UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

COMPASSDATA, INC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS,

SECTIONS, 61.113(a) and (b); 91.7(a); 91.119(c); 91.151(a); 91.405(a); 

91.407(a)(1); 91.409(a) and 91.417(a)

CONCERNING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM 

OVER THE STATES OF ARIZONA (AZ), COLORADO (CO), 

MINNESOTA (MN), MONTANA (MT), NORTH DAKOTA (ND), 

NEBRASKA (NE), NEW MEXICO (NM), SOUTH DAKOTA (SD), TEXAS 

(TX), UTAH (UT) AND WYOMING (WY) PURSUANT TO SECTION 333 

OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted 

22 January 2015

Hayden Howard

Vice President

CompassData, Inc.

12353 E. Easter Ave.

Centennial, CO 80112
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TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS .................................................................................3

OVERVIEW ........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER..................................................4

BACKGROUND .................................................................................................................5

BASIS FOR PETITION.......................................................................................................6

NAME AND ADDRESS OF PETITIONER.................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH COMPASSDATA, INC. 

SEEKS EXEMPTION ...................................................................................................7

THE EXTENT OF RELIEF COMPASSDATA, INC. SEEKS AND THE REASON 

COMPASSDATA, INC. SEEKS THE RELIEF ...........................................................7

THE REASONS WHY GRANTING COMPASSDATA, INC.'S REQUEST WOULD

BE IN THE PUBLIC INTEREST .................................................................................7

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..............................................................................11

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........25

CONCLUSION.................................................................................................................26

EXHIBIT 1 – Trimble Section 333 – Grant of Exception N. 11110

EXHIBIT 2 - Trimble UX5 Safety Check List

EXHIBIT 3 - Trimble UX5 Maintenance & Inspection Manual

EXHIBIT 4 - Trimble UX5 User Guide

EXHIBIT 5 - Trimble RPAS Training Manual

(NOTE: Exhibits No. 2, 3, 4, and 5 contain CONFIDENTIAL INFORMATION and should 

not be made available to the PUBLIC)
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

NAS National Airspace System

Section 333 FAA Modernization and Reform Act of 2012, Section 333 

SMS Safety Management System

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VMC Visual Meteorological Conditions
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OVERVIEW

COMPASSDATA, INC. seeks exemption from the requirements of Title 14 C.F.R. 

Sections 61.113(a) and (b); 91.7(a); 91.119(c); 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a) 

and 91.417(a) . This exemption will permit COMPASSDATA, INC. to operate an Unmanned 

Aircraft System (“UAS”) over certain rural areas in the States of AZ, CO, MN, MT, ND, NE, 

NM, SD, TX, UT and WY while keeping the documents required by the regulations at the 

ground control station and immediately accessible to the pilot in command. Furthermore, the 

exemption will relieve COMPASSDATA, INC. from the airworthiness certificate standards and 

the requirement to have a certificate of airworthiness issued for its UAS. This exemption will 

also permit any required markings concerning the operational status of the UAS to be displayed 

on the fuselage of the unmanned aircraft.

INTRODUCTION AND INTERESTS OF THE PETITIONER

COMPASSDATA, INC. (hereinafter referred to as “CompassData”) is a 20 year-old 

design, geospatial and infrastructure management firm with a long and well-recognized history in 

mapping and surveying. CompassData excels in the collection and processing of aerial imagery

from airborne and satellite platforms for the purpose of making highly accurate aerial maps for a 

range of clients and various applications. CompassData has recently acquired a Trimble UX5 

Unmanned Aircraft System (hereinafter referred to as the “UX5 UAS”). As set forth in this 

petition for exemption, CompassData seeks to operate its UX5 for the special purpose of aerial 

photography for use in mapping and land surveying applications. CompassData is a professional 

mapping surveying organization with licensed surveyors in numerous states; certified mapping 

professionals; and the company has earned AC20-153(a) & RTCA-DO200A and ISO-9001:2008 

certifications. 
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BACKGROUND

The Unmanned Aircraft System UX5 for which CompassData seeks exemption is a UAS 

designed and built by Trimble Navigation Limited. Trimble has applied for and received a 

Special Airworthiness Certificate for this aircraft and, additionally Trimble has received a 

