PRECISION 

PRODUCIS 

Lasers, Instruments, GPS, Software 

September 02, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

1400 Hugh Avenue 

Louisville, KY 40213 

Ph: 502-459-1300 

Fax: 502-473-1900 

•Knoxville, TN 

•Nashville, TN 

•Lexington, KY 

www.yourprecision.com 

Re: Summary Processing Exemption Request Under Section 333 of the FAA Reform Act and Part 

I I of the Federal Aviation Regulations Based Upon Exemption 1111 OA issued to Trimble 

Navigation Limited 

Dear Sir or Madam: 

Precision Products, LLC ("Applicant") herewith applies for the issuance of an exemption under 

Section 333 of the FAA Modernization and Reform Act of 20 12 ("Reform Act") based upon Exemption 

11110 issued to Trimble Navigation Limited ("Trimble") on December 10, 2014, as amended on May 7, 

2015 with issuance of Exemption 11110A in FAA Docket 2014-0367. 

The requested exemption would allow Applicant to operate the UX5 and the UX5 hp aircraft 

manufactured by Trimble or other Trimble aircraft approved for commercial operations under 

Exemptions Ill! 0 and 11110A, as they may be amended in the future. Applicant notes that, in 

Exemption 11257, the FAA also recently authorized use of the Trimble UX5 by a third party under 

conditions like those in Exemption Ill l 0A. 1 Applicant hereby conftrms that it will accept the 

conditions in Exemptions l II lOA and I 1257. 

Applicant aircraft will be used to conduct aerial surveys and perform aerial data collection for 

agriculture, mining, and other purposes, but not for closed set filming (hereinafter "the Purpose"). 

Applicant hereby applies for an exemption from the listed Federal Aviation Regulations ("F ARs") to 

allow commercial operation of its small unmanned aerial vehicles (sUA Vs"), so long as such operations 

are conducted within and under the conditions outlined herein or as may be established by the FAA in 

an exemption granted under either Section 333 or Section 49 U.S.C. §4470 I (f). 

As this exemption request is identical to the already issued precedent, this request should 

qualify for summary processing as the FAA has already provided public notice of and granted similar 

exemptions. The FAA has issued exemptions in circumstances similar in all material respects to those 

presented in this petition. ln numerous exemptions, the FAA has found that the enhanced safety 

achieved using an unmanned aircraft ("UA") with the specifications described by the petitioners and 

carrying no passengers or crew, when compared to flights of much larger manned aircraft that carry 

crew in addition to flammable fuel, gives the FAA good cause to find that the sUA V operation enabled 

by the exemptions serves the public interest. 2 In those cases, use of the proposed sUA V not only 

enhanced safety but also fulfilled the Secretary ofTransportation's (the FAA Administrator's) 

responsibility to" ... establish requirements for the safe operation of such aircraft systems in the national 

airspace system." Section 333(c) of the Reform Act. 

Exemption No. 11257 to Montana Land Surveys (see Docket No. FAA-2014-0889). 

Exemption Nos. 11062 to Astraeus Aerial (see Docket No. F AA-20 14-0352), 11109 to Clayco, Inc. (see 

Docket No. FAA-2014-0507), llll 2 to VDOS Global, LLC (see Docket No. FAA-20 14-0382), and 11213 to 

Aeryon Labs, Inc. (see Docket No. FAA-2014-0642 
PRECISION 

PRODUCIS 

1400 Hugh Avenue 

Louisville, KY 40213 

Ph: 502-459-1300 

Fax: 502-473-1900 

•Knoxville, TN 

•Nashville, TN 

•Lexington, KY 

Lasers, Instruments, GPS, Software www.yourprecision.com 

The name and address of the applicant is: 

Todd Jones 

Precision Products 

1400 Hugh A venue 

Louisville, KY. 40213 

Phone: (502) 459-1300 

todd@yourprecision.com 

Regulations from which the exemption is requested: 

14 C.F.R. 6l.23(a) and (c) 

14 C.F.R. 61.101 (e) (4) and (5) 

14 C.F.R. 61.ll3(a) 

14 C.F.R. 6l.315(a) 

14 C.F.R. 91.7(a) 

14 C.F.R. 91.ll9(c) 

l4 C.F.R.9 1.121 

14 C.F.R. 91.15l(a)(l) 

14 C.F.R. 91.405(a) 

14 C.F.R. 91.407(a)(l) 

14 C.F.R. 91.409 (a)( I) and (2) 

14 C.F.R. 9l.417(a) and (b) 

This exemption application is expressly submitted to fulfill Congress' goal in passing Sections 

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) 

before completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types ofsUAVs do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following: 

• The sUA V's size, weight, speed and operational capability. 

