ta

January 22,2015

U.S, Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: ExemptionRequestUnderSection333of the FAAReformActand Part

11 of the Federal AviationRegulations

Dear Sir orMadam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "ReformAct")

and 14 C.F.R. Part 1 1, CompassData, Inc. (CompassData), an owner and operator of

theTrimble UXS Unmanned Aircraft System (UXs UAS), seeks an exemption from theFederal

Aviation Regulations ("FARs") as per the enclosed document.

The requested exemption would permit commercial operation by CompassData of Trimble's

UXS that performs precision aerial surveys consisting of still photographs taken with an

integrated onboard camera. The UX5 takes a series of high quality, still digital images that are

used toproduce precision digital map products including; point clouds, triangulated models, and

contour maps of the surveyedarea. Applications for these UAS devices and associated data

processing functionsinclude agriiulture, mining, professional surveying, environmental

monitoring, oil & gas exploration and other similar activities.

Operations under the exemption will be subject to strict operating requirements andconditions

to ensure at least an equivalent level of safety to currently authorized operations usingmanned

aircraft and under conditions as may be modified by the FAA as required by Section333.

As described more fully below, the requested exemption would authorize commercialoperations

of aerial surveys using the UXS.The UXS will beoperated under controlled conditions at low

altitude in airspace that is limited in scope, as describedmore fully herein; and it has automated

controlfeatures, as described below. The UX5 also willbe operated by an individual who has

passed an FAA approved pilot's license anda required manufacturer's training program for the

UAS. Finally, thetX5UAS will be operated only in Class G airspace in areas that will be

disclosed to the FAA inadvance.

CompassData respectfully submits that because this small, unmanned aerial vehicletheUX5-will be used in lieu of comparatively hazardous operations now conducted with fixed

wing androtary conventional aircraft, the FAA can have confidence that the operations will

achieve at leastan equivalent level or greater level of safety. Approval of this exemption would

therebyenhance safety and fulfill the Secretary of Transportation's (the FAA

Administrator's)responsibilities under Section-333(c) of the Reform Act to "establish

requirements for the safe operation ofsuch aircraft systems in the national airspacesystem."
The name and address of the applicant b:

CompassData, Inc.

Attn: Hayden Howard, Vice President

Phone:303-6274058

Em a i | : havdenh@compassdatainc.com

12353 E. EasterAve.

Centennial, CO 80112

The regulations from which the exemption is

requested are asfollows:

14 C. F. R. 61 .1 1 3(a)&(b):

14 C.F.R.91.7(a):

14 C.F.R.91.119(c):

14 C.F.R.91.151(a):

14 C.F.R.91.405(a):

14 C.F.R.91.407(aX1):

14 C.F.R.91.409(aX2);

14 C.F.R.91.417(a\.

The enclosed document discusses each rule listed above and explains why exemptions

pursuant tothe proposal set forth in this letter are appropriate, provide an equivalent level of

safety, and arein the publicinterest.

In summary, CompassData seeks an exemption from the FARs set forth above and in the

enclosed document to allow commercial operations of Trimble UXS small unmanned vehicle

conducting precision aerialsurveys.

CompassData, Inc.

Encl:

cc: JamesWilliams

RobertPappas Dean

Griffith,Esq.