Evans Professional Land Surveys LLC 

1052 S Fresno St, Chandler, AZ 85225 

480-244-5036 

23 November 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, 

Evans Professional Land Surveys, LLC(“EPLS”) 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 EPLS to operate the UX5 and UX5 hp aircraft manufactured by 

Trimble or other Trimble aircraft approved for commercial operations under Exemption 11110A and 

1110B. EPLS 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 

EPLS hereby confirms that it will accept such conditions as well as those set forth in Exemption 

No. 11240, Regulatory Docket No. FAA-2014-0894. 
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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: 

Timothy J Evans 

Evans Professional Land Surveys, LLC 

1052 S Fresno St 

Chandler, AZ 85286 

Phone: (480) 244-5036 

tim.evans@evans-pro.com 

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) 

EPLS 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: 
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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. EPLS. 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. 

EPLS 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. 

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

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

To the extent necessary, EPLS 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 EPLS 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. 

 

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.
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Very truly yours, 

Timothy J Evans 

Evans Professional Land Surveys, LLC 

1052 S Fresno St 

Chandler, AZ 85286 

(480) 244-5036 

Enclosure 

cc: James Williams 

 Robert Pappas 

 Thuy Cooper 

 Dean Griffith, Esq. 

 James Kirkland 

 Kyle Gilbertson