12 June 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave ., SE Washington , DC 20590 Re: Summary Processing: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Based Upon Exemption 1111 OA Issued to Trimble Navigation Limited Dear S ir or Madam : GPServ, In c. ("Applica nt") herewith applies for the issuance of an exemption under Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") based upon Exemption 11110 issu ed to Trimble Navigation Limited ("Trimble ") on December 10 , 2014, as amended on May 7 , 20 1 5 with issuance of Exemption 11110A in FAA Docket 2014-0367 . The requested exemption would allow Applicant to operate the UX5 and the UX5 hp ai r craft manufactured by Trimbl e or other Trimble aircraft approved for commercial operations under Exemptions 11110 and 11110A, as they may be amended in the future. Appl icant notes that , in Exemption 11257 , the FAA also recently auth orized use of the Trimb le UX5 by a third party under conditions like those in Exemption 1111 OA. 1 Applicant hereby confirms that it wi ll accept the conditions in Exemptions 111 1OA and 11257. Applicant aircraft will be used to conduct aerial surveys and perform aeria l data co ll ecti on for ag ri cultu re , mining , and othe r purposes , but not for closed set filming (hereinafter "the Purpose "). Applicant hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercia l operation of its small unmanned ae rial vehicles ("sUAVs" ) , so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA in an exemption granted under e ith er Secti on 333 or Section 49 U .S
.C. §44701 (f). As this exempti on request is identical to the already issued precedent, this request should qua lif y for summary processing as the FAA has a lready provided public notice of and granted sim ilar exemptions. The FAA has issued exemptions in circumstances sim i la r in all material respects to those presented in this petition
. In num erous exemption s , the FAA has found t hat the enhanced safety achieved using an unmanned aircraft ("UA" ) with the specificat ions described by the petitioners and carrying no passengers or crew , when compared to flights of much larger manned aircraft that carry crew in addition to f lammable fuel , gives the FAA good cause to find th at the sUAV o peration enabled by th e exempt ions serves th e

Exemption No
. 11257 to Montana Land Surveys (see Docket No. FAA-2014-0889). 62 1 Brook haven Drive · O rl ando, FL 32803 T

o ll Fre e 888·782 · 1997 L ocal 40 7 ·601·5816 f ax 407 · 60 1 ·5826U .S. Department of Tran s portation 12 -Jun - 15 Page 2 public interest. 2 In those cases , use of the proposed sUAV not only enhanced safety but also fulfilled the Secretary of Transportation ' s (the FAA Administrator's) responsibility to " ... establish requ i rements for the safe operation of such aircraft systems in the national airspace system ." Sect ion 333 (c) of the Reform Act. The name and address of the applican t is: David H
. Holt, President GPServ, Inc
. 621 Brookhaven Drive Orlando , FL 32803 Phone : (407) 601 -5816 dave@gpserv.com Regulations from which the exemption is requested : 14 C.F.R. 61 .23(a) and (c) 14 C
. F
. R. 61 . 101 (e)(4) and (5) 14.C
. F
. R. 61 . 113(a) 14 C.F
. R. 61 . 315(a) 14 C
. F
. R. 91 .7(a) 14 C.F.R. 91 . 119(c) 14 C.F.R. 91 . 121 14 C.F.R. 91 . 151(a)(1) 14 C.F.R. 91.405(a) 14 C
. F.R. 91.407(a)(1) 14 C.F.R. 91.409(a)(1) and (2) 14 C.F.R. 91.417(a) and (b) This exemption application is expressly submitted to fulfill Congress ' goal i n passing Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. I n maki ng this determination , the Secretary is required to determine which types of sUAVs do not create a hazard to use rs of the NAS or the public or pose a threat to national security i n light of the following : • The sUAV's size, weight , speed, and operational capabi li ty; • Operation of the sUAV in close proximity to airports and populated areas ; and • Operation of the sUAV within visual line of sight of the operato r. Reform Act§ 333(a)
. Lastly , if the Secretary determines that such veh icles " may operate safe ly in the national airspace system , the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system. " 

### /d. § 333(c) (emphasis added)
. 3

2 E xemption Nos
. 1 1062 to Astraeus Aeria l (see Docket No
. FAA-2014- 0 352) , 1 1 109 to Clayco , Inc
. (see Docket No
. FAA-2014-0507), 11112 to VDOS Global , LLC (see Docket No
. FAA-20 1 4-0382) , and 11213 to Aeryon Labs , Inc
. (see Docket No
. FAA-2014-0642)
. 62 1 Broo khaven Dr i ve · Orl and o, FL 3 2803 To ll Free 888 -782· 1997 Lo cal 4 07·60 1 ·58 16 Fax 407-601·5826U.S. Department of Transportation 12-Jun - 15 Page 3 

