CHI-51051

Charter Communications Operating, LLC’s Petition for Exemption

For Purposes of Operating Small Unmanned Aircraft System

FAA Rules Docket: ____________

Name and Address of Petitioner

Charter Communications Operating, LLC

12405 Powerscourt Drive

St. Louis, MO 63131

Counsel for Petitioner

Thomas L. Gemmell

HUSCH BLACKWELL LLP

120 South Riverside Plaza, 22nd Floor

Chicago, Illinois 60606

(312) 526-1523

tom.gemmell@huschblackwell.com
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A. Summary

Charter Communications Operating, LLC seeks exemption from the requirements of 14

C.F.R. §§ 45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.315(a), 91.7(a),

91.105, 91.119(c), 91.121(a)(1)(iii), 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and

91.Charter(a) and (b). This exemption will permit Charter Communications Operating, LLC and

its advertising business unit, Spectrum Reach, (herein collectively “Charter”) to operate small

unmanned aircraft systems (sUAS) at or below 400’ above ground level from a ground control

station by a pilot in command having at least a sport or recreational pilot certificate and a valid

U.S. driver’s license. Furthermore, the exemption will relieve Charter from the requirement to

have a certificate of airworthiness issued for its unmanned aircraft (UA). This exemption will

also permit Charter to operate the UAS with at least a five-minute power reserve and to display

any required markings as large as practicable on the aircraft’s surface.

B. Introduction

Charter is a national communications company with a long and well-recognized history of

providing superior video, Internet and telephone services to consumers and businesses. As set

forth in this Petition, Charter seeks to operate DJI Phantom 2 quadcopter UAS (hereinafter

“Phantom 2”) for the purpose of inspecting its infrastructure and related distribution systems,

including transmission lines, switches, antennas and transceivers, and conducting aerial

photography and videography in support Charter’s advertising and marketing efforts, continuing

an established legacy that has always sought the highest standards of operations and safety.

Pursuant to 14 C.F.R. § 11.81 (Petition for Exemptions.), Charter provides the following

information in support of its petition:

C. Background
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Charter seeks an exemption to operate the Phantom 2 for compensation or hire within the

national airspace system (“NAS”)1. The Phantom 2 is comprised of an airborne unmanned

aircraft (the “UA”) and a transportable ground control station (the “GCS”). The Phantom 2 UA

weighs approximately 2.2 pounds (with battery) with a diagonal diameter of approximately 14

inches. The Phantom 2 UA is equipped with four (4) rotors driven by four 920 KV electric

motors powered by a 5200 mAh, 11.1V lithium-polymer battery.

Phantom 2 marked with identification (N-Number) pursuant to 14 C.F.R. Part 45.

D. Basis for Petition

Charter, by and through undersigned counsel, pursuant to Federal Aviation Regulations

(FAR) (14 C.F.R. § 11.61)2 and the FAA Modernization and Reform Act of 2012 (“FMRA”),

 1 Charter has reserved N9233 for one of its Phantom 2 UAs, and will submit Aircraft

Registration Applications for each UA upon the grant of the exemptions sought by this petition.

2 14 C.F.R. § 11.61(b) (“Using a petition for exemption, you may ask FAA to grant you relief

from current regulations in 14 C.F.R.”)

N9233
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Section 333, Special Rules for Certain Unmanned Aircraft Systems (“Section 333”), hereby

respectfully petitions the Administrator for an exemption from the requirements of 14 C.F.R. §§

45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.315(a), 91.7(a), 91.105,

91.119(c), 91.121(a)(1)(iii), 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and

91.Charter(a) and (b).

1. Section 333

Congress identifies Section 333 as a pathway for “expedited operational authorization” of

certain UAS in the NAS. Section 332(b)(1) (“expedited operational authorization.”).

3

 Under

Section 333, Congress mandates that the FAA “shall determine if certain unmanned aircraft

systems may operate safely in the national airspace system before completion of the plan and

rulemaking required by section 332 of this Act or the guidance required by section 334 of this

Act” (Section 333(a)) upon consideration of its “size, weight, speed, operational capability,

proximity to airports and populated areas, and operation within visual line of sight.” Section

333(b)(1). If the FAA makes such a determination, the FAA “shall [also] establish requirements

for the safe operation.” Section 333(c). The FAA further may find that the UAS does not require

“airworthiness certification under section 44704 of title 49, United States Code.” Section

333(b)(2).

2. 49 U.S.C. § 44701

The FAA is further authorized to grant exemptions from its safety regulations and

minimum standards under 49 U.S.C. § 44701 (“Section 44701”) “if the Administrator finds

the exemption is in the public interest.” Section 44701(f) (authorizing the grant of

 3 See also www.faa.gov/uas/legislative_programs/section_333/ (noting that Section 333 grants

the FAA “the statutory flexibility to expedite requirements for the safe operation of certain

aircraft systems in the NAS.”).
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exemptions from safety regulations and minimum standards under section 44701(a) and (b) and

sections 44702-44716).4

For the reasons addressed herein, this Petition qualifies for expedited approval of

Charter’s request for exemption under both Sections 333 and 44701.

E. The Phantom 2 Meets the Statutory Criteria for Exemption under Section 333

Given its small size, light weight, slow speed, limited load capacity, superior

operational capabilities, and that the operations will be conducted only during the day, under

visual meteorological conditions (“VMC”), within visual line of sight (“VLOS”) of the Pilot In

Command (“PIC”) with the assistance of a visual safety observer (“VO”) and not in the proximity

of airports or populated areas, the Phantom 2 is the very sort of UAS that qualifies for expedited

approval under Section 333.

