cool ex 

April 14, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

VIA EMAIL TRANSMISSION 

Re: Application for Amendment to Exemption 11110 - Trimble Navigation, Ltd. 

FAA Docket 2014-0367 

Dear Sir or Madam: 

On March 4, 2015 Trimble Navigation LTD (hereinafter" Trimble"), through its 

attorneys, submitted an application for an Amendment to Exemption 11110, originally issued 

December 10,2014 in FAA Docket 2014-0367, to allow operation of an updated model of its 

UAS, the UX5hp. Given the recent changes in the terms of other exemptions issued by the FAA 

under Section 333 of the FAA Modernization and Reform Act of 2012, Trimble hereby files this 

supplemental amendment request to allow Trimble's UX5 and UX5hp to be operated under the 

same terms and conditions that the FAA has granted to other UAS operators under Section 333, 

as most recently reflected in Exemption 11240, Aerius Flight LLC, and Exemption 11257, Roger 

W. Meyer, PLS, which granted a Section 333 exemption involving a Trimble UX5 aircraft. 

Specifically, Trimble requests that its Exemption 11110 be amended to not only allow it 

to operate its UX5hp aircraft as stated in the March 4, 2015 request, but that the following 

provision of its Exemption 11110 be removed or modified, as noted below, or, alternatively, the 

conditions in Exemption 11240 and Exemption 11257 be substituted in their entirety. 

Specifically, Trimble requests that the following modifications be made to Exemption 

11110: 

1.) Amend Exemption 11110 condition #4 by adding language " ... or U.S. driver's 

license" at the end of the second sentence. (See Exemption 11240.) 

2.) Amend Exemption 11110 condition # 15 by removing the present language and 

substituting the following: review requirements specified in 14 CFR § 61.56 in an 

aircraft in which the PIC is rated on his or her pilot certificate." (See Exemption 

11240.) 

3.) Amend Exemption 11110 condition #16 by removing the present language and 

substituting the following: 

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Coo ex 

April 14, 2015 

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"The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will 

be operated under this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency must be logged in a 

manner consistent with 14 CFR § 61.51 (b). Flights for the purposes of training 

the operator's PICs and VOs (training, proficiency, and experience-building) and 

determining the PIC's ability to safely operate the UAS in a manner consistent 

with how the UAS will be operated under this exemption are permitted under the 

terms of this exemption. However, training operations may only be conducted 

during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119. The operator shall update 

its training manual as required under condition 6 of this exemption." (See 

Exemption 11240, with addition of final sentence.) 

4.) Amend Exemption 11110 condition # 19 by reducing the stated time of 

remaining battery life from ten (10) minutes to five (5) minutes. (See Exemption 

11240.) 

5.) Amend Exemption 111 10 condition #20 by substituting the following: 

"Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). 

All operations shall be conducted in accordance with an A TO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA."1 (See 

Exemption 11240.) 

6.) Amend Exemption 11110 by removing condition #29 as no longer needed. (See 

Exemption 11240.) 

7.) Amend Exemption 11110 by removing condition #30 as no longer needed. (See 

Exemption 11240.) 

To the extent necessary, Trimble refers the FAA to its original exemption request 

submitted in Docket FAA-2014-0367 for a listing of regulations (as amended by Exemption 

11 11 0) for which an exemption is being sought; a demonstration of the public interest; and a 

showing of an equivalent level of safety. Because the UX5hp is essentially the same aircraft as 

approved for commercial operations in Exemption 11110, and the conditions under which it will 

1 Trimble refers the FAA to its March 4, 2015 request for amendment to Exemption 11110 and its request for a COA 

allowing operations at 400 feet and below and the issuance of a COA allowing such operations. The UX5 and 

UX5hp software require operations at 400 feet AGL for survey operations. 

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Cooley 

April14, 2015 

Page Three 

operate remain essentially the same as those included in Exemption 1111 0 and Exemptions 

11240 and 11257, notice need not be provided in the Federal Register nor public comment 

solicited.2 

If you have any questions, please contact us at your earliest convenience. 

Encl. 

cc: James Williams 

Robert Pappas 

Thuy Cooper 

Dean Griffith, Esq. 

James Kirkland 

Kyle Gilbertson 

Jonathan B. Hill 

M. Anne Swanson 

Counsel for Trimble Navigation, Ltd. 

2 Applicant interprets Section 333 as placing a duty on the Administrator not only to process applications for 

exemptions under Section 333 but, if he determines that the conditions set forth herein do not fulfill the statutory 

requirements for approval, to craft conditions for the safe operation of the UAS. 

1299 PENNSYLVANIA AVENUE, NW, SUITE 700, WASHINGTON. DC 20004-2400 T: (202) 842-7800 F: (202) 842-7899 WWW.COOLEY.COM