### The Federal Aviation Act , in addition to the authority granted by Section 333 of Reform Act
. expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms in cludes exempting civil aircraft, as the term is defined under§ 40101 of the Act , from the requirement that all civil aircraft , which includes sUAVs , must have a current airworthiness certificate
.4 

### The sUAVs that Applicant proposes to use are fixed wing and weigh 55 or fewer lbs. in c luding payload
. They operate, under normal conditions, at a speed of no more than 87 knots
. They will operate at altitudes of no more than 400 feet, as further exp lained , and only within line of sight. They will operate as set forth in the manuals previously submitted and made a part hereof. Operatio ns in compliance with these manuals will ensure that the sUAV will " not create a hazard to users of the national airspace system or the public"5 

### and that the aircraft will operate in compliance with the conditions set forth in this application
. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY/NATIONAL SECURITY The Applicant states that operating in compliance w ith t he condit io ns set forth in Exemption 1111 OA will provide an equivalent level of safety for the ope ration of the UX5 and UX5 hp
. Approval of exemptions allowing commercial operations of sUAVs for aerial data collect ion will enhance safety by reducing risk. Conventional operations , using jet or piston power aircraft , operate at extremely low altitudes just feet from the subject being photographed and in extreme prox imity to people and structures and present the risks associated with vehicles that weigh in the neighbo rhood of 6,000 lbs. , carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and f rom the project location. In contrast, a sUAV weighing fewer than 55 lbs. and powe red by batteries e lim inates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAV is carried to the target area and not flown. The sUAV will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. T hese lightweight aircraft operate at slow speeds, close to the ground , and in areas that are under the control of the operator and , as a result , are far safer than conventional operations conducted with large r manned aircraft operati ng in close p roximity to the ground and people
. G iven the small size of the sUAVs involved and the restricted environment within whi ch they will operate , Applicant falls squarely within that zone of safety (an equiva lent level of safety) in which Congress envisioned that the FAA must , by exemption, a llow commercial operations of sUAVs to commence immediately. Also , due to the size of the sUAVs, th e restricted areas in which they will operate , and the fact that they will be flown by pilots ho lding at least an FAA sport or recreational pil ot license, approval of the application presents no national security issue.

3 

### Applicant interprets this provision to pla ce the d uty on the Administrator to not only process applications for exemptions und er section 333 , but for t he Administrator to craft conditions for the safe operation of the sUAV, if it should be determined that the cond itions set forth here in do not fulfill the statutory requirements for approval. 4 

### "The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of the Transportation Act if the Ad ministrator finds the exemption in the public interest. " 49 U .S. C
. §44701 (f). See al so 49 U
. S
. C
. § 447 11 (a) ; 49 U
.S
. C
. 

### § 44704; 14 C
. F.R. 

### § 91
.203(a)(1 ). 5 

### Sect ion 333(b) of the Reform Act.
621 Brookhaven Dr ive · O rlando, FL 32803 To ll Free 888-782- 199 7 Lo cal 407-601 -5816 F ax 40 7- 601-58 26U.S. Department of Transpo rtation 12-Jun - 15 Page 4 

### PUBLIC INTEREST The FAA has granted exemptions to the regulations listed on page 2 in the exemptions cited above. As discussed in detail for each of these regulat ions in the attached Appendix A, the public interest will be served by an exemption because , with respect to each, operation in compliance with the requested conditions will ensure an equivalent leve l of safety. As also explained at length in Trim b le 's original Section 333 exemption request submitted on May 30 , 2014, the grant of the requested e xemption is in the public interest given the clear direction in Section 333 of the Reform Act; the au t hority included in the Federal Aviation Act, as amended ; the strong equ ivale nt level of safety surround in g the proposed operations; and the significant public benefit derived f rom , among other th i ngs, the enhanced safety and reduced environmental impact , including the reduced emissions associated wi th a ll owi ng battery powered sUAVs instead of turbine or gas powered aircraft.********* Pursuant to 14 C.F.R. Part 11, the following summary is provided fo r publication in the Federal Register , should it be determined that publication is needed: Applicant 

### seeks an exempt ion from the following rules: 14 C.F.R. §§61.23(a) and (c }, 61. 101 (e )(4) and (5 }, 61. 113(a}, 61.315(a}, 91. l(a}, 91. 119(c}, 91
. 121 , 91.151(a)(1), 91.405(a), 91.405(a)(1), 91.409(a)(1) and (2}, and 91.417(a) and (b) to operate commercially a small unmanned vehic le (55 lbs. or less) in motion picture and television operations and aerial data collect ion. Satisfact ion of the criteria provided in Sect ion 333 of th e Reform Act of 2012 - size, w ei ght , speed , operating capabilities, prox imity to a irports and populated areas and operation w ithin vi sual lin e of s ight and national security - provide more tha n adequate ju stifi cation for the grant of the requested exemption allowing commercial operation of applicant's sUAV for the Purpose outlined herein and a re cons istent with exemptions a lready granted , including Exemption 111 OA. Accordingly , the app licant respectfully requests that the FAA grant the requested exemption withou t delay.

