To Whom It May Concern:

In pursuant with Section 333 of the FAA Modernization and Reform Act of2012 and 14 

C.F.R. Part 11, KPRC CHANNEL 2, A Graham Media company an operator of a small 

Unmanned Aircraft System (sUAS) and television industry, seeks an exemption from the 

Federal Aviation Regulations (FARs) to allow commercial operations and news gathering 

of its sUAS. Regulations ("FARs") to allow commercial operation of its sUASs, so long 

as such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive sUAS under controlled conditions in 

airspace that is limited, predetermined, controlled as to access and would provide safety

enhancements to the already safe operations in the film and television industry presently

using conventional aircraft. Approval of this exemption would thereby enhance safety

and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to 

"...establish requirements for the safe operation of such aircraft systems in the national 

airspace system." Section 333(c) of the Reform Act.

Information Supporting this Petition as Specified in 14 C.F.R. §11.81

(a) Your name and mailing address and, if you wish, other contact information such as a 

fax number, telephone number, or e-mail address;

Robert Grant KPRC CHANNEL 2 News.

8181 SouthWest Freeway

Houston TX, 77074-1705

Email: rgrant@kprc.com

(b) The specific section or sections of 14 C.F.R. from which KPRC CHANNEL 2 seeks 

an exemption

• 2 1 - Subpart H Certification procedures for products and parts, Airworthiness 

Certificates 

• 45.23 - Display of marks; general 

• 61.113- Private pilot privileges and limitations: Pilot in command 

• 91.103- Preflight Actions 

• 91.105- Flight crewmembers at stations 

• 91.109- Flight instruction; Simulated instrument flight and certain flight tests 
.f)

• 91.119- Minimum safe altitudes: General 

• 91.121-Altimetersettings 

• 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 

• 91.203 -Civil aircraft: certification required 

• 91.405- Maintenance required 

• 91.407- Operation after maintenance, preventative maintenance, rebuilding, and 

alteration 

• 91.409 -Inspections 

• 91.417 - Maintenance records 

(c) The extent of relief Channel 2 seeks, and the reason Channel 2 seeks the relief

Channel 2 seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61, 

and 91 to the extent to operate small UASs to record aerial video for commercial 

and News worthy purposes. 

This exemption application is expressly submitted to fulfill Congress' goal in 

passing Section 333(a) through (c) of the Reform Act. This law directs the 

Secretary of Transportation to consider whether certain unmanned aircraft systems 

may operate safely in the national airspace system (NAS) before completion of the 

rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not 

create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; 

and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act§ 333 (a). Lastly, if the Secretary determines that such vehicles 

"may operate safely in the national airspace system, the Secretary shall 

establish requirements for the safe operation of such aircraft in the national 

airspace system" 

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil 

aircraft, as the term is defined under §40101 of the Act, that includes 

sUASs, from the requirement that all civil aircraft must have a current 
airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsection (a) or (b) of this section or any

sections 44702-44716 of this title if the Administrator finds the exemption 

in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 

USC §44704; 14CFR§91.203 (a) (1). 

14 C.F.R. 21 - Subpart H Certification procedures for products and 

parts, Airworthiness Certificates

Channel 2 seeks exemption from 14 C.F.R. 21, Subpart Hwhich states the 

certification procedures for products and parts as well as airworthiness 

certificates. The sUAS to be operated hereunder is less than 55 lbs. fully

loaded, carries neither a pilot nor passenger, carries no explosive materials 

or flammable liquid fuels, and operates exclusively within a secured area as 

set out in the Manual. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator, 

pursuant to the Manual's requirements, and under the requirements and in 

compliance with local public safety requirements, to provide security for 

the area of operation as is now done with conventional filming. The FAA 

will have advance notice of all operations. These safety enhancements, 

which already apply to civil aircraft operated in connection with motion 

picture and television production, provide a greater degree of safety to the 

public and property owners than conventional operations conducted with 

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAS, due to its size, speed of 

operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a substantial external 

load. Channel 2 has developed our own training procedures and regulations to promote 

and provide safe flying experiences for our PIC(s) which can be viewed in section (e) of 

this petition. Unlike other civil aircraft, operations under this exemption will be tightly

controlled and monitored by both the operator, pursuant to the Manual's requirements, 

and under the requirements and in compliance with local public safety requirements, to 

provide security for the area of operation.

