[ABC Letterhead]

10 July 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,

WM SURVEYS INC (WMS) 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 WMS 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. WMS 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 WMS 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 Meagher

WM SURVEYS INC.

2747 Shwerwin Ave. #12

Ventura, Ca. 93003

Phone: (805) 677-4850

wmhinc@west.net

WMS 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

10 July 2015

Page 2

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

thereto.

WMS 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. WMS hereby requests a blanket COA for flights up 

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

flights, as required.

To the extent necessary, WMS 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 WMS 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 Meagher

WM SURVEYS INC.

2747 Shwerwin Ave. #12

Ventura, Ca. 93003

Phone: (805) 677-4850

wmhinc@west.net

Enclosure

 

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.