## yours,**)/)~** i
.

# Holt, PrLnt GPServ, In c

621 Brook haven D r ive · Or lando, FL 3 2803 To ll F ree 888 -782 · 1997 Loca l 40 7 - 601-5816 F ax 40 7 - 60 1 -5826U.S. Department of Transportation 12- Jun - 1 5 Page 5



### APPENDIX A 14 C.F.R. 

### § 61 .23(a) and (c): 

### Medical Certificates: Requirement and Duration Sections 61.23(a) and (c) address t he requirement of medical certificates for pilots. Section 61
. 23(a) requires a person exercising the privileges of a recreational pilot to hold at least a third class medical certificate. Section 61.23(c) permits the holder of a sport pilot certificate to act as PIC of a lightsport aircraft with either a medical certificate or U.S. issued driver's license. Light-sport aircraft may weigh up to 1,430 pounds and seat up to two persons, including the pilot. Comparative ly, the Trimble craft will weigh fewer than 55 pounds, and it will not carry pilots, passengers , or cargo. The UAS w i ll also be operated within visual li ne of sight of the PIC and below 400 feet above ground level and limited to operations with permission over private or controlled - access property. Given these safety parameters, App l icant requests that the FAA wa ive Section 61.23(a) upon a finding that an equivalent level of safety will be provided by allowing operation of t h e Trimble craft by p ilots with a recreational or sport pilot certificate and a valid U.S. state issued driver's license , in lieu of an FAAissued medical certificate
. Applicant also requests that the FAA grant relief from Section 61.23(c) to allow sport pilot certificate holders to operate aircraft other than light-sport aircraft with a valid U.S. issued driver's license
. The FAA has granted exemptions to conduc t similar operations in a number of cases, including Exemption 11213. 

### 14 C.F.R. Part 61: Private Pilot Privileges and Limitations: Pilot in Command Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Section 61.315(a) addresses the privileges and limitations of the holder of a sport pilot certificate. Because the sUAV will not carry a pilot or passengers , the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to hold a certificate issued by the FAA authorizing operation of any aircraft (ATP, Commerci al, Private , Recreational or Sport). Unlike a conventiona l aircraft that carries the pi lot and passengers , the sUAV is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the manual. The level of safety provided by the requirements included in the manuals exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation of the sUAV are so diminished from the level of risk associated with commercia l operations contemplated by Part 61 when drafted, that allowing operations of the sUAV as req uested with any cert ifi cate issued by the FAA as the PIC greatly exceeds t he present level of safety achieved by 14 C.F.R. Part 61
. The FAA has granted exemptions for private and sport or recreational pilots to co nd uct similar operations in Exemptions 11062 , 11213, 11360a nd 11447. 

### 14 C. F.R. 

### § 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft Specifically , 91.119(c) limits aircraft flying over areas ot her than congested areas to an altitude of 500 feet above the surface, except

621 Brookhaven Drive - Or lando , Fl 32803 T oll Free 888-782 -1997 Locol 407- 60 1 -58 16 Fax 407 - 6 0 1 -5826U.S
. Department of Transportation 12-Jun-15 Page 6

over open water or sparsely populated areas . In those cases , the aircraft may not be operated closer tha n 500 feet to any person , vessel , veh icle , or structure . As set forth herein , the Trimble craft will neve r operate at higher than 400 feet AG L
. They will , however, be operated to avoid congested or populated a r eas that are depicted in yellow on VFR section al charts
. Because aerial survey work must be accompli s hed at re lative ly low altitudes and at altitudes less than 400 feet AGL , an exemption from Section 91
. 119(c) is needed
. The equiva lent level of safety will be achieved g iven the size , weight , speed, and materi al with which the Trimble craft are built. Also , no flight will be taken withou t the pe rm ission of the landowner or those who contro l the la nd. Because of the advance notice to the landown er, all affected i ndividuals will be aware of the survey fl ights. Compared to aerial survey operations conducted wi t h aircraft or rotorcraft weighing far more t han the Trimble craft and carrying flammable fuel , an y risk associated with these operations will be far less than those currently allowed with conventiona l ai rcraft operating at or below the same altitude
. Indeed , the low-altitude operations of the sUAV will ma inta in separation betwee n these sUAV operations and the operations of con ven tional a ircraft t hat must comply w it h Section 9 1 .119
. The FAA has granted exemptions to conduct sim i lar operat ions in Exemptions 11 062, 112 13 , 11360 and 11447
. 

