Jonathan B. Hill

+1 202 776 2725 jhill@cooley.com

1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 20004

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- 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

, L td. ( hereinafter “Trimble”), through its attorneys, submitted applications for amendments to Exemption 11110, originally

issued December 1 0, 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

Sectio n 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 r otorcraft 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 confidenti ally with this application.

Attachment 1 to this petition for amendment is a listing of operations manuals submitted confidentially.May 19, 2015 Page Two

1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 20004

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- 7899 WWW.COOLEY.COM All the listed aircraft will be operated in accordance with the procedures set forth in the

manuals listed above and su bmitted confidentially. The F AA h a s i ssu e d exemption grants in

c i rc umst a n ce s simil a r in a ll m a t er i a l re sp ec ts to those p r e s e n t e d in this p e tition. I n E x e mption

No. 11062 to Ast rae us A er i a l ( s e e Do c k e t No. F AA

− 2014

− 035 2 )

, No. 11109 to C l a y c o, I n c

. ( s e e Do c k e t No. F A A

− 201 4

− 0507 )

, No. 11112 to VDOS Glob a l, LL C ( s ee Do c k e t No.

F AA

− 2 0 14

− 0382 )

, a nd No. 11213 to A e r y o n L a bs, I n c

. ( s e e D o c k e t No. F AA

− 201 4

− 0642 ) , the

F AA f ound th a t the e n h a n ce d s a f e t y ac h i e v e d usi n g a n un m a nn e d a i rc r af t ( “ U A ” ) with the

s p ec i f i ca tions d e s cr ib e d b y the p e tition e r a nd c ar r y i n g no p a s s e n g er s o r cre w, ra th e r t h a n a

m a n n e d a i r c raf t of s i g ni f i c a ntly g r ea t e r p r opo r tions c a rr y i n g c re w in a ddition to f l a mm a ble f u e l,

gave the F A A g ood c a use to f ind th a t the UAS op era tion at issue was in t h e public int ere st.

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 for e going and for all the reasons set

forth in Trimble’s previous filings in Docket 2014

- 03 67 , which are now incorporated by

reference

, Trimble notes that the FAA has grante d 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 am endment 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 Page Three

1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 20004

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- 7899 WWW.COOLEY.COM 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:

c c: Robert Pappas Thuy Cooper

Jake Troutman

Dean Griffith

James Kirkland Kyle GilbertsonMay 19, 201 5 Page Four

1299 PENNSYLVANIA AV ENUE, NW, SUITE 700, WASHINGTON, DC 20004

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- 7899 WWW.COOLEY.COM List of Confidential Manuals



### 1. Operations Manual

- Service

- drone Eagle G4.

2. Operations Manual

- Trimble UX3.

# Exhibit 1 (Confidential)

# Exhibit 2 (Confidential)