Grant of Exemption No. 11110 to commercially operate this aircraft. CompassData seeks an 

exemption to operate a UX5 UAS under the same terms and conditions as have been granted

to Trimble. It is CompassData’s intention to operate UX5 UAS serial number UX500415 

with registration number1 N501HH, for compensation or hire within the national airspace 

system (“NAS”). The UX5 UAS is classified as a small UAS weighing approximately six 

pounds and constructed primarily of EPP (expanded poly propylene). The complete system 

consists of the unmanned aircraft body with on-board camera, the Trimble Tablet Rugged PC

Ground Control Station (GCS), portable ground launcher, and operating software. The UX5 

UAS is equipped with a single motor and propeller powered by a lithium polymer battery. 

1 CompassData has reserved registration number N501HH, and has submitted an Aircraft

Registration Application to: FAA Aircraft Registration Branch in Oklahoma City, OK.
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BASIS FOR

PETITION

Petitioner, COMPASSDATA, INC., hereby petitions the Administrator for an exemption 

from:

Title 14 C.F.R. Sections 61.113(a) and (b); 91.7(a); 91.119(c); 91.151(a); 91.405(a); 

91.407(a)(1); 91.409(a) and 91.417(a) .

The specific details regarding this request for exemption are included in the Trimble 

Navigation Limited Grant of Exemption No.11110 which is incorporated herewith as part 

of the CompassData exemption application as Exhibit 1.

The exemption would allow operation by CompassData of the UX5 UAS for the purpose 

of precision aerial photography for use in mapping and land survey applications.

Name and Address of the Petitioner

The name and address of the Petitioner is: 

CompassData, Inc.

12353 E Easter Ave.

Centennial, CO 80112

The point of contact for this Petition and specific contact information is as 

follows:

Hayden Howard, Vice President

12353 E Easter Ave.

Centennial, CO 80112

Email: haydenh@compassdatainc.com

1-303-627-4058
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(1) EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS 

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

A. CompassData requests an exemption from the following regulations as well as 

any additional regulations that may technically apply to the operation of the 

UX5:

The following is a list of the exemptions with a discussion of the equivalent level of 

safety for each item for which exemption is being requested. CompassData is in full 

concurrence with Trimble’s request and agrees to comply with the equivalent level

of safety statements in the Trimble Grant of Exemption No.11110 (Exhibit 1).

14 C.F.R. § 61.113(a) & (b); Private Pilot Privileges and Limitations; Pilot in

Command; Commercial Pilot Privileges and Limitations.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

 14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections

B. The Reasons Why Granting CompassData’s Request Would be in the Public 

Interest; That Is, How It Would Benefit the Public as a Whole.

Granting the present Petition will further the public interest by allowing 

CompassData to safely, efficiently, and economically perform aerial acquisition and 

research over the States of AZ, CO, MN, MT, ND, NE, NM, SD, TX, UT and WY

performing mapping and land survey applications in support of government entities, 

scientific studies, wildlife monitoring, and civil construction, while also furthering 
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the development of the nation’s economy related to the oil and gas industries. 

Additionally, use of the UX5 UAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy and the environment. 

Notably, the benefits of the proposed operation of the UX5 will be realized without 

impacting any privacy issues.

C. The Public Will Benefit From Aerial Acquisition andResearch Performed

CompassData submits this Petition to perform precision aerial photography 

throughout the states of AZ, CO, MN, MT, ND, NE, NM, SD, TX, UT and WY, in 

support of government entities, commercial enterprises, and research institutions,

the oil and gas industries, mining and environmental compliance. The UX5 UAS 

will provide safe, efficient, and economical aerial acquisition and research 

operations to further each of these fields, all of which are critical to the well-being 

of the general public.

The specific operations that CompassData will perform using the UX5 UAS 

provide many advantages compared to traditional land survey and manned aerial 

photography operations. The use of the UX5 UAS will allow for timely, less 

costly and more site specific data capture than is possible with traditional methods. 

The types of work planned for the UX5 UAS include, but are not limited to, 

facility inspections, surveying and planning new worksites, performing right of 

way analysis, environmental monitoring, and remediation planning and 

monitoring. 

