## Petition for Exemption for Huawei Technologies USA under FAA

Modernization and Reform Act of 2012, Public Law 112

- 95 FEB. 14, 2012, Section 333

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

To Whom I t May Concern,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Huawei Technologies USA. (“Huawei”) hereby applies for an exemption from all airworthiness certification requirements under the FAA Modernization and Reform Act of 2012, Public Law 112

- 95 FEB. 14, 2012,
Section 333 to allow commercial operations of small unmanned aerial system (“sUAS”).

For your convenience, Huawei has organized this Exemption request as follows:
I. Petitioners Description II. Relevant Statutory Authority
III. Public Interest IV. Safety Considerations
V. Summary Description for Registrars Database
VI. Additional Information
VII. Summary

I. PETITIONERS DESCRIPTION

Huawei is a telecom infrastructure and services provider operating as an independent legal entity based in Plano, Texas . Huawei serves over 55+ customers and roughly 25000+ installed sites across the USA. Additionally, Huawei has been operating in the USA since 2001 and plans to further service it’s existing and future customers under the above referenced request for exemption.

The Contact Information for Petitioner is as follows :

Applicant Name: Tim Danks Company Name: Huawei Technologies USA Address: 5700 Tennyson Parkway, Plano, Texas, 75025 Contact Information: Cell: 469 733 0924, Email: tim.danks@huawei.comII. RE LEVANT STATUTORY AUTHORITY

Huawei submits a petition for exemption under FAA Modernization and Reform Act of 2012,
Public Law 112

- 95 FEB. 14, 2012, Section 333 for use of s UAS aircraft in accordance with the requirements of th e exemption allowance within the N ational Airspace . As part of Huawei ’s ongoing telecom infrastructure business in the USA we intend to provide additional supporting services for telecom site survey and inspection for our customers. Huawei is requesting relief from FAA regulation in accordance with Section 333 in order to operate sUAS for commercial

purposes that will benefit the public and will not adversely affect safety

.

III. BENEFIT TO PUBLIC

The requested exemption will enable Huawei to benefit the public as a whole. Congress’s national policy favors early integration of UAS into national airspace in controlled, safe working environments such as those proposed in this petition. The following are just some ways the public will benefit from Huawei’s proposal ;

Safety
Huawei considers s afety of site/tower activities primary benefit to the public as a whole. In the last seven ( 7 ) years there have been more than fifty ( 50 ) deaths and countless serious injuries related to tower climbing activities. In some cases the purpose of the climb was for simple o bservation
and inspection only and as a result these tragedies could have been avoided through the use of
sUAS aircraft. Utilizing available technology with commercially available s UAS systems

, Huawei has developed methodologies and software to provide detailed analytical and full 3D mapping of tower and site topologies which allow much safer inspection and reporting.

Connecting Rural America Another public enhancement is through the support o f Huawei’s customers while building the necessary infrastructure to provide rural America with high speed Broadband access. Until today

, rural America has been drastically underserved in comparison with dense urban and suburban areas of the country thus limiting the access to education, knowledge and general development in
a manner consistent with th ose larger populat ed areas. Th e prohibitive cost of deploying infrastructure to support rural a reas vs. the revenues returned to the network operators for these
services has made it difficult to achieve these goals . In conjunction with various initiatives to serve these areas many operators, both small and large, are now working to close these gaps but cost remains a significant factor in deploying these networks. Costs for a manned tower climb for simple survey and ob s erv ation work is expensive and time consuming due to both availability of tower crews and speed of work

. Utilizing sUAS technologies

, combined with Huawei’s methodologies and software will provide lower cost and faster response to be able to deploy these networks cheaper and faster for our customers . This will then allow for these savings and
the services to be provided to the end customer s (general public) much sooner.IV SAFETY CONSIDERATIONS :

Safety is Huawei’s primary focus when employing sUAS technologies and as such, Huawei would not adversely affect safety according to current FAA regulations and would

, in fact

, enhance
safe ty for telecom site inspection s and reporting preventing injury or death

. F urther, procedures developed and implemented by Huawei meet or exceed the current safety requirements established by the FAA in that Huawei uses top quality sUAS equipment and has policies in place for flight conditions, procedures and personnel training requirements.

More specifically, Huawei intends to utilize the DJI Phantom 2 Vision+ and/or DJI In spire1 sUAS aircraft for the purposes described above. DJI has been identified as the industry leader in sUAS
and t hese aircraft have been identified as some of the most stable and easily controlled in the industry. Combined with Huawei’s methodologies and software

, the tasks for site and tower

survey are simplified and automated to a degree that minimizes user error and ensures a consistently safe and secure flight each and every time.

