Dr.	Christopher	Hamilton		•	1629	E.	University	Blvd. •	P.O.	Box	210092	•	Tucson,	AZ	85721-0092

Tel:	(301)	301-3818 •	FAX:	(520)	621-4933 •	hamilton@lpl.arizona.edu

December 7, 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,

The University of Arizona’s Lunar and Planetary Laboratory (LPL) herewith 

applies for the issuance of an exemption under Section 333 of the FAA 

Modernization and Reform Act of 2012 based upon Exemption 11110A issued to 

Trimble Navigation Ltd. (“Trimble”) on December 10, 2014 in FAA Docket 2014-

0367 and 11110B issued to Trimble on July 23, 2015.

The requested exemption would allow LPL to operate the UX5 and UX5 hp

aircraft manufactured by Trimble or other Trimble aircraft approved for 

commercial operations under Exemption 11110A and 1110B. LPL 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 April 2, 2015, under updated 

conditions, and LPL hereby confirms that it will accept such conditions as well as 

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

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

collection for agriculture, mining, aerial photography/video acquisition, real estate, 

land surveying, vertical and horizontal constructions inspections, but not for

closed set filming. Applicant hereby applies for an exemption from the listed 

Federal Aviation Regulations (“FARs”) to allow commercial operation of its small 

unmanned aerial vehicles (“sUAVs”), 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. 

§44701(f).

The name and contact information for the applicant are:

Dr. Christopher W. Hamilton

Lunar and Planetary Laboratory (LPL)

University of Arizona

1629 E. University Blvd.

Tucson AZ 85721 USA

Phone: 301-305-3818

E-mail: hamilton@lpl.arizona.edu
Regulations	from	which	the	exemption	is	requested:

14	C.F.R.	61.23(a)	and	(c)

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

14.C.F.R.	61.113(a)

14	C.F.R.	61.315(a)

14	C.F.R.	91.7(a)

14	C.F.R.	91.119(c)

14	C.F.R.	91.121

14	C.F.R.	91.151(a)(1)(b)

14	C.F.R.	91.405(a)

14	C.F.R.	91.407(a)(1)

14	C.F.R.	91.409(a)(1)	and	(2)

14	C.F.R.	91.417(a)	and	(b)

LPL intends to operate the UX5 or the UX5hp from Trimble and will operate it in 

strict compliance with the conditions set forth in Exemption 11110A and 11110B, 

as such conditions may be amended or modified by the FAA from time to time,

as was done in Exemption Nos. 11240 and 11257, or such other conditions as 

the FAA shall specify, and the following manuals: 

1) Trimble UX5 Data Sheet; and

2) Trimble UX5 Aerial Imaging Solution User Guide (User Guide)

3) Trimble UX5 hp Data Sheet; and

4) Trimble UX5 hp Aerial Imaging Solutions user Guide

Copies of these manuals are attached.

These manuals are very similar to the manuals submitted by Trimble in support 

of the issuance of Exemption 11110A and 11110B, updated to reflect changes 

reported in Trimble’s March 4, 2015 amendment to Exemption 11110. The 

manuals will be updated by Trimble, as needed to reflect any changes to 

Exemption 11110, based on amendments thereto.

The four attachments listed above are referenced in the request for exemption 

and contain trade secret and commercial proprietary information and that are not 

available to the public. LPL is requesting that these attachments be treated as 

proprietary information pursuant to 14 C.F.R. Section 11.35, and maintains that 

they are protected from public release under the Freedom of Information Act. 

See 5 U.S.C. 552 et seq.

LPL acknowledges that under current FAA guidance a separate Certificate of 

Waiver or Authorization (“COA”) is required to fly at altitudes in excess of 200 

feet AGL, and it will apply for COAs where required. LPL hereby requests a 

blanket COA for flights up to 200 feet AGL in the form approved by the FAA. 

LPL will also file NOTAMs for its flights, as required.

To the extent necessary, LPL refers the FAA to the original exemption and the 

amended exemption requests submitted by Trimble in Docket FAA-2014-0367 for 

demonstration of the public interest and an equivalent level of safety. Because 
the UX5 and the UX5hp specified in this request are the same or, essentially the 

same, as the craft already approved in Exemption 11110A and 11110B, and LPL

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 public comment solicited.1

If you have any questions, please contact the undersigned.

Respectfully,

Dr. Christopher Hamilton

Lunar and Planetary Laboratory (LPL)

University of Arizona

1629 E. University Blvd.

Tucson AZ 85721 USA

Enclosure

cc: James Williams

Robert Pappas 

Thuy Cooper

Dean Griffith, Esq. 

James Kirkland 

Kyle Gilbertson

 1 Applicant reads Section 333 as placing the 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.