• Operation of the sUAV in close proximity to airports and populated areas; and 

• Operation of the sUA V within visual line of sight of the operator. 

Reform Act§ 333(a). Lastly, if the Secretary determines that such vehicles "may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system." !d. § 333(c) (emphasis added).3 

The Federal Aviation Act, in addition to the authority granted by Section 333 of Reform Act, 

expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms 

Applicant interprets this provision to place the duty on the Administrator to not only process applications 

for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the sUA V, if 

it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval. 

2 
PRECISION 

PRODUCIS 

1400 Hugh Avenue 

Louisville, KY 40213 

Ph: 502-459-1300 

Fax: 502-473-1900 

•Knoxville, TN 

•Nashville, TN 

•Lexington, KY 

Lasers, Instruments, GPS, Software www.yourprecision.com 

includes exempting civil aircraft, as the term is defined under § 40 I 0 I of the Act, from the requirement 

that all civil aircraft, which includes sUA Vs, must have a current airworthiness certificate.

4 

The sUAVs that Applicant proposes to use are fixed wing and weigh 55 or fewer lbs. including 

payload. They operate, under normal conditions, at a speed of no more than 87 knots. They will 

operate at altitudes of no more than 400 feet, as further explained, and only within line of sight. They 

will operate as set forth in the manuals attached hereto and made a part hereof(Trimble UX5 Data 

Sheet/User guide contained in docket F AA-20 15-1192). Operations in compliance with these manuals 

will ensure that the sUA V will "not create a hazard to users of the national airspace system or the 

public"5 and that the aircraft will operate in compliance with the conditions set forth in this application. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY/NATIONAL SECURITY 

The applicant states that operating in compliance with the conditions set forth in Exemption 

!Ill OA will provide an equivalent level of safety for the operation of the UX5 and UX5 hp. Approval 

of exemptions allowing commercial operations of sUA V s for aerial data collection will enhance safety 

by reducing risk. Conventional operations, using jet or piston power aircraft, operate at extremely low 

altitudes just feet from the subject being photographed and in extreme proximity to people and 

structures and present the risks associated with vehicles that weigh in the neighborhood of 6,000 lbs., 

carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to 

and from the project location. In contrast, a sUAV weighing fewer than 55 lbs. and powered by 

batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried 

on board. The sUAV is carried to the target area and not flown. The sUA V will carry no passengers or 

crew and, therefore, will not expose them to risks associated with manned aircraft flights. These 

lightweight aircraft operate at slow speeds, close to the ground, and in areas that are under the control of 

the operator and, as a result, are far safer than conventional operations conducted with larger manned 

aircraft operating in close proximity to the ground and people. 

Given the small size of the sUAVs involved and the restricted environment within wb.ich they 

will operate, Applicant falls squarely within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial restricted areas in which they 

will operate, and the fact that they will be flown by pilots holding at least an FAA sport or recreational 

pilot license, approval of the application presents no national security issue. 

"The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44 702-44716 of the Transportation Act if the Administrator finds 

the exemption in the public interest." 49 U.S.C. §4470l(t). See also 49 U.S.C. § 44711(a); 49 U.S.C. § 447704; 14 

C.F.R. § 91.203(a)(l). 

5 Section 333(b) of the Reform Act. 

3 
PRECISION 

PRODUCIS 

Lasers, Instruments, GPS, Software 

PUBLIC INTEREST 

1400 Hugh Avenue 

Louisville, KY 40213 

Ph: 502-459-1300 

Fax: 502-473-1900 

•Knoxville, TN 

•Nashville, TN 

•Lexington, KY 

www.yourprecision.com 

The FAA has granted exemptions to the regulations listed on Page 2 in the exemptions cited 

above. As discussed in detail for each of these regulations in the attached Appendix A, the public 

interest will be served by an exemption because, with respect to each, operation in compliance with the 

requested conditions will ensure an equivalent level of safety. As also explained at length in Trimble's 

original Section 333 exemption request submitted on May 30, 2014, the grant of the requested 

exemption is in the public interest given the clear direction in Section 333 of the Reform Act; the 

authority included in the Federal Aviation Act, as amended; the strong equivalent level of safety 

surrounding the proposed operations; and the significant public benefit derived from, among other 

things, the enhanced safety and reduced environmental impact, including the reduced emissions 

associated with allowing battery powered sUA Vs instead of turbine or gas powered aircraft. 

