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Mark E. McKinnon

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mmckinnon@mckennalong.com

July 2, 2015

To Whom it May Concern:

As you are aware, this office represents Cable News Network, Inc. (CNN) regarding the 

above-referenced Petition for Exemption, filed on May 11, 2015, in which CNN seeks regulatory 

relief to allow commercial operation of small unmanned aircraft system. CNN hereby requests an 

amendment to its Petition for Exemption to authorize UAS operations for the purpose of closed-set 

motion picture and television filming. In addition, CNN seeks to add two additional aircraft: the 

CyPhy Works Persistent Aerial Reconnaissance and Communication System (PARC) and the Altus 

Delta X-8. 

CNN will submit the CyPhy Works PARC Operator's Technical Manual, the Altus 

Multirotor User Manual/Maintenance Manual, and a revised CNN UAS Operations Manual that 

includes the CyPhy Works PARC and the Altus Delta X-8. CNN will also submit a separate motion 

picture and television operations manual (MPTOM) that contains operating procedures for closed-set 

filming operations. These manuals are submitted as confidential documents pursuant to 14 C.F.R. 

§ 11.35(b), as the materials contain confidential commercial and/or proprietary information that 

CNN has not and will not share with others. Additionally, these documents contain operating 

conditions and procedures that are not generally available to the public and are protected from 

release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.

For ease of use, this Amendment sets forth the heading of the applicable section of the May 

11, 2015 Petition for Exemption, followed by a description of the addition or change to the section. 

II. DESCRIPTION OF PROPOSED OPERATIONS

CNN seeksto amend Section II of its petition to add the CyPhy Works PARC, and the Altus 

Delta X-8 for use in support of its news gathering operations. As set forth below, these vehicles 

meet the criteria established in Section 333 of the Reform Act.

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Re: Amendment to CNN Petition for Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (Docket No. FAA-2015-1851)
U.S. Department of Transportation

July 2, 2015

Page 2

IV. CNN'S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF 

THE REFORM ACT

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and 

Operational Capability 

CNN Amends its Petition for Exemption to add the following description of the CyPhy 

Works PARC, and the Altus Delta X-8, and a description of how these vehicles meet the 

requirements of Section 333. 

1. CyPhy Works PARC

The CyPhy Works PARC system consists of a Ground Control Station (GCS) and a purpose 

built hexrotor vertical take-off and landing (VTOL) vehicle. The PARC vehicle is powered from the 

ground, and the flight duration is not limited by battery life. PARC weighs approximately 21.75 

pounds when operating with is full payload capacity of 3.6 pounds. The vehicle is equipped with six 

electric motors configured as a hexrotor. The PARC system is designed to provide long term 

persistent stare capabilities and enable reliable long distance communications. PARC uses CyPhy 

Works’ patented microfilament system to deliver extreme endurance, increased capabilities, and a 

smaller logistical footprint. The vehicle also has the following safety features:

 The PARC System continuously monitors vehicle and tether energy supply system health 

during flight and it will automatically land upon detection of faults, including 

hardware/software errors, with no Operator intervention required. PARC will automatically 

land if any single motor fails, there is a loss of power support, or the vehicle overheats. 

 It has the capability to automatically launch, hover, and recover through the Operator 

Control Unit control interface. When commanded by the operator, the system will ascend or 

descend from its maximum altitude in less than 4 minutes.

 Because the vehicle’s power is supplied by the tether, a fly-away event is impossible. In the 

unlikely event the tether is broken, the aircraft institutes an immediate auto-landing.

 In the event of a power interruption or microfilament failure, the PARC vehicle has an on 

board backup battery that will allow the vehicle to safely and autonomously return to its 

launch site.

 The maximum altitude of the vehicle is limited to the length of the tether. The Operator 

Control Unit flight screen provides controls for the operator to adjust the altitude up to 400

feet AGL.

 The PARC filament tether was designed with sufficient strength that it cannot break with 

static thrust or in a dynamic thrust situation. 
U.S. Department of Transportation

July 2, 2015

Page 3

Based on the foregoing, the PARC meets all of the criteria for safe operation of a UAS and 

the amendment should be granted. 

2. Altus Delta X-8

The Altus Delta X-8 is a battery powered multirotor UAS with eight electric motors laid out 

on a cross or “X” platform. The Delta X-8 measures approximately 50 inches in diameter with the 

propellers fitted. The vehicle has a maximum take-off weight of 49 pounds and operates at a 

maximum speed of 12 m/s (~27 mph). Maximum flight time for the Delta X-8 is 12-15 minutes 

depending on operating conditions. The vehicle operates on a command and control frequency of 

2.4 Ghz and telemetry data is transmitted on a frequency of 915-928 Mhz. The Delta X8 system is 

designed with safety and redundancy as a foremost consideration and includes a dual autopilot, the 

eight rotor X configuration, and an emergency parachute. 

The heart of the Delta X-8 is the dual autopilot system. Each autopilot has its own GPS 

receiver, antenna and Internal Measurement Unit (IMU) system keeping a constant watch on aircraft 

health and performance. The dual autopilot systems monitor each other and ensure accurate 

telemetry is sent to the operator on the ground. A single autopilot can take over exclusively if the 

other fails. The dual autopilot system also incorporates the following modes for safe flight:

 Return-to-Home on communications failure;

 Auto takeoff and landing in the event of a system failure/malfunction;

 GPS hold by default, where the aircraft will maintain position if the pilot releases the 

controls.

The eight rotor layout on a cross or “X” platform provides not only a stable and potent lifting 

platform, but the redundancy of two rotors per arm. In the unlikely event of a motor or rotor failure, 

the balance across all four arms means that the X-8 can maintain safe and level flight. Finally, if the 

vehicle loses balance, becomes unstable in nature, or experiences a total motor failure, an emergency 

parachute tethered to the top of the aircraft will automatically deploy, allowing the vehicle to 

descend safely to the ground. 

B. Approval is Warranted Based on the Operational Restrictions in CNN’s

Operating Documents

CNN Amends Section IV(B)(1) and (2) to read as follows:

1. Operations authorized by this grant of exemption are limited to the AirRobot AR180, 

DJI Inspire 1, DJI Phantom 2 Vision, 3DR Solo, Watt 200 ETAP, CyPhy Works 

PARC, and Altus Delta X-8 when weighing less than 55 pounds including payload. 

Proposed operations of any other aircraft will require a new petition or a petition to 

amend this exemption.
U.S. Department of Transportation

July 2, 2015

Page 4

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

permitted. 

In summary, CNN request that FAA permit CNN to conduct Closed Set Motion Picture and 

Television Filming, and also permit the use of the CyPhy Works PARC and Altus Delta X8. If you 

have any questions regarding this amendment, or require any additional information to process 

CNN's Petition, please do not hesitate to contact us. 

Very truly yours,

Mark E. McKinnon

Matthew J. Clark

Counsel for Cable News Network, Inc.

Attachments

(The following attached items will be submitted under separate cover as they contain proprietary and 

commercial information exempt from disclosure under the Freedom of Information Act, 5 U.S.C. § 

522 et seq., and should be held in a separate file pursuant to 14 C.F.R. § 11.35(b)).

 Revised CNN UAS Operations Manual

 CNN Motion Picture and Television Operations Manual (MPTOM)

 CyPhy Works PARC Operators Technical Manual 

 Altus Multirotor User Manual

 Altus X8/X4 Maintenance Manual