### TRUMBULL UNMANNED

5340 Weslayan St. #6588 Houston, TX 77005 USA 1

- 844

- TRUMBULL info@trumbullunmanned.com

October 24 ,	2014

Mr.	James	Williams Manager,	Flight	Standards	Service Unmanned	Systems	Integration	Office

Federal	Aviation	Administration 800	Independence	Avenue,	SW Washington,	DC	20591

U.S.	Department	of	Transportation Docket	Management	System

1200 New	Jersey	Avenue,	SE Washington,	DC	20590

Dear	Mr.	Williams,

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA), Trumbull Unmanned,	LLC (Trumbull) respectfully	requests	exemption	from	multiple	regulatory provisions of	Title	1 4	of	the	Code	of	Federal	Regulation	(CFR) and	other	rules	and	statutes pertaining	to usage	of	small	Unmanned	Aircraft	Systems (sUAS) operated	by	Trumbull in
support of safe	aerial	inspections,	mapping,	and	monitoring	of	infrastructure	and	operations

in	the energy industry

.

Please	note,	t his	version	does	not contain Appendices B

- F referenced	in	the	submission

because	it	contains Trumbull’s	commercial	proprietary	information and	trade	secrets

. Tru mbull	submits	these	appendices	as	a	Confidential	document	under	14	CFR	11.35(b).

Trumbull	has	not	and	will	not	share	that	information	with	others	unless under appropriate confidentiality	agreements.	The	content	in	Appendices B

- F is	protected	from	release	u nder	the

Freedom	of	Information	Act.	Sec.	5	U.S.C.	552 et	seq.

The complete version of	Trumbull’s	request,	including all appendices for	which Trumbull seeks	confidential	treatment,	has	been	sent to Marc	Bury,	Assistant	Chief	Counsel	for

International Law,	Legislation	and	Regulations division	to	allow	access	within	the	FAA	who

need to	review	all	portions	of	this	exemption	request	for	full access	to	the	documents	in	a

controlled	manner

. We	appreciate	your efforts;	thank	you	for	your time	and	consideratio n	in

this	matter.

Respectfully,

Dyan	Gibbens,	President Trumbull	Unmanned,	LLC

### TRUMBULL UNMANNED

5340 Weslayan St. #6588 Houston, TX 77005 USA 1

- 844

- TRUMBULL info@trumbullunmanned.com

September	29,	2014

Mr.	James	Williams Manager,	Flight	Standards	Service Unmanned	Systems	Integration	Office

Federal	Aviation	Administration 800	Independence	Avenue,	SW Washington,	DC	20591

U.S.	Department	of	Transportation Docket	Management	System

1200	N ew	Jersey	Avenue,	SE Washington,	DC	20590

Re:	request	for	exemption	from	multiple	regulatory	provisions	of CFR for	usage	of	sUAS operated	by	Trumbull	Unmanned	LLC. in support of safe	aerial	inspections,	mapping,	and monitoring	of infrastructure	and operations in	the	petroleum	industry

Dear	Mr.	Williams,

Trumbull	Unmanned	LLC

. (Trumbull) respectfully	requests	an	exemption	from	multiple provisions	of	Title	14	of	the	Code	of	Federal	Regulations	(CFR)	to	permit	the	use	of	small Unmanned	Aircraft	Systems	(sUAS) in	support	of safe	aerial	inspections,	mapping,	monitoring

, and	security of	infras tructure	and	operations in	the	energy	industry

.

This	request	stems	from	a	strong	safety	culture	and	conservative	risk

- based	approach towards	UAS	operations	to	reduce	hazardous	exposure	and	health,	safety,	and	environment (HSE)	risk	within	the	petroleum	i ndustry and	safety	in	the	energy	industry	at	large

. It	is important	to	note	that	these	activities	will initially augment	and	complement	current practices	and	not	fully	replace	manned	inspections, monitoring ,	or	security. Safe	integration

can	revolutionize the oil, gas ,	and	power maintenance	and	repair	cycle	and	enhance regulatory	compliance	and	environmental	responsibility.

