Mark McKinnon

Dentons US LLP

1676 International Drive • Penthouse

McLean, VA 22102

- 4 832

United States

email: mark.mckinnon@dentons.com

T 703.336.8808

F 703.336.8750 Salans FMC SNR

Denton

McKenna Long

dentons.com

September 3

, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Re: Amendment to Exemption 12174 granted to CNN (Docket No. FAA

- 2015

- 1851)

To Whom it May Concern:

As you are aware, this of fice represents Cable News Network, Inc. (CNN) regarding the

above

- referenced Petition for Exemption, which was granted on July 27, 2015. CNN hereby

requests an amendment to its Exemption to add an additional aircraft, the Fotokite Pro

.

CNN will submit the Fotokite Pro User Manual and fac t sheet as a confidential document

pursuant to 14 C.F.R. § 11.35(b), as the materials contain confidential commercial and/or

proprietary information that CNN has not and will not share w ith others. Additionally, the

document contain s operating conditions and procedures that are not generally available to the

public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et

seq

.

I. D ESCRIPTION OF P ROPOSED O PERATIONS

CNN seeks to amend its Exemption to add the Fotokite Pro in support of its news

gathering operations and for closed set filming

.

I I

. CNN' S P ROPOSED UAS O PERATIONS M EET THE R EQUIREMENTS OF S ECTION 333 OF

THE R EFORM A CT

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and

Op erational Capability

The Fotokite Pro sy stem consists of a Ground Control Station ( GCS ) and a purpose built

vertical take

- off and landing ( VTOL) vehicle. The Fotokite Pro vehicle operates using a tether

that is attached to a power source on t he ground

. The tether has a maximum length of 20 meters

and its strength is rated at over 20 times the total lifting power of the UAS. The Fotokite Pro

weighs under 2 pounds . The vehicle is equipped with four electric motors configured as a quad

formation . The Fo tokite Pro system is designed to provide long term persistent stare capabilities

and enable reliable long d uration flight

. The vehicle also has the following safety features:September 3, 2015

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 Because the vehicle’s power is supplied by the tether, a fly

- away event is impos sible. In

the unlikely event of a tether loss, the vehicle will conduct a controlled emergency

landing.

 The vehicle's position is controlled by the tether. As a result, there are no issues

regarding radio control frequencies or radio interference.

 The Fotokite Pro uses unique "soft

- propellers " that can be stopped with ones fingers if

absolutely necessary. These propellers are incapable of cutting the tether.

 The Fotokite Pro has a built in battery warning system that gives notice that the vehicle

sho uld be landed.

 The tether control system also relieves the need for GPS systems and the need for

autonomous return to home or autonomous alternate landing systems to deal with an

interruption of GPS signal.

Based on the foregoing, the Fotokite Pro m eets all of the criteria for safe operation of a

UAS and the amendment should be granted.

III. The Requested Amendment is in the Public Interest

The Fotokite Pro offers substantial safety benefits for news gathering and closed set

filming over conventi onal cinematography using helicopters or fixed wing aircraft.

If you have any questions regarding this amendment, or require any additional

information to process CNN's Petition, please do not hesitate to contact us.

Very truly yours,

Mark E. McKinnon

Counsel for Cable News Network, Inc.

Attachments

(The following attached items will be submitted under separate cover as they contain proprietary

and commercial information exempt from disclosure under the Fr eedom of Information Act, 5

U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 C.F.R. § 11.35(b)).September 3, 2015

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 Fotokite Users Manual

 Fotokite Spec ifications Sheet

Very Truly Yours,

Mark E. McKinnon

Counsel for CNN