February 10, 2016

Docket Operations, M

-30 U.S. Department of Transportation (DOT) 1200 New Jersey Avenue, SE., RoomW12

-140, West Building Ground Floor Washington, DC 20590

-001

RE:Section 333 exemption

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R., Part 11, ZUFFA, LLC, (“ZUFFA”), operator of Small Unmanned Aircraft Systems (“sUAS”) equipped to conduct aerial videography of professional football game and training facilities, requests a limited exemptionfrom the below

-listed regulations to allow commercial operation of its sUASs, provided that the proposed sUAS operations comply with the conditions outlined below oras established by the Federal Aviation Administration (“FAA”) under Section 333. The name and address of the applicant is: ZUFFA, LLC, 2960W.Sahara, Las Vegas, NV 89102, c/o Tim Bellamy, Senior Vice President & Associate General Counsel, (702) 851

-2478, tbellamy@ufc.com

. ZUFFA makes this request under the “summary grant” process that the FAA announced in April 2015.1 This request is similar in all material respects to a number of recent grants of exemption, including Grant of Exemption No. 11488 to Advanced Aerial Cinematography, LLC (FAA Docket No. 2014

-0090). Regulations from which the exemption is requested: 14 C.F.R. part 21 14 C.F.R. § 45.23 (b) 14 C.F.R. §§ 61.113 (a) & (b) 14 C.F.R. § 91.7 (a) 14 C.F.R. § 91.9 (b) (2) & (c) 14 C.F.R. § 91.103 14 C.F.R. § 91.109 14 C.F.R. § 91.119 14 C.F.R. § 91.121 14 C.F.R. § 91.151 (a) 14 C.F.R. §§ 91.203 (a) & (b) 14 C.F.R. § 91.405 (a) 14 C.F.R. 407 (a) (1) 14 C.F.R. § 409 (a) (2) 14 C.F.R. §§ 417 (a) & (b)ZUFFA proposes that it receive an exemption to use sUAS to gather footage from UFC Events held throughout the nation.ZUFFA would use the footage in its sports and entertainment programming. The proposed sUAS operation will be conducted safely to minimize risk to the national airspace system (“NAS”) or to persons and property on the ground. ZUFFA proposes that the exemption applyto civil aircraft that operate within the limitations listed below. These limitations
were established in the FAA’s grant of Advanced Aerial Cinematography’s request for an exemption:

1. The sUAS will weigh less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purpose of picture and television filming are permitted. 3. The sUAS may not be operated at a speed exceeding 87 knots (100 miles per hour). ZUFFA may use either groundspeed or calibrated airspeed to determine compliancewith the 87 knot speed restriction. In no casewill the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UAwill be operated at an altitude of no more than 400 feet above ground level (AGL) Altitude will be reported in feet AGL 5. The UA will be operated within visual line of sight (VLOS) of the Pilot in Charge (PIC) at all times. This requires the PIC to be able to use human vision unaided by any device otherthan corrective lenses, as specified on the PIC’s FAA

-issued airman medical certificate or U.S. driver’s license. 6. All operations will utilize a visual observer (VO). The UAwill be operated within the VLOS of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains the VLOS capability. The VO and PIC will be able to communicate verbally at all times; electronic messaging or texting will not be permitted during flight operations. The PIC will be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC will ensure that VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the sUAS and conduct its operations in accordancewith the conditions and limitations stated in the grant of exemption, are hereinafter referred to as the operating documents. The operating documents will be accessible during sUAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and will be followed. Otherwise, ZUFFAwillfollow the procedures as outlined in its operating documents. ZUFFA may update or revise its operating documents. It is ZUFFA’s responsibilityto track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. ZUFFA will also present updated and revised documents if it petitions for extension or amendmentto this grant of exemption. If ZUFFAdetermines that any update or revision would affect the basis upon which the FAA granted this exemption, then ZUFFA must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional testflights may only be conducted by a PICwith aVO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. ZUFFA is responsiblefor maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PICwill conduct a pre-flight inspection and determine the sUAS is in a condition for safe flight. The pre-flight inspection will account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft will be prohibited form operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. 11. ZUFFAwill follow the sUAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements forthe aircraft and aircraft components. 12. Each sUAS operated under this exemption will comply with all manufacturer safety bulletins. 13. ZUFFAwill not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the sUAS in a manner consistent with how the sUAS will be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-building) and determining the PIC’s ability to safely operate the sUAS in a manner consistent with howthe sUASwill be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 14. UAS operationswill not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations will be conducted under visual meteorological conditions (VMC). ZUFFA will not operate flights under special visual flight rules (SVFR).15. The UAwill not operatewithin 5 nautical miles of an airport reference point (ARP)
as denoted in the current FAA Airport/Facility Director (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted on the current FAA

