Before the

FEDERAL AVIATION ADMINISTRATION

Washington, DC 20591

In the Matter of 

Bonneville International Corporation

d/b/a KSL Broadcast Group

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Docket No. __

BONNEVILLE INTERNATIONAL CORPORATION 

D/B/A KSL BROADCAST GROUP

PETITION FOR EXEMPTION

SUMMARY GRANT REQUESTED

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”) 

and 14 C.F.R. Part 11, Bonneville International Corporation d/b/a KSL Broadcast Group

(“KSL”) respectfully requests an exemption from the Federal Aviation Administration (“FAA”) 

regulations detailed in Section III to permit commercial aerial data collection1 using unmanned 

aircraft systems (“UAS”) to support newsgathering.

The FAA may grant exemptions to allow commercial UAS operations so long as 

operations are conducted under the conditions necessary to meet the requirements of Section 

333. The FAA recently used this authority to authorize UAS use for newsgathering, the same 

relief requested herein, pursuant to summary grant procedures.

2

 KSL respectfully requests a 

similar summary grant, under conditions outlined herein, for the reasons set forth below.

KSL seeks authority to use the DJI Inspire 1, DJI Phantom 2, and DJI Phantom 3 

Advanced, all of which have been previously approved by the FAA in past grants of exemptions,

for newsgathering.

3

 This exemption petition is accompanied by the relevant manufacturer user 

manuals, safety guidelines, and pre-flight checklists which KSL intends to utilize.

 1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the 

unmanned aircraft. Examples include imagery (photography, video, infrared, etc.), electronic 

measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, 

etc.), or any other gathering of data by instruments aboard the craft.

2 See Exemption No. 12901, Cox Media Group LLC, Docket No. FAA-2015-2672 (Sept. 17, 2015)

(“CMG Exemption”); Exemption No. 12174, Cable News Network, Inc., Docket No. FAA-2015-1851 

(July 27, 2015); Exemption No. 13286, KFI AM 640, Docket No. FAA-2015-3283 (Oct. 22, 2015).

3 See, e.g., CMG Exemption (authorizing use of DJI Inspire 1, DJI Phantom 2, and DJI Phantom 3 

Advanced for newsgathering); Exemption No. 13663, Sky Aerial Drones, LLC, Docket No. FAA-2015-

3723 (Nov. 17, 2015) (authorizing use of DJI Inspire 1 and DJI Phantom 2 for newsgathering); 

Exemption No. 13375, Ronal Brian Emfinger, Docket No. FAA-2015-3402 (Oct. 27, 2015) (authorizing 

use of DJI Inspire 1 and DJI Phantom 2 for newsgathering).
2

The contact information for the applicant is:

Michael L. Dowdle

Senior Vice President of Business Affairs, and General Counsel

Bonneville International Corporation d/b/a KSL Broadcast Group

55 North 300 West

Second Floor

Salt Lake City, UT 84101

Tel: 801-575-5555

I. KSL’s Proposed Operations

KSL seeks nationwide authority to use UAS previously authorized by the FAA, 

specifically the DJI Inspire 1, DJI Phantom 2, and DJI Phantom 3 Advanced,

4 under previously 

granted conditions and limitations for newsgathering.5

Each UAS Pilot in Command (“PIC”), acting as an employee or agent of KSL for its 

UAS operations, will have at minimum a private, recreational, or sport certificate from the FAA 

and a valid driver’s license (or appropriate medical certificate).

6 All KSL UAS operations will 

be conducted with a team composed of at least one PIC and one Visual Observer (“VO”), 

“provid[ing] an additional level of operational safety.”7 During operations, this team will be 

equipped with checklists and operations and maintenance manuals.

II. An Exemption Will Advance the Public Interest

KSL’s proposed UAS operations are in the public interest and would not adversely affect

public safety or national security. Since KSL started broadcasting on June 1, 1949 as Utah’s first 

commercial television station, it has developed a reputation as the market’s television technology 

leader, producing the first color television broadcast in 1964 and Utah’s first High-Definition 

newscast in 2008. KSL seeks to uphold this reputation by deploying UAS technology to 

continue to provide accurate news coverage.8

KSL intends to use UAS technology to gather news to provide its viewers with enhanced 

and compelling content. In addition to covering newsworthy events and stories, KSL will use 

 4 Id.

5 See note 2.

6 See “FAA Summary Grants Speed UAS Exemptions,” available at

https://www.faa.gov/news/updates/?newsId=82485; Blanket COA, available at http://uavus.org/wpcontent/uploads/2015/10/Section_333_Blanket_200_COA_Effective_7-1-2015.pdf. 

