~.,,. 

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.