Trudeau Consulting, LLC., Newtown, CT – Section 333 Exemption Petition

May 18, 2015

US Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14

C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109;

119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

Pursuant to the FAA Modernization and Reform Act of 2012, and procedures within 14 CFR 11, Trudeau 

Consulting, LLC, an owner/operator of small unmanned aircraft, is requesting an exemption from the 

Federal Aviation Regulations (FAR’s) listed below, so that the company may operate our small unmanned 

aerial vehicle (UAV), commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

Trudeau Consulting, LLC, has an inventory containing (1) battery-powered DJI Phantom III, equipped with 

a high-resolution video/still camera. The intention of this company is to provide aerial videography for the 

benefit of local businesses including but not limited to: real estate listings, farming/vineyards, and tourism 

destinations. It is the hope of Trudeau Consulting that the footage we provide will bolster the economy.

Additionally, the owner/operator of Trudeau Consulting, LLC, aims to provide workshops, training, and 

live demonstrations to local law enforcement. A secondary mission of the company is to raise awareness 

of this technology to our local police, fire, and EMS resources. 

As part of standard operating procedures, Trudeau Consulting, LLC has made a public pledge to never 

operate the UAV equipment in a manner that would endanger the public (such as night flying, or over 

densely populated areas). Also being a resident of Newtown and given the sensitive circumstances that 

surrounded the events of 12/14/12, Trudeau Consulting has made a pledge to never fly over or direct 

cameras toward the reconstruction of Sandy Hook Elementary. I believe this is an important footnote, 

and I encourage you to ask similar companies in this area to make that same pledge.

It is the hope of Trudeau Consulting, LLC, that the granting of our request will be in line with the Secretary 

of Transportation’s responsibilities to integrate UAV’s properly, into the overall airspace network. The 

granting of the exemption for Trudeau Consulting, LLC, will aid in that mission, in such a way that we can 

advocate the safe and proper usage of these devices.
I. Contact Information:

Trudeau Consulting, LLC

Brian Trudeau

18 Old Castle Drive

Newtown, CT 06470

(413) 204-3407

brian@trudeauconsulting.com

II. Title 14 sections of the FAA which Trudeau Consulting, LLC requests exemption:

14 CFR 21;

14 C.F.R. 45.23(b);

14 FR 61.113 (a) & (b);

14 .F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).

III. The extent of relief Trudeau Consulting, LLC seeks and the reason:

We, Trudeau Consulting, LLC, submit this application in accordance with the Reform Act, 112 

P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent 

we, Trudeau Consulting, LLC, contemplated commercial cinematic, academic and other flight

operations within the national airspace system. The Reform Act in Section 332 provides

for such integration of civil unmanned aircraft systems into our national airspace system

as it is in the public’s interest to do so. Trudeau Consulting LLC’s ultra light weight UAS

meets the definition of “small unmanned aircraft” as defined in Section 331 and

therefore the integration of our ultra light weight UAS is expressly contemplated by the

Reform Act. We would like to operate our light weight UAS prior to the time period by

which the Reform Act requires the FAA to promulgate rules governing such craft.

Thereby, providing direct experience and valuable information for formal regulation that

can be administered uniformly to all real estate related UAS aerial video and

photography. The Reform Act guides the Secretary in determining the types of UAS's

that may operate safely in our national airspace system. Considerations include: The

weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be

operated near airports or heavily populated areas; and, Whether the UAS will be

operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an

exemption for us, Trudeau Consulting, LLC. 

Our UAS utilizes four (4) counter-rotating propellers for balance, control and stability. Our 

UAS is equipped with GPS and auto return safety technology. Weighing less than fifteen (15) 

pounds (far below the max. 55 pound limit); including camera with gimbal.

The Phantom III model is designed to hover in place via GPS and operate in less than a 13 

knot (15 mph) wind. For safety, stability and fear of financial loss we will not fly in winds 

exceeding 13 knot (15 mph). Built in safety systems include a GPS mode that allows our UAS 

to hover in place when radio controls are released. 

When pilot communication is lost UAS is designed to slowly descend to point of take off. No 

UAS operations near airports, Hospitals nor Police heliports, and do not operate near areas 
where general public is within fifty to one hundred (50-100) yards depending on location, 

conditions and weather. We are constantly on alert for any manned aircraft (Police/Medical

helicopters, etc.) and prepared to land/abort immediately to the nearest and safest

ground point should a manned aircraft approach our location or we suspect manned

aircraft may approach near our location. Our UAS is capable of vertical and horizontal

operations, and are flown only within our line of sight of us, as the remote control pilot.

Utilizing battery power rather than combustible fuels, flights generally last between ten

(10) to fifteen (15) minutes, with an altitude under three hundred (300) feet. 

Trudeau Consulting, LLC is highly aware of the risks when operating our UAS/ultra light

weight unmanned aircraft and will not “create a hazard to users of the national airspace

system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of our UAS

it falls well within Congress’s contemplated safety zone when it promulgated the Reform

Act and the corresponding directive to integrate UAS's into the national airspace

System. 

IV. How Trudeau Consulting, LLC’s request will benefit the Public:

Small businesses in the area will benefit financially from aerial video and photography, who 

typically have too small of a budget to afford manned flyover video services. Trudeau 

Consulting, LLC, is confident that with the competitive advantage of this type of media, we 

will offer a service to the local economy.

Additionally, with the workshops and training that will be provided free-of-charge to local law 

enforcement and public safety groups, the public will as a whole, be safer as a result of 

having this type of equipment available, if an emergency arises.

V. Reasons why Trudeau Consulting, LLC’s exemption will not adversely affect safety:

An exemption provided to Trudeau Consulting, LLC will not affect public safety. Rather, by

reducing the demand for manned aerial vehicles using combustible gases, public safety as a 

whole will be increased. 

To reiterate our policies and procedures:

 The Phantom III weighs less than 15 pounds

 Flights will be limited to 300 feet

 Flight time is limited to 10-15 minutes per flight

 The Phantom III will return to its home position well before running out of battery 

power

 Flights will be controlled using a combination of line-of-sight and live video feed to the 

ground.

 The Phantom III will return to its home point if connection with the controller is lost.

 Trudeau Consulting, LLC, will obtain permission as needed, prior to flying.
Thank you for your time and cooperation!

Sincerely,

Brian Trudeau

Trudeau Consulting LLC

18 Old Castle Drive

Newtown, CT 06470