# ::;;


# --- ERICSSON
April30, 2015 U
. S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington , DC 20590 Dear Siror Madam : Attached please find Ericsson Caribbean , Inc.'s ("Ericsson") request for an exemption from the listed Federal Aviation Regulations to allow commercial operation of its Small Unmanned Aircraft Systems ("sUASs") to conduct aerial photography and visual surveys for various data and telecommunication projects and installations as part of its service delivery to mobile telecommunication operators. On March 4 , 2015, Ericsson Ireland , an affiliate of Ericsson , obtained from the Irish Aviation Authority (IAA) in the Republic of Ireland a commercial license to execute the same type of activities as referred to in this letter
. Also attached to this letter is the sUAS Flight Operations Manual ("Operations Manual"), which outlines the operating requirements, limitations, and technical specifications forthe sUAS
. This Operations Manual was developed in Ericsson Ireland as part ofthe licensing requirements ofthe Government of Ireland but it has been modified and adapted to the conditions for sUAS operations within FAA controlled territory
. Applicant submits the Operations Manual as proprietary information pursuantto 14 CFR 11
.35 (b). The Operations Manual contains operating conditions and procedures that are not available to the public and are protected from release underthe Freedom of Information Act 5 USC 552 et. seq. Thank you foryour time and consideration , and please let us know ifyou have any questions
.

1

# =' ...., ERICSSON In a separate filing in this same docket we will also provide the following supporting documents: 1) Phantom 2 Vision Plus Pilot Training Guide 2) Phantom 2 Vision Plus User Manual 3) Flying Camera Project- Training Material 4) Remote Piloted Aircraft System (Drone) Site Risk Assessment Form 5) sUAS Checklist- OJI Phantom 6) sUAS Flight Records and Logs

r cisco A. Rullan egal Counsel Ericsson Caribbean, Inc. City View Plaza 

### II Suite6010 Guaynabo, PR 00968 Tel. 954-804--5724 Francisco .rullan@ericsson
.com

2

# =' _.., ERICSSON April 30, 2015 U.S
. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington , DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 CFR Part 21; 14 CFR 45.23 (b); 14 CFR 45.27 (a); 14 CFR 61.113 (a) & 

### (b); 14 CFR 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.105; 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & 

### (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & 

### (b); 8900.227 §16 (c) (4) and §16 (e) (1) Dear Sir or Madam : Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 CFR. Part 11 , Ericsson Caribbean, Inc. ("Ericsson"), a provider of telecommunications and data technology services, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its Small Unmanned Aircraft Systems ("sUASs") for aerial photography and visual surveys of telecom sites ("sites") in various projects as part ofthe service delivery, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. As detailed in this document and the attached Operations Manual , the requested exemption would permit the operation ofsUAS under controlled conditions in airspace that is 1) limited, 2) predetermined, 3) controlled as to access, and 4) would provide safety enhancements to the already best practices safety protocols followed by Ericsson at each one of its sites. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "
...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system ." Section 333 (c) of the Reform Act. The name and address ofthe applicant is: Ericsson Caribbean , Inc. City View Plaza Tower II Suite 6010 Guaynabo , Puerto Rico 00968 USA

1

# ~ 

# .... ERICSSON Regulations from which the exemption is requested: 14 CFR Part 21 14 CFR 45
.23 (b) 14 CFR 45
.27 (a) 14 CFR 61
.113 (a) & (b) 14 CFR 91
.7 (a) 14 CFR 91
.9 (b) (2) 14CFR91
.103 14 CFR 91
.105 14CFR91
.109 14 CFR 91
.119 14CFR91
.121 14 CFR 91
.151 (a) 14 CFR 91
.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1 ) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b) 8900.227 §16 (c) (4) and §16 (e) (1) 

### I. STATUTORY AUTHORITY FOR EXEMPTIONS The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate
. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 of this title ifthe Administrator finds the exemption in the public interest. 49 U.S
.C. §44701(f) See also 49 USC §44711 (a) ; 49 USC §44704; 14 CFR 91
.203 (a) (1). Section 333(b} ofthe Reform Act assists the Secretary in determining whether sUASs may operate in the National Airspace System (NAS) without creating a hazard to the user, the public, or a threat to national security
. In making this determination , the Secretary must consider: • The sUAS's size, weight, speed , and operational capability; • Whether the sUAS operates within the visual line of sight of the operator • Whether the sUAS operates outside of highly populated areas and away from close proximity to airports Reform Act §333 (a). Ifthe Secretary determines that a sUAS "may operate safely in the national ai rspace system , the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system ." 

### /d. §333 (c)
.

2

# ~ 

# _.., ERICSSON Ericsson's sUASs are multirotor vehicles, weighting 10 lbs. or less including payload. They operate under normal conditions at a speed of no more than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously
. The sUASs will operate only in the pilot's and/or assistants visual line of sight at all times and will operate within the restricted private areas as described in the Flight Operations Manual , attached as Exhibit 1 (hereinafter "the Operations Manual") Adherence to the Manual will insure that the sUASs will "not create a hazard to users ofthe national airspace system or the public." Reform Act Section 333 (b). Given the small size ofthe sUASs involved and the restricted and sterile environment within which they will operate, our application falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of sUASs to commence immediately. Also due to the small size ofthe sUASs and the low altitudes (less than 400 feet AGL) and restricted private areas in which our sUASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended ; the strong equivalent level ofsafety surrounding the proposed operations, and the significant public benefit, including enhanced safety, the grant ofthe requested exemptions is in the public interest. Accordingly, Ericsson respectfully requests that the FAA grant the requested exemption without delay. 

### ll. PUBLIC INTEREST This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333 (a) through (c) ofthe Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the NAS before completion of the rulemaking required under Section 332 ofthe Reform Act. By granting an exemption the FAA will fulfill Congress's intent of allowing UAS to operate with significant safety precautions in low risk environments. The use of sUASs on a site can significantly reduce the risk to workers of falls while surveying , inspecting or monitoring site progress (e.g., some ofthe cell towers in Puerto Rico are as tall as 300 feet)
. sUASs can inspect, photograph , and collect data on hard to get to areas that otherwise would require worker inspection
. Falls are the leading source ofworkplace fatality and injury on construction sites 1 , and reducing falls through sUAS use for site imaging could save workers lives. Additionally, sUASs could replace the use of helicopters and small aircraft to monitor telecom sites. The sUASs we propose to fly in this application have a weight less than 10 pounds, and carry no combustible material on board, as opposed to the much larger conventionally powered small aircraft. Shifting to sUASs from helicopters presents a marked safety increase for our workers and the public
. Lastly, sUASs reduce the environmental impact by dramatically decreasing the energy used for aerial imaging and data collection over a site
. Our sUASs use rechargeable

3

# ~ 

# _.. ERICSSON lithium ion batteries, as opposed to fossil fuels burned in operation of small aircraft that are many hundreds oftimes heavier.

