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# ARMS

8 June 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, ConAgra Foods, Inc. ("CNI") 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 CNI to operate the UX5 aircraft manufactured by Trimble or other Trimble aircraft approved for commercial operations under Exemption 11110, as amended, such as the UX5hp for which an amendment has been filed. CNI 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 CNI 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: Clark Hymas ConAgra Foods, Inc. 230514 S 100 Circles PRSW Paterson, WA 99345 Phone: (509)875-3228 clark.hymas@conagrafoods.com CNI 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) Copies of these manuals are attached.U.S. Department of Transportation

8 June 2015 Page 2

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. CNI 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. ConAgra Foods, Inc. hereby requests a blanket COA for flights up to 200 feet AGL in the form approved by the FAA. CNI will also file NOTAMs for its flights, as required. To the extent necessary, CNI 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 11110, and CNI 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.' If you have any questions, please contact the undersigned. Very truly you

Clark Hymas ConAgra Foods, Inc. 230514 S 100 Circles PRSW Paterson, WA 99345
Enclosure

cc: Troy Grimes Troy Emmerson

I 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.