Jonathan B. Hill

+1 202 776 2725

jhill@cooley.com

1299 PENNSYLVANIA AVENUE, NW, SUITE 700, WASHINGTON, DC 20004-2400 T: (202) 842-7800 F: (202) 842-7899 WWW.COOLEY.COM

May 19, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Application for Amendment to Exemption 11110A, Trimble Navigation, Ltd.,

FAA Docket 2014-0367

Dear Sir or Madam:

On March 4, 2015 and April 14, 2015, Trimble Navigation, Ltd. ( hereinafter “Trimble”), 

through its attorneys, submitted applications for amendments to Exemption 11110, originally 

issued December 10, 2014 in FAA Docket 2014-0367 to (1) allow operations of an updated 

model of its UX5, named the “UX5hp” and (2) update the terms of the conditions contained in 

Exemption 11110 to those that are being issued currently to all exemption holders under 

Section 333 for the FAA Modernization and Reform Act of 2012. On May 7, 2015, the FAA 

issued Exemption 11110A allowing the commercial operation of the of the UX5 hp with updated 

standard terms and conditions.

This letter is a further request for an amendment to add the following aircraft to the 

amended Exemption 11110A for commercial use in aerial data collection:

1) Service-drone Eagle G4

2) Trimble UX3

The Service-drone Eagle is a rotor aircraft weighing a maximum of 11 lbs. at takeoff (in 

any event, less than 55lbs.), with payload. It will not operate at a speed greater than 87 knots. 

Preflight maintenance will be accomplished as set forth in the Operations Manual submitted 

confidentially with this application.

The Trimble UX3 is a rotorcraft weighing a maximum of 11 lbs. at takeoff (in any event, 

less than 55 lbs.), with payload. It will not operate at a speed greater than 87 knots. Preflight 

maintenance will be accomplished as set forth in the Operations Manual submitted confidentially 

with this application.

Attachment 1 to this petition for amendment is a listing of operations manuals submitted 

confidentially. 
May 19, 2015

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All the listed aircraft will be operated in accordance with the procedures set forth in the 

manuals listed above and submitted confidentially. The FAA has issued exemption grants in 

circumstances similar in all material respects to those presented in this petition. In Exemption 

No. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), No. 11109 to Clayco, Inc. (see

Docket No. FAA−2014−0507), No. 11112 to VDOS Global, LLC (see Docket No.

FAA−2014−0382), and No. 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the

FAA found that the enhanced safety achieved using an unmanned aircraft (“UA”) with the

specifications described by the petitioner and carrying no passengers or crew, rather than a

manned aircraft of significantly greater proportions carrying crew in addition to flammable fuel, 

gave the FAA good cause to find that the UAS operation at issue was in the public interest.

To the extent necessary, Trimble refers the FAA to its original exemption request 

submitted in Docket FAA-2014-0367 for a listing of regulations (as amended by Exemption 

11110A) for which an exemption is being sought; a demonstration of the public interest; and a 

showing of an equivalent level of safety. Based on the foregoing and for all the reasons set 

forth in Trimble’s previous filings in Docket 2014-0367, which are now incorporated by 

reference, Trimble notes that the FAA has granted similar exemptions, as set forth above, for 

aerial data collection, and it, therefore, believes that this amendment request is subject to the 

FAA’s already announced Summary Exemption Process.

1

Finally, as set forth in more detail in its March 4, 2015 amendment request, Trimble 

requests that all of its aircraft granted authorization to conduct commercial operations under this 

amendment be allowed to operate without a separate Certificate of Operation (“COA”) in Class 

G airspace, at 400 feet AGL and below, and at least 5 nautical miles from the geographic center 

of an airport unless a letter of agreement with the airport’s management is obtained. 

 1 Applicant interprets Section 333 as placing a 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.
May 19, 2015

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If you have any questions, please contact us at your earliest convenience.

Sincerely yours,

Jonathan B. Hill

M. Anne Swanson

Counsel for Trimble Navigation Limited

Encl:

cc: Robert Pappas

Thuy Cooper

Jake Troutman

Dean Griffith

James Kirkland

Kyle Gilbertson
May 19, 2015

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List of Confidential Manuals

1. Operations Manual-Service-drone Eagle G4.

2. Operations Manual-Trimble UX3.
Exhibit 1 

(Confidential) 
Exhibit 2 

(Confidential)