1 "Commonly Used Statistics", Occupational Safety & Health Administration. Available at: https:/ /www.osha.gov/oshstats/commonstats.htmI 

### ill. 

### EQUIVALENT LEVEL OF SAFETY Ericsson proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe protocols followed on data and telecommunication sites and imaging and surveying operations conducted with helicopters and other conventional aircraft
. Ericsson will be bound by the following limitations when conducting its sUAS operations under an FAA issued exemption: 1. Safety will be the first and foremost consideration in any sUAS operation. 2. The MTOM weight of the sUAS will be less than 10 lbs. 3. Minimum crew for each operation will consist ofthe sUAS PIC. 4. An observer will be utilized ifthe sUAS in any case will be flown outside line of sight for the pilot. Flights therefore always will be operated within line of sight of the pilot and/or an assistant at all times
. The observer, if required and pilot will at all times be able to communicate by voice and/ortext. 5. Maximum total flight time for each operational flight will 

### be 25 minutes. The sUAS calculates battery reserve in real time. The sUAS has two levels of low battery capacity warning. The first appears when the battery has less than 30% power and the second appears when it has less than 15% power. The sUAS will return to its ground station with at least 15% battery power reserve should that occur prior to the 25 minute flight time. 6. Flights will be operated normally at an altitude of200 feet AGL, never exceeding 400 feet AGL
. 7. Flights will be operated in Class G airspace whenever possible. Ifoperation in other airspace is required , the relevant controlling agency will be notified at least 24 hours prior to the operation and, if required , any necessary permission obtained
. 8. Flights will be operated at daylight and undervisibility and cloud clearance requirements equivalent to Visual Flight Rules (VFR). 9. The sUAS will at all times give way to any aircraft carrying persons.

4

# =' _.., ERICSSON 10. Prior to a sUAS flight, an area of operation will be established. This area of operation will include a defined lateral and vertical area, where the sUAS will operate. Safety procedures will be established for persons, property and applicable airspace within the area of operation. 11 . Ericsson's sUAS aircraft will utilize GPS navigation , failsafe , automatic ReturnTo-Home (RTH) and/orflight abort safety features when appropriate for the operation. 12. A briefing will be conducted in regard to the planned sUAS operations prior to operation at each new location. All personnel who will be performing duties within the boundaries ofthe area of operation will be present for this briefing
. 13. All required permissions and permits will be obtained from appropriate state, county or city jurisdictions, including local law enforcement, fire , or other appropriate governmental agencies
. 14. Written and/or oral permission from the relevant property owners will be obtained prior to an operation
. 15. The pilot will have been trained in operation of sUASs generally and received up-to-date information on the particular sUAS to be operated as required in the Operations Manual. 16. The pilot must poses at least a second class medical certificate 17. The sUAS pilot will be trained in advance for the safe operation ofthe sUAS to be operated
. Th is will include operation ofthe sUAS both in normal and emergency modes of operation , and will include familiarization with the Operations Manual. Training will also include types of maneuvers to be performed and the safe operation in relation to persons, property and applicable airspace . 18. The sUAS pilotwill establish a working relationship with a representative atthe local Right

### Sta1dards District Offioos (FSOO) with which to annually review safety procedu res and other operations to further enhance safety
. IV. DESCRIPTION OF SPECIFIC REGULATIONS 14 CFR Part 21 , Subpart H: Airworthiness Certificates 14 CFR 91.203 (a) (1) Subpart II , entitled Airworthiness Certificates , establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 91
.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Ericsson , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S
.C
.§44701 (f)) and Section 

### 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed , operational capability, and proximity to airports and populated areas ofthe particular UAS
. In our particular case, the sUASs that we are intending to use are small , and will operate at slow speeds, close to the ground, far from airports and in a low risk, low population environment. An analysis of these criteria demonstrates that the sUAS operated without an

5

# ::;; 

# _... ERICSSON airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or helicopter) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated hereunder is less than 10 lbs. fully loaded , carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels , and operates exclusively within a secured area as set out in the Operations Manual. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, pursuant to the Operations Manual's requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area ofoperation as is currently done on active sites. The FAA will have advance notice of all operations
. These safety enhancements, which already apply to civil aircraft operated in connection with sites, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 CFR Part 21 , Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed of operation , location of operation , lack of explosive materials or flammable liquid fuels, and ability to carry an external load no greater than two lbs
. 14 CFR 45.23 (b): Marking of the Aircraft and 14 CFR 45.27 (a): Location of marks; nonfixed-wing aircraft 

### This regulation requires certain experimental , provisionally certificated aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high "limited," "restricted ," "light-sport," "experimental ," or "provisional ," near each entrance to a cabin , cockpit, or pilot station
. Even though the sUAS will have no airworthiness certificate , an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed
. Given the size ofthe sUAS , two-inch lettering will be impossible. The equivalent level of safety will be provided by having the sUAS marked with the word "Experimental" will be placed one of the arms of the sUAS in compliance with 45.29 

### (f) and on both sides ofthe UAS in compliance with 45.27 (a) where the pilot, observer and others working with the sUAS will see the identification ofthe sUAS as "Experimental." The FAA has issued the following exemptions to this regulation: Exemptions Nos
. 10700, 8738, 10167 and 10167A.

6

# ='



# --- ERI CSSON 14 CFR 61.113 (a) 

### &(b): Private pilot privileges and limitations: Pilot in command Sections 61
. 113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the aircraft to have completed a sUAS flight training course of at least 50 hours before flying a sUAS
. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on board
. The area of operation is controlled and restricted , and all flights are planned and coordinated in advance as set forth in the Operations Manual. The risks associated with the operation ofthe sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a pilot who has met the minimum requirements stated in chapter 2.2 ofthe Operations Manual exceeds the present level of safety achieved by 14 CFR 61
. 113 (a) & (b). 

### 14 CFR 91.7 (a): Civil aircraft airworthiness The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition
. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the Operations Manual for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be provided. 

