{.\ fl fl ~fTIInstrum~nts 

~~~~~ & Supplies 

7114 East Earll Drive, Scottsdale, AZ 85251 

480-994-1306 • FAX 480-994-8337 • 800-272-0180 

17 June 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Application for Issuance of Section 333 Exemption Based upon 

Exemption 11110 Issued to Trimble Navigation Ltd. 

Dear Sir or Madam, 

Allen Associates Inc. herewith applies for the issuance of an exemption under Section 

333 of the FAA Modernization and Reform Act of 2012 based upon Exemption 11110 

issued to Trimble Navigation Ltd. ("Trimble") on December 10, 2014 in FAA Docket 

2014-0367. The requested exemption would allow Allen Associates Inc. to operate the 

UX5 aircraft manufactured by Trimble or other Trimble aircraft approved for commercial 

operations under Exemption 11110, as amended, such as the UX5hp for which an 

amendment has been filed. Allen Associates Inc. notes that the FAA recently 

authorized use of the Trimble UX5 by a third party in Exemption No. 11257, Regulatory 

Docket No. FAA-2014-0889, on April2, 2015, under updated conditions, and Allen 

Associates Inc. hereby confirms that it will accept such conditions as well as those set 

forth in Exemption No. 11240, Regulatory Docket No. FAA-2014-0894. 

The name and contact information for the applicant are: 

Richard Gage 

Allen Associates Inc. 

7114 E Earll Drive 

Scottsdale, AZ 85251 

Phone: (408) 994-1306 

RGAGE@ALLENINST.COM 

Allen Associates Inc. intends to operate the UX5 or the UX5hp from Trimble and will 

operate it in strict compliance with the conditions set forth in Exemption 11110, as such 

conditions may be amended or modified by the FAA from time to time, as was done in 
: U.S~ Department ofTransportation 

17June2015 · 

Page2 

. -

Exerhption Nos·. 11240 and 11-257, or such ·othercondition.s as. the FAA snail specify, 

and the followi11g manuals: · · 

_ ·1) Trimble UX5 Data Sheet; and -_ ' . . . . · . 2) Trimble UX5 Aerial Imaging Solution User Guide (User Guide) 

Copies o.f these manuals are attached. 

These manuals are very similar to the manuals -~ubmitted by Trimble in support of the 

issuance of Exemption 11110, updated to reflect changes reported in Trimble's 

March 4, 2015 amendment to Exemption 111 10. The manuals will be updated by 

.Trimble, as nee_ded to reflect any_ changes to Exemption ~ 1110, based ·o·n_ amendments ther~to. · · · -

~ Ailen Associates Inc. acknowledges that under current FAA guidance a separate. · Certificate of\/Vaiver or Authorization ("COA") is required to fly at altitudes in excess of 

200 feet AGL, and it will apply for COAs where required~ ABC hereby requests a · bla-nket COA for flights u·p to 200 feet AGL in the form· approved by the FAA. Allen 

Associates Inc.-will also file NOTAMs for-its fl,ights, as req~ired. · 

To.the extent necessary, Allen Asso_ciates Inc. refers the FAA· to the original exempti.on 

and the amended exemption requests submitted by Trimble inDocketFAA~2014-0367 

_ for demonstration of the public interest and an _equivalen-t level of safety. Because the 

UX5 and the UXShp specified in this request are the same or, essentially the same, as · 

~ the craft already approved in· Exemption 11110, arid Allen Associates Inc. will operate 

the aircraft in strict compliance with the conditions in existing exemptions previously 

· granted by the FAA, or as they may be amended, notice need not be provided: in the 

Federal Register nor pubiic ·comment solicited.1 . · · _ · 

_If you have any questions, please· contact the undersigned! . Vem· 

Richard Gage 

Allen Associates Inc. 

7114 ·E Earll Drive 

·scottsdale, AZ 85251 

-Phone: (4.08) 994-1306 

Applicant reads Section 333 as· plaqing the duty on the Administrator not only to process 

applications for exemptions under Se.ctiqn 333 but, if he determines that the conditions set forth here_in do 

. not fulfill the statutory requirements for approval,. to craft conditions for the safe operation of the UAS. 
U~S: Departme~t of Transportation 

·17 June 2015 ·· · · 

Page.3 . 

Enclosure 

.cc: James Williams 

. Robert Pappas 

Thuy Cooper . 

· bean.Griffith, Esq. 

James .Kirkland . · 

~yle Gilbertson. 

· .. ' . 

. '