1 May 25 , 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 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 t o 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 t his 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 operation s within FAA controlled territory.

Applicant submits the Operations Manual as confidential, proprietary inf ormation 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 an d consideration, and please let us know if you have any questions.

The following supporting documents have been attached : 1) Phantom 2 Vision Plus Pilot Training Guide 2) Phantom 2 Vision Plus User Manual 3) Phantom 2 Vision Plus Operations Manual 4) Flyi ng Camera Project

– Training Material

Sincerely,

______________________ Todd Wilson Vice President, Field Services Organization
Ericsson Inc.2 May 25 , 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 CF R. Part 11, Ericsson Inc. ("Ericsson"), a provider of
tele communications and data tech nology 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 Ope rations 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 safe ty 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 operatio n 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 Inc.

6300 Legacy Drive

Building Tejas

Plano

, Texas 75024

USA3 Regulations from which the exemption is requested are as follows :

14 C F R Part 21
14 CF R 45.23 (b)
14 CF R 45.27 (a)
14 CF R 61.113 (a) & (b)
14 CF R 91.7 (a)
14 CF R 91.9 (b) (2)
14 CFR 91.103
14 CFR 91.105
14 CFR 91.109
14 CFR 91.119
14 CF R 91.121
14 CF R 91.151 (a)
14 CF R 91.203 (a) & (b)
14 CF R 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 i ncludes 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, th e 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 a irports

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." Id. §333 (c).

Eri csson's sUASs are multirotor vehicles, weighting 10 lbs. or less including payload. They operate under normal conditions at a speed of no more than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. The sUASs will operate only in the pilot's and/or assistants visual line4 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 w hich 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 o f 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 exemptio ns is in the public interest. Accordingly, Ericsson respectfully requests that the FAA grant the requested exemption without delay.



### II. 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 gra nting 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., so me of the cell towers in the
United States 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 o f 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 propos e 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 wo rkers 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 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.html5 

### III. EQUIVALENT LEVEL OF SAFETY

Ericsson proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the l imitations 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 exempt ion:

1. Safety will be the first and foremost consideration in any sUAS operation.

2. The MTOM weight of the sUAS will be less than 10 lbs.

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

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 vo ice 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 th at 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 rel evant 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 R ules (VFR).

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

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 Return

To

- 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.6 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 Operat ions 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 Flight Standards District Offices (FSDO) 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)
Sub part II, entitled Airworthiness Certificates, establishes the procedural requirements
for the issuance of airworthiness c ertificates 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. I n our particular case, the sUASs 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 airworthiness ce rtificate, 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 propo sed.

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 . L ike 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.7 These safety enhancements, which already apply to civil aircraft operated in

conn ection 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 t hat 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 o f marks; nonfixed

- wing aircraft

This regulation requires certain experimental, provisionally certificated aircraft, or light

sport category aircraft to be marked with letters between 2 inc hes 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 wi ll 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.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in
command

S ections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because
the s UAS 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 o peration 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

ope rations 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).8 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 equivale nt 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 the re 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 hav e immediate access
to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 CFR 91.103: Preflight Action This regulation requires each pilo t 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 91.103 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.9 By design, sUASs and remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished through the use of a cont rol 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 prescrib ed
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 s UAS 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 cons ent. See Manual for detailed procedures.

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 o fficials. 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 f ar more than the maximum 10 lbs. proposed herein and carrying flammable fuel, any risk associated with our operations is far less than those presently presented with helicopters and other conventional aircraft operating at or below 500 feet AGL in the cons truction industry. In addition, the low

altitude 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

bar ometric 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 al titude 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 the10 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 powere d 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 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 achie ved 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 restrictio n 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 certification 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 fli ght 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 10 lbs. and is operated without an onboard pilot. Therefore there is no ability or place to carry certification and registration documents or to display them on the sUAS.

An equivalen t 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 numerous11 exemptions to th is 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 repaire d 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 Er icsson. 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 pa yload and operate only in restricted areas for limited periods of time. If mechanical issues arise the sUAS can land immediately and 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 second

class 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); 91.105; 91.109; 91.119; 91.121; 91.151 (a);91.203 (a) & (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (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 combustib le fuel, and carry an onboard human pilot. In contrast, a sUAS weighing12 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 passenger s 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 supporti ng 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.

Privacy

All flights will occur over controlled access private property with the private property
owner's pri or 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 exemp tions allowing commercial operation of applicant's sUASs in the telecom and data technology services industry pursuant to the Operations Manual appended hereto.

Sincerely,

____________________ Todd Wilson Vice President, Field Services Organization
Ericsson Inc.