February 18, 2016 

U.S. Department ofTranspmiation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Re: Petition to Amend Exemption No. 14439; Docket No. FAA-2015-5268 

Dear Sir or Madam: 

Raycom Media ("Raycom") hereby petitions for an amendment to Exemption No. 14439, which 

the FAA issued to Raycom on January 14, 2016 to permit unmanned aircraft system ("UAS") 

operations for newsgathering, commercial production, and facilities inspection. Raycom 

requests that the FAA amend Exemption No. 14439 to authorize the use ofthree additional UAS 

models: Yuneec Typhoon Q500 4K, Yuneec Tornado H920, and Yuneec Typhoon H. 

The Aircraft and Proposed Operations 

All of the U AS for which Ray com seeks authorization are rotorcraft weighing less than 55 

pounds including payload. The FAA has granted previous Section 333 petitions seeking 

authorization to operate Yuneec UAS models, including the Typhoon Q500 4K and the Tornado 

H920. 1 The Typhoon H, launched at the 2016 Consumer Electronics Show and scheduled for 

release this year, is the newest model in the Typhoon product line. The Typhoon H is a 

hexacopter that is similar in size to the Typhoon Q500 series. It measures 520 x 456 x 296 mm 

while in flight, with a takeoff weight ofless than five pounds including payload. The Typhoon 

H uses a 14.8v Lithium-ion battery and the Yuneec ST16 Personal Ground Station transmitter. 

Recent Section 333 petitioners have requested authorization to operate the Typhoon H.2 

Raycom seeks authorization for these additional UAS models to enhance its existing operations 

in the areas of news gathering, commercial production, and facilities inspection. Raycom will 

continue to operate all authorized UAS models in accordance with the terms of its grant of 

exemption and Ce1iificate of Waiver or Authorization. Raycom does not request any relief from 

the Federal Aviation Regulations beyond that which was granted in Exemption No. 14439. 

See, e.g., Exemption No. 12477 to VizTools LLC, Docket No. FAA-2015-0605 (issued Aug. 17, 2015) 

(authorizing operation of the Yuneec Typhoon Q500 4K); Exemption No. 14669 to VSI Aerial LLC, Docket No. 

FAA-2015-3624 (issued Feb. 4, 2016) (authorizing operation ofthe Yuneec Typhoon Q500 4K and Yuneec Tornado 

H920). 

2 See, e.g., Clearview Aerial Imagery, Petition for Exemption, Docket No. FAA-2016-1402 (posted Jan. 19, 

2016); Aeroworks Productions, LLC, Petition for Amendment, Docket No. FAA-2015-1765 (posted Feb. 1, 2016); 

Francisco Farray, Petition for Exemption, Docket No. F AA-20 16-3585 (posted Feb. 4, 20 16). 
Public Interest Benefits of Granting this Petition for Amendment 

Grant of this petition for amendment is in the public interest because it will enable Raycom to 

continue and expand its mission to use UAS to conduct safer newsgathering and obtain better 

content. As Raycom explained in its initial petition for exemption, UAS enable Raycom both to 

improve the accuracy and depth of information available to the public during breaking news 

situations, and to offer enhanced marketing and commercial content. In addition, the ability to 

use UAS allows Raycom to more safely and cost-effectively inspect its facilities, helping to 

ensure uninterrupted transmission of important content to Raycom's viewers. 

Please do not hesitate to contact Raycom's outside counsel, Kathleen A. Kirby of Wiley Rein 

LLP at 202-719-3360 or lddrby@wileyrein.com, and SaraM. Baxenberg of Wiley Rein LLP at 

202-719-3755 or sbaxenberg@wileyrein.com, with any questions about this filing. 

Sincerely, 

David Burke 

Raycom Media