1. Section 333(b)(1) Criteria

a. Size

The Phantom 2 has a diagonal length of approximately 14 inches.

b. Weight

The Phantom 2 weighs 2.2 pounds (with battery and propellers).

c. Speed

The Phantom 2 has a maximum speed of 29 knots.

d. Operational Capability

The Phantom 2 was specially designed for aerial photography and videography. 

 4 See e.g. 49 USC §44711(a) ((1) prohibiting operations without airworthiness certificate; (2)

prohibiting serving as airman without airman’s certificate; (5) prohibiting commercial operations

in violation of regulations); 49 USC §44704 (issuance of airworthiness certificate); 14 C.F.R.

§91.203 (a)(1) (carry airworthiness certificate)).
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Supported by a rechargeable 5200mAh, 11.1V LiPo battery, the Phantom 2 can fly for 25

minutes (per charge) and carry a variety of cameras or sensors. Other operational metrics of the

Phantom 2 are as follows:

Aircraft Weight (with battery)

Hover Accuracy

Max Yaw Angular Velocity

Max Tilt Angle

Max Ascent / Descent Speed

Max Flight Speed

Diagonal Length

Flight Time

Take-off Weight

Operating Temperature

1000g (2.2 lbs.)

Vertical: 0.8m;/Horizontal: 2.5m

200°/s

35°

Ascent: 6m/s (19.6’); Descent: 2m/s (6.5’)

15m/s (29 knots)

350mm (13.8 inches)

25mins

≤1300g (2.86 lbs.)

-10°C ~ 50°C

Battery Type

Capacity

Charging Environment Range

Discharging Environment Range

3S LiPo

5200mAh, 11.1V

0°C to 40°C (32°F to 104°F)

-20°C to 50°C (-4°F to 122°F)

Remote

Control

Operating Frequency

Communication Distance

Receiver Sensitivity (1%PER)

Working Current/Voltage

Built-in LiPo Battery Working

Current/Capacity

2.4GHz ISM

1000m (3280 feet)

-97dBm

120 mA@3.7V

3.7V, 2000mAh

e. Proximity of Airports

Flight operations pursuant to this Petition will be tightly controlled. Flight operations

will not occur within 5 nautical miles of an airport reference point (ARP) as denoted in the

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the

center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless

a letter of agreement with that airport’s management is obtained or otherwise permitted by a
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COA issued to the exemption holder. The letter of agreement with the airport management will

be made available to the Administrator or any law enforcement official upon request.

f. Visual Line-of-Sight

The Phantom 2 will at all times be flown by Charter only in the daytime (not at night)

under VMC within VLOS of the PIC with the further assistance of a VO with whom the PIC will

have the ability for direct and continuous verbal communications so as to ensure that the flight

operations remain within the PIC’s VLOS and prescribed flight boundaries and deconflict with

objects in the air and on the ground. Thus, pursuant to the FAA’s Interim Operational Approval

Guidelines for UAS the proposed operations provide an approved method of control and

collision avoidance to satisfy the “see and avoid” requirement of 14 C.F.R. § 91.113:

While considerable work is ongoing to develop a certifiable “detect, sense, and avoid”

system, no current solution exists. Compliance with the “see and avoid” aspect of 14

C.F.R. 91.113, Right-of-Way Rules: Except Water Operations, becomes one of the

primary issues in UAS operational approvals. As a result, alternate methods of

compliance are required to accomplish the “see and avoid” function. See and avoid risk

mitigation strategies are normally based on the use of visual observers or other methods

of segregation.

Interim Operational Approval Guidance 08-01, Unmanned Aircraft Systems Operations in the

U.S. National Airspace System (March 13, 2008) at 8. Only qualified and current PIC’s and

VOs, as provided in this Petition, will be used.

2. Other Factors

a. Phantom 2 Safety Systems

The Phantom 2 is replete with mechanisms to ensure safe operations and protect persons

and property on the ground. In addition to having experienced operator/PIC and VO, the

Phantom 2 has a variety of inherent safety systems, including:

• 2.4 Ghz Frequency Hopping: The Phantom 2 utilizes the 2.4 Ghz spectrum to
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communicate between the GCS and the UA. The Phantom 2 is enabled with

automatic frequency hopping in case of interference to prevent lost link situations.

• Return to Home Enabled: The Phantom 2 is enabled with a return to home

function that causes the aircraft to return to the point of take-off, descend and land

upon losing contact with the GCS, loss of GPS, or if the failsafe mode is activated

by the PIC.

• Geo-Fencing Capabilities: The Phantom 2 is equipped with geo-fence capabilities

enabling the PIC to restrict the Phantom 2’s operating area to a certain distance

from take-off.

• Flight Plan Altitude Settings: The Phantom 2 has the ability for the

operators to set Maximum and Minimum flight altitudes for a specific

flight ‘corridor’ for safe operations.

• No-Fly Zone Feature: In order to increase flight safety and prevent accidental

flights in restricted areas, the Phantom 2 is equipped with a Flight Limitation

System to prevent the UA from flying within restricted airspace, including within

5 miles of airports or at an altitude greater than 394 AGL (without GPS). 

• Ground Control Station Warnings: Battery level is monitored in flight on the GCS. 

A low battery failsafe is triggered when the battery is depleted to a point that may

affect safe return of the aircraft home. The aircraft will automatically land when

the battery level can only support the aircraft to land from the current altitude.

b. Flight Operations Documents

To ensure consistently safe operations, Charter will operate and maintain the Phantom 2 in

accordance with this Petition, Charter’s UAS Safety Procedures Manual (SPM) (Exhibit A hereto
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(submitted on a confidential basis)), and the DJI Phantom 2 User Manual, DJI Smart Flight Battery

Safety Guidelines and related DJI safety, inspection and maintenance notices (as published and

updated by DJI), collectively referred to herein as “DJI Safety Materials”.

