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April30, 2015 

U. S. Department of Transportation Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Dear Sir or 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 for the 

sUAS. This Operations Manual was developed in Ericsson Ireland as part of the 

licensing requirements of the 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 pursuant to 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 under the Freedom of 

Information Act 5 USC 552 et. seq. 

Thank you for your time and consideration, and please let us know if you have any 

questions. 

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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 

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ERICSSON 

April 30, 2015 

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

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 of the FAA Modernization and Reform Act of 2012 (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 of the 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 of sUAS 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 of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) 

responsibilities to " ... establish requirements for the safe operation of such aircraft 

systems in the national airspace system." Section 333 (c) of the Reform Act. 

The name and address of the applicant is: 

Ericsson Caribbean, Inc. 

City View Plaza Tower II 

Suite 6010 

Guaynabo, Puerto Rico 00968 

USA 

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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) of this section or any sections 44702-44716 of 

this title if the 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} of the 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). If the Secretary determines that a sUAS "may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system." /d. §333 (c). 

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Ericsson's sUASs are multi rotor 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 

of the national airspace system or the public." Reform Act Section 333 (b). 

Given the small size of the 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 of the 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 of safety surrounding 

the proposed operations, and the significant public benefit, including enhanced 

safety, the grant of the 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) of the 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 

of the 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 of the 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 of workplace 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 

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lithium ion batteries, as opposed to fossil fuels burned in operation of small aircraft that 

are many hundreds of times heavier. 

1 "Commonly Used Statistics", Occupational Safety & Health Administration. Available at: 

https:/ /www. osha .gov/oshstats/commonstats. htm I 

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 1 0 lbs. 

3. Minimum crew for each operation will consist of the sUAS PIC. 

4. An observer will be utilized if the 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/or text. 

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 of 200 feet AGL, never exceeding 

400 feet AGL. 

7. Flights will be operated in Class G airspace whenever possible. If operation 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 under visibility and cloud clearance 

requirements equivalent to Visual Flight Rules (VFR). 

9. The sUAS will at all times give way to any aircraft carrying persons. 

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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/or flight 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 of the 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 of the sUAS to 

be operated. This will include operation of the 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 pilot will establish a working relationship with a representative at the 

local Right Sta1dards District Offioos (FSOO) with which to annually review safety 

procedures 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 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the 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 

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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 or flammable 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 of operation 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 of the 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 of the UAS in compliance with 45.27 (a) where the pilot, 

observer and others working with the sUAS will see the identification of the sUAS as 

"Experimental." The FAA has issued the following exemptions to this regulation: 

Exemptions Nos. 10700, 8738, 10167 and 10167A. 

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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 of the 

sUAS are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations of the 

sUAS as requested with a pilot who has met the minimum requirements stated in 

chapter 2.2 of the 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. 

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14 CFR 91.103: Preflight Action 

This regulation requires each pilot in command take certain actions before flight to 

ensure the safety of flight. 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 of the 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 

like 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 of safety 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 of the 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, which 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. 

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The equivalent level of safety will be achieved given the size, weight, speed of the 

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 of the advance notice to 

the property owner and any onsite personnel as outlined in the Manual, all affected 

individuals will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighting far more than the maximum 1 0 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 of the 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 longer time 

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 of the 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 

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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 civil 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) of this 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 on board 

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 CFR 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 of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this 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 

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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 order to perform as a pilot or observer. 

Requiring the crew to meet the 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 at the 

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 of the 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 safer than conventional operations conducted with turbine 

helicopters operating in close proximity to the ground and people. 

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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 of sight and national security- provide more than adequate • 

justification for the grant of the 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 of this 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 of sUAS 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 of this document is to detail the items to be covered for the operation of the 

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 of the 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 of Transportation 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 of the 

associated support equipment, control station, data links, telemetry, communications and 

navigation equipment, etc., necessary to operate the unmanned aircraft. 

The UA is the flying portion of the 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, not just 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 of the 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 of the 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 of the 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 of those 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 of the 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 of this 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 of the 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 if the desired outcome is achievable for the activity. 

If the 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 of the 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 of the 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 only take place after written 

permission has been achieved. If applicable, 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 of take-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 of the conditions likely to be faced at the site and 

any precautions which should be taken. In the event of weather conditions that fall 

outside of the operational envelope of the aircraft, the operation will be cancelled or 

postponed. Onsite weather checks will also be carried out by the sUAS Operator. 

Preparation and serviceability of equipment and sUAS 

Before an operation, a pre-flight check will also be made of the 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 of the 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 of these batteries is the ability to self-combust. Caution must be 

used in the care and management of the 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 of flight 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 of the operation. 

Selection of operating areas and alternatives 

Onsite, a suitable take-off and landing site will be chosen that fits the requirements of the 

operation. A second landing site may also be chosen if there is the possibility of the first 

being compromised. 

Crew Briefing 

Before the operation commences the crew must be briefed on the following: 

• The purpose of the 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 of the 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 of the 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 of the 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 Unit that 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 if this 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 of the 

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. 

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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 of flight. 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 off the 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 of the 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. Other than the safety aspect of unplugging the flight 

packs, the main aim of the shut-down checklist is to ensure that no equipment is left on. 

Specific checklists are attached and featured in Appendix B of this manual. 
7 Absolute Rules 

Regardless of whether segregated airspace has been granted or not, LM Ericsson IAA 

Permission for Aerial Work and Section 333 of the 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 more than 400 feet (120 meters) above 

ground level and no faster than 1 00 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 of the sUAS 

• sUAS shall not be operated over or within the confines of a congested area except 

with the written permission of the 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, vehicle or 

structure not under the control of the 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 of the 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 of the Air Controlling 

Authority. 

• sUAS shall not be operated closer than 2 kilometers from an aircraft in flight. The 

operator must always see and avoid manned aircraft. If there 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 of the system which 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 of failure will certainly result in a crash. A loud 

warning will be called by the sUAS Operator to anyone near to make them aware of the 

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, if above 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 of the 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 of the 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 

If the source of the 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 which will climb the aircraft to a 

predetermined altitude (usually set to 60m) if below that height, or stay at its present 

height, if above 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. If the 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 or the ground. Should a fly-away occur, the sUAS Operator will note the 

speed and flight direction of the aircraft and inform local Air Traffic Control, if applicable, 

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 

flight, 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 to the 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) 

Hover Accuracy (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 

Communication 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 of the 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 or fire 

• Mechanical failure of the 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