### 14 CFR 91.9 (b) (2): Civil aircraft flight manual, marking, and placard requirements The sUAS , given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the Operations Manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation : Exemption Nos
. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and10700.

7

# =' 

# -- ERICSSON
14 CFR 91.103: Preflight Action This regulation requires each pilot in command take certain actions before flight to ensure the safety offlight. An exemption is needed from this requirement as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements , checking takeoff and landing distances, and all other actions in the Preflight Checklist in the Manual. These actions will provide an equivalent level of safety
. 14 CFR 91.105: Flight crewmembers at stations This regulation defines the obligations ofthe flight crewmembers during takeoff and landing , and while en route. This part is not applicable due to the sUAS is not carrying any flight crewmembers
. 

### Ericsson will not operate the aircraft unless someone is at the controls at all times. Each flight will be manual, with the exception when the sUAS goes into emergency mode lik e return-to-home. This will achieve an equivalent level of safety to 14 

### CFR. 91.105. because the flight crew will be at their stations at all times during the flight. The stations will not be on the aircraft but on the ground. 14 CFR 91.109: Flight Instruction Section 91 .1

### 03 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls
. By design , sUASs and remotely piloted aircraft do not have fully functional dual controls
. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has previously approved exemptions for aircraft without fully functional dual controls
. See Exemption Nos
.5778K & 

### 9862A
. The equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control the sUAS via radio signals from the controller, and by the size and speed ofthe aircraft. 14 CFR 91.119: Minimum Safe Altitudes Section 91 .119 establishes safe altitudes for operation of civil aircraft
. Section 91 .119 (d) allows helicopters to be operated at less than the minimums prescribed , provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA
. This exemption is for a multirotor craft that flies similarly to a helicopter, with vertical take-off and vertical landing, wh ich will typically operate at altitudes of 200 feet AGL, so an exemption may be needed to allow such operations
. The sUAS will never operate at altitude higher than 400 feet AGL and will be in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. See Manual for detailed procedures
.

8

# :=!


# --- ERICSSON The equivalent level of safety will be achieved given the size, weight, speed ofthe sUAS as well as the location where it is operated
. No flight will be taken without the permission of the property owner or local officials. Because ofthe advance notice to the property owner and any onsite personnel as outlined in the Manual , all affected individuals will be aware ofthe planned flight operations
. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 10 lbs. proposed herein and carrying flammable fuel , any risk associated with our operations is far less than those presently presented with helicopters and other conventional aircraft operating at or below 500 feet AGL in the construction industry
. In addition , the lowaltitude operations of the sUAS will ensure separation between these sUAS operations and the operations of conventional aircraft that must comply with Section 91.119. 

### 14 CFR 91.121: Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "
...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure
." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 

### 14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions Section 91
. 151 (a) outlines fuel requirements for beginning a flight in VFR conditions
. Our sUAS is limited to operations in sterile and controlled environments as outlined in the Manual , and has a limited range and flight time which require an exemption from 14 CFR 91
. 151 (a)
. The battery powering the sUAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR 91
. 151 , sUAS flights would not be possible to perform
. Given the limitations on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a longertime frame for flight in daylight is reasonable
. Ericsson believes that an exemption from 14 CFR 91
. 151 (a) falls within the scope of prior exemptions
. See Exemption 11191 (allowing Singer's Creation to operate without compliance with FAR 91
.151 (a))
. Operating the sUAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151 (a) was intended to alleviate given the size and speed ofthe sUAS. The sUAS calculates battery reserve in real time. The sUAS has two levels of low battery capacity warning that are presented on the monitoring system . The first appears when the battery has less than 30% power and the second appears when it has less

9

# :=1 

# _.. ERICSSON than 15% power. The sUAS will return to its ground station with at least 15% battery power reserve should that occur prior to the 25 minute flight time. An equivalent level of safety can be achieved by limiting flights to 20 minutes, or enough battery reserve to ensure that the sUAS lands at the ground station with at least 15% of battery power (as determined by the onboard monitoring system and the pilot) , whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and 11191
. 

### 14 CFR 

### 91 .203 (a) & 

### (b): Carrying civi l aircraft certificatio n and registration The regulation provides in part: (a) Except as provided in 91
.715, no person may operate a civil aircraft unless it has within it the following : (1) An appropriate and current airworthiness certificate
.. .. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The sUAS fully loaded weighs no more than 1 0 lbs. and is operated without an onboard pilot. Therefore there is no ability or place to carry certification and registration documents or to display them on the sUAS
. An equivalent level of safety will be achieved by keeping these documents at the ground flight control point where the pilot flying the sUAS will have immediate access to them , to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

### 14 C FR 

### 91 .405 (a); 

### 407 (a) 

### (1); 409 (a) 

### (2); 417 (a) & 

### (b): Maintenance inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) of this section , have discrepancies repaired as prescribed in part 43 ofthis chapter
.. .," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Ericsson. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual. An equivalent level of safety will be achieved because these sUASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time
. If mechanical issues arise the sUAS can land immediately and



### 10

# ::;; 

# _.., ERICSSON will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety
. 8900.227 Paragraph 16 (c) (4) PIC Medical. and Paragraph 16 (e) (1) Observer Medical. This policy provides that both the PIC and observer must have a valid FAA secondclass medical certificate issued under part. 67 in orderto perform as a pilot or observer. Requiring the crew to meetthe same medical requirements as commercial pilot carrying passengers in a large aircraft is an unnecessary burden. We propose that the minimum medical requirements be vision corrected to 20/20 and a valid , state-issued driver's license. The risk of both the PIC and observer becoming incapacitated atthe same time and suddenly is very low. Further, since the sUAS is operating close to the ground , it could be brought in for landing in a very short time if incapacitation was suspected
. Finally, most sUAS's are equipped with an automatic return to home feature which would provide a final level of safety
. We feel this would provide an equivalent level of safety. Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules:14 CFR 21, subpart H; 14 CFR 45.23 (b); 45.27 (a) ; 14 CFR 61.113( a) & (b); 14 CFR 91
.7 (a); 91
.9 (b) (2) ;91
. 103 (b) ; 91.1 05; 91.1 09; 91.119; 91.121; 91.151 (a);91.203 (a) & (b); 91.405 (a); 91.407 (a) (1 ); 91.409 (a) (2); 91
.409 (a) (2) 

### &91.417 (a) 

### & (b); 8900
.227 §16 (c) (4) and §16 (e) (1) to operate commercially a small unmanned vehicle (55 lbs. or less) in various data and telecommunication projects and installations as part ofthe service delivery, Approval of exemptions allowing commercial operations of sUASs in the data and telecommunication industry enhances safety while reducing risk
. Manned aircraft monitoring and surveying creates a greater risk because the craft are much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS weighing fewer than 10 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board
. The sUAS will carry no passengers or crew and , therefore , will not expose them to the risks associated with manned aircraft flights. The operation of sUASs , weighting less than 10 lbs. , conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein , including exempting the applicant from the requirements of Part 21 and allowing commercial operations
. These lightweight aircraft operate at slow speeds, close to the ground , and in a sterile environment and, as a result , are far saferthan conventional operations conducted with turbine helicopters operating in close proximity to the ground and people
.

