ETAK Systems, LLC.

4045 Perimeter West Dr. 

Suite 600

Charlotte, NC 28214

Phone: (704) 398-9941

Fax: (704)398-8539

August 24, 2015

U.S. Department of Transportation (DOT)

Docket Operations, M-30

1200 New Jersey Avenue., SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Re: Exemption Request 

To whom it may concern,

ETAK Systems would like to submit a revision for our exemption concerning our sUAS program. 

For our specific revision, ETAK Systems would like to be able to:

1. Fly our FAA approved and registered sUAS outside of the barriers of a cellular compound for 

diagnostic signal strength measurements. 

2. Fly our FAA approved and registered sUAS from a cellular compound to the neighboring 

cellular compound using the vehicles built in flight instrumentation and ground station 

programs.

3. Fly our FAA approved and registered sUAS along power line right of ways to do line and 

tower audits that would normally have to be done from a manned airplane or helicopter. 

These flights would be within the right of way as designated by the utility company and the 

height above the lines and towers would not exceed 400 ft agl using the available navigation 

equipment available. 

ETAK would like to fly outside of these constraints to measure signal strength for our customers. 

Signal strength is affected by multiple variables and scenarios, examples include: weather, structures, 

antenna down tilt, and distance between neighboring cell sites.

With ETAK Systems seeking the above revised exemption, wireless carriers will be able to have a 

better understanding of their cell coverage within a certain area and be able to update or correct there 

coverage map to better serve their customers. With better coverage and a faster diagnostic turnaround, 

the communities and customers receive a better product as well as a more safe and reliable connection. 
With a signal strength diagnostic report, wireless carriers will be able to improve not only there 

coverage to normal customers and communities, but also to first responders and 911 alert systems. The 

risk of having a dropped call in an emergency situation could be solved and dead zones could be more 

easily identified. Having a more detailed coverage map of these areas could help ETAK and wireless 

carriers work to a better solution to fill in these dead zones. Filling in dead zones helps wireless carrier 

widen their coverage maps.

Being able to fly the power lines and towers using the instrumentation readings that are 

available from the gps and fpv camera units would greatly enhance the ability of the operator to observe 

and inspect equipment that would be with a set flight path and would not deviate or change. 

As referenced in exemption 112061, the sUAS will stay within a set flight path for all flights and 

will remain the required distances from all no-participants and all non-essential vehicles and personnel. 

The close proximity of the sUAS units and the low level of flight away from any airways or 

airports/heliports would make this operation considerably safer than using a manned helicopter or 

airplane.

Please do not hesitate to contact me via email at cterry@etaksystems.com if you have any 

questions or concerns.

1 BNSF Railway Company – Regulatory Docket Number FAA-2014-0704

Respectfully submitted,

Charlie Terry

Engineering Manager

ETAK Systems, Inc.