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 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 confidential, 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.

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) Flying Camera Project – Training Material

Sincerely,

______________________

Todd Wilson

Vice President, Field Services Organization

Ericsson Inc.
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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 CFR. Part 11, Ericsson 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 Inc.

6300 Legacy Drive

Building Tejas

Plano, Texas 75024

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

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)

14 CFR 91.103 

14 CFR 91.105

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

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." Id. §333 (c).

Ericsson's sUASs are multirotor vehicles, weighting 10 lbs. or less including payload. 

They operate under normal conditions at a speed of no more than 50 knots and have 

the capability to hover and move in the vertical and horizontal plane 

simultaneously. The sUASs will operate only in the pilot's and/or assistants visual line 
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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.

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 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 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 of workplace fatality and injury on construction sites1

, 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 

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.html
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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 limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a 

safety enhancement to the already safe protocols followed on data and 

telecommunication sites and imaging and surveying operations conducted with 

helicopters and other conventional aircraft.

Ericsson will be bound by the following limitations when conducting its sUAS operations 

under an FAA issued exemption:

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

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

3. Minimum crew for each operation will consist 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 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.

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.
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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 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)

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 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 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.
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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.

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).
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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, 9565B, 10167, 10167A, 10602, 32827, and 10700.

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 91.103 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.
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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.

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 10 lbs. 

proposed herein and carrying flammable fuel, any risk associated with our operations is 

far less than those presently presented with helicopters and other conventional aircraft 

operating at or below 500 feet AGL in the construction industry. In addition, the lowaltitude operations of the sUAS will ensure separation between these sUAS 

operations and the operations of conventional aircraft that must comply with Section 

91.119.

14 CFR 91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set "...to the elevation 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 
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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 

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 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 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 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 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 
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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 

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); 

91.105; 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 combustible fuel, and carry an onboard human pilot. In contrast, a sUAS weighing 
12

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.

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.

Sincerely,

____________________

Todd Wilson

Vice President, Field Services Organization

Ericsson Inc.