Direct Dial: 703.760.5204 kpomfret@williamsmullen.com

BYFEDEX 

### WILLIAMS MULLEN

July 27, 2015

U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE Washington, D.C. 20590 Re: Section 333 Exemption Request Dear Sir or Madam: '- .· _,. :... ·

. ..[·

Pursuantto Section 333 ofthe FAAModernization and Reform Act of2012 (the "ReformAct"), Nationwide Insurance ("Petitioner") hereby applies for an exemption from the Federal AviationRegulations ("FARs") described in SectionVII below and any other exemptions necessary to allow Petitionerto operate the small Unmanned Aircraft Systems ("UAS") described in Section IV to (i) inspect commercial and residential buildings to assist in insurance underwriting and determining insurance claims and (ii) collect informationcritical to policyholders and first responders immediately priorto and following a natural disaster, as more fully described in Section IX below. I. Background on Petitioner Nationwide, a Fortune 100 companybased in Columbus, Ohio, is one ofthe largest and strongest diversified insurance and financial services organizations in the U.S. and is rated A+ by both A.M. Best and Standard & Poor's. The companyprovides a full range ofinsurance and financial services, including auto, commercial, homeowners, farm and life insurance; public and private sector retirementplans, annuities and mutual funds; banking and mortgages; pet, motorcycle and boat insurance. II. Contact Information

28620884_1 The contact information for Petitioner is set forth below: Nationwide Insurance c/o Peter D. Lore AVP, P&C Property Claims Nationwide Insurance 3 Nationwide Plaza, 3-13-202 Columbus, OH 43215

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### III. Request forExemption to Use UAS for Survey and Inspection ofDamage after CasualtyEvents and RiskAssessment and Management Petitionerproposes to inspect commercial andresidential buildings using the UAS under controlled conditions. The data collection will be conducted for commercial purposes, primarily to assist in insurance underwriting and determining insurance claims. Ineach case aerial data collection will be conducted underthe conditions set forth herein and the Section 333 exemption grant. Inthat regard, the airspace will be (i) limited, (ii) predetermined, and (iii) controlled as to access. Petitioner will limit operations to property whose owners have beennotified in advance and have provided consent. Operations will always occur within the line ofsight ofthe UAS operator. Petitionerwill take steps to protectthe privacy ofthe property owners and nearby individuals. In addition, Petitionerproposes to conduct operations, subjectto notice to and approval ofproper federal, state and local officials, over areas thathave suffered a natural disaster, or are about to suffer a natural disaster, such as a hurricane, tornado, flood or wildfire. The purpose of these operations will be to develop practices and procedures that will improve the speed of Petitioner's response and increase the amount and type ofinformation Petitioner canprovide policyholders, first responders and appropriate industry experts in a timely manner. In connection with such operations, Petitioner will develop operating procedures that will integrate UAS into its response strategyto ensure safety to persons and property. Giventhe potential for this exemptionto leadto developments that will save lives and property after a storm or disaster, the Petitionerrequests thatthis request for exemptionbe considered on an expedited basis. Inthat regard, Petitioner notes thatthe FAAhas previously granted exemptions for similar activities for the Microdrone md4-1000, the AlturaZenith ATX8, the DJI Phantom 2 andthe DJI Inspire.I. 1 

### IV. Unmanned Aircraft System A. Microdrone md4-1000 The Microdrone md4-1000 is a batterypowered quadcopter weighing less than 6 kg, including payload. Ithas a maximum speed of26 mph and a maximum flight operating endurance of88 minutes. Its flight and navigation controller centers on an inertial measurement

1See, e.g., Asymmetric Technologies (Microdrone md4-1000- Exemption No. 11171), State Farm Mutual Automobile Insurance Company (Altura Zenith ATX8- Exemption No. 11175 and Exemption 11188), Montico Inc. (DJI Phantom 2- Exemption 11230), Erie Insurance (DJI Phantom 2- Exemption 11293), NextEraEnergy, Inc. (DJI Phantom 2- Exemption 11224), Travelers Companies, Inc. (DJI Phantom 2- Exemption 11494) Build Imagery, LLC (DJI Inspire 1-Exemption 11204),) and CineDrones, LLC (DJI Inspire 1-Exemption 11279).