5

 

In seeking this exemption, Charter proposes to operate the Phantom 2 pursuant to the

following specific operating limitations:

1. The Phantom 2 shall not be flown at an indicated airspeed exceeding 87 knots. In no case

will the UA be operated at airspeeds greater than the maximum UA operating airspeed

recommended by the aircraft manufacturer. 

2. The Phantom 2 shall only be operated below 400 feet above ground level (AGL). Altitude

must be reported in feet AGL.

3. The Phantom 2 shall be operated within VLOS of the PIC and VO (unaided by a device

other than corrective lenses).

4. All operations will utilize a VO. The VO may be used to satisfy the VLOS requirement

as long as the PIC always maintains VLOS capability. The VO and PIC will be able to

communicate verbally at all times. 

5. The PIC will be designated prior to the flight and the PIC designation will apply for the

duration of the applicable flight.

6. The PIC is responsible for ensuring that the VO can perform the required functions.

7. Any time the UA is operating, all documents required under 14 C.F.R. § 91.9 and §

91.203 shall be available to the PIC at the GCS. Such documents shall be made available

to the Administrator or any law enforcement official upon request.

 5 The DJI Safety Materials in their most current and up-to-date form are publicly available at

http://www.dji.com/product/phantom-2/download.
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8. Prior to each flight the PIC shall inspect the UAS for any inoperable components, items or

equipment to ensure the UAS is in a condition for safe flight. If the inspection reveals a

condition that affects safe operations, the UAS shall not be operated until the necessary

maintenance has been performed and the UAS is found to be in a condition for safe flight. 

The inspection will include the GCS. Any discrepancies and all maintenance or

alterations shall be documented in the aircraft records, such records to be made available

to the Administrator upon request.

9. Any UAS that has undergone maintenance or alternations that affect its operation or

flight characteristics, e.g., replacement of a flight critical component, will undergo a

functional test flight prior to conducting further operations. Functional test flights will

only be conducted by a PIC with a VO and must remain at least 500 feet from other

people. The functional test flight will be conducted in such a manner so as to not pose an

undue hazard to persons or property. 

10. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in

a condition for safe flight. 

11. The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement,

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under the requested exemption will comply with all manufacturer

safety bulletins.

13. Record of the UAS maintenance, preventive maintenance, alternations, status of

replacement/overhaul component parts, and the total time in service of the UAS shall be

documented and maintained.

14. Flight operations will not occur within 5 nautical miles of an airport reference point
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(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not

denoted with an ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport’s management

is obtained, or otherwise permitted by a COA issued to the exemption holder. The letter

of agreement with the airport management will be made available to the Administrator or

any law enforcement official upon request.

15. The UA shall not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

16. Upon loss of communication or GPS signal, the UA shall return to the point of take-off,

descend, and land.

17. The PIC is required to abort the flight in the event of unanticipated obstacles or

emergencies.

18. The PIC shall not begin a flight unless (considering wind and forecast weather

conditions) there is enough available power for the UA to conduct the intended operation

and to operate after that for at least five (5) minutes or with the reserve power

recommended by the manufacturer if greater.

19. Prior to conducting any operations, the operator shall obtain a Certificate of Waiver or

Authorization (COA). Operator shall follow the conditions and limitations for the FAA’s

“blanket” Certificate of Waiver or Authorization (COA) for flights at or below 200 feet

AGL. https://www.faa.gov/news/updates/?newsId=82245. For operations outside the

blanket parameters, operator will obtain a separate COA specific to the proposed

operation.

20. The UA shall be marked with an identification (N-Number) in accordance with 14 C.F.R.
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§ 45.23, such markings to be as large as practicable pursuant to 14 C.F.R. § 45.29(f), and

identified by a serial number registered in accordance with 14 C.F.R. Part 47.

21. The UA shall at all times remain clear and yield the right of way to all other manned

operations and activities (e.g. gliders, ultralights, parachutes).

22. The UAS shall not be operated by the PIC from any moving vehicle or device.

23. If the UAS loses communications or loses its GPS signal, the UA will return to a predetermined location within the private or controlled-access property.

24. The UA shall at all times be operated 500 feet away from all non-participating persons,

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator will ensure

that nonparticipating persons remain under such protection. If a situation arises

where nonparticipating persons leave such protection and are within 500 feet of

the UA, flight operations will be immediately terminated in a manner ensuring the

safety of nonparticipating person; and

b. The owner/controller of any vessels, vehicles or structures has granted permission

for operating closer to those objects and the PIC has made a safety assessment of

the risk of operating closer to those objects and determined that it does not present

an undue hazard.

The PIC, VO, operator trainees or essential person are not considered nonparticipating

persons.

25. All operations shall be conducted over private or controlled-access property with

permission from the property owner/controller or authorized representative. Permission
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from property owner/controller or authorized representative will be obtained for each

flight to be conducted.

26. UAS operations may not be conducted at night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights

under special visual flight rules (SVFR) are not authorized.

27. The PIC shall possess either an airline transport, commercial, private, recreational or sport

pilot certificate. The PIC must also hold a current FAA airman medical certificate or a

valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a

territory, a possession, or the Federal government. The PIC must also meet the flight

review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated

on his or her pilot certificate.

28. The operator will not permit any PIC to operate unless the PIC demonstrates the ability to

safely operate the UAS in a manner consistent with how the UAS will be operated under

the requested exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from persons, vessels, vehicles, and structures. PIC qualification

flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). 

Flights for the purposes of training the operator’s PICs and VOs will only be conducted

during dedicated training sessions. During training, proficiency, and experience-building

flights, all persons not essential for flight operations are considered nonparticipants, and

the PIC will operate the UA with appropriate distance from nonparticipants in accordance

with 14 CFR § 91.119. 