D. The Public Will Benefit From Decreased Congestion of the NAS.

The UX5 UAS uses an electric motor propulsion system that is powered by a 
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battery. This serves as a safe, efficient, and economical, non-polluting alternative 

to the manned aircraft traditionally utilized to obtain aerial photography. Use of 

the UX5 for these planned applications will significantly reduce the number of 

manned aircraft used to perform aerial acquisitions in these regions. The 

requested exemptions allowing the use of a UX5 UAS will also have the added 

benefit of reducing noise and air pollution, as well as increasing the safety of life 

and property in the air and on the ground. The size, weight and mass of this small 

UAS as compared to manned aircraft will greatly enhance the safety of acquiring 

precision survey data. Furthermore, by reducing the number of manned aircraft 

operating in the NAS, congestion around airports caused by arriving and departing 

aircraft will be reduced. The UX5 UAS does not require an airport to takeoff or 

land. Likewise, a reduction of manned aircraft conducting aerial survey missions 

would result in fewer aircraft that must be handled by air traffic control during the 

ground, takeoff, departure, arrival, and landing phases of flight operations.

E. The Public Will Benefit From the Safety and Efficiency of the UX5 UAS.

Conducting aerial acquisitions with the UX5 UAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial survey flight operations. By using 

battery power and an electric motor, the UX5 UAS produces no air pollution, and is 

the most viable environmentally conscious alternative to the cabin class, internal 

combustion twin engine aircraft that are typically used for aerial photography

today. The UX5 UAS, while reducing the carbon footprint of aerial acquisitions, 

also eliminates noise pollution as its battery powered electric motor is barely

audible during the take-off phase, and cannot be heard when operating more than 
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100 feet above ground level.

By using the UX5 UAS to perform aerial acquisitions, the substantial risk to life 

and property in the air and on the ground, which is usually associated with 

traditional manned aircraft flight operations, will be substantially reduced or 

completely eliminated. 

F. Performing Aerial Acquisition Operations with the UX5 UAS Will Benefit 

the Economy

CompassData is Woman Owned Small Business encouraging business 

development and job growth with interest in utilizing the new UAS professional 

systems. Through its early entrance into the use of the UX5 UAS CompassData 

has found that the UX5 UAS to be safe, efficient and an economical alternative to 

using manned aircraft to conduct aerial acquisitions. As such, operation of the 

UX5 UAS will allow United States based companies, like CompassData, to

remain competitive and contribute to growth of the U.S. economy. Specifically, 

increasing operational costs due to increasing aviation fuel prices and the costs of

Environmental Protection Agency (“EPA”) regulatory actions, U.S. owned and 

operated companies must adopt new and alternative technology in order to remain

competitive.

By operating the UX5 UAS, companies such as CompassData can remain 

competitive and profitable, and therefore provide greater job stability to employees

and contractors, which will ultimately contribute to growth of the U.S. economy. 

Improved financial performance of U.S. companies, through commercial use of the 

UX5 UAS, provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows companies to invest in 
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research and development in order to remain competitive.

G. Privacy Issue Concerns

Like the manned aerial acquisition flight operations that have been conducted in 

the United States for more than 90 years, the proposed use of the UX5 UAS will 

not create privacy issues nor will it violate any privacy laws when being used for 

the purposes stated in this petition. Specifically, the UX5 UAS will be operated 

only in rural areas, and in accordance with all Federal Aviation Regulations, 

including the minimum and maximum altitude requirements of 14 C.F.R. § 

91.119. Most significantly, the UX5 UAS will not be operated closer than 500 feet 

to any person, vessel, vehicle, or structure, except when necessary for takeoff or 

landing.

(2) EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS 

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

CompassData requests an exemption from the following regulations as well as any

additional regulations that may technically apply to the operation of the UX5:

14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations; Pilot in Command; 

Commercial Pilot Privileges and Limitations.

Section 61.113(a) limits private pilots to non-commercial operations. Unlike a conventional

aircraft that carries a pilot, passengers, and cargo, the UX5 UAS is remotely controlled

carrying no pilot, no passengers or freight on board. CompassData respectfully proposes that 

operator requirements should take into account the characteristics of the particular UAS. The
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UX5 UAS has a high degree of pre-programmed control and various built-in technical 

capabilities that strictly limit the potential for operation outside of the operating conditions set 

forth in the exemption application. The UX5 UAS has a semi-autonomous navigation and 

control system comprised of a Ground Control Station (GCS) and auto-pilot system. All flights 

are pre-programmed with precision GPS guidance and do not require human intervention. 

