1 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,

Axiom Ventures Inc. DBA (“Hummingbird Systems”) 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 

Hummingbird Systems 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. Hummingbird 

Systems 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 Hummingbird Systems 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:

Mearon Okonsky

Axiom Ventures Inc.

375 S. Rancho Santa Fe Rd. Ste 103 

San Marcos, CA 92078

Phone: (858) 335-9089

Email: mearon@gmail.com

Hummingbird Systems 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.
U.S. Department of Transportation

1 July 2015

Page 2

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 

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

thereto.

Hummingbird Systems 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. ABC hereby requests a 

blanket COA for flights up to 200 feet AGL in the form approved by the FAA. CNI will

also file NOTAMs for its flights, as required.

To the extent necessary, Hummingbird Systems refers the FAA to the original 

exemption and the amended exemption requests submitted by Trimble in Docket FAA2014-0367 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 Hummingbird 

Systems 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,

Mearon Okonsky

Axiom Ventures Inc.

375 S. Rancho Santa Fe Rd. Ste 103

San Marcos, CA 92078

Enclosure

cc:

 

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.