11

# ~ 

# _.., ERICSSON Privacy All flights will occur over controlled access private property with the private property owner's prior consent and knowledge
. Images taken may include individuals who have also given consent to being filmed or otherwise have agreed to be in the area where aerial photography will take place
. Summary Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-size, weight, speed , operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security- provide more than adequate • justification for the grant ofthe requested exemptions allowing commercial operation of applicant's sUASs in the telecom and data technology services industry pursuant to the Operations Manual appended hereto
.

ISCO A. Rullan Legal Counsel Ericsson Caribbean, Inc. City View Plaza II Suite 6010 Guaynabo, PR 00968 Tel. 954-804-5724 Francisco.rullan@ericsson.com



### 12

# ~ 

# ....., ERICSSON 

# Ericsson Operational Manual Small Unmanned Aircraft System (sUAS): Phantom 2 Vision+ PROCEDURE MANUAL



# -

- -



# - /

RevB

### Commitment of Accountable Manager This Operations Manual describes the organization and procedures by which Ericsson Caribbean Inc
. Puerto Rico carries out its Small Unmanned Aircraft Operations
. It is accepted that these procedures do not override the necessity of complying with any new or amended regulation published by the Federal Aviation Administration (FAA) from time to time , where these new or amended regulations are in conflict with these procedures.

Signed
........ ..... ... ...... . ....... ...... .. ...... ............................. ..... ........ ... ...... For and on behalf of Registered Company Name: Ericsson Caribbean Inc
. (EPR) Registered Address: City View Plaza 48 Carr 165 Suite 601 0 Guaynabo PR 00968 Puerto Rico, USA. Enquiries regarding the content ofthis document should be addressed to: diego.rafael.cardenas@ericsson.com

### 1 Administration, Control & 

### Responsibilities
...................................6 1.1 Purpose
.............................................................................................6 1.2 Scope
................................................................................................6 1.3 Definitions and Abbreviations
.............................................................

### 6 1.4 Document Control and Amendment Process
.....................................7 1.5 Referenced Documents
.....................................................................7 1.6 Organization
......................................................................................7 1.7 Insurance Information
........................................................................8 1.8 Nominated Personnel
........................................................................8 1.9 Responsibilities
..................................................................................8 

### 2 Crew Composition, Qualification & Health requirements .............9 2.1 Flight Team Composition
...................................................................9 2.2 Qualification Requirements
................................................................9 2.3 Lone Working
...... . ........................................... . ................................. 9 2.4 Crew Health
....................................................................................... 9 2.5 Operation of Multiple types of sUAS
..................................................9 

### 2.6 Supervision ofsUAS Operations
........................................................9 2.7 Logs and Records
............................................................................ 10 2.8 Useful Android Applications
............................................................. 10 

### 3 Operational Procedures
............................ ... ................................. 11 3.1 Types of Operations
........................................................................ 11 3.2 Operating limitations and conditions
................................................ 11 

### 4 Flight Planning and Preparation ................................................... 12 4.1 Determination of intended task and feasibility
.................................. 12 4.2 Operating Site Location and assessment......................................... 12 4.3 Risk Management................................................................. ..... .. .... 12 4.4 Pre-notification
................... . ............................................................. 

### 12 4.5 Site Permissions
.............................................. . ............................... 13 4.6 Weather
........................................................................................... 13 4.7 Preparation and serviceability of equipment and sUAS
.................... 13 4.8 Software Upgrades and Calibration
................................................. 13 4.9 Charging and fitting Batteries
........................................................... 13 

### 5 On Site Procedures ........................ ................ ............................... 14 5.1 Site Survey
...................................................................................... 14 5.2 Selection of operating areas and alternatives
.................................. 14 5.3 Crew Briefing
................................................................................... 14 5.4 Controlled Access Measures
........................................................... 14 5.5 Communications
.............................................................................. 15 5.6 Weather Checks
.............................................................................. 15 5.7 Loading of equipment
...................................................................... 15 

### 6 FLIGHT PROCEDURES.......................... ........................................ 16 6.1 Pre-embarkation
.............................................................................. 16 

### 6.2 Pre-flight
.............. . ...... .... ................................................................. 

### 16 6.3 Start-up
............................................................................................ 17 6.4 Take-off
........................................................................................... 17 6.5 In flight
............................................................................................. 17 6.6 Shut-down
....................................... ............................. ................... 17 

### 7 Absolute Rules............................................................................... 18

### 8 EMERGENCY PROCEDURES........................................................20 8. 1 Loss of power to engine
...................................................................20 8.2 Aircraft Battery Failure
.....................................................................20 8.3 Transmitter Battery Failure
..............................................................20 8.4 Loss of Control Frequency
...............................................................20 8.5 Malicious or accidental interference with control frequency
.............. 20 8.6 Pilot Incapacitation
...........................................................................21 8.7 Fly Away Action
....................................................... ........... ............. 21 8.8 Battery fire
.......................................................................................21 

### 9 AIRCRAFT OPERATION
................................................................

### 22 9.1 Technical Description
.......................................................................22 9.2 Aircraft Specifications
......................................................................23 9.3 Accident Prevention and Flight Safety Programme
..........................24 

### 10 APPENDIX A- PERMISSION FOR AERIAL WORK ...................... 25 11 APPENDIX 

### 8 ................................................................................... 26 11.1 sUAS Checklist- DJI Phantom
........................................................26 

### 12 APPENDIX C...................................................................................27 12.1 RECORDS AND LOGS
........ ..... .................. .... ........ ...... .................. 27 

### 13 APPENDIX D...................................................................................28 13.1 Risk Assessment
.......................................... .................. ................. 28

# 1 1.1

1.2

1.3 

# Administration, Control & Responsibilities Purpose The purpose ofthis document is to detail the items to be covered for the operation ofthe DJI Phantom Vision 2+ Small Unmanned Aircraft System (sUAS) by Ericsson Caribbean Inc
. personnel. 