********* 

Pursuant to 14 C.F.R. Part 11 , the following summary is provided for publication in the Federal 

Register, should it be determined that the publication is needed: 

Applicant seeks an exemption from the following rules: 

14 C.F.R. §§61.23(a) and (c), 61.10/(e)(4) and (5), 61.1/J(a), 61.3/5(a), 9/.7(a), 91.1 19(c), 

91.121, 91.15/(a)(l), 91.405(a), 91.405(a)(l), 91.409(a)(/) and (2), and 9/.417(a) and (b) to operate 

commercially a small unmanned vehicle (55 lbs. or less) in motion picture and television operations and 

aerial data collection. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of20 12-size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within visual line 

of sight and national security - provide more than adequate justification for the grant of the requested 

exemption allowing commercial operation of applicant's sUA V for the Purpose outlined herein and are 

consistent with exemptions already granted, including Exemption 11110A. Accordingly, the applicant 

respectfully requests that the FAA grant the requested exemption without delay. 

cc: Robert Pappas 

Thuy Cooper 

Dean Griffith 

Very truly yours. 

Todd 

~~~ Jones, Owner 

Precision Products, LLC 

4 
PRECISION 

PRODUCIS 

1400 Hugh Avenue 

Louisville, KY 40213 

Ph: 502-459-1300 

Fax: 502-473-1900 

•Knoxville, TN 

•Nashville, TN 

•Lexington, KY 

Lasers, Instruments, GPS, Software www.yourprecision.com 

APPENDLXA 

14 C.F.R. § 61.23(a) and (c): Medical Certificates: Requirement and Duration 

Sections 61.23(a) and (c) address the requirement of medical certificates for pilots. Section 

6 1.23(a) requires a person exercising the privileges of a recreational pilot to hold at least a third class 

medical certificate. Section 6 1.23(c) permits the holder of a sport pilot certificate to act as PIC of a 

light-sport aircraft with either a medical certificate or U.S. issued driver's license. Light-sport aircraft 

may weigh up to I ,430 pounds and seat up to two persons, including the pilot. Comparatively, the 

Trimble craft will weight fewer than 55 pounds, and it will not carry pilots, passengers, or cargo. The 

UAS will also be operated within visual line of sight of the PIC and below 400 feet above ground level 

and limited to operations with permission over private or controlled-access property. 

Given these safety parameters. Applicant requests that the FAA waive Section 6 1.23(a) upon 

finding than a equivalent level of safety will be provided by allowing operation of the Trimble craft by 

pilots with a recreational or sport pilot certificate and a valid U.S. state issued driver's license, in lieu of 

an FAA-issued medical certificate. Applicant also requests that the FAA grant relief from Section 

6 1.23(c) to allow sport pilot certificate holders to operate aircraft other than light-sport aircraft with a 

valid U.S. issued driver's license. The FAA has granted exemptions to conduct similar operations in a 

number of cases, including Exemption I 12 13. 

14 C.F.R. Part 61: Private Pilot Privileges and Limitations: Pilot in Command 

Sections 6 1.11 3 (a) & (b) limit private pilots to non-commercial operations. Section 6 1.3 15(a) 

addresses the privileges and limitations o f the holder of a sport pilot certificate. 

Because the sUAV will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft to hold a 

certificate issued by the FAA authorizing operation of any aircraft (A TP, Commercial, Private, 

Recreational or Sport). Unlike a conventional aircraft that carries the pilot and passengers, the sUA Vis 

remotely controlled with no living thing on board. The area of operation is controlled and restricted, 

and all flights are planned and coordinated in advance as set forth in the manual. The level o f safety 

provided by the requirements included in the manual exceeds that provided by a single individual 

holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the 

operation of the sUA V are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of the sUA V as requested with any 

certificate issued by the FAA as the PIC greatly exceeds the present level of safety achieved by 14 

C.F.R. Part 6 1. The FAA has granted exemptions for private and sport or recreational pilots to conduct 

similar operations in Exemptions 11062, 11 2 13, 11 360 and 11447. 

14 C.F.R. § 91.119: Minimum Safe Altitudes 

Section 91 . 11 9 establishes safe altitudes for operation of civil aircraft. Specifically, 9 1. 11 9(c) 

limits aircrafts flying over areas other than congested areas to 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. 

5 
PRECISION 

PRODUCIS 

Lasers, Instruments, GPS, Software 

1400 Hugh Avenue 

Louisville, KY 40213 

Ph: 502-459-1300 

Fax: 502-473-1900 

•Knoxville, TN 

•Nashville, TN 

•Lexington, KY 