Further, Huawei ’s F light E ngineers are provided with significant training on the aircraft, the tools, the regulations/requirements and all safety procedures for the operation of the aforementioned system. In conjunction with the manufacturer’s operations manuals

, s ome of the basic training
material is attached to this petition . Please note that the Huawei specific training materials are continuously updated to comply with US market requirements which further improve safety, operational capabilities and awareness.

V. Summary Description for Publishing in the Federal Register:

Huawei Technologies USA seeks exemption from all airworthiness certification requirements under the FAA Modernization and Reform Act of 2012, Public Law 112

- 95 FEB. 14, 2012, Section
333

VI. Additional Information Pertaining to this Exemption Request:

Huawei’s goal is to operate in an accident free environment by ensuring all employees are trained on the latest safety procedures for the sUAS they operate, being proactive when performing pre

flight operations and identifying any potential safety hazards, and demonstrating the ability to identify and appropriately eliminate hazards and risks to the aircraft as well as persons involved in the flight.

Huawei ’s sUAS will be used for survey and inspection of telecommunication towers

, according to
the below outline

. The vast majority of these sites will be in rural areas with no other persons in
the area

, aside from the flight engineer and visual observer.Purpose/Scope
Huawei will utilize the sUAS for our customers ’ pre

- site qualifications and survey, quality control audits, pre/post

- construction inspection, microwave path survey, RF line

- of

- site, antenna downtilt/azimuth verification, limited rooftop inspections, regulatory inspections, grounding line, fiber and cable installation and maintenance inspection.

Operational Borders
A ll rules of “no

- fly zones” and regulations under Section 333 will be strictly adhered to

. a) Horizontal
The aircraft operational horizontal borders below vertical limit of 200 feet will be defined by the customer site property requirements. The aircraft will be flown over a very small area of
land

, considered part of the tower site and compound

, in order to visually inspect and provide high granularity photographs and a 3D rendering of the site and tower area as well as 360 degree panoramic line of sight visua l s to adjacent sites. During the actual vertical tower inspection

, the aircraft will circle the tower at a distance of roughly 15

- 25 feet horizontally from the edge of the tower infrastructure

. The property in question will be owned/operated or leased by o ur customers with prior written approval for any inspection we undertake and thus

can be controlled to limit/restrict people in the immediate area of the flight path. b) Vertical
The general vertical operational limit within the site/compound horizontal borders is set to
200ft. Due to telecommunications tower heights ranging from 100 to 350 feet in height this may require some flights to extend above the 200 foot ceiling. In cases where the tower itself
exceeds this lim it the horizontal borders will be restricted to a 25 ft radius around the tower
structure and the vertical border will be defined by the tower height

, up to maximum 350ft, whereby t he aircraft will ascend to a height approximately 5 feet above the top of t he tower
for 5 to 10 seconds

, then descend to below tower maximum height for th e remainder of the flight. The h orizontal border for the tower inspection defined by Huawei’s policy i s maximum
25 feet from the tower . Thus, any air traffic in the NAS will spo t the tower top FAA lighting/warning beacon ( s ) from approximately 1+ miles out thereby eliminating any possible danger

. I n all cases, tower top FAA lighting/warning beacons will be verified to be in operation prior to flight as part of the pre

- flight checklist.Control and Management of the sUAS during flight
In order to ensure safe and effective operations while maintain ing proper controlled flight and complete control of the sUAS the following requirements will be followed :

. a) Maximum Operating Speeds and Altitude
Huawei will operate the sUAS between 100

- 350 feet in order to inspect telecommunications
sites and towers. Maximum speed during inspection will be between 4ft/s and 10ft /s

, on both horizontal and vertical planes

. b) Visual Line Of Si ght Huawei’s internal policy for operation of the sUAS requires a Flight Engineer and a Visual
Observer located with 100 feet of the base of the tower and with full Visual Line of Sight at all times complying with Section 333(b)(1)

. c) In F light H azards Operating in close proximity to a telecommunications tower does pose some level of risk due
to tower attached equipment extending out horizontally from the tower

. However, t o mitigate these risks both a flight Engineer and a Visual Observer shall monitor f light path and any possible obstructions throughout flight operation . Since the sUAS flights for purposes of survey and inspection require a relatively straight vertical ascent

, then rotation around the
tower at a safe distance of 15

- 25 feet from the tower

, potential hazards are minimized. d) Proximity to Airports and No

- Fly Zones
Huawei will not operate within five (5) miles of any airport or “no

- fly” zone s in accordance with all Section 333 stipulations. e) W e a ther Conditions
Huawei’s policy requires high visibil ity and clear days with no rain, clouds or adverse weather patterns for operation of the sUAS

.

