Martin Instrument

Surveying Solutions

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,

Martin Instrument Inc. 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 Martin Instrument Inc. 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. Martin Instrument Inc. 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 Martin 

Instrument Inc. 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:

William A. Wilburn

Martin Instrument Inc.

12077 Starcrest Dr.

San Antonio, Texas 78247

Phone: (210) 490-4604

willw@martininstrument.com

Martin Instrument Inc. 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 
U.S. Department of Transportation

8 June 2015

Page 2

Trimble, as needed to reflect any changes to Exemption 11110, based on amendments 

thereto.

Martin Instrument Inc. 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. Martin Instrument Inc. hereby 

requests a blanket COA for flights up to 200 feet AGL in the form approved by the FAA. 

Martin Instrument Inc. will also file NOTAMs for its flights, as required.

To the extent necessary, Martin Instrument Inc. 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 Martin Instrument Inc. 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,

William A. Wilburn

Martin Instrument Inc.

12077 Starcrest Dr.

San Antonio, Texas 78247

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.