14 C.F.R. § 45.23 (b). Marking ofthe Aircraft

Channel 2 seeks exemption from 14 C.F.R. 45.23, which discusses the display of marks. 

Specifically,

section 45.23 states, "(a) each operator of an aircraft must display on that aircraft marks 

consisting of the Roman capital letter "N" (denoting United States registration) followed 

by the registration number of the aircraft. Each suffix letter used in the marks displayed 

must also be a Roman capital letter (b) when marks include only the Roman capital letter 
"N" and the registration number is displayed on limited, restricted or light-sport category

aircraft or experimental or provisionally certificated aircraft, the operator must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters 

not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," 

"light- sport," "experimental," or "provisional," as applicable".

Channel 2 will need exemption from this regulation due to the small size of the aircraft 

and that there is no cabin, cockpit, or pilot station for the aircraft. The words 

"Experimental" has been placed on the fuselage in compliance with §45.29 (f) where the 

pilot, observer and others working with the sUAV will see the identification of the UAS 

as "Experimental." The FAA has issued the following exemptions to this regulation to 

Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command. OpenSky seeks exemption from 14 C.F.R. 61.113, which discusses private 

pilot privileges and limitations for the Pilot in command (PIC).

Channel 2 is seeking exemption from this regulation, because OpenSky believes that 

there is inconclusive evidence that a person with a private pilot certificate can 

successfully maneuver a sUAS without first hand flight experience with the particular 

sUAS. In fact, having a private pilot license does not automatically ensure competence at 

flying an sUAS in 3rct person view as required to properly operate an sUAS within the 

required line of sight. However, we believe that the PIC and our FOVO (Field Operation 

Visual Observer) must be able to understand and correctly interact with the general 

aviation community. Therefore, we believe our own flight training with the sUAS will be 

more than satisfactory. Our PIC and FOVO will be both certified in Ground School 

training to be able to properly interact with General Aviation protocols. They will also 

actively pursue a private pilot's license as well have the necessary medical qualifications.

14 C.F.R. 91.103- Preflight Actions

Channel 2 seeks exemption from 14 C.F.R. 91.103 which states that each pilot in 

command shall, before beginning a flight, become familiar with all available information 

concerning that flight. This information must include: (a) For a flight under IFR or a 

flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, 

alternatives available if the planned flight cannot be completed, and any known traffic 

delays of which the pilot in command has been advised by ATC; actions, including 

reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft 

performance data before starting a flight.

Channel 2 will be operating our sUAS in VFR. Our operations manual already includes 

preflight procedures directly pertaining to our sUAS which includes equipment checklist 

as well a preplanning details regarding weather conditions, review of any possible flight 
path of general aviation, our mission flight path and weather conditions amongst other 

parameters required to complete the mission.

14 C.F.R. 91.119- Minimum safe altitudes: General

Channel 2 seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe 

altitudes. As this exemption is for a sUAS that is a helicopter and the exemption requests 

authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated 

platform from which filming is planned, an exemption may be needed to allow such 

operations. As set forth herein, except for the limited conditions stated in the Manual, the 

UAS will never operate at higher than 400 AGL. It will however be operated in a 

restricted area with security perimeter, where buildings and people will not be exposed to 

operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS 

as well as the location where it is operated. No flight will be taken without the permission 

of the property owner or local officials. Because of the advance notice to the property

owner and participants in the filming activity, all affected individuals will be aware of the 

planned flight operations as set forth in the Manual. Compared to flight operations with 

aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and 

the lack of flammable fuel, any risk associated with these operations is far less than those 

presently presented with conventional aircraft operating at or below 500 AGL in the 

movie industry. In addition, the low-altitude operations of the sUAS will ensure 

separation between these small- UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 C.F.R. 91.121- Altimeter settings

Channel 2 seeks exemption from 14 C.F.R. 91.121, which discusses altimeter settings for 

lowest usable flight level.