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U.S. Department ofTransportation, Docket Operations July 27,2015 Page 3 unit, consisting ofan accelerometer and a gyroscope for each axis, supplementedby a 3-axis magnetometer, a barometric altitude sensor and a GNSS receiver. With all these sensor readings puttogether, the md4-1000 is able to fly self-stabilizedwith GNSS PositionHold. As soon as there is no input from the operator, the md4-1000 will stay onthe spot, waiting for the next command. It is possible to let the md4-1000 hover in the same spot for several minutes. The aircraft is operated using a remote control ground station and is capable ofsetting pre-programmed distance and height limits. Inthe event ofa loss link, GPS failure or law battery condition, the aircraft can be programmedto descend and land orreturnto home. B. Aerialtronics AlturaZenith ATX8 The Altura Zenith ATX8 is a multi-rotor aircraftbuiltwith a monocoque carbon airframe. The Zenith has a 5.6 kg take-offweight and a maximumpayload of2.9 kg. The Zenith carries a 16.600 mAhbattery, which facilitates up to 45 minutes offlight-time. It canbe flown with either a radio ortablet and carries a variety ofpayloads. The Zenith has a maximum cruise speed of20 m/s. It features auto-takeoffand landing, auto go home and landing, GPS waypoint navigation, direction lock, and GIS mapping. Specifications include:

• Length x Width: 23.6" x 23.6" • Height: 13.7"- 21.6" tall • Weight: 7.7lbs., withoutpayload (less than 15 lbs. withpayload) C. DJI Phantom 2 Vision+ The DJI Phantom 2 Vision+ is a light weight multi-rotor copterthat that will be operated at a maximum speed ofless than 50 mph and a flight time ofno more than 20 minutes. Ithas a high level ofpre-programmed controls and various built-intechnical capabilities (programming ofa geo-fence and height limitations) that preventthe operator from doing a mission outside of the operating limits. Ifits communications withthe PIC is lost, the safety system will allow it either to hover in place and slowly descend orto returnto a predeterminedpoint. D. DJI Inspire 1 The DJI Inspire 1weighs less than 7 lbs., has four motors and has the ability to hover and move along a vertical and horizontal plane simultaneously. Its dimensions are 438mmx 451mm x 301mm or 17.24inchx 17.75inchx 11.85 inches. Under still air the maximum speed is no more than 49mphwith a cruising speed of25mph. Its safety system will allow it either to hover in place and slowly descend ifcommunication withthe PIC is lost or to return to a predetermined point.

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U.S. Department ofTransportation, Docket Operations July 27, 2015 Page4

In support ofthis exemptionrequest, Petitioneris submitting under separate cover the applicable operational documents for the UAS described above (the "Operational Documents"). We request that the Operational Documents be given confidential treatment. V. Statutory Authority for Requested Exemptions This petition for exemption is submitted in accordance with Section 333 ofthe Reform Act. Pursuantto Section 333 ofthe Reform Act, the Federal Aviation Administration (FAA) Administrator (the "Administrator") is to permit operation ofan unmanned aircraft system where it does not create a hazardto users ofthe national airspace system (NAS) orthe public orpose a threat to national security. Moreover, the Federal Aviation Act grants the Administrator general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides such a requested exemption is in the public interest. See 49 U.S.C. §§ 106(£), 44701-44716, etseq. A party requesting ap exemption must explainthe reasons why the exemption: (i) would benefit the public as a whole, and (ii) would not adversely affect safety orhow it would provide a level ofsafety at least equal to the existing rules. 14 C.F.R. § 11.81. VI. Safety Measures and Public Interest Benefits As described in more detail in Section IX, the Petitioner will take measures to ensure such operations will not create a hazard to aviation orthe public. Flights will be conducted under 400 feet AGL thereby avoiding interference withusers oftheNAS. Flights will be suspended immediately to yieldright-of-way to any other aircraft. Geo-fencing will be utilized when available to ensure that a UAS does not fly outside ofthe intended area. The site will be secured and only authorized personnel will be permitted onthe grounds. Giventhe size and speed ofthe UAS, the controlled nature ofthe locations being used and the lack ofexplosive materials or flammablejetfuels, the operations will not pose a threatto national security. There are a number ofreasons why granting the Petitioner's request to operate the UAS for commercial aerial data collection is inthe public interest. For example, use ofUAS inthis manner will make conditions for insurance claim representatives safer. Today claim representatives must climb onto a rooffor data collection. Such activities are inherently dangerous as each year claim handlers are injured due to falls from roofs. Claimhandlers will be able to reduce their exposure to suchhazards by using a UAS. Inaddition, they will be able to obtainthe data necessary to make accurate assessments ofa roofmore quickly. In addition, the use ofthe UAS to conduct aerial data collection over areas thathave been impacted by a natural disaster will allow access to areas that are dangerous to reach by foot.