Accordingly,	the	grant	of	an	exemption	is	consistent	with	the	intent	of	the	Congress,	as	shown

in	Section	333	of	the	FAA	Modernization and	Reform	Act	of	2012	( Section	333 )	that	safe systems	be	permitted	into	the	National	Airspace	System	(NAS)	prior	to	the	issuance	of	final regulations	governing	general	use	of	these	systems.Trumbull Unmanned FMRA Section 333 Exemption Request 3 Glossary	of	Abbreviations

ATC Air	Traffic	Control

CFR Code	of	Federal Regulations

COA Certificate	of	Waiver	or	Authorization

DoD Department	of	Defense

FAA Federal	Aviation	Administration

HSE Health,	Safety,	and	Environment

LOS Line	of	Sight

NAS National	Airspace	System

Section	333 FAA Modernization	and	Reform	Act	of	2012,	Section	333

sUAS small	Unmanned	Aircraft	System

UAS Unmanned	Aircraft	System

UAV Unmanned	Aerial	Vehicle

UA Unmanned	Aircraft

GCS Ground	Control	Station

PIC Pilot	in	Command

VLOS Visual	Line	of	Sight

Background Information

– Trumbull	Overview

Trumbull	integrates	sUAS	into	the energy indus try	and	offers	data analytics ,	engineering, logistics	and	UAS	operational	services. Located	in	Houston,	Texas, o ur operators	possess
thousands	of flight	hours,	both	i n	manned	and	unmanned	aircraft,	with	experience in emergency	response,	combat/combat	support,	and	numerous	high

- risk operations

.

Each	employee	possesses	a	decade	of	experience	in both manned	and	unmanned	aviation, ranging	from	DoD	to	commercial	operation s. For	years, our	team	performed	UAS	operations stateside	and	abroad.	During	this	time,	we research ed global UAS	best	practices	in operations, logistics,	engineering	and	operational	support. Also, Trumbull	collaborates	with	both	national

and	international UAS	test	sites	as	well	as	universities on developing	technologies,	shaping regulations

, and discovering	and	sharing best	practices

.

In	addition	to	UAS	operational	experience,	Trumbull	has	an	agile	data	science	practice. Our

team	is comprised	of manned	and	unmanned pilot s ,	engineer s
, and	programmer s

. As	a

company,	w e	focus	on	safety	and	risk	management	through	UAS	operations,	engineering	and logistics

.

Trumbull	teammates	have	performed	large

- scale,	enterprise	wide	aerospace	and	unmanned integrati on	efforts. To	date,	Trumbull	has	performed	UAS	benefits	assessments,	risk mitigation	and	safety	protocol development ,	integration	efforts	and	planning for	lead ers	in	the

energy	sector .	We	appreciate	and	t hank	you	for	your	time	and	consideration	in	this	ma tter. Please	contact	us	for	questions	or	concerns.4 Trumbull Unmanned FMRA Section 333 Exemption Request 14	C FR	11.81	(a)

– Name	and	address	of	the	Petitioner

Trumbull	Unmanned,	LLC 5340	Weslayan	St.	#6588 Houston,	TX	77005

Office: ( 281)	624

- 6827 JR@trumbullunmanned.com

14	CFR	11.81	(b)

– Exemptions	Requested:

The	FAA	considers	all	aircraft	whether	manned	or	unmanned	as	“aircraft”	flown	by	a	“pilot”. Title	14	of	the	Code	of	Federal	Regulations	(14	CFR)	governs	the	manner	in	which	all	aircraft and	pilots	operate	within	the	National	Airspace	System	(NAS).	Due	to	the	nature	of	their systems	and	operation

, Unmanned	Aircraft	Systems	(UAS)	are	unable	to	comply	with	certain sections	of	14	CFR	as	the	regulations	were	written	prior	to	the	consideration of	small	UAS operating	within	the	NAS.	Trumbull	is	requesting	an	exemption	from	certain	parts	of	14	CFR cited	below	in	addition	to	such	further	exemptions	and	relief	as	the	FAA	may	determine	is necessary	to	permit	the	operations	described	herein 1

.