C.F.R. 91121 states,

Current altimeter setting

29.92 (or higher) 29.91 through 29.42 29.41 through 28.92

28.91 through 28.42 28.41 through 27.92 27.91 through 27.42 27.41 through 26.92

Lowest usable flight level 180

185

190

195 200 205 210

_l
(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum 

flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet 

and add the appropriate n u m b e r o H e e t s p e c 1 " f 1 e d b e I o w , a c c o r d ' m g 

t o t h e c u r r e n t r e p o r t e d a I t 1. m e t e r s e t t m g : "

Current altimeter setting

29.92 (or higher) 29.91 through 29.42 29.41 through 28.92 28.91 through 28.42 28.41 

through 27.92 27.91 through 27.42 27.41 through 26.92

Adjustment factor None

500

1,000

1,500 2,000 2,500 3,000

Channel 2s UAS uses both GPS altitude and barometric sensors and relays that 

information to our ground station. However, this data is used help the sUAS to 

automatically maintain position hold at the required elevation and therefore this code is 

not pertinent the functionality of this sUAS.

14 C.F.R. 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) 

conditions

Channel 2 seeks exemption from 14 C.F.R. 91.151, which discusses fuel requirements 

for flight in VFR conditions. Specifically, 91.151 states "(a) No person may begin a flight 

in an airplane under VFR conditions unless (considering wind and forecast weather 

conditions) there is enough fuel to fly to the first point ofintended landing and, assuming 

normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) 

At night, to fly after that for at least 45 minutes. (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".

Channel 2 sUAS has a typical mission time ofless than 10 minutes with maximum flight 

time of 25 minutes. Since this amount less than the 30 minute reserve minimum, this 

reserve minimum would not even make sense in allowing the sUAS a chance to fly. 

According to OpenSky's aircraft flight manual, the PIC is instructed to maintain flight 

until battery power reaches 25%, or 1st level warning. At this level, landing procedures 

will be intiated. Once the sUAS reads 20%, 2nd level warning, the flight control system 

automatically take over and initiates safe landing sequence at the logged in takeoff point. 

Channel 2 policy outlined in our Flight Operations Manual achieves satisfactory safety

standards.
Channel 2 believes that an appropriate and current airworthiness certificate would not be 

necessary to fly a sUAS given the size of the aircraft and the necessary level of skill 

needed to operate the aircraft. Before putting in to service, each of our sUAS goes 

through our own airworthiness proceedures of miminum test flight and reliability checks. 

Also, our sUAS are recalibrated each at the site location before each flight to ensure that 

all systems functions as designed. OpenSky seeks exemption from this regulation because 

we believe this rule was not meant for a sUAS and operators.

14 C.F.R. 91.405, 91.407, 91.409, and 91.417

Channel 2 seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417, which 

discusses required aircraft maintenance, operation after maintenance, preventive 

maintenance, rebuilding, or alteration, inspections, and maintenance records. In Channel 

2 aircraft flight manual, maintenance and inspection procedures have been established for 

the aircraft. Channel 2 believes these regulations are meant for manned operated aircrafts 

and not unmanned systems, therefore making them unnecessary. Nevertheless, we seek 

an exemption from any such specific provisions to the extent FAA finds it necessary to 

grant this request.

(d) The reasons why granting Channel 2’s request would be in the public interest; that is, 

how it would

benefit the public as a whole.

Channel 2 is classified as an News organization and provides news worthy images to 

viewers. Channel 2‘s use of a sUAS can assist in making task safer and minimize human 

exposure to being at dangerous elevations. Channel 2‘s sUAS usage in the aerial 

Commercial and News gathering cinematography will also reduce the time required to 

captured the needed scenes as compared to convention helicopters or airplanes. 

