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Federal Aviation Administration 

1200 New Jersey A venue, SE 

Washington, DC 20590 

Re: Petition of Graham Media Group For Exemption Pursuant to 

Section 333 of the FAA Modernization and Reform Act of2012 

To Whom It May Concern: 

Graham Media Group, Inc. ("GMG") requests pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 ("Section 333") and 14 C.F.R. Part 11 an Exemption 

from the Federal Aviation Administration ("FAA") Regulations identified in Section II below. 

GMG seeks an Exemption so as to permit it to operate unmanned aircraft weighing less than 55 

pounds for aerial data collection. In particular, GMG owns five television stations and intends to 

use UA for newsgathering and related activities at its television stations. 1 

The Exemption sought by GMG is within the authority of the FAA to grant under Section 

333 and 14 C.F.R. Part 11, and is consistent with a number of such exemptions that have been 

recently granted by the FAA under equivalent circumstances.2 

I. Operator/Petitioner. 

The name of the Operator/Petitioner is: 

Graham Media Group, Inc. 

161 N. Clark Street 

Suite 2900 

Chicago, IL 60601 

1 GMG owns KRPC (Houston, TX), KSAT (San Antonio, TX), WDIV (Detroit. Ml), W JXT (Jacksonville, FL) and 

WKMG (Orlando, FL). Each station is a wholly-owned subsidiary ofGMG. The exemption being sought would be 

for the benefit of each ofits currently-owned stations and any future television station wholly-owned by GMG. 

2 See Exemption No. 11408, Arrow Data, LLC, Docket No. FAA-2015-0131 (April 22, 2015); Exemption No. 

11841, Motown Digital, LLC, Docket No. FAA-2015-0529 (June 17, 2015); Exemption No. 12174, Cable News 

Network, Inc., Docket No. F AA-20 15-1851 (July 27, 20 15); Exemption No. 1290 I, Cox Media Group, LLC, 

Docket No. FAA-2015-2672 (Sept. 17, 2015). Each of the cited Exemptions refers to additional Exemptions deemed 

by the FAA to have presented "circumstances similar in all material respects" to the cited Exemptions. 

SSO West Lafayette Boulevard t Detroit, Ml 48226 
(313) 223-2274 

II. Regulations From Which Relief Is Reguested. 

GMG requests exemption from the following sections of 14 CFR: 

61.23(a) and (c) (medical certificates) 61.101(e)(4) and (5) (recreational pilot) 61.113(a) (private pilot certification and qualification) 61.315(a) (sport pilot) 

91.7(a) (airworthiness) 91.119 (minimum safe altitudes) 91.121 (altimeter) 

14 C.F.R. 91.151(a)(1) (fuel requirements in VFR conditions) 

14 C.F.R. 91.405 (a) (maintenance) 

14 C.F.R. 91.407(a)(l) (approval for return to service) 

14 C.F.R. 91.409(a)(l) and (2) (annual and airworthiness certification inspection) 

14 C.F.R. 91.417(a) and (b) (maintenance records) 

Any additional regulation an exemption from which is deemed appropriate by the FAA 

for the UA operations described in this petition. 

III. Make and Model of Proposed Aircraft: 

GMG seeks an exemption for the following listed UA. In nearly all instances, a link is 

provided to descriptive materials for the specific UA, as well as to the Flight/Operations 

Manual. In each instance, the FAA has previously issued one or more exemption with 

respect to the same UA.3 In each instance, one such prior Exemption is identified. 

CyPhy Works Persistent Aerial Reconnaissance and Communication System (PARC) 

http://cvohvworks.com/robots/parc/ 

Previous Exemption No. 12174B (CNN) 

3 Or, in the case of the recently announced DJilnspire Pro, an Exemption was issued with respect to a substantially 

equivalent earlier version. 

