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 i Precision.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.