7 Exemption No. 11213, Aeryon Labs, Inc., Docket No. FAA-2014-0642, at 3 (Mar. 24, 2015).

8 Bonneville International Corporation (“Bonneville”) was formed in 1964. Bonneville has continued and 

expanded KSL’s commitment to serving the local community. Bonneville’s corporate lifestyle of caring 

has helped them contribute millions in airtime, leveraging the power and trust inherent in broadcasting to 

become purposefully involved in making the communities served by its 15 radio stations and KSL-TV

even better places to live.
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UAS to gather and disseminate crucial information during emergencies. A grant of authorization 

to conduct UAS operations will enhance KSL’s ability to gather and deliver important news to 

the people of Salt Lake City, keeping them connected, safe, and informed.

The FAA has previously granted requests to operate UAS for newsgathering.9 KSL

believes that, like in past decisions, “the enhanced safety achieved using an unmanned aircraft 

(UA) with the specifications described by the petitioner [seeking ‘to conduct aerial photography, 

videography, and cinematography to support newsgathering’] and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition 

to flammable fuel, gives the FAA good cause to find that the UAS operation ... is in the public 

interest.”10

In the past, KSL had to rely on using planes and helicopters to get an aerial vantage point 

for a news story. UAS would supplement these larger manned aircraft, allowing the news event 

to dictate the appropriate tool, thereby reducing noise and air pollution, and even more 

importantly, reducing the potential risk to life and property associated with flying manned 

aircraft. UAS use would enable KSL’s news team to gather and deliver an unparalleled level of 

news and information, and do so more quickly and safely than ever before. For example, UAS 

use would enable KSL’s news team to collect information and imagery at a breaking news scene 

that a reporter on the ground or helicopter in the air could not otherwise obtain due to hazards,

obstructions, or other safety or logistical issues. The public interest weighs heavily in favor of 

granting an exemption for aerial photography and videography for newsgathering to KSL.

III. The Extent of Relief KSL Seeks and the Reason It Seeks Such Relief

A. The FAA Possesses the Statutory Authority to Grant This Exemption

The FAA has general authority to grant exemptions from FAA safety regulations and 

minimum standards after determining that such exemptions are in the public interest.11 

Moreover, the FAA may grant the regulatory relief KSL seeks under Section 333 of the FMRA 

and Part 11 of the FAA’s rules. Under Section 333, the FAA may allow “certain unmanned 

aircraft systems” to “operate safely in the national airspace system before completion” of the 

rulemaking to allow UAS generally into the national airspace system.

12 To date, the FAA has 

granted thousands of exemptions pursuant to its Section 333 authority.

B. Granting Relief From Certain Regulations Will Not Adversely Affect Public Safety

KSL specifically requests exemption from the following regulations to the extent 

necessary to permit KSL to operate UAS for aerial data collection: 14 C.F.R. §§ 61.23(a) and 

(c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 

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

 9 See note 2.

10 CMG Exemption at 1-2.

11 49 U.S.C. § 40109(b).

12 FMRA § 333, 126 Stat. 11, 75 (2012).
4

As a general matter, KSL’s operations will provide an equivalent level of safety when 

compared to manned aircraft operations. Unlike a manned aircraft, the proposed UAS is 

lightweight, has no flammable fuel or other lubricants, operates at slower speeds, and stays well 

below any conflicting air traffic. Further, all activities will be closely monitored by a team of 

professionals. The team will employ flight manual and maintenance manual procedures, and 

analytical risk management, thereby providing an equivalent level of safety. KSL will not 

operate UAS for the purposes of closed-set filming.

KSL will achieve an equivalent level of safety with the waived rules by operating 

according to the following parameters:

1. KSL will only operate the DJI Inspire 1, DJI Phantom 2, and DJI Phantom 3 

Advanced pursuant to the exemption and any associated Certifications of Waiver 

or Authorization (“COAs”).

2. The UAS will be operated at a speed no greater than 87 knots. In no case will the 

UAS be operated at airspeeds greater than the maximum UAS operating airspeed 

recommended by the aircraft manufacturer.

3. The UAS will be operated within visual line of sight (“VLOS”) of the PIC or VO, 

at an altitude no greater than 400 feet above ground level.

4. All operations will utilize a VO. The PIC and VO will be able to communicate 

verbally at all times.

5. KSL’s operating documents will be made accessible during UAS operations and 

made available to the Administrator upon request.

6. Any UAS that undergoes maintenance or alterations that affect the UAS operation 

or flight characteristics, will undergo a functional test flight prior to conducting 

further operations, in such a manner so as to not pose an undue hazard to persons 

and property.

