M. Anne Swanson 

+1 202 776 2534 

aswanson@cooley .com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

May 11, 2015 

Re: Application for Issuance of Section 333 Exemption Based upon 

Exemption 1111 0 Issued to Trimble Navigation Ltd. 

Dear Sir or Madam, 

HLCM Group, Inc. ("HLCM"), by its attorneys, herewith applies for the issuance of an exemption 

under Section 333 of the FAA Modernization and Reform Act of 2012 based upon Exemption 

11110 issued to Trimble Navigation Ltd. ("Trimble") on December 10, 2014 and amended on 

May 7, 2015 in FAA Docket 2014-0367. The requested exemption would allow HLCM to 

operate the UX5 and UX5hp aircrafts manufactured by Trimble or other Trimble aircraft 

approved for commercial operations under Exemption 11110, as may be amended in the future. 

HLCM 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 April2, 2015, under updated 

conditions, and HLCM hereby confirms that it will accept such conditions as well as those set 

forth in Exemption No. 11240, Regulatory Docket No. FAA-2014-0894. 

The name and contact information for the applicant are: 

Mr. Carlos Sanabria 

HLCM Group, Inc. 

Street 31 JJ-1 0, Alturas de Flam boyan 

Bayamon, PR 00959 

Phone: (787)398-8852 

csanabria@hlcmgroup.com 

HLCM intends to operate the UX5 or the UX5hp from Trimble and will operate it in strict 

compliance with the conditions set forth in Exemption 11110, 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: 

1) Trimble UX5 Data Sheet; and 

2) Trimble UX5 Aerial Imaging Solution User Guide (User Guide) 

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May 11, 2015 

Page Two 

Copies of these manuals are attached. 

These manuals are very similar to the manuals submitted by Trimble in support of the issuance 

of Exemption 11110, 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. 

HLCM 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. HLCM hereby requests a blanket COA for flights up to 200 feet AGL 

in the form approved by the FAA. HLCM will also file NOTAMs for its flights, as required. 

To the extent necessary, HLCM refers the FAA to the original exemption and subsequent 

amendment 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 as the 

crafts already approved in Exemption 11110, and HLCM 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. 

Enclosure 

cc: James Williams 

Robert Pappas 

Thuy Cooper 

Dean Griffith, Esq. 

James Kirkland 

Kyle Gilbertson 

rVery ly yours, 

/[/~ a 

M. Anne Swanson 

Henry H. Wendel 

Counsel for HLCM Group, Inc. 

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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