June 23, 2015

Thomas Tilson Dba: Volintius 49 Chestnut Street S. Hamilton, MA 01982 Cell 617-510-6691 Email: thomastilsonjr@gmail.com

Department of Transportation Docket Management Syst em 1200 New Jersey Ave. SE Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments:

 Exponent Technology Services User Operations Manual V 1.1  DJI Phantom 3 Professional User Manual V 1.2

References: 1) FAA Exemption No. 11138, Regulatory Docket No. F AA20140481 in the matter of the petition of DOUGLAS TRUDEAU
2) FAA Exemption No. 11136, Regulatory Docket No. F AA–2014–0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC
3) FAA Exemption No. 11080 Regulatory Docket No. FA A20140355 in the matter of the petition of FLYING CAM INC
Dear FAA,

In accordance with the FAA’s Guidelines for Submitt ing a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012, I, Th omas Tilson, request exemption from the following sections of Title 14, Code of Federal Regulations § §
61.113(a). 61.113(b). 91.119(c). 91.121. 91.151(a) . 91.405(a). 91.407(a)(1). 91.409 (a)(1). 91.409(a) (2). 91.417(a) & (b).
In order to operate small unmanned aircraft system s (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purpo ses of construction inventory control, aerial photography, structural inspections of bridges, pip elines, well and cell towers and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system a s compared to a manned aircraft. Operations will be performed only at the request of and with the autho rization and permission of clients or their authorized agents in order to facilitate commerce a nd raise awareness of the beneficial uses of small unmanned air systems. So long as such operations ar e conducted within and under the conditionsoutlined herein or as may be established by the FAA as required by Section 333. The conditions

identified and proposed by, Thomas Tilson, are draw n from references 13.

**The FARs**
I, Thomas Tilson, request exemption from the above mentioned FARs for the following reasons. I have been a licensed Commercial, Multi-engine, Instrumen t rated Pilot since 1979, hold a Class III Medical Certificate.
**61.113(a) & (b).** I, Thomas Tilson, request relief in order to facil itate the utilization of pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption would be required to comply with any conditions as set forth and in a si milar fashion to the previously granted exemptions. A Visual Observer will be used at all times while und er this requested exemption.
**91.119(c)** As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be opera ted closer than 500 feet to essential persons, or objects that would not be possible without addition al relief. The petitioner requests modification, waiver or exemption and clarification concerning th e terms “congested areas” and “densely populated”. I, Thomas Tilson, request waiver for this condition to allow reasonable and responsible operations wit h safety as my main concern in areas of subdivisions and neighborhoods if required.

**91.121** As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic G PS with a barometric sensor for altitude informatio n. **91.151(a)** As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS spe cific relief has been granted in Exemption Nos. 881 1, 10808, and 10673 for daytime, VFR conditions. The U AS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regard ing remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remainin g reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced m inimum power reserve for flight in daytime VFR conditions was reasonable. 91.405(a). 91.407(a)(1). 91.409 (a)(1) & (2). 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), I, Thomas Tilson , propose to inspect and ensure that the UAS is in a condition for safe flight in accordance with t he operating documents. The FAA found that adherenc e to the petitioner’s operating documents and the con ditions and limitations specified, describing the requirements for maintenance, inspection, and recor dkeeping, were sufficient to ensure that safety would not be adversely affected.

**The UAS’s**
The Exponents Align M690L is a small rotorcraft in the quadcopter configuration with a weight of 3450g designed primarily to carry aloft RFID, sensors and photo equipment. It has a maximum speed of less than 34 knots (15m/s) and a maximum climb rate of l ess than 1200 feet per minute (6 m/s). It is powered by four electric motors We have enclosed Ex ponent Technology Services User Operations Manual V 1.1 .The DJI Phantom 3 is a small rotorcraft in the quad copter configuration with a weight of 1280g designe d

primarily to carry aloft photo equipment. It has a maximum speed of less than 35 knots (16m/s) and a maximum climb rate of less than 1000 feet per minut e (6 m/s). It is powered by four electric motors. W e have enclosed DJI Phantom 3 Professional User Manua l V 1.2 .

**Risk mitigation**
I, Thomas Tilson, have reviewed FAA exemptions ref erence’s 13 Conditions and Limitations section and believe that the procedures specified therein are r easonable and will be utilized in order to manage a nd mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UAS’s airworthiness will be verified befor e launch. Airworthiness will be maintained by performance of routine inspections before each flig ht, maintaining flight and maintenance logs to reco rd time on failure prone components. I, Thomas Tilson, request that in a manner similar to reference 3, b e allowed to operate within 5 miles of an airport pro vided that.
**“The UA may not operate in Class B, C, or D airspac e without written approval from the FAA. The UA**  **may not operate within 5 nautical miles of the geog raphic center of a non towered airport as denoted**  **on a current FAA published aeronautical chart unles s a letter of agreement with that airport’s**  **management is obtained, and the operation is conduc ted in accordance with a NOTAM as required by**  **the operator’s COA. The letter of agreement with th e airport management must be made available to**  **the Administrator upon request.”**

Operations within 5 miles of an airport are not ant icipated to be routine but I am requesting a mechanism to facilitate such activities without req uesting a new and separate exemption(s) should the need arise. Operations within class B airspace are not requested due to the lack of mode C transponder

. **Public interest**

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with ma nned aircraft of greater proportions, carrying a crew and flammable fuel. In regards to performing i nspections of construction assets, bridges, towers, and natural gas pipelines the UAS will minimize the risk to persons attempting to climb these structur es and photograph problem areas. It will provide a way for companies to have their assets counted without the need for people to travel in areas that are har d to reach by vehicle or foot.

In addition the use of the UAS in order to facilita te commerce could lead to economic growth. Operations for this petition will enable service fo r business owners or their designees seeking enhanc ed business processes like inventory control. A visual observer will be utilized at all times that the UA S is performing duties for compensation and the PIC will hold a Private Pilot’s license.
Flight data including UAS flight time, Control Unit operation time, incident, and details will be reco rded for each flight and made available to the FAA at an y time needed. Any deviations from normal operations will also be recorded and made available to FAA.Conclusion

I, Thomas Tilson am requesting this exemption for t he purposes of inventorying construction material, bridge inspections, land surveying, pipeline inspec tions, tower inspections, and other flight operatio ns. The reason for such a general and broad based reque st is that I, Thomas Tilson, wish to utilize a busi ness strategy in order to capitalize on opportunities as they may arise in the future without the long turnaround time associated with additional exemptio ns. My business model is based on the idea of offering small UAS services to individuals or compa nies who wish to employ these services as a safe, effective, and legal option to enhance their busine ss or prevent structural disasters that may influen ce the general public or individuals. My own research shows an upward demand for these services that currently exists in the construction industry, natu ral gas market and other markets are just beginning to realize the need for such services. I have been a l icensed Pilot since 1978 and have flown 2000 + hour s in fixed wing aircraft.

Sincerely, 

# Thomas Tilson

Thomas Tilson
Operator