Tony Scott - Frontier Precision Inc. 

+l .701.222.2030 

TonyQFrontierprecision.com 

2020 Frontier Dr. Bismarck ND 58504 T: 701.222.2030 F: 701.258.5324 WWW.FrontierPrecision.com 

August 19, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Application for Amendment to Exemption 11110A, Frontier Precision Inc., 

FAA Docket 2015-1192 

Dear Sir or Madam: 

On June 11, 2015, Frontier Precision Inc. (hereinafter Frontier), through its attorneys, submitted 

applications for amendments to Exemption 11110, originally issued August 14, 2015 in FAA 

Docket 2015-1192 to (1) allow operations of an updated model of its UX5, named the "UX5hp" 

and (2) update the terms of the conditions contained in Exemption 11110 to those that are being 

issued currently to all exemption holders under Section 333 for the FAA Modernization and 

Reform Act of 2012. On August 14th, the FAA issued Exemption 11110A allowing the 

commercial operation of the UX5 and UX5 HP with updated standard terms and conditions. This 

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

Exemption 11110A for commercial use in aerial data collection: 

1) Trimble Navigation LTD. Multirotor ZX5 

The Trimble-drone ZX5 is a rotor aircraft weighing a maximum of 11 Ibs. at takeoff (in any event, 

less than 551bs.), 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. Attachment 1 to this petition for amendment is a listing of operations 

manuals submitted confidentially. 
August 19, 2015 _ 

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2020 Frontier Dr. Bismarck ND 58504 T: 701.222.2030 F: 701.258.5324 WWW.Frontie iPrecision.co rn 

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

listed above and submitted confidentially. 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, Trimble refers the FAA to its original exemption request submitted in 

Docket FAA-2015-1192 for a listing of regulations (as amended by Exemption11110A) 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 Frontiers 

previous filings in Docket 2015-1192, which are now incorporated by reference, Frontier 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.i 

Finally, as set forth in more detail in its June 11, 2015 amendment request, Frontier 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. 

1 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. 

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

List of Confidential Manuals (Attachment 1) 

1. Operations Manual-Drone ZX5 

Very Truly Yours, 

Tony Scott 

Operations Manager for Frontier Preci' ' n lnc.