## Scope This operations manual applies to all personnel involved with the operation ofthe DJI Phantom Vision 2+. By law, any aircraft operation in the national airspace requires a certificated and registered aircraft, a licensed pilot, and operational approval. Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) grants the Secretary ofTransportation the authority to determine whether an airworthiness certificate is required for a UAS to operate safely in the National Airspace System (NAS)
. A Small Unmanned Aircraft System [sUAS] is defined by the Federal Aviation Administration [FAA] A UAS is the unmanned aircraft (UA) and all ofthe associated support equipment, control station , data links, telemetry, communications and navigation equipment, etc., necessaryto operate the unmanned aircraft. The UA is the flying portion ofthe system , flown by a pilot via a ground control system , or autonomously through use of an on-board computer, communication links and any additional equipment that is necessary for the UA to operate safely
. The FAA issues an experimental airworthiness certificate for the entire system , notjust the flying portion of the system . This authority is being leveraged to grant case-by-case authorization for certain unmanned aircraft to perform commercial operations prior to the finalization ofthe Small UAS Rule, which will be the primary method for authorizing small UAS operations once it is complete. The Section 333 Exemption process provides operators who wish to pursue safe and legal entry into the NAS a competitive advantage in the UAS marketplace, thus discouraging illegal operations and improving safety
. It is anticipated that this activity will result in significant economic benefits, and the FAA Administrator has identified this as a high priority project to address demand for civil operation of UAS for commercial purposes. 

## Definitions and Abbreviations ATZ Aerodrome Traffic Zone CFR Code of Federal Regulations GHz Gigahertz 

### FAA Federal Aviation Administration MTOM Maximum Take-off Mass

## 1.4

1.5



## 1.6 NTSB OSD RC 

## RTH sUAS VLOS National Transport Safety Board On-Screen Display Radio Control Return to Home Small Unmanned Aircraft System Visual Line of Sight 

## Document Control and Amendment Process When any updates are necessary to Ericsson Caribbean Inc. sUAS Operations Manual, such as the adding of new aircraft, crew or sUAS operational uses, an amended Operations Manual will be sent to the Federal Aviation Administration for approval and the amendment noted in the amendments table. 

## Referenced Documents 1. Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA) 2. Notice of proposed rulemaking (NPRM), Federal Register 

### I Vol. 80, No. 35 

### I Monday, February 23, 2015 

### I Proposed Rules: Operation and Certification of Small Unmanned Aircraft Systems. 14 CFR Parts 21, 43, 45, 47, 61, 91, 101, 107, and 183 

## Organization Ericsson is the driving force behind the Networked Society- a world leader in communications technology and services. Our long-term relationships with every major telecom operator in the world allow people, businesses and societies to fulfil their potential and create a more sustainable future. Our services, software and infrastructure- especially in mobility, broadband and the cloud

- are enabling the telecom industry and other sectors to do better business, increase efficiency, improve the user experience and capture new opportunities. Ericsson Caribbean Inc. was founded 1999 (company registration number 106645) with office address; City View Plaza, 48 Carr 165 Suite 6010, Guaynabo PR 00968, Puerto Rico, USA. Ericsson Caribbean Inc. has 100 employees providing services to the entire America continent. Parent company Telefonaktiebolaget LM Ericsson (company registration number 556016- 0680) was founded 1876 and with global headquarter in Stockholm, Sweden. Total Number of employees worldwide 118,055, whereof 15,516 in North America and 11,066 in Latin America Forty percent ofthe world's mobile traffic is carried over Ericsson networks.

# 2
2.1

2.2



## 2.3

2.4

2.5

2.6 

# Crew Composition, Qualification & Health requirements Flight Team Composition Normal operations: sUAS Pilot. More demanding operations may require a payload operator or additional crew. 

## Qualification Requirements All personnel operating Ericsson Caribbean Inc. sUAS must have undertaken the following : • FAA approved ground training • FAA approved flight demonstration 

## Lone Working All personnel operating Ericsson Caribbean Inc. sUAS must adhere to the following: • Group Directive, 034 02-3132 Uen , Occupational Health and Safety 

## Crew Health All personnel operating Ericsson Caribbean Inc. sUAS must have a level of medical fitness equivalent ofthose required for a Private Pilot's License; however no formal certification is needed at this point. 

## Operation of Multiple types of sUAS Upon the introduction of a new variety of sUAS the Ericsson Caribbean Inc. sUAS Operator must familiarize themselves with the Operating procedures for that sUAS
. 

## Supervision of sUAS Operations All operations must comply within the Ericsson Group Management System. Those instructing the sUAS Operations must ensure that the sUAS Operators comply with FAA Regulations & Ericsson sUAS Operations Manual.

## 2.7

2.8 

## Logs and Records On each operation, specific logs ofthe following will be recorded: • Onsite weather conditions • Battery voltage before and after each flight • Pilot hours • Aircraft hours • Any incident small enough not to warrant Mandatory Occurrence Reporting • Lone Working 

## Useful Android Applications DJI Phantom Flight Helper For DJI Phantom Quadcopter Users Led light explanations Pre-flight Checks Setup Wizard Software Installation FAQ Phantom Forum DJI Dealers DJI Spare Parts Pro Version Also for non-Phantom Vision 2 + sUAS Flightlog - Pilot's Logbook Specific logs are attached and featured in Appendix C ofthis manual. http://www.staysafeapp.com/ For use when Lone Working

# 3 3.1

3.2 Aircraft Type 

# Operational Procedures Types of Operations The majority of Ericsson Caribbean Inc. sUAS operations will entail aerial photography and videography for the following: • Line Of Sight (LOS) Surveys • Site Feasibility Studies (Site Acquisition surveys) • Site Physical Installation Audits • OASIS (Quality Audits on Installations) • Health & Safety inspection and audits • Trouble shooting and inspection of corrective works • Drive test/signal test horizontally and vertically • Thermal inspection of antennas, active elements and cabling • Customer acceptance inspection Ericsson Caribbean Inc
. reserves the right to explore new operational uses within the confines ofthe FAA regulations & the guidelines highlighted within this manual. 