29. Any incident, accident or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA shall be reported to
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the FAA’s UAS Integration Office within 24 hours. Accidents shall also be reported to

the National Transportation Safety Board (NTSB). Further flight operations shall not be

conducted until the incident, accident or transgression is reviewed by UAS Integration

Office and authorization to resume operations is provided.

30. The UAS shall be operated pursuant this Petition, Charter’s SPM, as well as the DJI

Safety Materials, such documentation to be made available to the Administrator upon

request. If a discrepancy exists between such documentation and the conditions and

limitations directed by the Administrator in granting the exemption, the conditions and

limitation in the exemption shall take precedence and be followed.

c. Privacy

Charter will comply with all federal, state, and/or local privacy regulations that may apply

in the areas in which Charter will operate the Phantom 2 pursuant to this Petition. 

d. Physical Security

In order to ensure its safe and proper use, Charter will be the only operator of the UAS

and the UAS will at all times remain in Charter’s custody.

3. Charter’s History of Safe Operations Flying the Phantom 2

As a hobbyist, Charter has operated and amassed hundreds of hours operating the

Phantom 2 and other multi-rotor UAS with similar flight and control characteristics with no

injury to persons or damage to property. 

4. Lack of Threat to the NAS, Public, or National Security

Those reasons addressed, including meeting Section 333(b)(1) criteria, Charter’s

established record of safety, operations as outlined in this Petition, and the other factors

discussed, demonstrate that the Phantom 2 will be operated safely in the NAS without creating a
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hazard to other aircraft or persons or property on the ground or pose a threat to national security. 

For all of these reasons, Charter’s proposed operations using the Phantom 2 qualify for

expedited approval of the sought exemption pursuant to Section 333 for the specified uses and

under the proposed operating requirements and restrictions.

F. Charter’s Operations Pursuant to This Petition Qualify for Exemption Under

Section 44701. 

Granting Charter’s request for exemption would benefit the public and have no adverse

effect on safety. Accordingly, Charter’s operations pursuant to this Petition also qualify for an

exemption from the FAA’s related safety regulations under Section 44701.

1. Public Interest Benefits

The public would greatly benefit from granting Charter’s petition for exemption so it can

use the Phantom 2. The Phantom 2 is a battery powered UAS that serves as a safe, efficient, and

economical alternative to manned aircraft traditionally used for aerial inspection and data

collection. No pilot or crew need be airborne, thereby providing for superior safety to persons

and property in the air and on the ground than that provided by manned aircraft performing the

same operations. Granting the exemption would also reduce the number of manned aircraft in

the NAS and, as a result, reduce the environmental impact of such operations, as well as provide

for better aerial imaging and data collection and, as a result, a more robust economy. Using the

Phantom 2 also provides the benefit of greater operational flexibility and reduced cost when

compared to manned aircraft.

(a) Increased Aircrew Safety and Reduced Risk to Persons/Property On Ground

Because the Phantom 2 is unmanned, the proposed operations eliminate the risk to pilot and

crew associated with flying such aerial-imaging and data-collection missions at low altitude, in

confined airspace. Further, given its small size and weight and low airspeed, using the Phantom 2
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also reduces the risk of damage or injury to persons or property on the ground, and in the air, were

there to be a mishap. 

(b) Reduced Environmental Impact

Using the Phantom 2 UAS instead of manned aircraft also benefits the public by

eliminating or greatly reducing air and noise pollution associated with traditional aerial surveying

operations. Because it is battery powered (using rechargeable batteries) and uses electric motors,

the Phantom 2 consumes no fuel and generates no air pollution, and creates very little noise. As a

result, the public is benefited as a result of reduced environmental impact, reduced operator and

other human exposure, and greater fuel conservation, which serves additionally to support our

government’s specific efforts to reduce the U.S.’s carbon footprint.6

(c) Fewer Manned Aircraft In NAS and Reduced Need for ATC Handling

The Phantom 2 also does not require a runway or helipad to takeoff or land and will not

be operated within the proximity of airports. As such, fewer aircraft will need to be handled by

air traffic control during ground, takeoff, departure, arrival and landing phases. Operations

pursuant to this Petition (unmanned, VLOS, below 400 feet AGL, and not within proximity to

airports) will further reduce the number of manned aircraft flying or transiting at or above 500

feet AGL to and from the areas of operations as well as congestion around airports due to aircraft

arrival and departure.

(d) Superior Aerial Imagery and Increased Benefit to U.S. Economy

Better aerial footage and data collection can also be obtained using the small and nimble

Phantom 2 than can be obtained using manned aircraft or other ground-based methods. Due to its

 6 Reducing the U.S.’s carbon footprint is a high priority and consistent with the U.S. Environmental

Protection Agency’s regulatory efforts to phase out the use of fossil fuels. 
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small size and superior flight performance characteristics, the Phantom 2 allows for images and data

to be taken and collected from locations and angles and with better precision than using manned

aircraft. As a result, less time is needed in the air to obtain the desired information, which in addition

to providing the benefit of fewer aircraft in the NAS and associated reduced risk to objects and

persons and property in the air and on the ground, reduced noise, etc., allows for the more efficient

and effective delivery of energy and services, which benefits consumers. This additionally ensures

that companies such as Charter remain competitive and profitable, thereby providing their

employees greater job stability, which ultimately contributes further to the U.S. economy through

increased consumerspending. 

(e) Increased Operational Flexibility and Reduced Cost

Using the Phantom 2 also provides the benefit of greater operational flexibility and reduced

cost when compared to manned aircraft. Instead of each time having to hire a manned aircraft at

thousands of dollars/hour, subject to the pilot’s schedule and availability, Charter can operate the

Phantom 2, which it has purchased and outfitted at lower combined cost, innumerable times and at

the convenience of Charter and its customers.