### 14 C.F.R. 

### § 91.121: Altimeter Settings This regulation requires each perso n operating an aircraft to maintain cruis ing altitude by reference to an altimeter that is set "
... to the elevation of the departure airport or an approp ri ate altimeter setting available before departu re. " As each sUAV mode l in at least one operati ng mode w ill not have a barometric altimeter, but instead a GPS altitude read out, an exemption will be needed. An equivalent level of safety will be achieved by the operato r, pursuant to the manua ls , confirming t he altitude of the launch site shown on the GPS altitude indicator before fl ight. The FAA h as granted exemptions to conduct similar operations in Exemptions 11062 , 1121 3, 11360 and 11447
. 

### 14 C . F.R. § 

### 91 . 151(a): Fuel Requirements for Flight i n VFR Conditions Section 91.151 (a) prohib its an individual f rom beginn ing "a fl ight i n an ai rp lane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fue l to f ly to the f i rst point of intended landing , and , assuming normal cruising speed - ( 1) During the day , to f ly after that for at least 30 minutes ; or (2) At night , to fly after that fo r at least 45 minutes. " The battery powering the sUAV limits the duration of a f light. To meet the 30-minute reserve requirement in 14 C
. F
. R. 

### § 91.151 , sUAV flights would be severely l imited , i n some cases to approximately 10 minutes in length
. Given the limitations on the sUAV's pro posed fli ght area and the location of its proposed operations within a predetermined area , a longer time frame for f l ig ht in daylight or night VFR conditions is reasonable
. Applicant be l ieves that an exemption from 14 C
. F.R. 

### § 91.151 (a) falls wit hin the scope of prior exemptions. See Exe mption 10673 (allowing Lockheed Marti n Corporation to operate without compliance with FAR 91
. 151 (a)). Operating the sUAV , i n a tightl y controlled area where on ly people and property owners or official representatives who have signed waivers will be allowed , with less tha n 30 m inutes of reserve fuel , does not engender the type of risks that Sect ion 91
. 151 (a) was i nte nded to alleviate given the size and speed of the sUAV
.
62 1 Brookhaven Drive · Or lando, FL 32803 Toll Free 888-782·1997 Local 4 07·60 1 ·58 16 Fox 407·6 0 1 · 58 2 6U.S. Department of Tran spo r tation 1 2- Jun- 1 5 Pag e 7 Applicant believes that an equivalent level of safety ca n be achieved by limiting flights to f ive minutes of reserve time on the batteries. This rest riction would be more than adequate to return the sUAV to its planned landing zo ne from anywhere in its limited operating area. Simil a r exemptions have been granted to other operations in Exemptions 2689F , 5745 , 10673 , 108 08 and Exempt ions 1 1062 , 11213 , 11360 and 11447. 14 C .F. R. Part 91: Maintenance I nspections Section 91.405(a) requires that an aircraft operator or owner "shall have th at aircraft inspected as prescribed in subpart E of this part and shall between req uired inspections , except as provided in paragraph (c) of this sect ion, have discrepancies repai red as prescribed in part 43 of this chapter
...." Section 91.407 similarly makes reference to requiremen ts in Part 43 ; Section 9 1.409(a) (2) requires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner o r operator to keep records showing certain mainten a n ce work that has be e n accom p lished by certif icated mechanics , under Part 43 , or licen sed pilots and records of ap proval of the a i rcraft fo r return to service
. Given that these sections and Part 43 apply on ly to airc raft with an airworthiness certificate , thes e sections will not apply to the applicant. Maintenan ce will be accompl ished by the operator pursuant to t he manuals
. An equ ivalent level of safety will be achieved because these sUAVs a re very limited i n size and wil l carry a small payload and operate only in areas for limited periods of time
. If mechan ical issues arise , t he sUAV can land immediately since it will be operatin g f rom no higher than 400 feet A G L. As p rovided in the manuals , the operator will ensure that the sUAV is in wo rking order prior to init iati ng flight , p erform required maintenance , an d keep a log of any maintenan ce pe rformed
. Mo reove r, the o perator is the pe rson most familiar with the ai rcraft and best suited to maintai n the aircraft in an a irworthy condit ion in order to provide the equivalent level of safety
. The FAA has granted exemptions for s imilar operations in Exemptions 11062 , 11213 , 11360 and 11447.

62 1 Broo kh aven Drive · Orlan d o, Fl 32803 To ll Free 888-78 2- 1 997 local 407-601 -58 16 F ox 407-60 1 -5826