Robert Thomson, Thomson’s Management, Inc.

6793 Tremble Trail

Pellston, Michigan 49769

Telephone: 231-539-8440

Email: thomsonr172@gmail.com

September 3, 2015

U. S. Department of Transportation

Docket Management System

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam:

We respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of 

the Federal Aviation Regulations.

Petitioner:

Robert Thomson, Thomson’s Management, Inc.

6793 Tremble Trail

Pellston, Michigan 49769

Telephone: 231-539-8440

Email: thomsonr172@gmail.com

Thomson’s Management, Inc. intends to incorporate the use of sUASs for a variety of projects 

which may include but not be limited to project and construction management, inspections and 

monitoring; environmental review projects; aerial surveying; agricultural projects; educational 

and research projects; remote sensing projects, wildlife and forestry monitoring projects; aerial 

filmmaking, photography and real estate purposes; search and rescue, etc.

Specific Section(s) seeking exemption:

14 C.F.R Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.109

14 C.F.R. 91.119
U. S. Department of Transportation

Docket Management System

July 20, 2015

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14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) and (b)

14 C.F.R. 91.215

14 C.F.R. 91.104 through 91.417

Extend of relief requested:

To permit commercial operation of Small Unmanned Aircraft Systems (sUASs) for operations 

conducted within and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333.\

Said exemption would permit the operation of sUASs under controlled conditions in limited, 

predetermined and controlled airspace. Upon granting of this proposed exemption request,

Thomson’s Management, Inc. would conduct commercial operations of sUASs meeting or 

exceeding all operational and safety requirements per Section 333.

Public Benefit:

1. Project and construction management, inspections and monitoring. The use of sUASs on

construction sites may improve the safety of workers, local residents and general public

by assessing potential dangerous situations. Falls and injuries may be reduced or

eliminated through a more thorough review of the construction sites. In some cases,

sUASs may reduce the reliance of helicopters or small aircraft to monitor said sites. This

may improve safety as well as reduce environmental impact by reducing energy usage;

2. Environmental Review projects. The use of sUASs during the process of reviewing

projects as required by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in-depth

Environmental Review of the project site as well as surrounding areas. Reliance of

helicopters or small aircraft may be eliminated;

3. Aerial surveying. The use of sUASs in connection with aerial surveying of smaller areas 

may eliminate the use of helicopters or aircraft. This could provide a more cost effective, 

safer and more energy efficient product;

4. Agricultural projects. Wildlife and Forestry projects. The use of sUASs could assist with 

surveying agricultural projects as well as wildlife and forestry projects by providing 

information when problems occur, vermin infestation, fire hazards, etc.;

5. Remote Sensing projects. The use of sUASs could provide views and information for 

remote and inaccessible areas. This could promote worker safety as well as reduce the 

reliance on helicopters and aircraft;

6. Educational and Research projects. The use of sUASs could provide information for said 

projects in a more cost effective and efficient manner than other available options;
U. S. Department of Transportation

Docket Management System

July 20, 2015

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7. Aerial filmmaking, photography and real estate purposes. The use of sUASs may provide a 

point of view previously unavailable through other means. They would be more cost 

effective, efficient and more safely than helicopters and aircraft; and

8. Search and rescue. The use of sUASs may provide assistance to local law organizations

during search and rescue missions. SUASs may reach areas unattainable or viewable with 

helicopters and aircraft. SUASs may be implemented quicker as time is of the essence

during search and rescue operations.

Reasons why the exemption would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to the existing rule.

Proposed operations using sUASs provide increased safety enhancement especially when 

compared with helicopters and aircraft for the following reasons:

1. The sUASs will weigh less than twenty-five (25) pounds;

2. Flights will be operated within the visual line of sight of the pilot;

3. Maximum total flight time for each operational flight will be thirty (30) minutes. Flight 

times may be less than thirty (30) minutes as the UAS will continuously monitor

battery reserve and return to the ground station with at least 20% battery power 

reserved;

4. Flights will be operated at an altitude of 200 feet AGL. Flights will never exceed 400

feet AGL;

5. Minimum crew for each operation will consist of the sUAS pilot and a Visual Observer;

6. . A briefing will be conducted daily by all personnel working with said sUAS;

7. All onsite personnel and client employees will be required to execute a waiver. 

Verbal/written consent will be required of all persons within 100 feet of flight operation;

8. Written and/or oral permission from relative property owners will be obtained prior to 

operating the sUAS;\

9. All permits, permissions, etc. will be obtained from local government offices as 

required;

10.The sUAS operated will weigh less than 55 pounds including payload (camera, lens, 

gimbal, etc.); and

11.The sUAS will operate at speeds less than 50 knots, hover and simultaneously move 

vertically and horizontally;

12.The sUAS will have the capability to return and land at the pre-determined location 

with the Security Perimeter should the sUAS lose communication or GPS signal 

during any operations;

13.The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies;

14.Operations will not be conducted over densely populated areas or heavily traffic 

highways; and

15.Operations will not be conducted within five (5) NM of an airport or heliport.
U. S. Department of Transportation

Docket Management System

July 20, 2015

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Thomson’s Management, Inc. will abide by all regulations including the following:

1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness 

Certificates;

2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks;

3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations;

4. 14 C.F.R. 91.7 Civil aircraft airworthiness;

5. 14 C.F.R. 91.9 Civil aircraft flight manual, marking and placard requirements;

6. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests;

7. 14 C.F.R. 91.119 Minimum safe altitudes: general;

8. 14 C.F.R. 91.121 Altimeter settings;

9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions;

10.14 C.F.R. 91.203 Civil aircraft: Certifications required;

11.14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. airworthiness 

certificates: Instrument and equipment requirements;

12.14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use;

13.14 C.F.R. 91.401 Applicability;

14.14 C.F.R. 91.403 General;

15.14 C.F.R. 91.405 Maintenance required;

16.14 C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding or 

alteration;

17.14 C.F.R. 91.409 Inspections;

18.14 C.F.R. 91.411 Altimeter system and altitude reporting equipment tests and 

inspections;

19.14 C.F.R. 91.413 ATC transponder tests and inspections;

20.14 C.F.R. 91.415 Changes to aircraft inspection programs; and

21.14 C.F.R. 91.417 Maintenance records.

Privileges of exemption outside the United States.

Thomson’s Management, Inc. may wish to exercise the privileges of this exemption outside 

the United States should a contract with a governmental office require same. All required rules 

and regulations will be followed should this occur.
U. S. Department of Transportation

Docket Management System

July 20, 2015

Page Five

Equipment and Specifications.

DJI Phantom 3 Pro, DJI Phantom 3 Advanced

Specifications: (Note all specification are the same unless noted)

Up to 23 minutes of flight time

HD video streaming to mobile devices

Top speed: 55 mph

Max Altitude: 400ft, per FAA rules

Weight: 1280 g; 

Wi-Fi range: up to 1.2 miles, depending on environment

Controller with color screen and live flight data

Via DJI GO app connected to iPad, iPhone, or Android tablet

Phantom 3 Battery: 15.2 V LiPo (6000 mAh)

Rechargeable controller batter: 6000 mAh / 7.2 Vdc; lasts 4 hours (extendable battery available)

24x12.7cm self-tightening props

880 kV motors

Linear landing accuracy Approx. 5 m (16.4 ft.)

Please feel free to contact our office if there are any additional questions or concerns