2. No Adverse Safety Effects

Granting Charter’s Petition will also not adversely affect aviation safety or pose any

undue risks to the public. The Phantom 2 will be operated in accordance with this Petition,

Charter’s SPM, and the DJI Safety Materials and in compliance with all applicable public safety

requirements. Accordingly, and as detailed herein, granting the requested exemption would not

adversely affect safety. Indeed, as detailed below, operations pursuant to the limitations and

guidelines addressed herein, in Charter’s SPM, and in the DJI Safety Materials will provide an

equivalent or even higher level of safety to those regulations from which Charter seeks
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exemption. 

The FAA has previously granted exemptions in circumstances similar, in all material

respects, to those presented herein. See Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11066A, 11067, 11067A, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153,

11156, 11157, 11158, 11159, 11160, 11161, 11213.

For all of these reasons, Charter’s operations pursuant to this Petition also qualify for an

exemption under Section 44701.

G. Exemptions Sought By Charter and Reasons For The Requested Relief

Pursuant to Section 333, Charter seeks an exemption from the requirements of 14 C.F.R.

§§ 45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.315(a), 91.7(a), 91.105,

91.119(c), 91.121(a)(1)(iii), 91.151(b), 91.405(a), 91.407(a)(1) and (2), 91.409(a)(1) and (2),

91.Charter(a) and (b).

1. Section 45.27(a). Location of marks; nonfixed-wing aircraft.

Section 45.27, entitled Location of marks; nonfixed-wing aircraft, subsection (a) states

(emphasis added):

(a) Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally

on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

To the extent subsection 45.27(a) may be deemed to apply to the Phantom 2, Charter

seeks an exemption from the subsection (i.e., that the marks be displayed on both surfaces of the

cabin, fuselage, boom, or tail) because the Phantom 2 UA is of insufficient size to accommodate

such marking. Thus marking the Phantom 2 UA as required by this subsection would not be

possible.

An equivalent level of safety can be provided instead by marking the Phantom 2 UA, as

may be applicable, with lettering as large as practicable (14 C.F.R. § 45.29(f)) on its largest
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available surface so as to permit such marking to be displayed to pilot, crew, and others both

when the Phantom 2 UA is on the ground and airborne.

2. Section 61.23 (a) and (c). Medical Certificates: Requirements and duration.

Charter seeks and exemption from 14. C.F.R. 61.23 (a) and (c). Section 61.23 entitled

Medical certificates: Requirements and duration, subsections (a) and (c) state:

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and

(c) of this section, a person—

(1) Must hold a first-class medical certificate:

(i) When exercising the pilot-in-command privileges of an airline transport pilot

certificate;

(ii) When exercising the second-in-command privileges of an airline transport pilot

certificate in a flag or supplemental operation in part 121 of this chapter that requires three or

more pilots; or

(iii) When serving as a required pilot flightcrew member in an operation conducted under

part 121 of this chapter if the pilot has reached his or her 60th birthday.

(2) Must hold at least a second class medical certificate when exercising:

(i) Second-in-command privileges of an airline transport pilot certificate in part 121 of

this chapter (other than operations specified in paragraph (a)(1)(ii) of this section); or

(ii) Privileges of a commercial pilot certificate; or

(3) Must hold at least a third-class medical certificate—

(i) When exercising the privileges of a private pilot certificate;

(ii) When exercising the privileges of a recreational pilot certificate;

(iii) When exercising the privileges of a student pilot certificate;

(iv) When exercising the privileges of a flight instructor certificate and acting as the pilot

in command;

(v) When exercising the privileges of a flight instructor certificate and serving as a

required pilot flight crewmember;
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(vi) When taking a practical test in an aircraft for a recreational pilot, private pilot,

commercial pilot, or airline transport pilot certificate, or for a flight instructor certificate; or

(vii) When performing the duties as an Examiner in an aircraft when administering a

practical test or proficiency check for an airman certificate, rating, or authorization. . . .

(c) Operations requiring either a medical certificate or U.S. driver's license. (1) A person

must hold and possess either a medical certificate issued under part 67 of this chapter or a U.S.

driver's license when—

(i) Exercising the privileges of a student pilot certificate while seeking sport pilot

privileges in a light-sport aircraft other than a glider or balloon;

(ii) Exercising the privileges of a sport pilot certificate in a light-sport aircraft other than

a glider or balloon;

(iii) Exercising the privileges of a flight instructor certificate with a sport pilot rating

while acting as pilot in command or serving as a required flight crewmember of a light-sport

aircraft other than a glider or balloon; or

(iv) Serving as an Examiner and administering a practical test for the issuance of a sport

pilot certificate in a light-sport aircraft other than a glider or balloon.

(2) A person using a U.S. driver's license to meet the requirements of this paragraph

must—

(i) Comply with each restriction and limitation imposed by that person's U.S. driver's

license and any judicial or administrative order applying to the operation of a motor vehicle;

(ii) Have been found eligible for the issuance of at least a third-class airman medical

certificate at the time of his or her most recent application (if the person has applied for a

medical certificate);

(iii) Not have had his or her most recently issued medical certificate (if the person has

held a medical certificate) suspended or revoked or most recent Authorization for a Special

Issuance of a Medical Certificate withdrawn; and

(iv) Not know or have reason to know of any medical condition that would make that

person unable to operate a light-sport aircraft in a safe manner.

In general, subsection 61.23 (a) and (c) require holders of certain classes of pilot’s

licenses to hold medical certificates in order to operate certain aircraft. Charter seeks an
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exemption from these subsections to allow its PICs to only hold a valid U.S. issued driver’s

license. 