Equipment Specifications
The table b elow contains the specific operational characteristics relevant to this petition for the
sUAS that Huawei intends to utilize

. Huawei will use the DJI Phantom 2 Vision+ and/or the DJI Inspire1 sUAS ( http://www.dji.com/ ) for the purposes described in this petition. For more detailed design and operational characteristics and limitations, the Specifications and User Manuals from
the manufacturer have been provided for your review.

Attribute Phantom 2 Vision+ Inspire1 Weight 2.7 lbs 6.5 lbs Payload 2.9 lbs N/A Maximum Flight S peed 15 m/s * 22 m/s *
RF Remote Controller**

Operating Frequency 5.728GHz

- 5.85GHz 5.725~5.825 GHz 2.400~2.483 GHz

Communication Distance CE Compliance: 400m; FCC Compliance:800m 2kmReceiver Sensitivity

- 93dBm

Transmit Power CE Compliance: 25mW;

FCC Compliance:100mW 9W

Range Extender Operating Frequency 2412MHz

- 2462MHz N/A * Huawei Technologies will not be operating at any speed approaching the maximum.

** The units have been verified by the manufacturer to not interfere with telecommunications equipment that may be in operation at the target site/tower.

Equipment Maintenance and Preflight Inspections Huawei Flight Engineers are required to follow all policies and procedures defined for use of sUAS under this petition. An outline is below and is in accordance with the manufacturers (DJI)
recommended policies a nd procedures in addition to Huawei Technologies own poli cies

. a) Preflight Conditions Assessment

a. Verify and document surroundings and any “no

- fly” zone s, local laws and regulations for operation of sUAS prior to any planned flight.
b. Operation can only take place during daylight hours 30 minutes after sunrise to 30
minutes before sunset.

c. Verify wind speeds are not in excess of 10

- 12 mph and no rain or inclement weather
is imminent.
d. Verify Visual Line Of Sight to top of flight path is unobstructed and will not become obstructed during flight.

e. Identify any possible ob stacles that need to be avoided (high voltage power lines, trees, guy wires for tower) for an unobstructed flight path and opti mum safety.
f. Verify all tower top FAA lighting/warning beacons will are in operation. b) Pre

- fli ght Checklist

a. Remote Controller, B attery, Range Extender and tablet are fully charged

. b. Propellers are mounted correctly and firmly

.
c. Micro

- SD card has been inserted if necessary.
d. Gimbal clamp has been removed and Gimbal functions normally.

e. Camera lens cap has been removed.
f. Motors can start and are functioning as normal

. g. DJI Pilot APP and Video Tablet App can connect to the aircraft

. h. Compass has been calibrated.
i. Controlled limited duration mini flight verification for takeoff and landing. c) Maintenance

a. R egular maintenance will occur per manufacturers (DJI) suggested maintenance schedule. This includes weekly, monthly and yearly inspections.
b. All maintenance and repairs will be completed by the manufacturer.

Flight Engineer Qualifications/Certifications
Huawei is currently develo ping a comprehensive training program to familiarize Flight Engineers with all policies, process and hands on operation associated with th e sUAS Site Survey program.This will be based roughly around work done in some other countries globally but with specific content and focus on USA requirements. This program will require Flight Engin eers to take online
and in

- class training

, as well as hands on instruction from an experienced sUAS operator. E ach Fligh t Engineer will be required to log a minimum of 8 hours of flight time below 25 feet to practice take off, landing, return to base and general operational familiarity. Currently, no Huawei Flight Engineer (s) hold airman certifications. All Huawei Technologies USA Field Engineer and Visual
Observers are expected to have First Aid and CPR training provided through local programs

.

VII. Summary:

In summary, Huawei believes its plan will meet all necessary criteria under Section 333

, while
also meeting or exceeding safety criteria to ensure th e safe operation of sUAS for the commercial purposes mentioned above. Approval of this petition at the earliest available time is appreciated so that continued investment and development of our cu stomer focused solution can be completed in a timely fashion

.

If you have any additional comments or questions please feel free to contact me directly.



### Best Regards

,

Tim Danks
VP of Professional Services Huawei Technologies USA Inc.

HUAWEI TECHNOLOGIES USA INC 5700 Tennyson Parkway
Suite 500 Plano, Texas 75024 Tel: 214

- 919

- 6000
Fax: 214

- 919

- 6601