Holland & Knight 

800 17th Street, NW, Suite 11 00 I Washington, DC 20006 I T 202.955.3000 I F 202.955.5564 

Holland & Knight LLP I www.hklaw.com 

Gary L. Halbert 

202.469.5150 

gary.halbert@hklaw.com 

Charles D. Tobin 

202.419.2539 

chartes.tobin@hklaw.com 

Jennifer 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: Fusion Media Network, LLC Petition for Summary Grant of Exemption Pursuant to 

14 C.F.R. Part 11 and Section 333 of the 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 (sUAS) to conduct commercial flights for aerial photography and 

filming, including closed set filming, under the conditions 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 in accordance with the conditions the FAA has placed on holders of similar 

exemptions. As such, we request summary approval of this petition for exemption 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 

Univision Communications, is a news and information media network that serves a young, 

diverse, and inclusive millennia! generation across its cable television and digital platforms. 

Reporting news and information is Fusion's core business and Fusion has a special focus on 

producing English-language news and information content for U.S. Hispanic millennials. Fusion's 

cable television network is carried by DirecTV, Dish, Cablevision, Charter, Cox, AT & T Uverse, 

Verizon FiOS and Google Fiber as well as over-the-top {OTT) providers like Apple TV, Roku, and 

Sling TV. 

1 See Section 333 of the FAA Modernization 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/?newsld=82485. 

Anchorage 1 Atlanta 1 Austin 1 Boston 1 Chicago I Dallas 1 Denver I Fort lauderdale I Jacksonville I lakeland I los Angeles I Miami 

New York 1 Northern Virginia 1 Orlando 1 Portland 1 San Francisco 1 Tallahassee I Tampa I Washington, 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 operating traditional 

helicopters, both for those operating the aircraft, and for people on the ground. The sUAS 

operates on battery power rather than carrying combustible fuel and its limited size and weight 

significantly reduce the potential 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 increased 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 with 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 

requirement 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 following 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 CFR § 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 of the Reform Act permits 

the FAA to provide exemptions regarding airworthiness certification under 49 U.S.C. §§ 44704 

and 44711. 

The small size of the 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 regarding 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, in compliance with Federal 

Communications Commission (FCC) requirements. Inspection, maintenance, repair and preflight 

safety risk assessment of the sUAS will be performed in accordance with the Operations Manual 

and the Manufacturer User Manual and subject to the conditions and limitations provided below. 

Maximum total flight time will be 18 minutes, and the Pilot in Command (PIC) will require return 

of the aircraft with five minutes battery reserve time, or with the amount of reserve power 

recommended by the manufacturer, if greater. The sUAS is equipped with auto safe return, as 

described in the User Manual. 

The PIC will conduct a pre-flight inspection and determine that the sUAS is in a condition 

for safe flight. The pre-flight inspection will account for all potential discrepancies, e.g., inoperable 

components, items, or equipment. Fusion will follow the sUAS manufacturers' maintenance, 

overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft 

components, as well as comply with all manufacturer safety bulletins. 

The sUAS will be operated by at least two people at all times: the PIC and a visual observer 

(VO). The PIC will hold an air transport, commercial, private, recreational or sport pilot certificate, 

in addition to an airman medical certificate or a valid United States driver's license. Pilots will be 

trained and have additional 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 proximity without the use of enhanced communication such as radios, telephones or 

texting. 

Conditions and Limitations 

In addition to the terms of the Operations Manual, which may overlap with the terms below, 

Fusion ("the Operator'') specifically proposes that if the exemption is granted, the sUAS, and 

Fusion's operation of the sUAS, will conform to the following conditions and limitations, which 

FAA has attached to its previous grants of exemptions, and which will ensure an equivalent or 

higher level 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 aircraft will require a new or amended 

exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (1 00 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum 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 times. 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 required of the VO. 

7. This 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 conditions and limitations in this exemption and the 

procedures outlined in the operating documents, the conditions 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 

revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

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

functional test flight prior to conducting further operations under this exemption. Functional 

test flights may only be conducted by a PIC with a VO and must remain at least 500 feet 

from other people. The functional test flight 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 maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation. 

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-flight inspection must account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals 

a condition that affects the safe operation of the UAS, the aircraft is prohibited 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 Operator must follow the UAS manufacturer's maintenance, overhaul, replacement, 

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

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold 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. 