In Exemption Nos. 11213 and 11578, the FAA previously found that because of the risk

mitigations established in the conditions and limitations of that exemption (which are

substantially the same as those set forth above), a person holding a valid driver’s license who is

operating a UAS will not adversely affect safety.

Accordingly, and consistent with the FAA’s allowance of operations under Section 333

exemptions by those who hold a sport or recreational pilot certificate, a third class medical

certificate is no longer required. Now, a Section 333 operator only needs a valid driver’s license

to satisfy the medical requirement. See http://www.faa.gov/news/updates/?newsId=82485

3. Section 61.101 (e)(4) and (5) Recreational pilot privileges and limitations.

Charter seeks and exemption from 14 C.F.R. 61.101 (e)(4) and (5). Section 61.101,

entitled Recreational pilot privileges and limitations, subsections (e)(4) and (5) state:

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may

not act as pilot in command of an aircraft—

(4) For compensation or hire;

(5) In furtherance of a business;

In general, subsections 61.101 (e)(4) and (5) prohibit a recreational pilot from conducting

commercial operations. Charter seeks exemption from the subsections because the Phantom 2

will not carry a pilot, passengers or property (other than a camera). 

In Exemption Nos. 11213 and 11578, the FAA previously found that holders of

recreational pilot certificates may serve as PIC for UAS operations as they have demonstrated

aeronautical knowledge relevant to UAS operations, are subject to Department of Homeland

Security screening, and risk is mitigated through conditions and limitations regarding PIC

training.
22

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The FAA now allows operations under Section 333 exemptions by those who hold a

sport or recreational pilot certificate. See http://www.faa.gov/news/updates/?newsId=82485

4. Section 61.113(a) and (b). Private pilot privileges and limitations: Pilot in

command.

Charter seeks an exemption from 14 C.F.R. 61.113(a) and (b). Section 61.113, entitled

Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) state

(emphasis added):

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds

a private pilot certificate may act as pilot in command of an aircraft that is carrying

passengers or property for compensation or hire; nor may that person, for compensation

or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft

in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

In general, subsections 61.113 (a) and (b) prohibit a private pilot from conducting

commercial operations. Charter seeks exemption from the subsections because the Phantom 2

will not carry a pilot, passengers or property (other than a camera). As addressed, the Phantom 2

is a very light, remotely controlled UAS with no persons or property on board. The area of

inspection operations is also generally remote or sparsely populated. Further, each flight is

planned and fully coordinated in advance in accordance with this Petition. Thus the risk

associated with the proposed operations is so diminished from that associated with commercial

operations contemplated by Part 61, that allowing a PIC having a private pilot certificate, rather

than a commercial certificate, the minimum flight hour and qualification criteria, and operating

according to the limitations and guidelines provided herein, provides a level of safety that

exceeds that provided by a pilot having a commercial certificate operating a conventional aircraft
23

CHI-51051

as required under the regulations. 

The FAA has previously granted exemptions in circumstances similar, in all material

respects, to those presented herein. See Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11066A, 11067, 11067A, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153,

11156, 11157, 11158, 11159, 11160, 11161, 11213, 11578.

Further, the FAA now allows for commercial UAS operations under Section 333

exemptions by those who hold a sport or recreational airman certificate. See

https://www.faa.gov/news/updates/?newsId=82485. See also Exemption Nos. 11213 and 11578.

5. Section 61.315(a) What are the privileges and limitations of my sport pilot

certificate?

Charter seeks an exemption from 14 C.F.R. 61.315(a). Section 61.315, entitled What are

the privileges and limits of my sport pilot certificate, subsection (a) states:

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport

aircraft, except as specified in paragraph (c) of this section.

In general, subsection 61.315(a) prohibits a sport pilot from being a PIC of anything other

than a light-sport aircraft. Charter seeks an exemption from the subsections because the

Phantom 2 will not carry a pilot, passengers or property (other than a camera or other sensors). 

In Exemption Nos. 11213 and 11578, the FAA previously found that holders of sport pilot

certificates may serve as PIC for UAS operations as they have demonstrated aeronautical

knowledge relevant to UAS operations, are subject to Department of Homeland Security

screening, and risk is mitigated through conditions and limitations regarding PIC training. 

Further, the FAA now allows for those who hold a sport or recreational pilot certificate to act as

PIC for commercial UAS operations under Section 333 exemptions. See

https://www.faa.gov/news/updates/?newsId=82485. 
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6. Section 91.7(a). Civil Aircraft Airworthiness.

Finding that Charter meets the Section 333 criteria renders subsection 91.7(a)

inapplicable. 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a) states (emphasis added):

“No person may operate a civil aircraft unless it is in an airworthy condition.” There is no FAA

standard by which such a determination of airworthiness can be made. Nonetheless, given the

limitations and procedures, as contained herein, in Charter’s SPM, and in the DJI Safety

Materials, for maintaining the aircraft and checking it before each flight to ensure that it is in

peak operational condition, an equivalent level of safety will be provided.

7. Section 91.105. Flight crewmembers at stations.

Charter seeks an exemption from 14 C.F.R. 91.105. Section 91.105, entitled Flight

crewmembers at stations, states (emphasis added):

(a) During takeoff and landing, and while en route, each required flight crewmember

shall—

(1) Be at the crewmember station unless the absence is necessary to perform duties in

connection with the operation of the aircraft or in connection with physiological needs;

and

(2) Keep the safety belt fastened while at the crewmember station.

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during

takeoff and landing, keep his or her shoulder harness fastened while at his or her

assigned duty station. This paragraph does not apply if—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or

(2) The crewmember would be unable to perform required duties with the shoulder

harness fastened.

