June 23, 2015 

Exponent Technology Services, Inc 

11362 Joseph Casavant, 

Montreal, Quebec, H3M 2B7 

Cell 617-510-6691 

Email: thomastilsonjr@gmail.com

Department of Transportation Docket Management System 

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. FAA20140481 in the matter of the petition of 

DOUGLAS TRUDEAU 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of the petition of 

ADVANCED AVIATION SOLUTIONS LLC 

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of 

FLYING CAM INC 

Dear FAA, 

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of 

the FAA Modernization and Reform Act of 2012, I, Thomas 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 systems (UAS) commercially in airspace regulated by the 

Federal Aviation Administration (FAA) for the purposes of construction inventory control, aerial 

photography, structural inspections of bridges, pipelines, 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 as compared to a manned aircraft. Operations will be

performed only at the request of and with the authorization and permission of clients or their 

authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small 

unmanned air systems. 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. The conditions 

identified and proposed by, Thomas Tilson, are drawn 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, Instrument rated Pilot since 1979, hold a Class III Medical 

Certificate. 

61.113(a) & (b). I, Thomas Tilson, request relief in order to facilitate 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 similar fashion to the previously granted exemptions. A 

Visual Observer will be used at all times while under 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 operated closer than 500 feet to essential persons, or 

objects that would not be possible without additional relief. The petitioner requests modification, 

waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”. 

I, Thomas Tilson, request waiver for this condition to allow reasonable and responsible operations with 

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 GPS with a barometric sensor for altitude information. 

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 specific relief has been granted in Exemption Nos. 8811, 

10808, and 10673 for daytime, VFR conditions. The UAS 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 regarding remaining battery power management. Those 

documents contain a condition in which the PIC will initiate a landing procedure when battery remaining 

reaches a specified level. Given the limitations on proposed operations and the location of those 

proposed operations, The FAA found that a reduced minimum 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 the operating documents. The FAA found that adherence 

to the petitioner’s operating documents and the conditions and limitations specified, describing the 

requirements for maintenance, inspection, and recordkeeping, 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 less than 1200 feet per minute (6 m/s). It is 

powered by four electric motors We have enclosed Exponent Technology Services User Operations 

Manual V 1.1 . 
The DJI Phantom 3 is a small rotorcraft in the quadcopter configuration with a weight of 1280g designed 

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 minute (6 m/s). It is powered by four electric motors. We 

have enclosed DJI Phantom 3 Professional User Manual V 1.2 . 

Risk mitigation 

 I, Thomas Tilson, have reviewed FAA exemptions reference’s 13 Conditions and Limitations section and 

believe that the procedures specified therein are reasonable and will be utilized in order to manage and 

mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure

that the UAS’s airworthiness will be verified before launch. Airworthiness will be maintained by 

performance of routine inspections before each flight, maintaining flight and maintenance logs to record 

time on failure prone components. I, Thomas Tilson, request that in a manner similar to reference 3, be 

allowed to operate within 5 miles of an airport provided that. 

“The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA 

may not operate within 5 nautical miles of the geographic center of a non towered airport as denoted 

on a current FAA published aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with a NOTAM as required by 

the operator’s COA. The letter of agreement with the airport management must be made available to 

the Administrator upon request.” 

Operations within 5 miles of an airport are not anticipated to be routine but I am requesting a 

mechanism to facilitate such activities without requesting 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 manned aircraft of greater proportions, carrying a 

crew and flammable fuel. In regards to performing inspections of construction assets, bridges, towers,

and natural gas pipelines the UAS will minimize the risk to persons attempting to climb these structures 

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 hard to reach by vehicle or foot. 

In addition the use of the UAS in order to facilitate commerce could lead to economic growth. 

Operations for this petition will enable service for business owners or their designees seeking enhanced 

business processes like inventory control. A visual observer will be utilized at all times that the UAS 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 recorded 

for each flight and made available to the FAA at any 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 the purposes of inventorying construction material, 

bridge inspections, land surveying, pipeline inspections, tower inspections, and other flight operations. 

The reason for such a general and broad based request is that I, Thomas Tilson, wish to utilize a business 

strategy in order to capitalize on opportunities as they may arise in the future without the long 

turnaround time associated with additional exemptions. My business model is based on the idea of 

offering small UAS services to individuals or companies who wish to employ these services as a safe, 

effective, and legal option to enhance their business or prevent structural disasters that may influence 

the general public or individuals. My own research shows an upward demand for these services that 

currently exists in the construction industry, natural gas market and other markets are just beginning to 

realize the need for such services. I have been a licensed Pilot since 1978 and have flown 2000 + hours in 

fixed wing aircraft. 

Sincerely, 

Thomas Tilson 

Thomas Tilson 

Operator