AFS-14-299-E

 Exemption No. 11042

 Regulatory Docket No. FAA-2014-0304

Mr. Jonathan B. Hill

Counsel for Trimble Navigation, Ltd.

Cooley LLP

1299 Pennsylvania Avenue, NW, Suite 700

Washington, DC 20004-2400

Dear Mr. Hill:

This letter is to inform you that we have granted your request for an exemption. It explains 

the basis for our decision, describes its effect, and lists the conditions and limitations.

The Basis for Our Decision

By letter dated May 6, 2014, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Trimble Navigation Limited (Trimble) for an exemption from §§ 21.191(f), 

21.195(a), 45.23(b), 91.9(b)(2), 91.151(a), 91.203(a) and (b) of Title 14, Code of Federal 

Regulations (14 CFR) to allow Trimble to operate the unmanned aircraft system (UAS) UX-5

in domestic operations consisting of research and development, crew training and market

surveys associated with ground surveys.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to Trimble.

The FAA has issued grants of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption Nos. 2689F, 5745, 9720, 9783, 

10167, and 10673 (copies enclosed), the FAA found that the issuance of an Airworthiness 

Certificate for the purpose of market surveys was appropriate even though the prototype had 
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not been manufactured in the United States, and that due to the small fuselage, a very limited 

area existed for placing identifying marks on an aircraft. The FAA found that relocating the 

identifying marks was in the public interest. The FAA also found that it was in the public 

interest to expand the fuel reserve authority to 10-minutes and the grant of exemption 

provided a level of safety at least equal to that provided by the rule.

We reviewed your reasons for requesting an exemption from 14 CFR §§ 91.9(b)(2) and 

91.203(a) and (b). Based on our review and consideration of FAA Memorandum subject 

“Interpretation regarding whether certain required documents may be kept at an unmanned 

aircraft’s control station”, (copy enclosed) dated August 8, 2014, we find this relief not 

necessary.

Having reviewed your reasons for requesting an exemption from §§ 21.191(f), 21.195(a), 

45.23(b), and 91.151(a), I find that—

• they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption Nos. 2689F, 5745, 9720, 9783, 10167, and 10673;

• the reasons stated by the FAA for granting the enclosed Grant of Exemption Nos. 2689F, 

5745, 9720, 9783, 10167, and 10673 also apply to the situation you present; and

• a grant of exemption is in the public interest.

Our Decision

Under the authority provided by 49 U.S.C. 106(f), 40113 and 44701, which the FAA 

Administrator has delegated to me, Trimble Navigation Limited is granted an exemption from 

14 CFR §§ 21.191(f), 21.195(a), 45.23(b), and 91.151(a) to the extent necessary to allow 

Trimble to operate the UX-5 for missions related to research and development, crew training 

and market surveys associated with ground surveys without meeting the fuel requirements for 

VFR, subject to the conditions and limitations described below.

Conditions and Limitations

1. This exemption is for the Trimble UX-5 only.

2. The word “Experimental” must be displayed on the aircraft to inform all parties of

the aircraft’s overall operating status.

3. The petitioner may use 1-inch (or smaller) lettering at the location specified in the 

petition.

4. This exemption is applicable for flights conducted under daylight hours in VFR 

conditions only.
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5. The exemption holder and Trimble members shall comply with the requirements of 

an approved pilot operating handbook and/or aircraft flight manual concerning 

minimum fuel quantity.

6. This exemption is not valid for operations outside the United States.

All flights must takeoff and land from the same airport with the appropriate aircraft flight 

manual readily available at that airport before takeoff and after landing. This exemption 

terminates on August 31, 2016, unless sooner superseded or rescinded.

Sincerely,

/s/

John Barbagallo

Acting Deputy Director, Flight Standards Service