Flight mission area and routing cannot be changed after launch. Flights are not directed by 

positive manual control, nor are evasive maneuvers. In the case of unplanned events, the 

operator inputs pre-programmed evasive maneuvers from the control unit, and the control unit 

executes that maneuver. Pre-programmed operator interventions include diversion to the right; 

initiation of holding at present position; suspension of mission; fly back to launch point; fly to 

point and hold; abort mission and land; and emergency power cut off and land (Flight 

Termination System).

Additional automated safety functions and safety enhancing features of the UX5 UAS include 

the following:

- Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate spiral 

landing

- Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels.

- If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds, landing

procedure begins.

- If the UX5 UAS auto-pilot fails the craft will immediately execute a very rapid exit 

from flight with a gentle downward spiral to the ground.

- Aircraft has an on-board failsafe that limits speed in the event of dive to approximately

14 m/s.
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- The aircraft, weighing less than 6 lbs., fully loaded, is constructed of EPP foam, or

similar material which is intended to absorb impact energy.

- The motor is driven by a pulse width modulated signal, not an analog signal.

Given these safety features, CompassData proposes that operators of the UX5 UAS should not 

be required to hold a commercial pilot certification. 

CompassData notes that the FAA has found that safety factors permitted operation of UASs by

operators with these qualifications in the case of operations pursuant to public COAs where the

mandatory operating conditions specified above are present. See Federal Aviation

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational 

Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 

U.S.C.§44701(f) to waive the pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by

allowing operation of the UX5 UAS by individuals with a valid private pilot’s certificate. 

Under the conditions set forth herein, the risks associated with the operation of the UX5 UAS 

(given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished 

from the level of risk associated with other commercial operations contemplated by Part 61 

with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAS as set 

forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) 

& (b).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. Should the exemption be granted allowing commercial operation of the UX5 UAS
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without an airworthiness certificate, no standard will exist for airworthiness of the UX5 UAS. 

Given the size of the aircraft and the requirements that have presumably already been met in 

the SAC approval process for the UX5 UAS (for instance, the UX5’s Maintenance & 

Inspection Manual and Safety Checklist), an equivalent level of safety will be achieved by 

insuring compliance with the Trimble UX5 UAS operations manuals (Exhibits 2, 3, 4 and 5)

prior to each flight.

14 CFR § 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 other than congested areas to an altitude of 500 feet above the

surface, except over open water or sparsely populated areas. In those cases, the aircraft may not 

be operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the UX5 UAS will not be operated at higher than 400 feet AGL. It will, 

however, be operated to avoid congested or populated areas that are depicted in yellow on VFR 

sectional charts. Because aerial survey work must be accomplished at relatively low altitudes 

and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with

which the UX5 UAS is built. Compared to aerial survey operations conducted with aircraft or 

rotorcraft weighing far more than 5.5 lbs. and carrying flammable fuel, any risk associated with 

these operations will be far less than those currently allowed with conventional aircraft 

operating at or below 500 feet AGL. Indeed, the low-altitude operations of the UAS will

maintain separation between these small-UAS operations and the operations of conventional

aircraft that must comply with Section 91.119.
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14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing and, assuming normal cruising speed – (1) During the day,

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The UX5 UAS batteries provide approximately 50 minutes of powered flight. Without an 

exemption from § 14 CFR 91.151, the UAS’s flights would be limited to approximately 20 

minutes in length.

Given the limitations on its proposed operations and the location of those proposed operations,

a longer time frame for flight in daylight VFR conditions is reasonable.

CompassData believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope 

of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate

without compliance with 91.151(a)). Operating the small UAS, without 30 minutes of reserve

battery power does not engender the type of risks that Section 91.151(a) was meant to prevent 

given the size and speed at which the UAS operates. The fact that it carries no pilot, passenger, 

or cargo also enhances its safety. Additionally, limiting UX5 UAS flights to 20 minutes would 

greatly reduce their utility. In the unlikely event that the UX5 UAS should run out of battery

power, it would simply land using a gentle downward spiraling pattern. Given its weight and 

construction material, the risks are less than contemplated by the current regulation.

