Mark McKinnon

Dentons US LLP

1676 International Drive • Penthouse

McLean, VA 22102-4832

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 office 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 fact 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 with others. Additionally, the 

document contains 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. DESCRIPTION OF PROPOSED OPERATIONS

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

gathering operations and for closed set filming. 

II. CNN'S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF 

THE REFORM ACT

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

Operational Capability 

The Fotokite Pro system 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 the 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 Fotokite Pro system is designed to provide long term persistent stare capabilities 

and enable reliable long duration flight. The vehicle also has the following safety features:
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 Because the vehicle’s power is supplied by the tether, a fly-away event is impossible. 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 

should 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 meets 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 conventional 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 Freedom 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)).
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 Fotokite Users Manual 

 Fotokite Specifications Sheet

Very Truly Yours, 

Mark E. McKinnon

Counsel for CNN