In general, Section 91.105 requires pilot and crew to be at their duty stations and

harnessed during flight. Charter seeks exemption from the Section 91.105 because the Phantom
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2 UA is by definition an unmanned aircraft, having neither pilot nor crew so as to be stationed or

harnessed as required by the regulation. An equivalent or even higher level of safety can be

provided instead by using an unmanned aircraft controlled by a PIC who at all times is located at

and controls the UAS from the GCS.

8. Section 91.119(c). Minimum safe altitudes.

Charter seeks an exemption from 14 C.F.R. 91.119(c). Section 91.119, entitled Minimum

safe altitudes: General, subsection (d) states (emphasis added):

Except when necessary for takeoff or landing, no person may operate an aircraft below

the following altitudes:

***

(c) Over other than congested areas. An altitude of 500 feet above the surface, except

over open water or sparsely populated areas. In those cases, the aircraft may not be

operated closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119(c) establishes safe altitudes for operation of civil aircraft over other than

congested areas. Charter seeks exemption from subsection 91.119(c) because, pursuant to this

Petition, the Phantom 2 will at all times be operated below 400 feet AGL.

An equivalent or even higher level of safety can be provided instead by, as provided

herein, operated below 400 feet AGL, so as to deconflict with manned vehicles operating above

500 feet AGL, within the VLOS of the PIC with the assistance of a VO so as to ensure the safety

of and deconfliction with any persons or property in the air and on the ground, including

participating and non-participating personnel, away from who the UA would generally be

restricted as addressed herein. Further the Phantom 2 flight operations will be monitored at all

times by both the PIC and VO and will be in compliance with local public safety requirements,

so as to prevent access to the restricted areas of operation. 

The FAA has previously granted exemptions in circumstances similar, in all material
26

CHI-51051

respects, to those presented herein. See Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11109, 11112, 11213.

9. Section 91.121(a)(1)(iii). Altimeter settings.

Charter seeks an exemption from 14 C.F.R. 91.121(a)(1)(iii). Section 91.121, entitled

Altimeter settings, states in relevant part (emphasis added):

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of

that aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

***

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure

airport or an appropriate altimeter setting available before departure

Subsection 91.121(a)(1)(iii) requires persons operating an aircraft to maintain altitude by

reference to an altimeter set “to the elevation of the departure airport or an appropriate altimeter

setting available before departure.” Charter seeks exemption from subsection 91.121(a)(1)(iii)

because the Phantom 2 uses both GPS and a barometer to determine altitude instead of a typical

on board barometric altimeter as contemplated by the regulation. Instead, the Phantom 2

continuously downlinks GPS altitude information and barometric information from the UA to the

PIC at the GCS to maintain altitude.

An equivalent level of safety will be provided instead by operating the UA below 400

feet AGL within the VLOS of the PIC (with the assistance of a VO) with the above described

altitude and barometric information downlinked from the UA to the PIC to maintain altitude and

ensure safety. Prior to each flight, a zero altitude/AGL will be established at the launch site, as

confirmed for accuracy by the PIC. 

The FAA has previously granted exemptions in circumstances similar, in all material
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CHI-51051

respects, to those presented herein. See Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11109, 11112, 11213.

10. Section 91.151(b). Fuel requirements for flight in VFR conditions.

Charter seeks an exemption from 14 C.F.R. 91.151(b). Section 91.151(b), entitled Fuel

requirements for flight in VFR conditions, states (emphasis added):

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the first

point of intended landing and, assuming normal cruising speed, to fly after that for at

least 20 minutes.

Though the Phantom 2 is an unmanned aircraft, and thus would not begin a flight with a

person in it as the regulation contemplates, to the extent subsection 91.151(b) may be deemed to

apply to the Phantom 2, Charter seeks an exemption from the subsection because the battery

powering the UAS only provides for approximately 25 minutes of flight and, therefore, it would

be impractical to operate in accordance with the 20 minute reserve required by the regulation.

An equivalent level of safety can be provided instead by limiting flights so there is

enough available power for the Phantom 2 UA to conduct the intended operation and to operate

after that for at least five (5) minutes or with the reserve power recommended by the

manufacturer if greater. Given that the Phantom 2 UA, has a maximum weight of

approximately 2.2 pounds and will fly at less than 29 knots, will be operated within the VLOS of

the PIC, within the confines of the particular landowner’s property with prior written consent of

the landowner and participating and non-participating film personnel, this restriction would

provide more than enough battery reserve to accommodate a safe return to the landing zone

from anywhere in the operating area with no adverse effect on the safety of persons and

property in the air or on the ground. 
28

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The FAA has previously granted exemptions in circumstances similar, in all material

respects, to those presented herein. See Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067. See also Exemption Nos. 8811, 10808, 10673 (granting exemption for UAS to allow

operations at less than the minimums prescribed in Section 91.151 for day VFR conditions);

Exemption Nos. 2689, 5745, 10650 (granted similar relief to manned aircraft).

11. Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 91.417(a) and (b). 

Maintenance inspections and recording.

Section 91.405(a), entitled Maintenance required, states:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this section, have

discrepancies repaired as prescribed in part 43 of this chapter;

Section 91.407(a)(1), entitled Operation after maintenance, preventive maintenance, rebuilding,

or alteration, states:

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under § 43.7 of this

chapter;

Section 91.409(a)(1) and (2), entitled Inspections, states:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft

unless, within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been

approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part

21 of this chapter.

