AFS-13-079-E

February 08, 2013

 Exemption No. 10700

 Regulatory Docket No. FAA-2012-1234

Mr. James Kirkland

Trimble Navigation Limited

935 Stewart Drive

Sunnyvale, California 94085

Dear Mr. Kirkland:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

The Basis for Our Decision

By letter dated November 14, 2012, you petitioned the Federal Aviation Administration 

(FAA) on behalf of Trimble Navigation Limited (TNL) for an exemption from §§ 21.191(f), 

21.195(a), 45.23(b), 91.9(b)(s), 91.203(a) and (b) of Title 14, Code of Federal Regulations 

(14 CFR) to the extent necessary to allow TNL to operate the unmanned aircraft system 

(UAS) X-100 for missions related to research and development, crew training and market 

surveys associated with ground surveys.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to TNL.

The FAA has issued grants of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption Nos. 9720, 9783, and 10167 (copies 

enclosed), the FAA found that it was unnecessary to carry and display the airworthiness, 

certification, and registration documents in UASs for operations described by the petitioner, 

that the issuance of an Airworthiness Certificate for the purpose of market surveys was 

appropriate even though the prototype had not been manufactured in the United States, and 
2

that due to the small fuselage, a very limited area existed for placing identifying marks on an 

aircraft. The FAA also found that relocating the identifying marks was in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption Nos. 9720, 9783, and 10167;

• the reasons stated by the FAA for granting the enclosed Grant of Exemption Nos. 9720, 

9783, and 10167 also apply to the situation you present; and 

• a grant of exemption is in the public interest.

Our Decision

Under the authority contained in 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to me, I hereby grant Trimble Navigation Limited an exemption from 

14 CFR §§ 21.191(f), 21.195(a), 45.23(b), 91.9(b)(s), 91.203(a) and (b) to the extent 

necessary to allow TNL to operate the X-100 for missions related to research and 

development, crew training and market surveys associated with ground surveys, subject to the 

conditions and limitations described below.

Conditions and Limitations 

1. This exemption is for Trimble UAS X-100 only.

2. The word “Expermental” must be displayed on the aircraft to inform all parties of 

the aircraft’s overall operating status.

3. The petitioner may use 1-inch lettering at the location specified in the petition.

4. The documents required by § § 91.9 and 91.203 must be available to the pilot in 

command of the UAS any time the aircraft is operating. 

5. Those documents must be made available within 10 days to any FAA, U.S. 

Department of Defense, or law enforcement official on request.

This exemption terminates on January 31, 2015, unless sooner superseded or rescinded.

Sincerely,

/s/

John M. Allen

Director, Flight Standards Service

Enclosure