14	CFR Part	61.113	(a)	and	(b)

– Private	pilot	privileges	and	limitations:	Pilot	in

command

14	CFR	Part	91.109

– Flight	Instruction 14	CFR	Part	91.119	(c)

– Minimum	safe	altitudes

14	CFR	Part	91.121

– Altimeter	settings 14	CFR	Part	91.151	(a)

– Fuel	requirements for	flight	in	VFR	conditions 14	CFR	Part	91.405	(a)

– Maintenance	required 14	CFR	Part	91.407	(a)	(1)

– Operation	after	maintenance,	preventive	maintenance, rebuilding	or alteration 14	CFR	Part	91.409	(a)(2)

– Inspections 14	CFR	Part	91.417	(a) and (b)

– Maintenance	Records

14	CFR	11.81	(c)

– The	extent	of	relief	Trumbull	seeks,	and	the	reason	Trumbull	seeks

the	relief:

14	CFR	61.113	(a)	and	(b)

§	61.113 Private	pilot	privileges	and	limitations:	Pilot	in	command.
(a) Except	as	provided	in	paragraphs	(b) through	(h)	of	this	section,	no	person	who	holds a	private	pilot	certificate	may	act	as	pilot	in	command	of	an	aircraft	that	is	carrying

1 After	reviewing	exemption	No.	11062	and	in	determining	that	the	UA	Trumbull	seeks	to	operate	are	similar	in size,	weight,	operating	conditions,	design	safety	features, and	will	be	operated	under	specific	limitations described	herein	and	in	the	attached	appendices	Trumbull	is	not	seeking	an	exemption	from	14	CFR	part	21, subpart	H.Trumbull Unmanned FMRA Section 333 Exemption Request 5 passengers	or	property	for	compensation	or	hire;	nor	may	that	person,	for	compensation
or	hire,	act	as	pilot	in	comman d	of	an	aircraft. (b) A	private	pilot	may,	for	compensation	or	hire,	act	as	pilot	in	command	of	an	aircraft
in	connection	with	any	business	or	employment	if: (1) The	flight	is	only	incidental	to	that	business	or	employment;	and
(2) The aircraft	does	not	ca rry	passengers	or	property	for	compensation	or	hire.

§	61.113 (a)	and	(b)	limit	private	pilots	to	non

- commercial	operations,	however	Trumbull proposes	that	its	sUAS	PICs	holding	at	least	a	third	class	medical	certificate and	a	private	pilot

certificate is	appropriate. As	noted	in	Exemption	No.	11062	the	areas	of	knowledge	required of	a	private	pilot	to	safely	operate	a	sUAS	in	the	manner	requested	in	this	document	is appropriate. Trumbull	requests	relief	from §	61.113 (a)	and	(b) to	allow	a	private	pilot certificate	holder	with	a	third	class	medical	to	perform	commercial	sUAS	operations.

14	CFR	91.109

§	91.109 Flight	instruction;	Simulated	instrument	flight	and	certain	flight	tests.
(a) No	person	may	operate	a	civil	aircraft (except	a	manned	free	balloon)	that	is	being used	for	flight	instruction	unless	that	aircraft	has	fully	functioning	dual	controls.
However,	instrument	flight	instruction	may	be	given	in	an	airplane	that	is	equipped	with a	single,	functioning	throwover	cont rol	wheel	that	controls	the	elevator	and	ailerons,	in
place	of	fixed,	dual	controls,	when

—

The	sUAS	that	Trumbull	intends	to	operate	by	design	do	not	have	fully	functional	dual
controls.	Flight	control	is	accomplished	through	the	use	of	a	ground	control	s tation	that

communicates	with	the	aircraft	via	radio	communications. Although	the	majority	of	training	is

conducted	outside	of a	commercial	operating	environment,	relief is	requested	for	a	required
supervision	flight	as outlined Appendix C.

14 CFR	91.11 9 (c)

§	91.119 Minimum	safe	altitudes:	General. Except	when	necessary	for	takeoff	or	landing,	no	person	may	operate	an	aircraft	below the	following	altitudes: (c) Over	other	than	congested	areas. An	altitude	of	500	feet	above	the	surface, except	over open	water	or	sparsely	populated	areas.	In	those	cases,	the	aircraft	may	not	be	operated closer	than	500	feet	to	any	person,	vessel,	vehicle,	or	structure.