No inspection performed under paragraph (b) of this section may be substituted for any

inspection required by this paragraph unless it is performed by a person authorized to

perform annual inspections and is entered as an “annual” inspection in the required

maintenance records.
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Section 91.417(a) and (b), entitled Maintenance records, state:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered

owner or operator shall keep the following records for the periods specified in paragraph

(b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of

the 100-hour, annual, progressive, and other required or approved inspections, as

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor,

and appliance of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the work

performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return

to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required

to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last

inspection required by the inspection program under which the aircraft and its appliances

are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives

including, for each, the method of compliance, the AD or safety directive number and

revision date. If the AD or safety directive involves recurring action, the time and date

when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration

to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the

work is repeated or superseded by other work or for 1 year after the work is performed.
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(2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this

chapter shall be retained until the defects are repaired and the aircraft is approved for

return to service.

In general, these regulations require that an airworthy certificated aircraft be inspected as

prescribed in 14 C.F.R. Part 91, Subpart E (Maintenance, Preventive Maintenance, and

Alterations), any discrepancies be repaired and the aircraft be approved for return to service as

prescribed in Part 43 (Maintenance, Preventive Maintenance, Rebuilding, and Alterations), and

that any work on the aircraft be recorded and such records maintained.

Charter seeks an exemption because, as addressed, the Phantom 2 UA will operate

pursuant to this Petition without airworthiness certification. An equivalent level of safety can be

provided instead by requiring, as provided herein, that inspections and maintenance be

accomplished according to the DJI Safety Materials and Charter’s SPM. Among other things, the

UAS will be inspected prior to each flight to confirm that it is in good working order, any

maintenance or repairs will be performed and logged, and, upon any work being performed on the

UA, the UA will be checked and approved for flight by qualified Charter personnel before being

returned to service. No pilot or crew need be airborne flying a heavy, fuel-ladened aircraft,

thereby providing for superior safety to persons and property in the air and on the ground. 

Further, all flights will be conducted during the day, below 400 feet AGL, within the VLOS of

the PIC with the assistance of a VO so as to ensure deconfliction with objects in the air and on the

ground and that flight operations remain within the boundaries of the consenting landowner’s

property. No flight will be taken without advance notice being given to and obtaining the

permission of the property owner and all participating and non-participating personnel. Given
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the Phantom 2 UA’s light weight, slow speed and low-altitude operations, there is little risk of

any damage to persons or property in the air or on the ground should a maintenance issue present

itself when airborne. Accordingly, any risk associated with using the Phantom 2 as proposed

herein is significantly reduced when compared to that presented by using manned aircraft to

conduct the same operations.

The FAA has previously granted exemptions in circumstances similar, in all material

respects, to those presented herein. See Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11066A, 11067, 11067A, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153,

11156, 11157, 11158, 11159, 11160, 11161, 11213, 11578.

H. A Summary That Can Be Published In The Federal Register, stating:

The Rules From Which Charter Seeks Exemption:

Charter Communications Operating, LLC seeks exemption from the requirements of 14 C.F.R.

§§ 45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.315(a), 91.7(a), 91.105,

91.119(c), 91.121(a)(1)(iii), 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2),and

91.417(a) and (b).

A Brief Description Of The Nature Of The Exemption Charter Seeks:

Approval of the above mentioned exemptions will allow Charter to operate the DJI Phantom 2

UAS for compensation in the National Airspace System. In relation to current aerial imaging

and data collection operations of manned aircraft operators, such exemptions will increase

safety, reduce risk to person and property on the ground, decrease carbon emissions, reduce the

need for Air Traffic Control handling, and provide better aerial imagery and information. The

Phantom 2 runs on rechargeable batteries and does not carry any persons on-board. Charter’s

customer’s will also benefit from greater operational flexibility and lower costs since Charter

can operate the Phantom 2 at a lower cost than traditional manned aircraft doing the same job.

Specifically, Charter is seeking exemptions to allow:

(1) The Phantom 2 to be marked with its registration number as large as practicable on

its largest available surface;

(2) At least a sport or recreational pilot certificated airman with a valid U.S. driver’s

license to operate the Leptron RDASS4 as the Pilot in Command;

(3) Charter to operate the Phantom 2 even though it has not been certified as airworthy;

(4) Allow the Pilot in Command to control the Phantom 2 from the controls that are
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located at the ground control station;

(5) Operate the Phantom 2 below 400 feet AGL;

(6) Operate the Phantom 2 with continuous downlinks of GPS and barometric altitude

information from the UA to the PIC at the GCS to maintain altitude instead of a traditional

barometric altimeter;

(7) Conduct operations limited to the greater of the power needed to conduct the

intended operation plus an additional five minutes or the reserve power recommended by the

manufacturer; and

(8) Conduct inspections and maintenance in accordance with the DJI Safety Materials

and Charter UAS Safety Procedures Manual.

I. Conclusion

Accordingly, as set forth above, Charter Communications Inc. seeks an exemption

pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of

2012, to permit safe operation of the Phantom 2 commercially, without an airworthiness

certificate, for the special purpose of conducting aerial imaging and data collection operations. 

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of

Section 333 of the FAA Modernization and Reform Act of 2012 to expedite approval of

operations of certain UAS in the NAS, while also advancing the interests of the public.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Charter Communications Operating, LLC

respectfully requests that the Administrator grant this Petition for an exemption from the

requirements of 14 C.F.R. §§ 45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b),

61.315(a), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii), 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) and (2),and 91.417(a) and (b).
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Dated: August 25, 2015 Respectfully submitted,

Husch Blackwell LLP

/s/ Thomas L. Gemmell

Thomas L. Gemmell

HUSCH BLACKWELL LLP

120 South Riverside Plaza, 22nd Floor

Chicago, Illinois 60606

Tel: (312) 526-1523

Fax: (312) 655-1501

tom.gemmell@huschblackwell.com

Attorneys for Petitioner