CompassData believes that an equivalent level of safety can be achieved by maintaining 10 

minutes of reserve battery power, which, allowing 40 minutes of flight time, would be more 

than adequate to return the UAS to its planned landing zone from anywhere in its operating 

area.
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Trimble Navigation Limited was granted an Exemption from this FAR, Exemption No. 10808 

for its X-100 UAS and an exemption for commercial operation of the UX5 UAS, Exemption 

No. 11110. Similar exemptions have been granted to others, including Exemptions 2689F, 

5745, and 10673.

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected

as prescribed in subpart E of this part and shall between required inspections, except as

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 

of this chapter . . . .” Section 91.407 similarly makes reference to requirements in Part 43; 

Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness 

certificate.

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots

and records of approval of the aircraft for return to service.

Maintenance of the UX5 UAS will be accomplished by the owner/operator pursuant to the 

manuals, included as Exhibits 2, 3, 4 and 5, provided as an attachment to the petition. An 

equivalent level of safety will be achieved because the UAS is small in size, will carry no 

external payload, will operate only in restricted predetermined areas and is not a complex 

mechanical devise. As provided in the attached

Maintenance Manual and the Safety Checklist, the operator of UX5 UAS will ensure that the 

UAS is in working order prior to initiating flight, perform required maintenance, and keep a 

log of any maintenance that is performed. Moreover, the operator is the person most familiar 

with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to 

ensure an equivalent level of safety. The UX5 UAS’s Maintenance Manual provides for 
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replacement of the airframe every 50 hours of flight. This will ensure an equivalent level of 

safety to the maintenance requirements in Part 91. In addition, between such air frame 

replacements, should a mechanical issue arise the aircraft will either return to its launch site or 

immediately land.

(3) Flight Operations Pursuant To The Exemption Sought Would Be Limited To Areas 

That Are Not In The Proximity Of Airports Or Over Populated Areas.

CompassData proposes to only conduct aerial acquisition flight operations over rural 

areas that are not near populated areas, airports, helipads, highways or state

roads. Specifically, CompassData’s proposed area of flight operations includes rural 

areas that are:

1. Non populated areas as depicted on VFR Sectional Aeronautical Charts;

2. Not within five (5) miles of any airport or helipad;

3. Not within one hundred (100) meters of state roads having more than two lanes;

and

4. Not within fifty (50) meters of state roads having two lanes or less.

In summary, CompassData seeks to operate its UX5 UAS only over rural areas within 

the States defined above while maintaining safe distances from any populated areas, 

airports, helipads, or roadways.

Flight Operations of The UX5 UAS are Limited To The Line of Sight of A

Certificated Pilot in Command and With A Safety Observer

CompassData will only utilize FAA Licensed Pilots to act as pilot in command of 

the UX5 UAS. Additionally, all pilots will be assisted by a safety observer. The pilot 

in command and safety observer must meet the requirements as set forth by the UX5 

Standard Operating Procedures, which is proprietary information, and is attached 

hereto as (Exhibits 2, 3, 4 and 5) and is to be held in a separate file pursuant to 14 
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C.F.R. § 11.35(b).

Flights Will Be Conducted Pursuant To Specific Operating

Limitations

In seeking this exemption, CompassData proposes to commercially operate the UX5 

UAS without satisfying the restricted category airworthiness certification process 

specified in 14 C.F.R. § 21.185, or otherwise having a certificate of airworthiness 

issued by the FAA, as contemplated by 14 C.F.R. Part 21. CompassData proposes to 

operate the UX5 UAS, for the special purpose of conducting aerial image acquisitions, 

pursuant to the following specific operating limitations as approved in the Trimble 

Grant of Exemption No. 11110. These operating limitations as stated in the Trimble 

Grant of Exemption include: 

1) Operations authorized by this grant of exemption are limited to the following 

aircraft described in the operator’s manual which is a fixed-wing aircraft weighing less 

than 6 pounds: Trimble Navigation Limited UX5 UAS. Proposed operations of any

other aircraft will require a new petition or a petition to amend this grant.

2) The UA may not be flown at an indicated airspeed exceeding 74.5 knots.

