P.O. Box 1747

Sulphur, LA 70664-1747

337-533-8116

January 15, 2016

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,

Pelican Land Surveying, LLC (PLS) 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 in 

FAA Docket 2014-0367. The requested exemption would allow PLS to operate the

UX5, UX5 HP and ZX5 aircraft manufactured by Trimble or other Trimble aircraft 

approved for commercial operations under Exemption 11110, as amended, such as the 

UX5, UX5 HP and ZX5 for which an amendment has been filed. PLS 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 PLS 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:

Darren Sargent

Pelican Land Surveying, LLC

448 South Post Oak Road, Sulphur, LA 70663

337-533-8116 (phone/fax)

darren@pelicansurvey.com

PLS [intends] to operate the UX5, UX5 HP and ZX5 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, UX5 HP or ZX5 Data Sheet; and
U.S. Department of Transportation

[Date]

Page 2

2) Trimble UX5, UX5 HP or ZX5 Aerial Imaging Solution User Guide (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 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.

PLS 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. PLS hereby requests a blanket COA for flights up 

to 200 feet AGL in the form approved by the FAA. PLS will also file NOTAMs for its 

flights, as required.

To the extent necessary, PLS 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, UX5 HP and ZX5 specified in this request are the same or, essentially the same, 

as the craft already approved in Exemption 11110, and PLS 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.

Very truly yours,

Darren Sargent

Pelican Land Surveying, LLC

448 South Post Oak Road, Sulphur, LA 70663

Enclosure

cc: James Williams

Robert Pappas 

Thuy Cooper

Dean Griffith, Esq. 

James Kirkland 

Kyle Gilbertson

 

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.