February 5, 2016 

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, 

I 

"'1 

LW Survey, Co. ("LWS") 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 LWS to operate the UX5, 

UX5 HP and ZX5 aircraft manufactured by Trimble or other Trimble aircraft approved for 

commercial operations under Exemption 11110, as amended, such as the UX5, UX5 HP 

and ZX5 for which an amendment has been filed. The Trimble UX5 will be used to 

evaluate information, including but not limited to: Topographic characteristics, volumetric 

estimates, slope and terrain impediments, Natural and cultural resource identification, 

As-built feature identification and analysis, hazard evaluation, and environmental 

monitoring evaluations. LWS 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 LWS 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 L. Harnisch 

LW Survey Company 

12345 W Alameda Parkway, Suite 205 

Lakewood, CO 80228 

Tel: 303-658-0358 

e-mail: wharnisch@pulsarobi.com 

LWS intends to operate the UX5, UX5 HP and ZX5 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 

LWS 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. LWS hereby requests a blanket COA for flights up 

to 200 feet AGL in the form approved by the FAA. LWS will also file NOTAMs for its 

flights, as required. 
U.S. Department of Transportation 

February 5, 2016 

Page2 

To the extent necessary, LWS 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, UX5 HP and ZX5 specified in this request are the same or, essentially the same, 

as the craft already approved in Exemption 11110, and LWS 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.

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If you have any questions, please contact the undersigned. 

Very truly yours, 

~;tL~~ 

LW Survey Company 

William Harnisch, CEO 

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.