. 

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

1 A 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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Cool ex 

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 of the 

FAA Reform Act and Part 11 of the 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 of the 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 of those already requested in lieu of the 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 of those 

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 of the UAS affected by this exemption 

must submit a written Plan of Activities to the local Flight Standards District Office 

(FSDO) with jurisdiction over the area of the proposed filming. The 3-day notification 

may be waived with the concurrence of the 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 

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b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption. 

c. Name and phone number of the 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 of the 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 of those who 

gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the 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 of the 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 under the 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 of that 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 1 will 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 of this 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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