The	inspection,	surveying,	mapping,	and	emergency	response	operations	that	Trumbull

int ends	to	support	must	be	accomplished	at	altitudes below	500	feet	AGL	thus	an	exemption
from		§	91.119 (c) is	needed. In	accordance	with	current	guidelines ,	we	request	operations

400	feet	AGL	and	below.6 Trumbull Unmanned FMRA Section 333 Exemption Request 14 CFR	91.1 21

§	91.121 Altimeter	settings.
(a) Each person	operating	an	aircraft	shall	maintain	the	cruising	altitude	or	flight	level	of that	aircraft,	as	the	case	may	be,	by	reference	to	an	altime ter	that	is	set,	when	operating...

14	C.F.R.	§	91.121 requires	a	person	operating	an	aircraft	to	maintain	cruis ing	altitude	or a flight	level	by	reference	to	an	altimeter	that	is	set	to	the	elevation	of	the	departure	airport	or
barometric	pressure.	Some	of	the	sUAS	Trumbull	intends	to	operate	are	not	equipped	with	a

barometric	altimeter,	but	instead	use	GPS	for	alt itude	control

, which	is	transmitted	to	the	pilot via	a	digitally	encoded	telemetric	data	feed. Relief	from §	91.121 is	requested	to	allow	the	GPS,

radio,	or	laser	altimeter	to	be	used	to	maintain	the	correct	AGL	altitude.

14 CFR	91.151 (a)

§	91.151 Fuel requirements	for	flight	in	VFR	conditions.
(a) No	person	may	begin	a	flight	in	an	airplane	under	VFR	conditions	unless	(considering
wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to	the	first	point	of intended	landing	and,	assuming normal	cruising	speed

— (1) During	the	day,	to	fly	after	that	for	at	least	30	minutes;	or (2) At	night,	to	fly	after	that	for	at	least	45	minutes.
(b) No	person	may	begin	a	flight	in	a	rotorcraft	under	VFR	conditions	unless	(considering
wind	and	forecast	we ather	conditions)	there	is	enough	fuel	to	fly	to	the	first	point	of intended	landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	20

minutes.

The	operations	Trumbull	intends	to	condu ct	are	not	point

- to

- point	flights	but	are	limited to	a

pre

- defined	area	within	visual	sight	of	the	PIC	and	will	not	require	an	airport	for	operations. This	risk	of	the	aircraft	running	out	of	fuel	as	outlined	in	§	91.151 (a) does	not	directly	apply
to	the	way	in	which	Trumbull	will	operate. Further	if	Tru mbull	were	to	maintain	a 30

- minute

reserve, some	of	its	UA its	operation	would	not	be	possible	as	the	reserve	time	is	greater	than the	flight	time	of	the	UA.

The	mapping	and	inspecting	operations	Trumbull	intends	to	conduct	will	be	limited	to daytime; however	our	intention	of	supporting	emergency	response	operation s	may	require night	operations	thus	relief	from §	91.151 (a)(2)

14 CFR	91.405	(a),	91.407(a)(1),	91.409(a)(1)	and	(2),	and	91.417(a)	and	(b)

§	91.405 Maintenance	required.

Each	owner or	operator	of	an	aircraft

—Trumbull Unmanned FMRA Section 333 Exemption Request 7 (a) Shall	have	that	aircraft	inspected	as	prescribed	in	subpart	E	of	this	part	and	shall
between	required	inspections,	except	as	provided	in	paragraph	(c)	of	this	section,	have
discrepancies	repaired	as	prescribed	in	part 43	of	this	chapter ;

§	91.407 Operation	after	maintenance,	preventive	maintenance,	rebuilding,	or	alteration.
(a) No	person	may	operate	any	aircraft	that	has	undergone	mainte nance,	preventive maintenance,	rebuilding,	or	alteration	unless

— (1) It	has	been	approved	for	return	to	service	by	a	person	authorized	under	§ 43.7 of	this
chapter...

