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 Ex emption 11110A, Trimbl e Navigation, Ltd.,

FAA Docket 2014-0367

Dear Sir or Madam:

On April 22, 2015, Western Data Syst ems, through Robert Hixon, submitted applications for amendments to Exemption 13138, originally i ssued 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 amend ment 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 wi ll 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 wi ll be accomplished as set fort h in the Operations Manual submitted confidentially wit h this application.

Attachments to this petition for amendm ent 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 a ccordance with the proc edures set forth

in the manuals listed. The FAA has issued exem ption 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 Glo bal, LLC (see Docket No.

FAA

− 2014

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

FAA

− 2014

− 0642), the FAA found t hat 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 signi ficantly greater proportions carrying crew in addition to flammable f uel, gave the FAA good cause to find that the UAS operation at issue was in the public interest.

To the extent necessary, Western Data S ystems 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 demons tration of the public interest; and a showing of an equivalent level of safety. Ba sed on the foregoing and for all the reasons set forth in Western Data System’s previ ous 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 fo rth above, for aerial data co llection, 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 airpor t 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