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 It 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.com
II. RELEVANT 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 sUAS aircraft in accordance with the 

requirements of the exemption allowance within the National 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 safety 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 observation 

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 sUAS 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 of 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 those larger populated areas. The prohibitive cost of deploying 

infrastructure to support rural areas 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 observation 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 customers (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

safety for telecom site inspections and reporting preventing injury or death. Further, 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 Inspire1 sUAS 

aircraft for the purposes described above. DJI has been identified as the industry leader in sUAS 

and these 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 Flight Engineers 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, some 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 preflight 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

All 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 visuals 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 our 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 limit 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 the aircraft will ascend to a height approximately 5 feet above the top of the tower

for 5 to 10 seconds, then descend to below tower maximum height for the remainder of the 

flight. The horizontal border for the tower inspection defined by Huawei’s policy is maximum 

25 feet from the tower. Thus, any air traffic in the NAS will spot the tower top FAA 

lighting/warning beacon(s) from approximately 1+ miles out thereby eliminating any possible 

danger. In 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.

Max. 200 ft

Site Perimeter

50 ft

Max. Tower Height + 5 ft

Ground Level

Graphical Representation 

of Operational Borders
Control and Management of the sUAS during flight

In order to ensure safe and effective operations while maintaining 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 Sight

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 Flight Hazards

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, to mitigate 

these risks both a flight Engineer and a Visual Observer shall monitor flight 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” zones in accordance with 

all Section 333 stipulations.

e) Weather Conditions

Huawei’s policy requires high visibility and clear days with no rain, clouds or adverse weather 

patterns for operation of the sUAS. 

Equipment Specifications 

The table below 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 Speed 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

2km
Receiver 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 and procedures in addition to Huawei Technologies own policies.

a) Preflight Conditions Assessment

a. Verify and document surroundings and any “no-fly” zones, 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 obstacles that need to be avoided (high voltage power lines, 

trees, guy wires for tower) for an unobstructed flight path and optimum safety.

f. Verify all tower top FAA lighting/warning beacons will are in operation.

b) Pre-flight Checklist

a. Remote Controller, Battery, 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. Regular 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 developing a comprehensive training program to familiarize Flight Engineers 

with all policies, process and hands on operation associated with the 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 Engineers to take online 

and in-class training, as well as hands on instruction from an experienced sUAS operator. Each 

Flight 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 the 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 customer 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