**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 We st Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE Wa shington DC 20590

**RE: Exemption Request Section 333 of the FAA Reform Act**

Dear Sir or Madam:

Werespectfully request exemption under Section 333 of th e 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. 91.119U. S. Department of Transportation

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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 a s may be established by the FAA as required by Section 333. \

Said exemption would permit the operation of sUASs under controlled conditio ns in limited, predetermined and controlled airspace. Upon granting of this proposed exemption request, **Th omson’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,

s UASs 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 conn ection 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. W ildlife 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 efficie nt manner than other available options;U. S. Department of Transportation

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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 tha n helicopters and aircraft; and 8. S earch and rescue. T he use of sUASs may provide assistance to local law organizations during search and rescue missions. SUASs may reach a reas unattainable or viewable with helicopters and aircraft. SUASs may be implemented quicker as time is of the essence during search and rescue operations.

**Reasons w hy** 

**the exemption w ould not adversely affect safety**  **or how the exemption**  **would provide a l**  **evel 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 sU ASs 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 fligh t 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 po unds 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 are as 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

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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. 1 4 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. 91.40 3 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 ins pections; 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

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**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 We ight: 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) Rech argeable 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 t here are any additional questions or concerns