14. The Operator may 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 

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 in a manner consistent with 14 CFR § 61 .51 (b). Flights for the 

purposes of training the Operator's PIGs and VOs (training, proficiency, and experiencebuilding) and determining the PIC's ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under this exemption are permitted under 

the terms of this exemption. However, training operations may 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 

must operate the UA with appropriate distance from nonparticipants in accordance with 

14 CFR § 91 .119. 

15. UAS operations may not be conducted during 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. 

16. The UA may not operate 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 COA issued to the exemption holder. The letter of agreement 

with the airport management must be made available to the Administrator 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 visibility is less than 3 statute miles from the PIC. 

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

19. The PIC must abort the flight in the event of unpredicted 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 with an A TO-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, 

registered in accordance with 14 CFR part 47, and have identification (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 available to the Administrator or any law enforcement official 

upon request. 

24. The UA must remain 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 nonparticipating persons 

from the UA and/or debris in 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, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating 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 of Activities to the local Flight Standards District Office (FSDO) 

with jurisdiction over the area of proposed filming. The 3-day notification may be waived 

with the concurrence of the 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 this 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 involved 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 permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including 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 in 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 safely 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 limitations provided above. 

10 Reform Act§ 333 (b). 
January 14, 2016 

Page 9 

Fusion reports news and information on topics of public interest. Its editorial team covers 

social and political issues such as immigration, the criminal 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 in the public interest, as it provides a safer and 

more cost-effective method for capturing aerial news footage. 

Expanded newsgathering through sUAS operated in a safe manner and in a controlled 

environment is completely consistent with Congress's recognition of the tremendous public 

benefit that can be gained by allowing for the use of this innovative and sophisticated technology, 

which is why Congress directed to the FAA '1o safely accelerate the integration of civil unmanned 

aircraft systems in the national airspace 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 unique aerial perspective for audiences on matters 

of interest to the public. Carefully managed sUAS operations 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 in the past to cover newsworthy events. 

As in previous decisions, "[t]he enhanced safety achieved using an unmanned aircraft 

(UA) with the specifications described by the petitioner 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 sUAS operation enabled by this exemption is in 

the public interest."11 Additionally, increased flexibility for filming due to the portability and 

affordability of sUAS will allow more timely and cost-effective news coverage, including 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 coalition working with 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 following provisions of the Federal Aviation 

Regulations for purposes of conducting the proposed operations: 

14 CFR § 61 .23(a) and (c) (Medical Certificates: Requirements and duration) 

Consistent with the FAA's summary grant policy12 and previous exemptions issued by the 

FAA, Fusion requests an exemption from the requirement for pilots to hold a medical certificate 

for certain operations. All PICs and VOs will hold at least a valid U.S. driver's license, which will 

provide an equivalent level of safety when operating under the conditions and limitations listed 

above. 

11 See, e.g., Exemption No. 11062, 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 limitations: Pilot in Command); 14 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 or 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, ensuring at least an equivalent level of 

safety. 

14 CFR § 91 .7(a) (Civil aircraft airworthiness) 

As the sUAS operated by Fusion will not have airworthiness certificates, Fusion requests 

an exemption from this requirement. FAA previously has determined that "for the purposes of this 

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 determine that the aircraft is 

airworthy, thus providing an equivalent level of safety. 

14 CFR § 91.119 (Minimum 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, including 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 determined that 

an equivalent level of safety may be achieved in circumstances 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 established 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 requirement. 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. 14 See, e.g., Exemption No. 11062. 
January 14, 2016 

Page 11 

requirement. 15 Fusion's Operations Manual imposes this same requirement, 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 CFR § 91.409(a)(1) and (2) 

(Inspections); 14 CFR § 91.417(a) and (b) {Maintenance records) 

As Fusion's sUAS will 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 in accordance with the Operations Manual and the 

Manufacturer's User Manual, which will provide an equivalent level of safety. 

The above requested exemptions are in line with previous exemptions granted by the 

FAA.

16 Fusion requests any further or different relief that the FAA deems necessary. 

Conclusion 

The limited size, weight, speed, and operating capabilities, lack of proximity to airports, and 

operation within visual line of sight and in accordance with the Operations Manual and Closed 

Set Manual satisfy the criteria provided in 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 limitations 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 

filming - 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 

Jennifer Nowak 

Counsel for Fusion Media Network, LLC 

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

1s See, e.g., Exemption No. 12901 , Exemption No. 12174.