§	91.409 Inspections

. (a) Except	as	provided	in	paragraph	(c)	of	this	section,	no	person	may	operate	an	aircraft unless,	within	the	preceding	12	calendar	months,	it	has	had

— (1) An	annual	inspection	in	accordance	with	part 43	of	this	chapter and	has	been
approved	for	return	to	service	by	a	person	authorized	by	§ 43.7 of	this chapter;	or (2) An	inspection	for	the	issuance	of	an	airworthiness	certificate	in	accordance	with

part 21	of	this	chapter

. ...

§	91.417 Maintenance	records.
(a) Except	for	work performed	in	accordance	with	§§ 91.411 and 91.413 ,	each	registered
owner	or	operator	shall	keep	the following	records	for	the	periods	specified	in	paragraph
(b)	of	this	section:
(1) Records	of	the	maintenance,	preventive	maintenance,	and	alteration	and	records	of

the	100

- hour,	annual,	progressive,	and	other	required	or	approved	inspections,	as
appropriat e,	for	each	aircraft	(including	the	airframe)	and	each	engine,	propeller,	rotor,
and	appliance	of	an	air craft.	The	records	must	include...

Trumbull	believes	that	an	exemption	from	these	maintenance	requirements	is	warranted

because	the UA will	not	have	an	a irworthiness	certificate,	and	the	FAA	has	not	developed
equivalent	part	91	maintenance	requirements	for	sUAS

. More	specifically,	no	individuals	are
authorized	by	the	FAA	to	approve	a	sUAS	for	return	to	service	under	91.407(a)	or	to	conduct

initial airworthiness inspections

.

14	CFR	11.81	(d)

– The	reasons	why	granting	Trumbull’s	request	would	be	in	the	public interest;	that	is,	how	it	would	benefit	the	public	as	a	whole:

Granting	the	exemption	will	further	public	interest	by	allowing	Trumbull	to safely,	efficiently, and	economically	perform	operations	to	further safe UAS	integration	into the petroleum industry .	An	overarching	goal	of	safely	integrating	sUAS	into	the petroleum industry	is	to promote	regulatory	compliance	and	environmental	responsib ility	for	the	public,	while,	at	the same	time,	enhancing	operational	efficiencies	and	cost	savings	and	avoidance	for petroleum companies.8 Trumbull Unmanned FMRA Section 333 Exemption Request With	a	strong	safety	and	risk	culture,	and	experience	in	UAS	test ing ,	our	team	will	ensure	safe sUAS	integration.		Safe	sUAS	operations	will	reduce	risk	and	unnecessary	exposure	for inspectors	and	pilots	as	compared	to	legacy	processes.	Risk	and	change	management	remain critical	components	of this sUAS	integration.

The	u se	of	sUAS	will	improve	incident	response	and	preparedness.	Compared	to	manned aircraft,	sUAS	typically	operate	at	less	than	5%	of	the	fuel	usage.	Due	to	lower	operating	costs, increased	inspections	will	result	in	proactive	maintenance	and	repair.	Safe	sUA S	operations will	enhance	situational	awareness, and	allow	for early	detection	and	early	action when

incidents	occur

.

The	Public	will	benefit	from	improved	regulatory	compliance	through	aerial inspections	and	monitoring.

Trumbull	will	be	supporting	the energy industry	through	the	development	and	use	of sUAS	in	the	aerial	inspection	and	monitoring	of	facilities, freestanding structures,	and

infrastructu re.	The	efficient	nature	of	UA allows	for	more	frequent	inspections increasing	the	likelihood	of	early	d etection	of	any	potentially	dangerous	or	harmful

structural breaches.	Further	certain	inspections	are	potentially	dangerous	operations,

unnecessaril y	placing	personnel	at	risk.	UA can	perform	these	inspection s, preventing personnel	from	having	to	enter potentially	hazardous	situations. Through	benefit analysis,	UA	are	proving	safer	than	legacy	inspection	processes. UA	usage will minimize	injuries	(and reduce	HSE	risk	to	inspectors	and	lost	time	injury	rates	for employees )

.

The	Public	will	benefit	from th e	enhanced	efficiency	of	the	UA.

Many	operations	Trumbull	intends	to	perform	are	curre ntly	conducted	by	manned

rotorcraft	or	fixed

- wing aircraft

. Compared	to	manned	aircraft, UA will	generate significant ly	less	air	and	noise	pollution while	conducting those	same	operations.

