Western Data Systems

2161 West Anderson Lane

Austin, TX 78757

December 02, 2015 

Western Data Systems 

Robert Hixon 

2162 West Anderson Lane 

Austin, TX 78757 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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

 FAA Docket 2014-0367 

Dear Sir or Madam: 

On April 22, 2015, Western Data Systems, through Robert Hixon, submitted 

applications for amendments to Exemption 13138, originally issued October 8, 2015 in 

FAA Docket 2015-3080 to (1) allow operations of its UX5, named the “UX5hp” 

This letter is a further request for an amendment to add the following aircraft to the 

amended Exemption 13138 for commercial use in aerial data collection: 

1) Trimble ZX5 

The Trimble ZX5 is a rotor aircraft weighing a maximum of 11 lbs. at takeoff (in 

any event, less than 55lbs.), with payload. It will not operate at a speed greater than 87 

knots. Preflight maintenance will be accomplished as set forth in the Operations Manual 

submitted confidentially with this application. 

The Trimble ZX5 is a rotorcraft weighing a maximum of 11 lbs. at takeoff (in any 

event, less than 55 lbs.), with payload. It will not operate at a speed greater than 87 

knots. Preflight maintenance will be accomplished as set forth in the Operations Manual 

submitted confidentially with this application. 

Attachments to this petition for amendment is a listing of operations manuals 

submitted. 
Western Data Systems

2161 West Anderson Lane

Austin, TX 78757

December 02, 2015 

All the listed aircraft will be operated in accordance with the procedures set forth 

in the manuals listed. The FAA has issued exemption grants in circumstances similar in 

all material respects to those presented in this petition. In Exemption No. 11062 to 

Astraeus Aerial (see Docket No. FAA−2014−0352), No. 11109 to Clayco, Inc. (see 

Docket No. FAA−2014−0507), No. 11112 to VDOS Global, LLC (see Docket No. 

FAA−2014−0382), and No. 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an 

unmanned aircraft (“UA”) with the specifications described by the petitioner and carrying 

no passengers or crew, rather than a manned aircraft of significantly greater proportions 

carrying crew in addition to flammable fuel, gave the FAA good cause to find that the 

UAS operation at issue was in the public interest. 

To the extent necessary, Western Data Systems refers the FAA to its original 

exemption request submitted in Docket FAA-2015-3080 for a listing of regulations for 

which an exemption is being sought; a demonstration of the public interest; and a 

showing of an equivalent level of safety. Based on the foregoing and for all the reasons 

set forth in Western Data System’s previous filings in Docket 2015-3080, which are now 

incorporated by reference, Western Data System’s notes that the FAA has granted 

similar exemptions, as set forth above, for aerial data collection, and it, therefore, 

believes that this amendment request is subject to the FAA’s already announced 

Summary Exemption Process. 

Finally, as set forth in more detail in our October 8, 2015 exemption request, 

Western Data System’s requests that all of its aircraft granted authorization to conduct 

commercial operations under this amendment be allowed to operate without a separate 

Certificate of Operation (“COA”) in Class G airspace, at 400 feet AGL and below, and at 

least 5 nautical miles from the geographic center of an airport unless a letter of 

agreement with the airport’s management is obtained. 
Western Data Systems

2161 West Anderson Lane

Austin, TX 78757

December 02, 2015 

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

Sincerely yours, 

Robert Hixon 

Western Data Systems 

5124664555 

robert@wds-us.com