24 April 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,

Field Data Solutions, Inc. dba Electronic Data Solutions (“Elecdata”) 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 Elecdata 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. Elecdata 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 Elecdata 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:

Linda Dean Glover

Field Data Solutions, Inc. dba Electronic Data Solutions

154 1st Ave W

Jerome, ID 83338

Phone: (208) 324-8006

linda@elecdata.com

Elecdata 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. 

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.

Elecdata 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. Elecdata hereby requests a blanket COA for flights up to 200 feet AGL in the form 

approved by the FAA. Elecdata will also file NOTAMs for its flights, as required. 

To the extent necessary, Elecdata 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 Elecdata 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,

Linda Dean Glover

Co-Owner, VP/Secretary

Field Data Solutions, Inc. dba Electronic Data Solutions

154 1st Ave W

Jerome, ID 83338

 

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.
Enclosure

cc: James Williams

Robert Pappas 

Thuy Cooper

Dean Griffith, Esq. 

James Kirkland 

Kyle Gilbertson