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Mark E. McKinnon

703.336.8708 Email Address mmckinnon@mckennal ong.com Ju ly 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 o f 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 revi sed 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 opera ting 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 t he May 11, 2015 Petition for Exemption, followed by a description of the addition or change to the section.

II. D ESCRIPTION OF P ROPOSED O PERATIONS

CNN seeks to 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. FA A

- 2015

- 1851)U.S. Department of Transportation

July 2, 2015 Page 2

IV. CNN' S P ROPOSED UAS O PERATIONS M EET THE R EQUIREMENTS OF S ECTION 333 OF

THE R EFORM A CT

A. Approval is Warra nted 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 requirem ents 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. T he PARC vehicle is powered from the ground, and the flight dur ation is not limited by battery life. PARC weighs approximately 21.75 pounds when operating with is full p ayload capacity of 3.6 pounds. The vehicle is equipped with six electric motors configured as a hexrotor. The PARC system is designed to provide lon g 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 ha s 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 requir ed. 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 int erface. When command ed by the o perator, 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 institut es 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.

 T he maximum altitude of the veh icle 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

sta tic 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 designe d with safety and redundancy as a foremost considerat i on 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, anten na 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 e xclusively if the other fails. The dual autopilot system also incorporates the following modes for safe flight:

 R eturn

- to

- Home on communications failure ;

 A uto 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

p latform, but the redundancy of two rotors per arm. In the unlikely event of a motor or rot or failure,

the balance across all four arms means that the X

- 8 can maintain safe and level flight. Finally, if t he 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 exempt ion 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 ot her 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 C losed Se t Motion Picture and

Television F ilming, 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 inf ormation 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 followi ng attached item s will be subm itted 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