### 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: Exem ption 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, Pursuan t 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 co mp any m ay 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
- res olution 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 Cons ulting that the footage we provide will bolster the econom y. 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 cam eras toward the reconstructi on 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 usag e 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 Trudea u 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 s ys tem. 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 p ublic’s interest to do so. Trudeau Consulting LLC’s ultra light weight UAS me ets 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. Wewould 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 admini stered 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; Wh ether the UAS will be operated near airports or heavily populated areas; and, Wh ether 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, Trude au 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. W eighing less than fifteen (15) pounds (far below the max. 55 pound limit); inclu ding 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. Wh en 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 areaswhere general public is within fifty to one hundred (50
- 100) yards depending on location, conditions and weather. W e are constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort im me diately 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 si ght 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 ( 3 00) feet. Trudeau Consulting, LLC is highly aware of t he 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 co ntemplated 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: Sm all businesses in the area will benefit financially from aerial video and photography, who ty pically 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 th e local econom y. 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 emerge ncy 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 gase s, 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 3 00 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 Consu lting, 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