## Operating limitations and conditions DJI Phantom Vision 2 + Operational Ceiling 2624ft amsl Operational Endurance 25 mins Maximum Speed 49ft/s amsl Maximum OAT +40C Minimum OAT -OC Maximum Wind speed for operation 20kts

# 4 4.1



## 4.2



## 4.3

4.4 

# Flight Planning and Preparation Determination of intended task and feasibility Before the commencement of any operation , Ericsson Caribbean Inc
. sUAS Operator will evaluate the proposed task, ensure that the operation is possible within the bounds of safety, regulation and practicality, and ifthe desired outcome is achievable for the activity
. Ifthe operation falls outside these bounds and cannot be modified to comply, it will not be undertaken
. 

## Operating Site Location and assessment
• Before the commencement of any operation , Ericsson Caribbean Inc. sUAS Operator will research the proposed locations suitability for sUAS operations . • This may include: • Aeronautical map information to check the proximity ofthe proposed site to airfields, the airspace the location falls inside and any Notice to Airmen (NOT AM) which may affect the operation. • Proximity to obstacles such as structures, buildings & bridges. • Proximity to any source of radio interference such as high intensity radio masts, power lines. • Proximity to residential housing and populace
. • The topography ofthe area. • Retrieving information and contact details on local Police Office Stations, hospitals and fire brigade in the event of an emergency. 

## Risk Management A risk assessment matrix (Appendix D) shall be used to help evaluate the potential risks of a particular operation and highlight the areas where safety gains may be made. If not enough can be done to mitigate the highlighted risks and the calculated value considered too high , the operation will be cancelled. 

## Pre-notification Should the site fall within a congested area, controlled airspace of within 5NM/ 8KM of an aerodrome boundary, contact will be made with the FAA and controlling authority requesting permission for the operation. The operation will onlytake place after written permission has been achieved. Ifapplicable, local Police Office may also be notified.

## 4.5

4.6

4.7

4.8

4.9 Site Permissions Permission must be obtained from those within 50m oftake-off & landing. Additional permission from site providers or agents must be sought in accordance with site access requirements & agreements. 

## Weather The sUAS Operator must familiarize themselves with the long range weather forecasts for the area. This will inform the Operator ofthe conditions likely to be faced at the site and any precautions which should be taken. In the event ofweather conditions that fall outside ofthe operational envelope ofthe aircraft, the operation will be cancelled or postponed. Onsite weather checks will also be carried out by the sUAS Operator
. 

## Preparation and serviceability ofequipment and sUAS Before an operation, a pre-flight check will also be made ofthe aircraft as shown in the pre-flight checklist in Appendix B. If any maintenance or repair works have been carried out on the aircraft, a flight test will be carried out to prove serviceability and safety
. The sUAS will be serviced by an approved competent person annually, and replaced after 

### 10,000 flight hours. 

## Software Upgrades and Calibration During Preparation the sUAS Operator is to conduct a check for SW upgrades and Calibration ofthe GPS system on board the aircraft
. This requires periodic checks for software updates
. The application required- DJI Phantom 

### 2- Naza-M Assistant Software v2.20 

## Charging and fitting Batteries Lithium Polymer batteries are used to power Ericsson Caribbean Inc
. sUAS. An undesirable by-product ofthese batteries is the ability to self-combust. Caution must be used in the care and management ofthe flight packs
. Flight batteries may be charged using chargers approved by the sUAS Manufacturer specifications & in accordance with Manufacturer guidelines. Flight packs will have their cell voltages recorded before and after charging in the battery log. (See Appendix C) Real time monitoring offlight pack voltage will be available to the pilot on an on screen display via live telemetry.

# 5 5.1

5.2

5.3

5.4 

# On Site Procedures Site Survey Ericsson Caribbean Inc. sUAS Operator will carry out the onsite survey to check that the site is as expected from the research on the intended location. Any variations on this information will be evaluated to ensure continued safety and suitability ofthe operation
. 

## Selection of operating areas and alternatives Onsite, a suitable take-off and landing site will be chosen that fits the requirements ofthe operation. A second landing site may also be chosen ifthere is the possibility ofthe first being compromised. 

## Crew Briefing Before the operation commences the crew must be briefed on the following : • The purpose ofthe operation • Applicable airspace considerations • Individual's responsibilities • Relevant safety information • Emergency procedures 

## Controlled Access Measures Having paced the area in which the Operation will take place the sUAS Operator should identify landmarks on the periphery ofthe operation so as to provide a reference for the restricted area. In each case the sUAS Operator should consider whether it is appropriate to place restrictions [cordon off] the take-off and landing area in order to keep third parties safe from sUAS operations.

## 5.5

5.6

5.7 Communications Ericsson Caribbean Inc. sUAS Operator should ensure they have full concentration on the Operation & to consider the risk of external distractions as part ofthe Operation Risk assessment. If operating as a lone worker, the sUAS Operator is prohibited from using other communications devices, non-essential to the Operation. Ericsson Caribbean Inc. sUAS operations crew may communicate using two way radio headsets
. This will ensure that difficult communication due to outside noise or distance between the crew will not compromise the safety or efficiency ofthe operation. If applicable the payload operator will have an ear free in order to listen to 3m Party input, or outside warnings. The pilot will receive any safety warnings or 3m Party input via the payload operator. This ensures no disturbance to the pilot's concentration from unwanted sources and only essential information is relayed
. The pre-flight briefing will cover the eventuality of crew communications failure and the procedures to be taken. These communications devices will not operate on a conflicting frequency to any flight operations equipment and Ericsson Caribbean Inc. sUAS Operators will hold any radio license (if required) to operate them. 

## Weather Checks Forecasts will be updated before all flights & captured in the Risk Assessment. Wind speed will be measured using handheld anemometer prior to take off & recorded in the flight log checklist. 

## Loading of equipment All payloads must be operated within the range limitations set down in the manufacturer's manual. However, payloads on the Ericsson Caribbean Inc. sUAS cannot be altered. The Phantom Vision 2+ has an integrated Camera/Gimbal Unitthat is not modular. Correct function will be assessed onsite before attempting the operations.

# 6

6.1

6.2 

# FLIGHT PROCEDURES Checklists are employed to ensure all equipment needed is present, that the sUAS to be flown is in an airworthy condition and that steps are taken in the correct sequence and without omission
. In cases where are two party crew are onsite both personnel should be involved in checklist completion , and ifthis is the case, a 'challenge-response' method will be utilized
. 

