# Holland & 

# Knight
800 17th Street, NW, S uite 11 00 

### I Washington, DC 20006 

### I T 202 .955 .3000 

### I F 202 .955.5564 H olland & Knight LLP 

### I www. h klaw.com Gary L. Halbert 202.469.5150 gary. halbert@hklaw
. com Charles D . Tobin 202.419 .2539 chartes .tobin@hklaw
. com Jenn ifer M . Nowak 202 .419 .2451 jennifer
. nowak@hklaw
.com January 14 , 2016 Via www.regulations.com U . S. Department of Transportation Docket Management System 1200 New Jersey Ave ., SE Washington, DC 20590 Re: Fus ion Media Network, LLC Petition for Summary Grant of Exemption Pursuant to 14 C.F
. R. Part 11 and Section 333 ofthe FAA Modernization and Reform Act of2012 Dear Sir or Madam: Fusion Media Network, LLC {hereinafter "Fusion"), hereby applies for an exemption from certain Federal Aviation Regulations (FARs) , listed below, to allow for the operation of small unmanned aircraft systems (s UAS) to conduct commercial flights for aerial photography and filming , includ i ng closed set f ilming , under the cond itions outlined herein or as may be established by the FAA. 1 As set forth below, the operations for which this exemption is sought would be carried out i n accordance with the conditions the FAA has placed on holders of similar exemptions . As such, we request summary approval of this petition for exempt ion pursuant to FAA' s summary grant policy, announced on April 9 , 2015 .2 Fusion Media Network, LLC (" Fusion ") , a joint venture between Disney/ABC News and Univisio n Communications , is a news and information media network that serves a young , diverse , and i nclusive m illennia! generation across its cable television and digital platforms. Reporting news and i nformation is Fusion 's core business and Fusion has a special focus on producing English-language news and information content for U.S
. Hispanic millennials . Fus ion 's cable television network is carried by DirecTV, Dish, Cablevis ion , Charter, Cox, AT & T Uverse , Verizon FiOS and Google Fiber as well as over-the-top {OTT) providers like Apple TV, Roku , and Sl i ng TV.

1 See Section 333 of the FAA Modern ization and Reform Act of 2012 (Reform Act), P . L. 112-95 (2012); 

### see also 14 C.F
. R. Part 11 . 2 See FAA Press Release , http :// www.faa.gov/news/updates/?news ld =82485.
Anchorage 1Atlanta 1Austin 1 Boston 1 Chicago I Dallas 1 De nver I Fort lauderdale I Jacksonville I lakeland I los Angeles I Miam i New York 1 Northern Virg ini a 1 Orlando 1 Portland 1 San Francisco 1Tallahassee I Tampa I Wash i ngton, D .C
. I West Palm Beach

### January 14, 2016 Page2 Fusion would operate the sUAS to conduct aerial newsgathering and reporting. Operating sUAS will allow Fusion to capture aerial footage from lower altitudes than possible from traditional helicopters, providing a unique perspective for reporting . Additionally, where helicopters may not be available or cost-effective, the use of sUAS will allow for aerial coverage of a greater range of newsworthy events . Further, operation of the sUAS will be safer than ope rating traditional helicopters, both for those operating the aircraft, and for people on th e ground . The sUAS operates on battery power rather than carrying combustible fuel and its limited size and weight significantly reduce the potentia l for harm to participating and nonparticipating individuals or property in the event of an accident. The increased level of safety associated with the use of sUAS , and the benefits from i ncreased public awareness of newsworthy events are decidedly in the public interest. Because the FAA has granted numerous exemptions to sUAS operators for the purposes of aerial data collection and closed set filming similar in all material respects to the relief requested here, 3 and Fusion agrees to comply w ith the limitations and conditions placed on those exemptions , this application sets no new precedents and meets the FAA's criteria for summary grant of an exemption . Therefore , Fusion respectfully requests that the FAA waive the 120-day requ irement set out in 14 C
. F. R. 