Addition ally	the	efficient nature	of	UA enable increased	inspection	frequencies thereby allowing earlier	detection	of	potentially	harmful	leaks	and	spills. UA	will	reduce	the carbon	footprint	for	comparable	inspections.	Further,	incr eased	inspections	will	also enhance	regulatory	compliance	and	environmental	responsibility.

The	Public	will	benefit from	the	increased	safety	of	UA.

The	scope	of	work	accomplished across the energy industry	requires	operations	in remote	areas	and	in	challenging	terrain	or	within	hazardous	industrial	facilitie s. Successful	integration	of	UA will	allow	for	safer	operations	in	remote or	difficult	to access	areas.	They	will	also	increase	safety in	hazar dous	facilities	where	inspections are	required. Additionally,	UA’s ability	to	support	first	responders	in	emergency

situations provides	a	significantly	increased	level	of	safety	while	coordinating	response

efforts. The	potential	for	increased	inspection	cy cles on	infrastructure will	further

reduce	risks	to our	client 's	employees	and	the	public

- at

- l arge

.Trumbull Unmanned FMRA Section 333 Exemption Request 9 The	Public	will	benefit	from	enhanced	situa tional	awareness	provided	by	UA to Emergency	Responders

.

UA serve	as a	safe	and	efficient	way	to	provide	an	overhead	view	of	emergency situations;	allowing	Emergency	Response	efforts	to	be	coordinated	more	efficiently and	further	minimize	risks	to	responders and	to	the	public

.

14	CFR	Part	11.81	(e)

– The	reason s	why	granting	the	exemption	would	not	adversely affect	safety,	or	how	the	exemption	would	provide	a	level	of	safety	at	least	equal	to	that
provided	by	the	rule	from	which Trumbull seeks	the	exemption:

14	CFR	61.113	(a)	and	(b)

Trumbull ’ s	s UAS	will	not	be	carrying	passengers	or	any	other	living	thing and can	be	safely operated	by	a	private	pilot	with	a	th orough	understanding	of	the	NAS	and	the	UA

. The additional	training	and	experience	acquired	through	the	pursuit	of	a	commercial	certificate is critical	to	a	pilot	for	hire	who	may	encounter	numerous	situations	during	a	flight	and	must ensure	the	safety	of	its	passengers.	The	extra requirement	of	a	commercial	certificate	does not meaningfully	provide	any	additional	aid	or	safety	to	the	operati ons	in	the	confined	and restricted	manner	with	which	Trumbull	intends	to	operate. As	outlined	in Appendix C

, Trumbull	operators	undergo	initial	and	periodic written	testing	and	flight	evaluation

process es in	addition	to	the	manufacturer	recommended	training.	The	operations	Trumbull intends	to	conduct	will	keep	the	sUAS	in	a	defined	operating	area	and	at	altitudes	well	below

those	of	conventional	aircraft ensuring	separation	of	aircraft	at	all	times

.

14	C FR	91.109

The	majority	of	training	with	sUAS	will	not	be	conducted	during	operations	outlined	in	this
petition,	however	as listed in Appendix C some instruction	may	be necessary. This	training	is
important	to	ensure	the	quality	of	Trumbull’s	pilots	within	the	commercial	operating

environment. Although	the	Instructor	may	not	have	access	to	dual	controls	a n	equivalent	level of	safety	can	be	achieved	by	ensuring	an	instructor	is	in	ar ms	reach	of	the	controls	at	all	times

or	is	able	to	control	the	aircraft	via	alternat e	equipment. Additionally	no	pilot	or	passengers are	aboard	the	sUAS	and	all	persons	will	be	a	safe	distance	away	should	the	sUAS	experience
any	difficulties	during	flight instruction.

