Holland & Knight 

800 17th Street. Suite 11 00 I Washington, DC 20006 I T 202.955.3000 1 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 

charles.tobin@hklaw.com 

Jennifer M. Nowak 

202.419.2451 

jennifer.nowak@hklaw.com 

December 14, 2015 

Via www.regulations.com 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: NBCUniversal Media, LLC Petition for Amendment of Exemption No. 13616 

(Docket No. FAA-2015-3384) 

Dear Sir or Madam: 

On November 16, 2015, the Federal Aviation Administration ("FAA") granted 

NBCUniversal Media, LLC's ("NBCUniversal") petition for an exemption to operate unmanned 

aircraft systems for the purposes of aerial data collection and closed set motion picture and 

television filming .

1 The UAS models approved for operation under the exemption were the DJI 

Inspire 1, DJI Phantom 2, and DJI S-1 000. NBCUniversal hereby requests an amendment to its 

exemption that will allow it to operate an additional small UAS, the DJI Phantom 3. 

NBCUniversal will operate the additional UAS model in strict accordance with 1) the 

conditions and limitations placed on its operations by Exemption No. 13616, 2) NBCUniversal's 

sUAS Safety Program , including the operations manuals submitted to the FAA as part of its 

original petition for exemption, and 3) the manufacturer's User Manual for the DJI Phantom 3. 2 

NBCUniversal's request is limited to exemption from the same list of regulations in its current 

exemption and does not seek exemption from additional regulations. 

1 Exemption No. 136 16, Docket No. FAA-2015-3384. 2 A copy of the manufacturer's user manual is available at 

httos://d l.dj icdn .com/downloads/phantom 3/en/Phantom 3 Professional User Manual V 1.6.pdf. 

Anchorage I Atlanta I Austin I Boston 1 Chicago 1 Dallas I Denver 1 Fort Lauderdale 1 Jacksonville 1 Lakeland 1 Los Angeles 1 Miami 

New York I Northern Virginia I Orlando 1 Portland 1 San Francisco 1 Tallahassee 1 Tampa 1 Washington, D.C. 1 West Palm Beach 
December 14, 2015 

Page 2 

The conditions cited in NBCUniversal's original petition for exemption remain unchanged 

and the same public interest analysis applies.

3 Like the other UAS models covered under 

NBC Universal's exemption, the small size of the DJI Phantom 3, the constrained environment in 

which the UAS will operate, and the company's strict compliance to all applicable conditions and 

limitations 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 as that provided 

by the regulations from which exemption is sought. 

This requested amendment is non-controversial and non-precedent setting. The UAS 

model requested for addition to the exemption has been approved by the FAA numerous times 

for operation under similar exemptions,

4 and the FAA has granted a large number of amendments 

to Section 333 exemptions in order to allow for the operation of additional aircrafP Accordingly, 

good cause exists for waiving publication in the Federal Register. 

For the foregoing reasons, NBCUniversal respectfully requests that the FAA promptly 

grant the requested amendment. 

Sincerely, 

Gary Halbert 

Chuck Tobin 

Jennifer Nowak 

Counsel for NBCUniversal Media, LLC 

3 To the extent necessary, NBCUniversal hereby incorporates by reference the public interest and equivalent level of 

safety analyses articul ated in its original application dated June 23 , 201 5 and submitted in Docket F AA-20 15-3384. 4 See, e.g., Exemption No. 12820, Docket No. F AA-20 15-2593 (Aitek Media); Exemption No. 1280 I, Docket No. 

F AA-20 15-2608 (Olympic Aerial); Exemption No. 11 770A, Docket No. F AA-20 15-0895 (Crosstimbers Video). 5 See, e.g. , Exemption No. 12 1748, Docket No. F AA-20 15-185 1 (CNN); Exemption No. I 1307 A, Docket No. FAA20 14-1 0 18 (Price Aviation); Exemption No. 12029A, Docket No. F AA-20 15-1 292 (Windshear Media).