TRUMBULLUNMANNED 

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	14	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,	this	version	does	not	contain	Appendices	B-F referenced	in	the	submission	

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

Trumbull	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	under	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	consideration	in	

this	matter.	

Respectfully,

Dyan	Gibbens,	President

Trumbull	Unmanned,	LLC

 Dyan Gibbens
TRUMBULLUNMANNED 

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	New	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	infrastructure	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	industry 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 industry	and	offers	data	analytics,	engineering,	

logistics	and	UAS	operational	services. Located	in	Houston,	Texas, our operators	possess

thousands	of flight	hours,	both	in	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	operations. For	years,	our	team	performed	UAS	operations	

stateside	and	abroad.	During	this	time,	we researched	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	pilots,	engineers, and	programmers.	As	a	

company,	we	focus	on	safety	and	risk	management	through	UAS	operations,	engineering	and	

logistics.

Trumbull	teammates	have	performed	large-scale,	enterprise	wide	aerospace	and	unmanned	

integration	efforts.	To	date,	Trumbull	has	performed	UAS	benefits	assessments,	risk	

mitigation	and	safety	protocol development,	integration	efforts	and	planning for	leaders	in	the	

energy	sector.	We	appreciate	and	thank	you	for	your	time	and	consideration	in	this	matter.	

Please	contact	us	for	questions	or	concerns.
4 Trumbull Unmanned FMRA Section 333 Exemption Request

14	CFR	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	herein1.

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	command	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	carry	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	control	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	station	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	91.119 (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	

intends	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	91.121

§	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	altimeter	that	is	set,	when	operating...

14	C.F.R.	§	91.121 requires	a	person	operating	an	aircraft	to	maintain	cruising	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	altitude	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	weather	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	conduct	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	Trumbull	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	operations	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	maintenance,	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	

appropriate,	for	each	aircraft	(including	the	airframe)	and	each	engine,	propeller,	rotor,	

and	appliance	of	an	aircraft.	The	records	must	include...

Trumbull	believes	that	an	exemption	from	these	maintenance	requirements	is	warranted	

because	the	UA will	not	have	an	airworthiness	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	responsibility	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	testing,	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	use	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	sUAS	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	

infrastructure.	The	efficient	nature	of	UA allows	for	more	frequent	inspections	

increasing	the	likelihood	of	early	detection	of	any	potentially	dangerous	or	harmful	

structural	breaches.	Further	certain	inspections	are	potentially	dangerous	operations,	

unnecessarily	placing	personnel	at	risk.	UA can	perform	these	inspections, 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 the	enhanced	efficiency	of	the	UA.

Many	operations	Trumbull	intends	to	perform	are	currently	conducted	by	manned	

rotorcraft	or	fixed-wing aircraft.	Compared	to	manned	aircraft,	UA will	generate	

significantly	less	air	and	noise	pollution	while	conducting	those	same	operations.	

Additionally	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,	increased	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	facilities.	

Successful	integration	of	UA will	allow	for	safer	operations	in	remote	or	difficult	to	

access	areas.	They	will	also	increase	safety	in	hazardous	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	cycles on	infrastructure will	further	

reduce	risks	to	our	client's	employees	and	the	public-at-large.
Trumbull Unmanned FMRA Section 333 Exemption Request 9

The	Public	will	benefit	from	enhanced	situational	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	reasons	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	sUAS	will	not	be	carrying	passengers	or	any	other	living	thing	and can	be	safely	

operated	by	a	private	pilot	with	a	thorough	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	operations	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	

processes 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	CFR	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	an	equivalent	level	

of	safety	can	be	achieved	by	ensuring	an	instructor	is	in	arms	reach	of	the	controls	at	all	times	

or	is	able	to	control	the	aircraft	via	alternate	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	91.119 (c)

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

restrictions	and	location	of	the	UA.	Trumbull	will	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	Appendix	B to ensure	no	operations	are	
10 Trumbull Unmanned FMRA Section 333 Exemption Request

unnecessarily	conducted	over	personnel	or	property	that	can	be	injured	or	damaged	by	the	

UA.	By	operating	at	altitudes	below	400	feet	AGL, UA	operations	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

By	‘zeroing’	the	AGL	altitude	at	the	launch	point in	accordance	with	the	procedures	outlined	

by	the	manufacturers	manual	an	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%	fuel	or	battery	reserve	for	all	operations.	This	reserve	will

ensure	the	UA	can	be	safely	landed	prior	to	reaching	a	critical	fuel	state.	Trumbull’s	UA are	

also	equipped	with	failsafe	mechanisms	that	automatically	return	and	land	the	UA	when	a	

pre-determined	fuel	or	battery state	is	reached.

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	

maintenance	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,	stating:

(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	relief	from	the	applicable	parts	of	14	CFR	61	and	91	as	requested	

within	this	petition	to	allow 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	providing

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	health, 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	detailed	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	Amendment	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	imagery	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	nature	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	in	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	LLC

 Dyan Gibbens
Trumbull 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