Ultimately, the result is quick completion of task an reduction of dangerous elevation 

perspective needs.

(e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which Channel 2 seeks exemption Our Engineering department will provide a level of 

safety that exceeds the level of safety required by the FAA for its use on sUAS. The 

following are Channel 2‘s safety procedures, features, regulations, and operating 

specifications for our sUAS:

• The Pilot In Command (PIC) and Field Operations Visual Observer (FOVO) will 

be required to wear hard hats, safety vests, and safety glasses to protect the head 
and eyes from potential mishaps during given operational flights including training 

or testing of sUAS. 

• The flight area of the sUAS will be observed for best take off and landing 

locations. Desired conditions include: flat and level surfaces clear of debris, at 

least 15ft from power lines and structures, and a minimum distance of 12ft from 

the PIC and observers. 

• The sUAS will also be in the Visual Line of Sight (VLOS) to both the PIC and 

FOVO during all flights. 

• Flights must take place during good weather conditions with no rain, low laying 

clouds, or heavy winds. All flights will take place during daylight hours with no 

evening or late night flights. 

• The PIC(s) of the sUAS will at least have 12 training hours or 24 flights accrued 

before being designated working flights. 

• All batteries must be charged completely before each flight and each flight must 

end when the battery has a 30% power level remaining. 

• A visual safety inspection will occur before each flight, testing propeller tightness, 

security mount of camera/detection equipment, remote range test, and proper 

safety equipment is adorned to PIC and FOVO. 

• The sUAS will be flown under a height of 500 ft AGL. 

• No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity

during a critical 

phase of flight so as to ensure that the sUAS is in a condition for safe flight 

operation and in a 

configuration appropriate for the purpose ofthe intended flight. 

• If there is more than just an operator at a site during a flight, the PIC operator and 

observer 

or FOVO will maintain two-way communication with each other during all 

operations; if unable to maintain two-way communications, or if any condition 

occurs that may otherwise cause the operation to be unsafe, the operator will 

immediately conclude the operation. 

• If the communication link is lost, the sUAS will go into fail-safe mode and safely

descend to its designated home-point location. If the communication link is 

reconnected during fail-safe mode, control ofthe sUAS can be regained before 

landing occurs at the home-point location. 
• There is no fuel or payload to the sUAS, therefore there will be no potential 

explosives or risk of explosion if a crash occurs with the sUAS. 

• The sUAS will feature a built in compass that will be recalibrated at every site to 

maintain accurate directional readings. The compass will also help in keeping the 

sUAS stable during 

flights.

• The sUAS will record GPS location data once Ready to Fly status has been 

obtained. A 

minimum of 6 satellites will activate the Ready to Fly status. 

• The weight of the sUAS is less than 20 lbs. 

• The aircrafts vertical and horizontal aspect concerning hovering accuracy is less 

than 0.5m 

and 1.5m respectfully. With a maximum wind resistance of 18mph. 

• The typical aircraft wheelbase will be less than 1OOOmm in length. 

• The aircraft runs off a Li-Po battery.

(f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The 

rule from which you seek the exemption; and (2) A brief description of the nature 

of the exemption you seek 

Petitioner:KPRC CHANNEL 2 News A GRAHAM MEDIA GROUP, LLC. 

Sections of 14 C.F.R. Affected: 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 

91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 

91.409; and 91.417 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 

C.F.R. 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 

91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 to 

Cinematographic filming subject to operating procedures that meet or exceed 

those that FAA requires. 

(g) Any additional information, views or arguments available to support your 

request Please see the introduction to this exemption request. 

(h) If you want to exercise the privileges of your exemption outside of the United 

States, the reason why you need to do so 

The Operations described in this exemption request will be conducted wholly

within the United States. 

Attached hereto, and submitted as a confidential document, is our Field 

Operations Manual. We respectfully submit that good cause exists so that this 

confidential manual does not need to be published in the Federal Register. 
Please do not hesitate to contact me via email at rgrant@kprc.com if you have any

questions