### § 11.63(d) and further expedite the approval of this application on a summary grant basis . Request for Exemption Petitioner contact information : Roberto Daza Producer Fusion Media Network, LLC Phone. 650.270.6664; Email: Roberto .daza@fusion .net Fusion seeks exemption for the uses described herein from the followi ng regulations : 14 CFR 

### § 61 .23(a) and (c) 14 CFR 

### § 61 . 101(e)(4 ) and (5) 14 CFR 

### § 61 . 113(a) 14 CFR 

### § 61.315(a) 14 CFR 

### § 91 .7(a) 14 CFR 

### § 91.119(c) 14 CFR 

### § 91.121 14 CFR 

### § 91.151(a)(1) 14 CFR 

### § 91.405(a) 14 CFR 

### § 91.407(a)(1) 14 C FR 

### § 91.409(a)(1) and (2) 14 CFR 

### § 91.417(a) and (b)

3 See, e.g., Exemption Nos. 11062, 11109, 11112 , 11213 , and 12645

### January 14, 2016 Page 3 Exemption Authority under Section 333 of the Reform Act Section 333 of the Reform Act directs the Secretary of Transportation , prior to a rulemaking in accordance with Section 322 , to "determine if certain unmanned aircraft systems may operate safely in the national airspace system" (NAS)
.4 At a minimum , this determination includes: (1) which types of unmanned aircraft systems, if any , as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization , or airworthiness certification under section 44704 of title 49 , United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1 ). 5 "If the Secretary determines ... that certain unmanned aircraft systems 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. "6 Specifically , Section 333 ofthe Reform Act permits the FAA to provide exemptions regarding airworthiness certification under 49 U.S
. C
. 

### §§ 44704 and 44711. The small size ofthe sUAS to be employed by Fusion, the restricted environment in which they will operate, the conditions placed on such operations by the FAA, and the adherence to Fusion's sUAS Operations Manual (Operations Manual) , Closed Set Filming Operations Manual (Closed Set Manual) , 7 and the manufacturers' User Manual ensure that the operations under the requested exemption will be conducted safely within the national airspace system and will provide an equivalent level of safety
. Description of Proposed sUAS Operations Fusion proposes to operate DJI Inspire 1. FAA has previously determined that a grant of exemption is appropriate for this model due to its size , weight, speed and operational capability. 8 Detailed specifications regard ing design and operational characteristics of the sUAS , including performance and performance limitations , operating procedures, and aircraft loading information, are provided in the manufacturers ' User Manual. 9 The sUAS Fusion proposes to operate is a small rotorcraft weighing less than 55 lbs that will be operated at a maximum speed of 43 knots and has the capability to hover, and move in the vertical and horizontal planes simultaneously . Communication with the sUAS will occur in the

4 Reform Act§ 333(a)
. 5 Reform Act§ 333(b)
. 6 Reform Act§ 333(c)
. 7 The Operations Manual and Closed Set Manual will be provided under separate cover as confidential commercial and proprietary material pursuant to 14 C
. F . R. § 11 .35(b)
. 8 See, e.g., Exemption No. 11954 , Exemption No. 12322 , and Exemption No. 12712 . 9 The User Manual for the OJI Inspire 1 can be found at https://dl.djicdn.com/downloads/inspire 1/en/lnspire 1 User Manual en v2 .0 1218 . pdf
.

### January 14, 2016 Page4 2.4 to 2.483 GHz spectrum and the 5 .728 to 5.850 GHz spectrum , i n compliance with Federal Communications Commission (FCC ) requ i rements . Inspection , maintenance , repair and preflight safety risk assessment of the sUAS will be performed in accordance with the Operations Manual and the Manufacturer User Manua l and subject to the conditions and l imitati ons provided below. Maximum total flight time wi ll be 18 m i nutes, and the Pilot i n Command (PIC) will require return of the a i rcraft w ith five minutes battery reserve t ime, or w ith the amount of reserve power recommended by the manufacturer, if greater. The sUAS is equ ipped with auto safe return , as described in the User Manual. The PIC will conduct a pre- flight i nspection and determine that the sUAS is in a condition for safe fl ight. The pre-flight inspection will account for all potentia l discrepancies, e.g. , inoperable components , items , or equ ipment. Fusion will follow the sUAS manufacturers ' maintenance , overhaul , replacement , i nspection , and l ife limit requ irements for the aircraft and aircraft components , as well as comply w ith all manufacturer safety bulletins . The sUAS will be operated by at least two people at all t i mes : the PIC and a visual observer (VO)
. The PIC will hold an air transport , commercia l, private , recreational or sport pilot certificate , in addition to an ai rman med ical certificate or a valid United States driver's license . Pilots will be trained and have add itional experience in the operation of unmanned aircraft operations, as described in more detail in the Operations Manual. The PIC and VO will communicate verbally and in close proxi mity without the use of enhanced communication such as radios , telephones or texting . Conditions and Limitations In addition to the terms ofthe Operations Manual , which may overlap with the terms below, Fusion ("the Operator'') specifi cally proposes that if the exemption is granted , the sUAS , and Fusion 's operation of the s UAS , will conform to the following conditions and limitations, wh ich FAA has attached to its previous grants of exemptions , and which will ensure an equivalent or higher leve l of safety
. 1 . Operations will be limited to the OJ I Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other ai rcraft w i ll require a new or amended exemption . 2 . Operations for the purpose of closed-set motion picture and television fil ming are permitted . 3 . The UA may not be operated at a speed exceeding 87 knots ( 100 miles per hour)
. The exemption holder may use either groundspeed or cal ibrated airspeed to determine compliance with the 87 knot speed restriction . In no case w i ll the UA be operated at airspeeds greater than the maxi mum UA operating airspeed recommended by the aircraft manufacturer
. 4 . The UA must be operated at an altitude of no more than 400 feet above ground level (AGL)
. Altitude must be reported in feet AGL.