3) The UA must be operated at an altitude of no more than 400 feet above ground 

level (AGL), as indicated by the procedures specified in the operator’s manual. All 

altitudes reported to ATC must be in feet AGL.

4) The UA must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any device other 

than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

5) All operations must utilize a visual observer (VO). The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. 

The VO and PIC must be able to communicate verbally at all times. The PIC must be 
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designated before the flight and cannot transfer his or her designation for the duration 

of the flight. The PIC must ensure that the VO can perform the functions prescribed in 

the operator’s manual.

6) Provided the additional requirements identified in these conditions and 

limitations are added or amended, the operator’s manual is considered acceptable to the 

FAA. The operator’s manual and this grant of exemption must be maintained and made 

available to the Administrator upon request. If a discrepancy exists between the 

conditions and limitations in this exemption and the procedures outlined in the 

operator’s manual, the conditions and limitations herein take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its 

operator’s manual.

The operator may update or revise its operator’s manual. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and revised 

documents if it petitions for an extension or amendment of this exemption. If the 

operator determines that any update or revision would affect the basis upon which the 

FAA granted this exemption, then the operator must petition for amendment to its 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions 

arise regarding updates or revisions to the operator’s manual.

7) Prior to each flight the PIC must inspect the UAS to ensure it is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe operation of the 

UAS, the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

8) Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, must 

undergo a functional test flight in accordance with the operator’s manual. The PIC who 
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conducts the functional test flight must make an entry in the UAS aircraft records of the 

flight. The requirements and procedures for a functional test flight and aircraft record 

entry must be added to the operator’s manual.

9) The preflight inspection section in the operator’s manual must be amended to 

include the following requirement: The preflight inspection must account for all 

discrepancies, i.e. inoperable components, items, or equipment, not covered in the 

relevant preflight inspection sections of the operator’s manual.

10) The operator must follow the manufacturer’s UAS aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements, with 

particular attention to flight critical components that may not be addressed in the 

manufacturer’s manuals.

11) CompassData must carry out its maintenance, inspections, and record keeping 

requirements in accordance with the operator’s manual. Maintenance, inspection, and 

alterations must be noted in the aircraft logbook, including total flight hours, 

description of work accomplished, and the signature of the authorized UX5 technician 

returning the UX5 to service.

12) UX5 technicians must receive and document training referenced in the 

operator’s manual.

13) Each UAS operated under this exemption must comply with all manufacturer 

System and Safety Bulletins.

14) CompassData UX5 maintenance personnel must make a record entry in the 

UAS logbook or equivalent document of the corrective action taken against 

discrepancies discovered between inspections.

15) The PIC must possess at least a private pilot certificate and a third-class airman 

medical certificate. The PIC must also meet the flight review requirements specified in 
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14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

16) Prior to operating for hire, the PIC must have completed Trimble’s five-day

UX5 Training Syllabus as outlined in the Safety Checklist. The Training Manual must 

also be updated to reflect the specific five day Training Syllabus presented by Trimble. 

The Training Manual specifies the minimum flight and skill requirements for the 

Remote Pilot, Instructor Pilot and Examiner. Those Manuals and records of those 

requirements must be documented and made available upon request by the 

Administrator. Those minimum flight requirements are repeated here as conditions and 

limitations:

Remote pilot [PIC]

- Minimum 2 flights on the UX5 as a remote pilot during the Type Rating 

module

- Minimum 2 flights on the UX5 as visual observer during the Type 

Rating module

- When failed: Minimum 4 flights on the UX5 for the failed part

Instructor pilot

• A minimum of 25 flights and 4 hours where:

- The flights occurred on 4 different calendar days.

- Two long endurance flights that last near the maximum permissible 

endurance (40 min for operations conducted under this exemption) or 

have a minimum duration of 45 min for previously logged flights or 

flights not conducted under this exemption (per the Trimble operation’s 

manual).

- One flight with a minimum measured wind speed of 30 kph (18.64 

mph). If the wind speed cannot be measured, you can provide proof 

from METAR as close as 25km from the weather station.
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- One flight with a minimum programmed leg distance of 1 km (if 

possible by CAA regulations, otherwise as long as possible.)