14 CFR	91.11 9 (c)

An	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed,	and	operating

restrictions	and	location	of	the	UA. Trumbull	wil l	be	conducting	operations	in	a	clearly	defined

and	restricted operating	area	usually	owned	by	the	client.	Operations	will	only	be	in	and

amongst participating	personnel who	have	been	briefed	on	the	operations,	their	potential
risks,	and	have	acknowledged	and	accepted	those	risks .	Additionally	Trumbull	will	strictly
adhere	to	the	operating procedures	outlined	in A p pendix B to ensure	no	operations	are10 Trumbull Unmanned FMRA Section 333 Exemption Request unnecessarily	conducted	over	personnel	or	property	that	can	b e	injured	or	damaged	by	the

UA .	By	operating	at	altitudes	below	400	feet	AGL

, UA	o perations	will	be	separated from	those conventional	aircraft	that	must	comply	with	§	91.119. Given	that UA operations	will	be
conducted	in	lieu	of	manned	aircraft	that	are	significantly	heavier, using	large	quantities	of
flammable	fuel,	UA are	significantly	safer	to	the	participants	and	the	public.

14 CFR	91.121

B y	‘zeroing’	the AGL altitude	at	the	launch	point in	accordance	with	the	procedures	outlined
by	the	manufacturers	manual	a n	equivalent	level	of	safety can	be	achieved.	In	addition to	the UA	always	being	within	VLOS,	the	PIC	will	have	a	real	time	display	of	the	systems	GPS	altitude
via	a	digitally	encoded	telemetric	data	feed	downlinked	from	the	UA	to	the	GCS.	This	data	will

ensure	the	UA remains	below the	maximum	operating	altitude (maximum	400	feet	AGL) at	all

times

.

14 CFR	91.151

Given	the	size	of	the	sUAS	and	the	manner	in	which	they	are	operated	this	is	as	safe	or	safer than	traditional	manned	operations.	Additionally	the	manner	in	which	the	UA	will	be flown within	a	confined	operating	area	and	flying	pre

- planned	routes	that	can	be	completed	prior	to fuel/battery	depletion minimize	the	risk	addressed	in §	91.151. In	accordance	with Appendix

B

, Trumbull	will	maintain	a	20% f uel	or b atter y	r eserve	for	all operations.	This	reserve	will ensure	the	UA	can	be	safely	landed	prior	to	reaching	a	cri tical	fuel	state.	Trumbull’s	UA are also	equipped	with	failsafe	mechanisms	that	automatically	return	and	land	the	UA	when	a

pre

- determined	fuel	or	batter y state	is	reac hed.

An	equivalent	level	of	safety	can	be	maintained for	operations	at	night by	confining	operations
to	a	defined	area	and	closely	adhering	to	Trumbull’s	risk	and	operating	procedures	outlined	in
Appendix B under the	section	titled	“Night Operations”.

14 CFR	91.405	(a),	91.407(a)(1),	91.409(a)(1)	and	(2),	and	91.417(a)	and	(b)

An equivalent	level	of	safety can	be	achieved	by	ensuring all	manufacturer	published
maintenance	procedures	in	additional	to	Trumbull’s	internal	operational	risk	mitigation	and

m aintenance	processes are	accomplished.	These	processes	can	be found in	Appendix D .	Given the	size	and	manner	in	which	the	sUAS	will	be	operated,	particularly that	it	will	remain	below 400	feet	AGL	and	within	visual	line	of	sight,	it	can	quickly	be	landed	after	any	indication	of

mechanical	issues further	limiting	any	risk.Trumbull Unmanned FMRA Section 333 Exemption Request 11 14	CFR	Part	11.81	(f)	A	summary	the	FAA	can	publish	in	the Federal	Register ,	stati ng:

(1) The	rule	from	which	you	seek	the	exemption

Petitioner: Trumbull	Unmanned,	LLC.

Sections	of	14	CFR	that	Trumbull	seeks	exemption:

14	CFR	Part	61.113	(a)	and	(b)

– Private	pilot	privileges	and	limitations:	Pilot

in	command

14	CFR	Part	91.109

– Flight	Instruction 14	CFR	Part	91.119	(c)

– Minimum	safe	altitudes

14	CFR	Part	91.121

– Altimeter	settings 14	CFR	Part	91.151	(a)

– Fuel	requirements	for	flight	in	VFR	conditions 14	CFR	Part	91.405	(a)

– Maintenance	required 14	CFR	Part	91.407	(a)	(1)

– Operation	after	maintenance,	preventive maintenance,	rebuilding	or	alteration 14	CFR	Part	91.409	(a)(2)