## Pre-embarkation A pre-embarkation checklist ensures all equipment needed to safely complete an operation is present. 

## Pre-flight The pre-flight checklist runs through the procedure used to inspect the aircraft and payload to ensure its airworthiness. This also includes a last-minute voltage check ofthe flight batteries to ensure sufficient charge
. The sUAS Operator should take time to assess the area in which the Operation will commence. This includes pacing the local & identifying the primary & a secondary landing area (as per Checklist). The Ericsson Caribbean Inc
. sUAS flight limits are configured within per FAA regulations
.

StltdltnQIICIIc* "OoollnClt...,.
... tolllolglll 

# -- '**

**~...,_** IIISpoollkn·lor dltllll M spercill.._..lltMon lhoo.J_____ .. $prglf ...

### "'few.... " R-toUIOf_lof_._ 

# J -

**-~** t20m

.. !500111

A -·

**-~**

# 6.3

6.4

6.5



# 6.6 Start-up The start-up checklist runs through the power-up procedures of all flight operation equipment to the take-off phase offlight. sUAS modes will be confirmed through LED & on-screen display indications (OSD). The pilot will announce 'Rotors On' before application of power. 

## Take-off When the sUAS Operator is ready for take-off, after a last scan to ensure no hazards exist, the pilot will start the timer and announce 'taking off before starting the engines
. The aircraft will then lift-off to a height of around 4-6ft offthe ground to clear the ground effect of its propellers. A flight controls check is then performed to satisfy the pilot that the aircraft responds as it should to his control input before departing to start the task. 

## In flight The sUAS Operator's primary concern whilst airborne is the safety of personnel and other airspace users. The sUAS Operator will: • Ensure that all regulations are adhered to. • Monitor elapsed flight-time and ensure to land before the estimated time for battery depletion as well as monitoring LED/ OSD indications for low power. • Fly the sUAS with anticipation of potential failures at all times and will ensure Failsafe and Return-to-home (RTH) features are armed at all times
. • Sacrifice the craft over the safety of personnel and property. • Landing • After returning from the operation , the pilot will scan the landing site for hazards. Once satisfied , the pilot will call 'Landing' before lowering the aircraft to the ground
. 

## Shut-down When the sUAS has come to a rest after landing, the shut-down checklist will be completed. Upon shutdown ofthe rotors the pilot will call 'rotors off and will never apply further power without briefing the crew. Subsequent actions will include unplugging the aircrafts flight batteries first to make the aircraft safe and then on to the shut-down of radio links, video uplinks and the payload. Otherthan the safety aspect of unplugging the flight packs, the main aim ofthe shut-down checklist is to ensure that no equipment is left on. Specific checklists are attached and featured in Appendix B ofthis manual.

# 7 Absolute Rules Regardless ofwhether segregated airspace has been granted or not, LM Ericsson IAA Permission for Aerial Work and Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA) and the Notice of proposed rulemaking (NPRM), Federal Register 

### I Vol. 80, No
. 35 

### I Monday, February 23, 2015 

### I Proposed Rules: Operation and Certification of Small Unmanned Aircraft Systems
. 14 CFR Parts 21 , 43, 45, 47, 61 , 91 , 101 , 107, and 183, the following absolute rules must be adhered to: • sUAS shall not be operated beyond Visual Line of Sight (VLOS) and not further than 500 meters from the point of operation
. Operators may work with a visual observer, but the operator still must be able to maintain visual line of sight • sUAS shall not be operated at a height of morethan 400 feet (120 meters) above ground level and no faster than 100 mph • Flights must take place during daylight hours • The operator must assess weather conditions, airspace restrictions and the location of people to lessen risks if he or she loses control ofthe sUAS • sUAS shall not be operated over or within the confines of a congested area except with the written permission ofthe Authority • sUAS shall not be operated over any assembly of persons on the ground nor closer than 150 meters laterally from such an assembly • sUAS shall not be operated within 150 meters of any person , vessel , veh icle or structure not underthe control ofthe sUAS operator; during take-off or landing however, the aircraft must not be flown within 50 meters of any person , unless that person is under the control ofthe sUAS operator. • sUAS shall not be operated within an aerodrome traffic zone or closer than 8 kilometers (5 nautical miles) from an aerodrome boundary, whichever is the greatest distance, except with the written permission ofthe Air Controlling Authority. • sUAS shall not be operated closer than 2 ki lometers from an aircraft in fl ight. The operator must always see and avoid manned aircraft
. Ifthere is a risk of collision , the drone operator must be the first to maneuver away • sUAS must stay out of airport flight paths and restricted airspace areas, and obey any FAA Temporary Flight Restrictions (TFRs) • sUAS shall not be operated unless there is in place a third party liability insurance policy covering the operation ofthe system wh ich is acceptable to the Authority • The drone must be registered and aircraft markings are required • Operators must be 17 years old , pass an aeronautical knowledge test, hold an FAA UAS operator certificate, and pass a TSA background check
. • Aeronautical knowledge testing must be renewed every 24 months (no private pilot license or medical rating would be required)• Operators must ensure their aircraft is safe for flight, but there are no airworthiness standards or certification requirements (a preflight inspection conducted 

### by the operator, checking communications links and equipment is sufficient) • Operators must report an accident to the FAA within 10 days of any operation that results in injury or property damage • No operations are allowed in Class A ( 18,000 feet & above) airspace. Operations in Class B, C, D and E airspace are allowed with the required ATC permission , Operations in Class G airspace are allowed without ATC permission • The proposed rule maintains the existing prohibition against operating in a careless or reckless manner. It also would bar an operator from allowing any object to be dropped from the UAS • The operator must discontinue the flight when continuing would pose a hazard to other aircraft, people or property

# 8 8.1

8.2

8.3

8.4

8.5 

# EMERGENCY PROCEDURES Loss of power to engine Motor failures may cause the sUAS to enter an uncontrolled descent. Multi-rotor aircraft have no gliding capability and this kind offailure will certainly result in a crash
. A loud warning will be called by the sUAS Operator to anyone near to make them aware ofthe situation and potential danger
. 

## Aircraft Battery Failure This is the same as total motor failure on single battery aircraft. The aircraft will quickly descend to the ground, uncontrollably with no power. Should the battery fail , the aircraft will descend uncontrolled, and a loud warning will be called to help those around to avoid the danger
. 

## Transmitter Battery Failure The Ericsson Caribbean Inc. Puerto Rico sUAS are equipped with an integrated Failsafe System
. This system is set up to "fail safe" in the event of loss of control link to the aircraft which is what will happen in this event. Failsafe mode will give control to the flight controller which will climb the aircraft to 60m altitude if below that height, or stay at its present height, ifabove 60m
. The aircraft will then return on this altitude above its departure point and wait for 30 seconds to see if it can re-establish the control link
. Should this not be possible, the aircraft will auto-land at its departure point and shut-down its motors, the shut-down checklist will then be read by the sUAS Operator. The designated sUAS Operator will ensure this mode is armed before flight. 