2 
Flight/Operations Manual 

https://dl.diicdn.com/downloads/phantom 3/en/Phantom 3 Advanced User Manual V 

1.6.pdf 

Dn Inspire 1 http://www.dji.com/product/inspire-1 

Previous Exemption No. 12174 (CNN) 

Flight/Operations Manual 

https://dl.diicdn.com/downloads/inspire lien/Inspire I User Manual en v2.0 1218.pdf 

DJI Inspire 1 Pro http://www.dii.com/product/inspire-l-pro-and-raw 

Substantially equivalent to the DJI Inspire I (above) 

Flight/Operations Manual 

http://dl.djicdn.com/downloads/inspire 1 pro/en/Inspire 1 Pro User Manual en v1.0 

1201.pdf 

DJI Spreading Wings S900 http://www.dji.com/product/spreading-wings-S900 Previous Exemption No. 11841 (Motown Digital) 

Flight/Operations Manual 

http://dl.diicdn.com/downloads/s900/en/S900 User Manual vl.2 en.pdf 

DJI Spreading Wings S 1000 http://www.dji.com/product/spreading-wingss1000?www=v1 Previous Exemption No. 12746 (Bitcentral) Flight/Operations Manual 

http://dl.diicdn.com/downloads/slOOO/en/SIOOO User Manual vl.10 en.pdf 

3D Robotics Solo https://3drobotics.com/solo-drone/ 

Previous Exemption No. 121748 (CNN) Flight/Operations Manual 

https://3drobotics.com/wo-content/uploads/2016/0llv8 01 05 16.pdf 

Yuneec Typhoon Q500+ https://www.yuneec.com/Tvnhoon-0500plus 

Previous Exemption No. 12159 (Eye-In-The-Sky) Flight/Operations Manual 

https://www.yuneec.com/download/manuals/tvnhoon g500plus user manual v2.0.pdf 

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IV. Safety. 

Petitioner firmly believes that if the requested Exemption is granted, the resulting 

operations will be as or more safe than the alternative. This conclusion is based upon the 

following: 

1) GMG is committed to strictly adhering to Graham Media Group Unmanned 

Aircraft Policy ("GMG UA Policy," a copy of which will be submitted under 

separate cover), which includes by reference the Operations Manual of the subject 

UA, and the Conditions and Limitations imposed by the FAA in previously 

granted Exemptions and expected to be imposed in the requested Exemption. 

2) Each of the subject UA is in size, weight, maximum ground speed and operational 

capability well with the standards set forth in FAA's previously imposed 

Conditions and Limitations. The UA for which an Exemption is sought (or a 

substantially similar version) have previously been the subject of Exemptions 

granted by the FAA. 

3) Prior to each flight, the UA will be inspected in accordance with Pre-Flight 

Checklist incorporated into the GMG UA Policy. In accordance with that Policy, 

a UA-specific maintenance plan and schedule based on manufacturer's directives 

shall be adhered to, and flight and maintenance records shall be kept for each UA. 

4) The Pilot and Visual Observer will comply with the requirements of the 

Conditions and Limitations. In addition, each will be subject to UA-specific 

training, and practice flight experience, as set forth in the GMG UA Policy. 

5) As in previously granted Exemptions, the UA operation for which an Exemption 

is sought would result in "enhanced safety" as compared to the use of manned 

aircraft of significantly greater proportions, carrying crew and flammable fuel. 

The Exemption requested is similar in all material respects with Exemptions previously 

granted by FAA in similar circumstances. As was found in those other circumstances? 

"enhanced safety [will be] achieved by using an unmanned aircraft." 

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station. In times of local or national breaking news or emergencies, or extreme weather, 

it is common that non-news programming is suspended and replaced by live local news. 

The grant of the requested Exemption will add an important element to the ability of the 

GMG stations to continue to serve the public interest of the communities they serve. The 

contemplated UA operations will afford the GMG stations a safe, efficient, economical 

and flexible means to deliver to their viewers in an enhanced way the news of the day. 

VI. Conclusion. 

The grant of the Exemption requested in this petition would be entirely consistent with 

and warranted by numerous Exemptions previously granted by the FAA under 

circumstances similar in all material respects to those here presented. GMG appreciates 

your prompt attention to this petition. If you have any questions, please do not hesitate to 

contact me. 

Sincerely, 

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