### January 14 , 2016 Page 5 5 . The UA must be operated within visual line of sight (VLOS) of the PIC at all times . This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC 's FAA-issued 

### airman medical certificate or U . S
. driver's license . 6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all ti mes. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ; electronic messaging or texting is not permitted during flight operations . The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties requ i red of the VO
. 7. Th is exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents . The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the condit ions and limitations in this exemption and the procedures outl i ned in the operating documents , the cond itions and limitations herein take precedence and must be followed
. Otherwise , the Operator must follow the procedures as outlined in its operating documents . The Operator may update or revise its operating documents . It is the Operator's responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The Operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption . If the Operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the Operator must petition for an amendment to its grant of exemption . The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revis ions to the operating documents. 8 . Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics , e .g ., replaceme nt of a flight critical component, must undergo a functional test flight priorto conducting further operations under th is exemption . Functional test flights may only be conducted by a PIC w ith a VO and must remain at least 500 feet from other people . The functional test f light must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9 . The Operator is responsible for ma i ntaining and inspecting the UAS to ensure that it is in a condition for safe operat ion . 10. Prior to each flight , the PIC must conduct a pre- flight inspection and determine the UAS is in a condition for safe flight. The pre-fl ight inspection must account for all potential discrepancies , e .g. , inoperable components , items , or equipment. Ifthe inspection reveals a condition that affects the safe operation of the UAS , the a i rcraft is proh ibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

### January 14, 2016 Page 6 11 . The Operato r must follow the UAS manufacturer's mai ntenance, overhaul , replacement , inspection , and life limit requ i rements for the ai rcraft and aircraft components . 12 . Each UAS operated under this exempt ion must comply with all manufacturer safety bulletins . 13. Under this grant of exemption , a PIC must ho ld either an airli ne transport, commercial , private , recreationa l , or sport p il ot certificate
. The PIC must also hold a current FAA airman med ical 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 i n 14 CFR 

### § 61 .56 in an aircraft in wh ich the PIC is rated on his or her pilot certificate
. 14. The Operator may not perm it 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 this exemption , including evasive and emergency maneuvers and maintaining appropriate distances from persons , vessels , vehicles and structures . PIC qualification flight hours and currency must be logged i n a manner cons istent w ith 14 CFR 

### § 61 .51 (b)
. Flights for the purposes of training the Operator's PIGs and VOs (training , proficiency , and experiencebuilding ) and determ i ning the PIC 's ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are perm itted under the terms of this exemption . However, training operations may only be conducted during dedicated train i ng sessions. During train i ng , proficiency , and experience-building flights , all persons not essenti al for flight operations are considered nonparticipants , and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91 . 119 . 15 . UAS operations may not be conducted duri ng night , as defined in 14 CFR 

### § 1 . 1 . All operations must be conducted under visual meteorological conditions (VMC)
. Flights under special vi sual flight ru les (SVFR) are not authorized . 16 . The UA may not operate within 5 nautical miles of an airport reference po i nt (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP , the center of the ai rport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport's management is obtained or otherwi se permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made ava ilab le to the Admin istrator or any law enforcement official upon request. 17. The UA may not be operated less than 500 feet below or less than 2 ,000 feet horizontally from a cloud or when visi bi lity is less than 3 statute m i les from the PIC
. 18. If the UAS loses communications or loses its GPS s igna l, the UA must return to a predetermined location with i n the private or controlled-access property . 19 . The PIC must abort the flight in the event of unpred icted obstacles or emergencies .