- 11 flights with a different selected height where:

- 2 flights are at the minimum height

- 2 flights are at the maximum allowable height

Examiner

- 100 flights and 20 hours (regardless of aircraft type) or as approved by a 

team of examiners.

Prior documented flight experience that was obtained in compliance with applicable 

regulations may satisfy this requirement. Training, proficiency, and experiencebuilding flights can also be conducted under this grant of exemption to accomplish the 

required flights and flight time.

17) If the UAS loses communications or loses its GPS signal, the UA must return to 

a pre-determined location within the private or controlled-access property and land or 

be recovered in accordance with the operator’s manual.

18) The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operator’s manual.

19) The PIC is prohibited from beginning a UX5 flight unless (considering wind 

and forecast weather conditions) there is enough power to fly to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 10 

minutes.

20) The operator is required to request a Notice to Airman (NOTAM) not more than 

72 hours in advance, but not less than 48 hours prior to the operation.
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23 21) All aircraft operated in accordance with this exemption must be identified by

serial number, registered in accordance with 14 CFR part 47, and have identification 

(N- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

22) Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements.

23) The documents required under 14 CFR 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request.

24) The UA must remain clear and yield the right of way to all other manned 

operations and activities at all times (including, but not limited to, ultralight vehicles, 

parachute activities, parasailing activities, hang gliders, etc.).

25) The UAS may not be operated by the PIC from any moving device or vehicle.

26) UAS operations may not be conducted during night, as defined in 14 CFR 1.1.

27) All operations shall be conducted in Class G airspace.

28) All operations must be conducted under visual meteorological conditions

(VMC). The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

29) During operations in Class G airspace, the UA may not operate within 5 

nautical miles of the geographic center of an airport as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport’s 
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management is obtained, and the operation is conducted in accordance with a NOTAM. 

The letter of agreement with the airport management must be made available to the 

Administrator upon request.

30) The UA may not be operated over congested or densely populated areas. These 

areas include but are not limited to the yellow areas depicted on World Aeronautical 

Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts 

(TAC). However, aeronautical charts may not reflect pertinent local information. 

Ultimately, it is the PIC’s responsibility to maintain the minimum safe altitudes 

required by § 91.119. 

31) Operation of the UA must be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures.

32) Operations of the UA may be conducted at distances less than 500 feet from 

participating persons, vessels, vehicles or structures that perform an essential function 

in connection with these special purpose operations. Operations closer than 500 feet 

from the PIC, VO, operator trainees and essential persons, are permitted when 

operationally necessary; but never so close as to present an undue hazard, per

§ 91.119(a).

33) Operations of the UA may be conducted at distances less than 500 feet from 

unoccupied vessels, vehicles or structures owned by the land owner/controller when the 

land owner/controller grants such permission and the PIC makes a safety assessment of 

the risk from operations closer to these objects.

34) All operations shall be conducted over government owned, private or 

controlled-access property with permission from the land owner/controller or 

authorized representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.

35) Any incident, accident, or flight operation that transgresses the lateral or vertical 
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boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB Web site: www.ntsb.gov.

SUMMARY

SUMMARY OF COMPASSDATA SECTION 333 EXEMPTION REQUESTS

CompassData hereby provides pursuant to Part 11 a summary of its exemption 

application to allow commercial operation of the UX5 UAS in precision aerial 

survey work. An exemption is requested from the following regulations:

14 C.F.R. 61.113(a) & (b);

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

14 C.F.R. 91.119;

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

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

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a).
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CONCLUSION

As set forth above, CompassData seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe 

operation of the UX5 UAS commercially, without an airworthiness certificate, for the 

special purpose of conducting aerial acquisitions over certain rural areas within the 

States of AZ, CO, MN, MT, ND, NE, NM, SD, TX, UT and WY. By granting this 

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the 

FAA Modernization and Reform Act of 2012, while also advancing the interests of the 

public, by allowing CompassData to safely, efficiently, and economically operate the 

UX5 UAS commercially within the NAS.

 

 Dated: 22 January 2015

Respectfully submitted,

Hayden Howard

Vice President

CompassData, Inc.

12353 E Easter Ave.

Centennial, CO 80112

303-627-4058

cc: James H. Williams, AFS-80

Robert Pappas

Dean Griffith, Esq.