27 October, 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 

Dear Sir or Madam, 

- -- ' .. 

Pursuant to Section 33~. of th'e FAA -Modernization anq ~efo,rm Act of 2012 (the "Reform · 

Act") and 14 CFR,Pa·rt 11, Steve Young (A.pplicant), Private Pilot ( cert# 3805867), and 

owner of Petroleum Field Services, LLC ("PFS."), hereby applies for an exemption from . 

the listed Federal Aviation Regulations ("FARs") to allow commercial operatiqn of 

designated UAS, provide<;! such operations are conducted within and under the conditions 

outlined.herein or as may be established by the FAA as required bY Section_ ~33. 

Commercial operation of a UAS, as described herein, which are equipped with camera(s) 

and sensors, would provide professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land sur:veying, engineering and other related professional activities. 

2. Aerial inspection/photography of residential/commercial structures under contract with 

the owners or local government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure including 

but not limited to oil and gas facilities, proposed development sites, reclamation projects, 

electrical power lines, wind turbines and cell towers. 

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation. 

The use of these unmanned aircraft would be a much safer alternative to current 

practices throughout industry. 

Petroleum Field Services, LLC ("PFS") I Applicant herewith applies for the issu~nce of 

an exemption under Section 333 of the FAA Modernization and Reform Act of 2012 

based many previously issued exemptions including Exemption 11110 issued to 

Trimble Navigation Ltd. (''Trimble") on December 10, 2014 in FAA bocket 2014-0367. 

The requested ex~mption· would allow ~FS to operate the UX5, UXHP and the multirotor ZX5 aircraft manufactured by Trimble or other Trimble aircraft approved for 

commercial operations: under Exemption 11110, as amended.· PFS notes that the FAA 
recently authorized use of the Trimble aircraft by a third party in Exemption No. 11257, 

Regulatory Docket No. FAA-2014-0889, on April 2, 2015, under updated conditions, 

and PFS 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 Trimble-drone ZX5 is a rotor aircraft weighing a maximum of 11 lbs. at takeoff (in 

any event, less than 55 lbs.), with payload. It will not operate at a speed greater than 87 

knots. Preflight maintenance will be accomplished as set forth in the Operations 

Manual. 

All the listed aircraft will be operated in accordance with the procedures set forth in the 

manufacturers operating manuals. The FAA has issued exemption grants in 

circumstances similar in all material respects to those presented in this petition. In 

Exemption No. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), No. 11109 

to Clayco, Inc. (see Docket No. FAA-2014-0507), No. 11112 to VDOS Global, LLC 

(see Docket No. FAA-2014~0382), and No. 11213 to Aeryon Labs, Inc. (see Docket 

No. FAA-2014-0642), the FAA found that the enhanced safety achieved using an 

unmanned aircraft ("UA") with the specifications described by the petitioner and carrying 

no passengers or crew, rather than a manned aircraft of significantly greater 

proportions carrying crew in addition to flammable fuel, gave the FAA good cause to 

find that the UAS operation at issue was in the public interest. 

To the extent necessary, applicant refers the FAA to its exemption request submitted in 

Docket FAA-2015-1192 for a listing of regulations (as amended by Exemption1111 OA) 

for which an exemption is being sought; a demonstration of the public interest; and a 

showing of an equivalent level of safety. Based on the foregoing and due to the 

precedent set by previously approved FAA exemptions for aerial data collection 

PFS requests that this request is granted. 

Finally, PFS and Applicant request to be granted authorization to conduct commercial 

operations with all of its aircraft under this exemption be allowed to operate without a 

separate Certificate of Operation ("GOA") in Class G airspace, at or below 400 feet 

AGL and at least 5 nautical miles from the geographic center of an airport, unless a 

letter of agreement with the airport's management is obtained. PFS acknowledges that 

under current FAA guidance a separate Certificate of Waiver or Authorization ("GOA") 

is required to fly at altitudes in excess of 400 feet AGL, and it will apply for COAs where 

required. PFS will also file NOTAMs for its flights, as required. 

The name and contact information for the applicant is: 

Steve Young- Private Pilot cert #3805867 

and 

Petroleum Field Services, LLC 

7535 Hilltop Circle 

Denver, CO 80221 

Phone: (303) 928-7128 

Steve@petro-fs.com 
PFS I Applicant intends to operate the UX5 or the UX5hp from Trimble and/ or the ZX5 

from time to time and would like to put this technology into effect no later than 

February 2016. PFS I Applicant will operate it in strict compliance with the conditions 

set forth by the FAA and as described in the manufacturers operating 

manuals. 

If you have any questions, please contact the undersigned. 

Respectfully, 

Steve Young 

Petroleum Field Services, LLC 

7535 Hilltop Circle 

Denver, CO 80221 

Phone: (303)-928-7128 

Steve@petro-fs.com 

Applicant interprets Section 333 as placing a 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.