August 31, 2015

Attention: 

USDOT

Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

Petitioner:

Trout Law PLLC

Kim J. Trout, Esq.

3778 N. Plantation River Dr., Ste. 101

Boise, Idaho 83703

208.577.5755

Petition of Trout Law for Exemption Pursuant to Section 333 of the FAA Modernization & Reform Act (2012)

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, Trout Law, 

planned operator of Small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial remote sensing, 

photography, and videography, hereby applies for an exemption from the subsequently listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its sUAS.

Trout Law PLLC is owned and operated by Kim J. Trout, Esq. Trout Law practices in the fields of business and 

construction law along with related endeavors in real estate development. Mr. Trout holds a Private Pilot 

Certificate Number: 3808396 and is type rated in Cessna 152, Cessna 172, and Piper Cherokee Arrow 180.

All Trout Law sUAS Pilots In Command (PIC) will be rated, current pilots. As enumerated below, the requested 

exemption would permit the operation sUAS under controlled conditions in airspace that is:

1. Predetermined

2. Limited

3. Controlled.

The proposed exemption would allow Trout Law to conduct commercial operations sUAS meeting or exceeding 

all of the operational and safety requirements Congress has set forth in Section 333.

Trout Law is a law firm and real-estate development company that intends to offer various sUAS-based services, 

including Active and Passive Remote Sensing:
• Practice Flights with No Commercial Purposes

• Near-Infrared Photography and Videography

• Thermographic Infrared Photography and Videography

• Ultraviolet Photography and Videography

• Visible Band Photography and Videography

• Audio-Including Sound Pressure Level-Monitoring and Collection

Specific applications of our technology include but are not limited to:

• Real Estate (Commercial and Residential)

• Artistic Applications such as Cinematographic and Photographic Production

• Environmental Monitoring

• Construction Monitoring

• Structural Assays

• Engineering

• LiDAR

• Events

• Emergencies

• Education and Research

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil

UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if

certain unmanned aircraft systems may operate safely in the national airspace system

before completion of the (comprehensive) plan and rule making required by section

332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section

332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited

operation authorization” if several factors are met. Petitioner meets all requirements to

permit FAA approval of commercial UAS operations.

The Petitioner Requests Relief From the Following:

• 14 C.F.R. Part 21

• 14 C.F.R. 45.23 (b)

• 14 C.F.R. 61.113(a) and (b)

• 14 C.F.R. 91.7 (a)

• 14 C.F.R. 91.9 (b) (2)

• 14 C.F.R. 91.109

• 14 C.F.R. 91.119

• 14 C.F.R. 91.121

• 14 C.F.R. 91.151(a)

• 14 C.F.R. 91.203 (a) & (b)

• 14 C.F.R. 91.205 (b)

• 14 C.F.R. 91.215

• 14 C.F.R. (91.401 – 91.417)

Trout Law petitions for exemption specifically to operate DJI Inspire 1 UAS flight platforms and imaging using 

various cameras/imaging devices. The Inspire 1 has a built-in capability to limit the height it flies above the 

ground altitude at takeoff, to limit the radius of the distance it flies from the operator, and to deny operations in 

various airspace classes. The Inspire 1 also has a failsafe autopilot system: when the communication between the 
main controller and the receiver is substantially compromised and the GPS signal is sufficient the system will 

automatically trigger Return To Home (“RTH”) functionality and land the sUAS.

Trout Law will only operate its Inspire 1 sUAS:

• • After successful completion of all maintenance in accordance with the manufacturers 

specifications

• • After a thorough preflight inspection compliant with manufacturer’s instructions

• • During daylight hours

• • In line of sight of the minimum crew: an sUAS Operator and an Observer

• • While Operator and Observer are in constant voice communications

• • So as to not create a hazard to users of the National Airspace System or the public

• • Within parameters specified in either Letter of Agreement or COA when within 5 miles of an 

airport

• • Yielding to other aircraft

• • Within a maximum flight time 20 minutes or at more than 25% of battery power, whichever 

occurs first

• • Limiting flight to 400AGL or no more than 100’ above the highest obstacle within 500’

• • At 50 knots or less

• • Within 500’ of the PIC

• • Never over an open assembly of people

• • Compliant with conditions specified in the FAA’s exemption document

Respectfully,

Kim J. Trout, Esq.

Managing Member

Trout Law PLLC