## Loss of Control Frequency Having been pre-configured as part ofthe pre-flight checklist failsafe parameters, the aircraft will be programmed to enter Autoland/ RTH mode. In the event of an Autoland/ RTH the shut-down checklist will be read and the aircraft made safe
. Investigations will then be made into the failure ofthe control frequency and the Incident Report will be completed
. No further flights will take place at that site until a cause and resolution has been found
. 

## Malicious or accidental interference with control frequency Ifthe source ofthe interference cannot be found and stopped , the operation will be cancelled
.

## 8.6

8.7

8.8 

## Pilot Incapacitation Should the sUAS become incapacitated for any reason the sUAS will activate the returnto-home function once the battery reaches a pre-configured warning level. Return-tohome mode will give control to the flight controller wh ich will climb the aircraft to a predetermined altitude (usually set to 60m) if below that height, or stay at its present height, ifabove 60m. The aircraft will then return to overhead its departure point and wait for 30 seconds for further instruction
. If none are received , the aircraft will auto-land at its departure point and shut-down it's motors. The aircraft will be made safe and appropriate help given to the pilot. 

## Fly Away Action Fly Away's are uncontrolled aircraft flight where no control input from the pilot has any effect. A Fly Away is very unlikely but still may occur. Ifthe aircraft does not encounter any obstacles, the auto-land feature is likely to be activated when the battery is depleted and the aircraft will attempt to land wherever it is. The other possibility is a collision with an obstacle orthe ground. Should a fly-away occur, the sUAS Operator will note the speed and flight direction ofthe aircraft and inform local Air Traffic Control , ifapplicable, and the local Police Office
. A reasonable estimation could be made about the potential range of a fly-away from the battery duration remaining and the aircrafts speed. Before fl ight, the sUAS Operator will ensure that the main controller is programmed to limit flight to 500m range and 400ft altitude
. This may limit the range the sUAS will travel. 

## Battery fire LiPo batteries in their initial stages (10-15secs) are almost impossible to extinguish. The sUAS Operator must have a fire extinguisher on hand to extinguish any secondary fires which may occur. All fires will be reported with an Incident Report and tothe relevant authorities DJI Smart Flight Battery Safety Guidelines to be adhered

# 9 AIRCRAFT OPERATION 9.1 Technical Description 9.1.1 Designation and Type OJ I Phantom Vision 2 

### + Model No. - PV331 

### Serial No.- PH645475998 V3.0 CE



# ·- .,. "

# ........

## 9.2 Aircraft

Gimbal

Camera

Remote Control

Range Extender

DJI VISION App 

## Aircraft Specifications Supported Battery Weight (Battery & Propellers Included) HoverAccuracy (Ready To Fly) Max Yaw Angular Velocity Max Tiltable Angle Max Ascent 

### I Descent Speed Max Flight Speed Diagonal Motor -Motor Distance Working Current Control Accuracy Controllable Range Maximum Angular Speed Operating Environment Temperature Sensor Size Effective Pixels Resolution HD Recording Recording FOV Operating Frequency Communication Distance (Open Area) Receiver Sensitivity ( 1%PER) Transmitter Power Working Voltage Built-In LiPo Battery Working CurrenVCapacity Operating Frequency Commun ication Distance (Open Area) Transmitter Power Power Consumption System Requirement Of Mobile Device Mobile Device Support DJI 5200mAh LiPo Battery 1242g Vertical: 0.8m ; Horizontal: 2.5m 200°/s 35° Ascent: 6m/s; Descent: 2m/s 15m/s (Not Recommended) 350mm Static : 750mA; Dynamic : 900mA ±0.03° Pitch : -90°

# -oo Pitch : 90°/s 0°C-40°C 1/2.3" 14 Megapixels 4384x3288 1

080p30 & 720p 110° 

### I 85° 5.728 GHz-5.85 GHz CE Compliance: 400m ; FCC Compliance: 800m -93dBm CE Compliance: 25mW; FCC Compliance: 1 OOmW 120 mA@3.7V 3.7V, 2000mAh 2412-2462MHz 500-?00m 20dBm 2W iOS version 6.1 or above/ Android system version 4.0 or above iOS recommended : iPhone 4s, iPhone 5, iPhone 5s, iPhone 6, iPhone 6 Plus, iPod touch 5 Android recommended : Samsung Galaxy S3, S4 , 

### Note 2, Note 3 or phones of similar configuration

## 9.3 

# Accident Prevention and Flight Safety Programme Safety is paramount to Ericsson Caribbean Inc. A constant learning process is employed where incidents are noted including their context, in order to prevent repeats. Depending on the seriousness ofthe incident, it may be just recorded in Ericsson Caribbean Inc. own incident log
. This is for small occurrences, such as minor sUAS Operator errors that could have led to damage to Ericsson Caribbean Inc
. equipment or compromise the quality of the service provided to customers. These minor incidents, however, would pose no risk of injury to people or damage to property. More serious events would need to be reported in the FAA's and National Transport Safety Board AccidenUincident Information Reporting Scheme
. http://www.ntsb.gov/ layouts/ntsb.aviation/index.aspx Examples of NTSB reportable occurrences would be: • Loss of control/data link • Navigation failures • Any incident that injures a third party • Battery damage orfire • Mechanical failure ofthe motors Information retrieved in this log will be implemented in checklists or flight safety briefings in the future to ensure a constant process of improvement.

# 10 APPENDIX A- PERMISSION FOR AERIAL WORK

Insert specific Permission in here once received from the FAA.

# 11 APPENDIX B 11.1 sUAS Checklist- OJI Phantom Title : sUAS Checklist- OJI Phantom Document Number: LMI-14:003329 Uen Revision : A Prepared By: 

### LMI/ROR/IDA Sean Fox

# 12 APPENDIX C 12.1 RECORDS AND LOGS Title: sUAS Flight Records & Logs Document Number: LMI-14:003328 Uen Revision: A Prepared 

### By: LMI/ROR/IDA Sean Fox

# 13 APPENDIX D 13.1 Risk Assessment
Title: Risk Assessment - Working with sUAS Document Number: LMI-14:003327 Uen Revision : A Prepared By: 

### LMI/RORIIDA Sean Fox