7. KSL will ensure the any UAS operated undergo sufficient maintenance and 

inspection to guarantee the UAS is in a condition for safe operation. KSL will 

follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, 

and life limit requirements for the aircraft and aircraft components. Each UAS 

operated under this exemption will comply with all manufacturer safety bulletins.

8. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. If the UAS is not in a condition for safe 

flight, KSL will not operate the UAS until maintenance or other measures have 

been taken to ensure that the UAS is in a condition for safe flight.

9. The PIC will hold, at minimum, a private, recreational, or sport pilot certificate. 

The PIC will begin conducting operations only after demonstrating the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 
5

under the 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 C.F.R. § 61.51(b).

10. The UAS will not be operated during night, as defined in 14 C.F.R. § 1.1. In 

addition to conducting operations under visual meteorological conditions, the 

UAS will be operated at no less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than three statute miles.

11. The UAS will not operate within five nautical miles of an airport reference point 

(“ARP”) as denoted in the current FAA Airport/Facility Directory 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 COA issued to 

KSL.

12. The PIC will not begin a flight unless there is enough power to conduct the 

intended operation and to operate after that for at least five minutes or with the 

reserve power recommended by the manufacturer. The UAS will return to a predetermined location in a lost-link scenario.

13. KSL will register and mark its UAS in accordance with 14 C.F.R. parts 45 and 47. 

The UAS markings will be as large as practicable.

14. The UAS will remain clear and yield to manned aircraft at all times. 

15. The PIC will conduct operations so as to avoid flying near or over 

nonparticipating persons. The PIC will abort operations in the event of 

unpredicted obstacles or emergencies.

16. KSL will report accidents to the FAA’s UAS Integration Office within 24 hours 

and the National Transportation Safety Board per its instructions.

Finally, as the proposed UAS is less than 55 lbs. when outfitted with all equipment, and 

there are no flammable liquids or other hazardous materials that would propose a danger to the 

public, no threat to national security exists.

IV. Summary for Publication in the Federal Register

Pursuant to 14 C.F.R. § 11.81, the following summary may be published in the Federal 

Register:

Petitioner seeks relief from the following rules: 14 C.F.R. §§ 61.23(a) and (c), 

61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b).
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Bonneville International Corporation d/b/a KSL Broadcast Group (“KSL”) requests an 

exemption from the above rules to undertake aerial data collection using unmanned aircraft 

systems (“UAS”) to support newsgathering. These operations will use highly dependable, multiredundant UAS subject to tight controls, risk management, and best practice mitigation strategies 

to ensure public safety. KSL will operate under the conditions and limitations that are 

substantially similar to those that the FAA requires for comparable operations, excluding closed 

set filming. The operations, including the attendant extensive safety measures, will provide a 

satisfactory level of safety to the public. Finally, because KSL’s petition for exemption is 

similar in all material respects to Section 333 petitions the FAA has already granted, KSL 

requests a summary grant.

V. Conclusion

For the reasons set forth above, the FAA should grant the requested exemption in full to

permit KSL to conduct newsgathering via UAS.

Respectfully submitted,

BONNEVILLE INTERNATIONAL 

CORPORATION D/B/A KSL 

BROADCAST GROUP

By: /s/ Michael L. Dowdle

Michael L. Dowdle

Senior Vice President of Business Affairs,

and General Counsel

55 North 300 West

Second Floor

Salt Lake City, UT 84101

Tel: 801-575-5555

December 30, 2015

Enclosure:

• Manufacturer User Manuals, Safety Guidelines, and Pre-Flight Checklist Links
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User Manuals, Safety Guidelines, and Pre-Flight Checklists

The listed user manuals, safety guidelines, and pre-flight checklists are incorporated by reference 

and available at the links provided below.

• DJI Inspire 1 

o User Manual V2.0: 

https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_en_v2.0_1218

.pdf

o Safety Guidelines V1.2: 

http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_Safety_Guidelines_and_Discl

aimer_v1.2_en.pdf

o Pre-flight checklist: 

https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_en_v2.0_1218

.pdf#page=50

• DJI Phantom 2 

o User Manual V1.4: 

http://dl.djicdn.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.

pdf

o Smart Battery Flight Safety Guidelines: 

http://dl.djicdn.com/downloads/phantom_2_vision_plus/Smart_Flight_Battery_Safety

_Guidelines.pdf

o For DJI Phantom 2, KSL will use a pre-flight manual akin to the one found at: 

https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_en_v2.0_1218

.pdf#page=50

• DJI Phantom 3 Advanced 

o User Manual V1.6: 

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual

__V1.6.pdf

o Safety Guidelines V1.2: 

http://dl.djicdn.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en_201

509.pdf

o Pre-flight checklist: 

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual

__V1.6.pdf#page=44