### January 14, 2016 Page 7 20. The PIC is prohibited from beginning 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 minutes or with the reserve power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance w ith an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the blanket COA. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registe red in accordance with 14 CFR part 47 , and have identificatio n (N-Number) markings in accordance with 14 CFR part 45 , Subpart C. Markings must be as large as practicable. · 23 . Documents used by the Operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR 

### §§ 91 . 9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made ava i lable to the Administrator or any law enforcement official upon request. 24. The UA must rema in clear and give way to all manned aviation operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving device or vehicle . 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons , vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonpart icipating persons from the UA and/or debris i n the event of an accident. The Operator must 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, f light operations must cease immediately in a manner ensuring the safety of nonpart icipating persons; 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 persons are not considered nonparticipating persons under this exemption . 27 . All operations shall be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted .January 14, 2016 Page 

### 8 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours . Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www. ntsb.gov . If this exemption permits operations for the purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply. 29 . The Operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption. 30. At least 3 days before aerial filming , the Operator of the UAS affected by this exemption must submit a written Plan ofActivities to the local Flight Standards District Office (FSDO) with jurisd iction over the area of proposed filming
. The 3-day notification may be waived with the concurrence ofthe FSDO
. The plan of activities must include at least the following : a . Dates and times for all flights ; b . Name and phone number of the Operator for the UAS aerial filming conducted under th is grant of exemption ; c. Name and phone number of the person responsible for the on-scene operation of the UAS ; d. Make , model , and serial or N-Number of UAS to be used ; e. Name and certificate number of UAS PICs i nvolved in the aerial filming ; f. A statement that the Operator has obtained permission from property owners and/or local officials to conduct the filming production event ; the list of those who gave perm iss ion must be made avail ab le to the inspector upon request ; g . Signature of exemption holder or representative; and h . A description of the flight activity , i ncl uding maps or diagrams of any area, city, town , county , and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. 31 . Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder's MPTOM
. Unless otherwise specified i n this grant of exemption , the UAS , the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to , parts 45 , 47 , 61 , and 91 . Safety and Public Interest The sUAS will be operated safe ly to insure that the sUAS will "not create a hazard to users of the national airspace system or the public ." 10 The sUAS will be operated in accordance with the Operations Manual , Closed Set Manual and the Manufacturers ' User Manual, and subject to the conditions and lim itations provided above .

10 Reform Act§ 333 (b)
.

### January 14 , 2016 Page 9 Fusion reports news and i nformation on topi cs of public interest. Its editorial team covers social and political issues such as immigrat ion , the crim i na l justice system , police practices, sex trafficking , drug use , and the environment. sUASs can enhance its coverage by allowing Fusion to record breaking news events in ways that are currently cost- prohibitive , such as taking overhead landscape imagery of a disaster zone or footage that sets scenes or establishes characters for a long-form news package or documentary. Granting Fusion an exemption to operate sUAS for newsgathering efforts is clearly i n the public interest , as it provides a safer and more cost-effective method for capturing aerial news footage
. Expanded newsgathering through sUAS operated i n a safe manner and in a controlled environment is completely consistent with Congress's recognition of the tremendous public benefit that can be ga i ned by allowi ng for the use of th is i n novative and sophisticated technology, which is why Congress d i rected to the FAA '1o safe ly acce lerate the integration of civil unmanned aircraft systems in the national ai rspace systems ." Consistent with this Congressional directive , the limited sUAS operations proposed here will enhance the safety of Fusion 's newsgathering operations , while allowing Fusion to provide a un ique aerial perspective for audiences on matters of interest to the public. Carefully managed sUAS operati ons will be far more cost-effective and far safer, both to operators and people and property on the ground , than the typical helicopter flight coverage used i n the past to cover newsworthy events . As in previous decis ions , "[t]he enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the pet itioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions , carryi ng crew in addition to flammable fuel , gives the FAA good cause to f i nd that the sUAS operation enabled by this exemption is in the public interest." 11 Addit ionally, increased f lexibility for filming due to the portability and affordability of sUAS will allow more t i me ly and cost-effective news coverage, includ i ng coverage in smaller viewing areas where aerial coverage is not currently available . Increased coverage of newsworthy events benefits the public and enhances public safety. Furthermore , Fusion is a member of the media coal ition working w ith researchers as part of the Mid-Atlantic Aviation Partnership to study the safe operation of drones by journalists for newsgathering, and has participated in the simulated exercises , authorized by the FAA, to develop best practices for drone video data collection. Specific Request for Exemption Fusion requests an exemption from the followi ng prov isions of the Federal Aviation Regulations for purposes of conducting the proposed operations : 14 CFR 

### § 61 .23(a) and (c) (Medical Certificates : Requirements and duration) Cons istent with the FAA's summary grant policy 12 and previous exemptions issued by the FAA, Fusion requests an exemption from the requ i rement for pilots to hold a medical certificate for certain operat ions . All PICs and VOs wi ll hold at least a valid U .S
. driver's license , which will provide an equiva lent level of safety when operating under the conditions and li mitations listed above . 1 1 See, e. g. , Exemption No. 1 1062 , at 22 . 12 Supra , n . 2 .

