Sullivan Surveying, Inc.

2/29/2016

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,

Sullivan Surveying,Inc. (“SSI”) 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 SSI 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. SSI 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 SSI

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:

Sullivan Surveying, Inc.

6111 Highway 4 Ripley, Mississippi 38663

662-837-8553

andy@sullivansurveying.com

SSI [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, and the 

following manuals: 

1) Trimble UX5, UX5 HP or ZX5 Data Sheet; and

2) Trimble UX5, UX5 HP or ZX5 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.
U.S. Department of Transportation

2/29/2016

Page 2

SSI 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. SSI hereby requests a blanket COA for flights up to 

200 feet AGL in the form approved by the FAA. SSI will also file NOTAMs for its flights,

as required.

To the extent necessary, SSI 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 SSI 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,

Andy Sullivan, President

Sullivan Surveying, Inc.

6111 Highway 4

Ripley, Mississippi 38663

Enclosure

cc:

 

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.