-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management will be made available to the Administrator or any law enforcement official upon request. 16. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 17. Ifthe sUAS loses communications or loses its GPS signal, the UAwill return to a pre-determined location within the private or controlled

-access property. 18. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 19. The PIC will be prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. 20. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations will be conducted in accordance with an ATO

-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA. 21. All aircraft operated in accordance with this exemption will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 22. Documents used by ZUFFA to ensure the safe operation and flight of the sUAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the sUAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official upon request. 23. The UA will remain clear and give way to all manned aviation operations and activities at all times. 24. The sUAS will not be operated by the PIC from any moving device or vehicle. 25. All Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures, unless:
a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. ZUFFA will ensure that nonparticipating persons remain under such protection. If
a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediately in a manner ensuring the safety of nonparticipating persons; andb. The owner/controller of any vessels, vehicles or structures has granted permissionforoperating closerto those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees, essential persons, or individuals who have signed consent forms are not considered nonparticipating persons under this exemption.

26. All operations will be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reportedto the FAA’s UAS Integration Office (AFS

-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:www.ntsb.gov

. Ifthis exemption permits operations for the purpose of closed

-set motion picture and television filming and production, the following additional conditions and limitations apply:

28. At least 3 days before aerial filming, ZUFFA will submit a written Plan of Activities to the local Flight Standards District Office (FSDO) withjurisdiction over the area of proposed filming. The 3

-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:
a. Dates and times for all flights; b. Name and phone number of the operator for the sUAS aerial filming conducted under this grant of exemption;
c. Name and phone number of the person responsible for the on-scene operation of the sUAS; d. Make, model, and serial or N

-Number of the sUAS to be used;
e. Name and certificate number of the sUAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property
owners and/or local officials to conduct the filming production event; the list of those who gave permission will be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state overwhich filmingwill be conducted and the altitudes essential to accomplish the operation. 29. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production. Unless otherwise specified, the sUAS operations will comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. ZUFFA incorporates all arguments insupport of the petition made in Advanced Aerial Cinematography’s November 24, 2014 application for exemption.
**Federal Register Notice** As stated above, publication in the Federal Register is unnecessary because this application
meets the FAA’s criteria for summary approval. To the extent that the FAA determines that publication is necessary, the following summary is provided:

Applicant seeks an exemption from the following rules: 14 C.F.R. § 21, subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 91.109; 91.119; 91.121; 91.151(a); 91.203 (a) and (b); 91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 (a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 lbs or less) in videography operations.
**The Exemption is in the Public Interest** As demonstrated above, the proposed sUAS operations would minimize the risk of harm to individual safety or damage to the NAS and property. The operations proposed by ZUFFA would provide tremendous public benefits by enabling millions of UFCfanstoviewfootagethat could not be captured via any other technology. The sUAS operations as described in this applicationwill befar saferand more efficientthan use ofhelicopters orotheraircraftto capture the required footage. The conditions outlined in this petition clearly satisfy Section 333’s exemption criteria regarding “size,weight,speed, operational capability, proximityto airports and populated areas, and operation within visual line of sight,” and therefore the proposed operations would not “create a hazard to users of the national airspace system or the public or pose a threat to national security.” As discussed above, ZUFFA agrees to use limitations that are substantially identical to those contained in the FAA’s recent grant of exemption for Advanced Aerial Cinematography. Accordingly, the proposed UAS operations ofZUFFA should not raise safety or national security concerns, and should receive summary approval. Should you have any questions or concerns, please do not hesitate to contact me
Best regards,

Timothy Bellamy Zuffa LLC d/b/a Ultimate Fighting Championship® Senior Vice President and Associate General Counsel