### January 14, 2016 Page 10

14 CFR 

### § 61 . 101(e){4) and (5) (Recreational pilot privileges and limitations); 14 CFR 

### § 61.113(a) (Private pilot privileges and lim itations: Pilot in Command); 1 4 CFR 

### § 61.315(a) {What are the privileges and limitations of my sport pilot certificate?) Fusion requests exemption from these provisions prohibiting pilots holding private , recreational or sport certificates from carrying passengers o r property for compensation or hire . FAA previously has found that holders of private , recreational and sport pilot licenses are capable of operating sUAS in a safe manner that does not adversely affect safety
. 13 Fusion 's operators will operate in strict accordance with the conditions and limitations imposed by the FAA, as well as Fusion's Operations Manual and Closed Set Manual , ens uring at least an equivalent level of safety
. 14 CFR 

### § 91 .7(a) (Civil aircraft airworth i ness) As the sUAS operated by Fusion will not have a irworth i ness certificates , Fusion requests an exemption from this requirement. FAA previously has determined that "fo r the purposes ofthis exemption , the pilot may determine the aircraft is in an airworthy condition prior to flight. " Fusion 's Operations Manual contains procedures which allow the PIC to determ i ne that the aircraft is a i rworthy, thus providing an equivalent level of safety. 14 CFR 

### § 91.119 (M inimum safe altitudes: general) Fusion requests an exemption from the minimum safe altitude requirements in 14 C.F
. R. 

### § 91 . 119 , as the operations will take place below 400 feet AGL. An equivalent level of safety will be achieved due to the size , weight and speed of the sUAS , and the strict operating conditions under which the sUAS will be operating , includi ng performance of emergency landings and prohibiting operations over congested areas . 14 CFR 

### § 91.121 (Altimeter settings) Fusion requests an exemption from the altimeter settings requirement in 14 C
. F.R. 

### § 91.121 because the sUAS may not have a barometric altimeter. The FAA has determ ined that an equivalent level of safety may be achieved in ci rcumstances where the sUAS will be operated 400 feet AGL or below, within visual line of sight, where GPS based altitude information is relayed in real time to the operator at a ground-based on-screen display , and a zero altitude initiation point is estab lished for the PIC to confirm accuracy of the on board GPS prior to the flight. 14 14 CFR § 91 . 151(a)(1) (Fuel requirements for flight in VFR conditions) Given the short mission life of the batteries powering the sUAS proposed for operations , Fusion requests an exemption from the 20-minute reserve requ i rement. The FAA previously has found an equivalent level of safety when operating a sUAS with a five-minute reserve

13 See, e. g., Exemption No . 11213 . 1 4 See, e.g., Exemption No . 11062 .

### January 14, 2016 Page 11 requirement. 15 Fusion's Operations Manual imposes this same requ irement, and Fusion therefore requests this same grant of exemption . 14 CFR 

### § 91.405(a) (Maintenance required) ; 14 CFR § 91.407(a)(1) (Operation after maintenance. preventative maintenance . rebuilding, or alteration) ; 14 C FR 

### § 91.409(a)(1) and (2) ( Inspections); 14 CFR 

### § 91.417(a) and (b) {Maintenance records) As Fusion's sUAS w ill not have an airworthiness certificate , Fusion requests exemption from the maintenance requirements that are typically applicable to such aircraft. All maintenance and inspections will be conducted i n accordance with the Operations Manual and the Manufacturer's User Manual , which will prov ide an equiva lent level of safety. The above requested exemptions are in line with previous exemptions granted by the FAA. 16 Fusion requests any further or different re lief that the FAA deems necessary . Conclusion The limited size , weight , speed , and operating capabil ities , lack of proximity to ai rports , and operation within visual line of sight and in accordance with the Operations Manual and Closed Set Manual satisfy the criteria provided i n Section 333 of the Reform Act of 2012 and justify the grant of the exemption allowing commercial operation of applicant's sUAS for newsgathering, reporting , and production purposes pursuant to the conditions and lim itations and the manual confidentially filed herewith . Further, the proposed operations fall squarely within categories FAA has identified as eligible for the summary grant process - aerial data collection and closed set film i ng - and are consistent with many exemptions already granted . Accordingly, Fusion respectfully requests that the FAA expeditiously grant the requested exemption . Sincerely,
Gary Halbert Chuck Tobin Jenn ifer Nowak Counsel for Fusion Media Network, LLC

1s See, e. g., Exe mption No . 11481, Exemption No . 12901 . 1s See, 

### e.g. , Exe mptio n No . 12901 , Exemption No. 12174.