– Inspections 14	CFR	Part	91.417	(a) and (b)

– Maintenance	Records

(2)	A	brief	description	of	the	nature	of	the	exemption	you	seek:

Trumbull	seeks	reli ef	from	the	applicable	parts	of	14	CFR	61	and	91	as	requested within	this	petition	to	all ow Trumbull	to	safely	and	efficiently	conduct	commercial	UAS flight	operations	in	support	of	the energy industry	and to further research	and development for	our	clients	and	the	unmanned aircraft	industry

- at

- large.12 Trumbull Unmanned FMRA Section 333 Exemption Request 14	CFR	Part	11.81	(g)

– Any	additional	information,	views	or	arguments	available	to
support Trumbull’s request:

Allowing	this	exemption	will	give	Trumbull	the	ability	to	further	promote	the	development	of UAS	technologies	in	a	manner	that increases	safety,	security, and efficiency, while provid ing positive	economic impact for our	clients	and	the	public.	Trumbull	maintains	strong relationships	across	the petroleum industry,	the	unmanned	aircraft	industry,	and	the	FAA	in an	effort	to	conservatively	integrate	unmanned technologies in a	manner	that	will	ensure safe operations that benefit	the public	at

- large. An	industry	as	safety

- conscious	as	the petroleum industry is	eager	to	pursue any	opportunity	to	reduce	risk	to its personnel and	the	public. SUAS	are	an	appealing	technology	that allow	companies	a	way	to reduce	h ealth, safety,	and

environment (HSE)	exposure	of	petroleum	industry	employees,	partners	and	the	public.	Safe and	proper	use	of	sUAS	can	also	support	increased	regulatory	compliance	and	environmental responsibility.	The	efficient	nature	of	UA	allow	for	more	detai led	and	frequent	monitoring	and documentation	of	wildlife	and	habitats,	reclamation	efforts,	and	air	sampling.	This	increased activity	can	all	be	done	while	reducing	environmental	impacts	of	operations

.

Trumbull	takes	any	and	all	First	and	Fourth	Am endment	concerns	related	to	the	operation	of unmanned	systems	seriously. Trumbull	operations	will	either	occur	on	the	clients ’ private property	or	in	remote	locations	where	all	participating	individuals	will	be	aware	of	and	have acknowledged	any	imager y	or	video	being	collected. Additional	procedures	ensuring	privacy can	be	found	in	Appendix B under	the	section	titled	“Data	Collection”.

14	CFR	Part	11.81	(h)

– Request	to	exercise	the	privileges	of	the	exemption	outside	the United	States,	the	reason	why Trumbull needs	to	do	so:

Given	the	global	na ture	of	our	client's operations

, Trumbull	requests	to	exercise	the	privileges of	the	exemption	outside	of	the	United	States.	The	activities	of	the petroleum industry	are global	i n	nature	and	will	benefit	from	the	increased	safety,	efficiency, security, and	economic advantages	of	utilizing	UA .	Trumbull	maintains	a	close	relationship	with	the	International

Consortium	of	Aeronautical	Test	Sites	and works	closely	with	those	countries to	accomplish all	ICAO	and	host	nation	requirements.

If	the	FAA	believes	additional	exemptions beyond	those	requested	in	this	petition are required	for	Trumbull	to	conduct	sUAS	operations	described	here,	we	respectfully	request	an exemption	from	any	such regulatory	provisions	as	deemed	necessary. For	any	questions	or concerns,	please	contact	me	directly	at	the	phone	number	or	email	address	provided.

Very	Respectfully,

Dyan	Gibbens,	President

Trumbull	Unmanned	LLCTrumbull Unmanned FMRA Section 333 Exemption Request 13 Appendix	A

Proposed	Aerial Vehicles

Lockheed	Martin	Long	Endurance	SUAS Lockheed	Martin	Indago Quadrotor

3DRobotics Fixed	Wing

3DRobotics Multirotor

3DRobotics Quadrotor

Arcturus T

- 20 Unmanned	Flying	Rolling	Orb	“UFRO” Sensefly	eBee

SteadiDrone DJI	S1000 Skywalker	Flying	Wing	X8 OSU	Noctua	fixed	wing	quiet	UAV