www.yourprecision.com 

As set forth herein, the Trimble craft will never operate at higher than 400 feet AGL. They 

will, however, be operated to avoid congested or populated areas that are depicted in yellow on VFR 

sectional charts. Because aerial survey work must be accomplished at relatively low altitudes and at 

altitudes less than 400 feet AGL, an exemption from Section 9l.ll9(c) is needed. 

The equivalent level of safety will be achieved given the size, weight, speed, and material with 

which the Trimble craft are built. Also, no flight will be taken without the permission of the landowner 

or those who control the land. Because of the advance notice to the landowner, all affected individuals 

will be aware of the survey flights. Compared to aerial survey operations conducted with aircraft or 

rotorcraft weighing far more than the Trimble craft and carrying flammable fuel, any risk associated 

with these operations will be far less than those currently allowed with conventional aircraft operating at 

or below the same altitude. Indeed, the low-altitude operations of sUA V will maintain separation 

between these sUA V operations and the operations of conventional aircraft that must comply with 

Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions ll 062, 

11213, 11360 and 11447. 

14 C.F.R. § 91.121: Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set" ... to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." As each sUA V model in at least one operating mode will 

not have a barometric altimeter, but instead a GPS altitude read out, an exemption will be needed. An 

equivalent level of safety will be achieved by the operator, pursuant to the manuals, confirming the 

altitude of the launch site shown on the G PS altitude indicator before flight. The FAA has granted 

exemptions to conduct similar operations in Exemptions 11062, 11213, 11360 and 11447. 

14 C.F.R. § 9l.l51(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR 

conditions unless (considering wing 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." 

The battery powering the sUAV limits the duration of the flight. To meet the 30-minute 

reserve requirement in 14 C.F.R. ~ 91.151, sUAV flights would be severely limited, in some cases to 

approximately 10 minutes in length. Given the limitations on the sUA V's proposed flight area and the 

location of its proposed operations within a predetermined area, a longer time frame for flight in 

daylight or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 C.F. R. § 91.151 (a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the sUA V, in a tightly controlled area where only people 

and property owners or official representatives who have signed waivers will be allowed, with less than 

30 minutes of reserve fuel, does not engender the type of risks that Section 91 . 151 (a) was intended to 

alleviate given the size and speed of the sUAV. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to five 

minutes of reserve time on the batteries. This restriction would be more than adequate to return the 

sUA V to its planned landing zone from anywhere in its limited operating area. Similar exemptions 

6 
PRECISION 

PRODUCIS 

Lasers, Instruments, GPS, Software 

1400 Hugh Avenue 

Louisville, KY 40213 

Ph: 502-459-1300 

Fax: 502-473-1900 

•Knoxville, TN 

•Nashville, TN 

•Lexington, KY 

www.yourprecision.com 

have been granted to other operations in Exemptions 2689F, 5745, 10673, 10808 and Exemptions 

11062, 11213, 11360 and 11447. 

14 C.F.R. Part 91: Maintenance Inspections 

Section 9!.405(a) requires that an aircraft operator or owner "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 .... " 

Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an 

annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner 

or operator to keep records showing certain maintenance work that has been accomplished by 

certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return 

to service. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the applicant. Maintenance will be accomplished by the operator 

pursuant to the manuals. An equivalent level of safety will be achieved because these sUA Vs are very 

limited in size and will carry a small payload and operate only in areas for limited periods of time. If 

mechanical issues arise, the sUA V can land immediately since it will be operating from no higher than 

400 feet AGL. As provided in the manuals, the operator will ensure that the sUA Vis in working order 

prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition in order to provide the equivalent level of safety. The FAA has 

granted exemptions for similar operations in Exemptions II 062, 11213, 11360 and 11447. 

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