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VII. Specific Sections from Which Petitioners Seek an Exemption Based upon the informationprovided and the exemptions that the FAAhas already grantedpursuantto Section 333, the Petitionerrequests the following exemptions: 14 C.F.R. § 61.23(a) 14 C.F.R. § 61.23(c) 14 C.F.R. § 61.101(e)(4) 14 C.F.R. § 61.101(e)(S) 14 C.F.R. § 61.113(a) 14 C.F.R. § 61.315(a) 14 C.F.R. § 91.7(a) 14 C.F.R. § 91.119(c) 14 C.F.R. § 91.121 14 C.F.R. § 91.151(a)(1) 14 C.F.R. § 91.405(a) 14 C.F.R. § 91.407(a)(1) 14 C.F.R. § 91.409(a)(1) 14 C.F.R. § 91.409(a)(2) 14 C.F.R. § 91.417(a) 14 C.F.R. § 91.417(b) VIII. Justifications for Each Exemption Request 1. 14 C.F.R. § 61.23(a), 14 C.F.R. § 61.23(c), 14 C.P.R.§ 61.101(e)(4), 14 C.P.R. § 61.101(e)(5), 14 C.P.R.§ 61.113(a) and 14 C.P.R.§ 61.315(a). Petitionernotes that FAA is requires the Pilot in Commandto hold either an airline transport, commercial, private, recreational or sport certificate pilot license and either a current FAA airman medical certificate or a valid U.S. driver's license issuedby a state, the District of Columbia, Puerto Rico, a territory, a possession, orthe Federal government. Petitioner will ensure that its PICs will satisfy each ofthese requirements. Since Petitioner's PICs will be operating UAS under the same conditions as those previously granted, an equivalent level of safety will be metby granting these exemptions. 2. 14 C.P.R. § 91.7(a) Civil aircraft worthiness. Section 91.7(a) requires that an operator determine an aircraft is in airworthy condition before a flight. Petitionerrequests relieffrom this sectionprovidedthatthe operator ofthe UAS determines priorto each flight that the aircraft is in compliance with the applicable Operational Documents. Such pre-flight inspection will provide the equivalent level ofsafety as that

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### WILLIAMS MULLEN

U.S. Department ofTransportation, Docket Operations July 27, 2015 Page 6 provided bythis section. Petitionernotes thatthe Administratorhas granted relieffrom this section inprevious exemptions. 3. 14 C.P.R.§ 91.119(c) Minimum safe altitudes over congested and other areas. Section 91.119(c) establishes safe altitudes for operation ofcivil aircraft over areas other than congested areas. The Petitionerrequests relieffrom this section withrespectto those participating persons, vehicles, and structures directly involved with operations. The UAS will never operate at higherthan 400 AGL. Relieffrom this section is warranted as operations will be conducted with adequate safety provisions as outlinedherein and inthe applicable Operational Documents. As a result, an equivalent level ofsafety will be metby granting this exemption. Petitionernotes thatthe Administratorhas grantedrelieffrom this section in previous exemptions. 4. 14 C.P.R. §91.121 Altimeter Settings. This regulation requires eachperson operating an aircraft to maintain cruising altitudeby reference to an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." An exemption from this section maybe needed if the UAS does nothave a barometric altimeter, butinstead has a GPS altitude read out. An equivalent level ofsafety will be achievedbythe operator, pursuantto the applicable Operational Documents, confirming the altitude ofthe launch site shown onthe GPS altitude indicatorbefore flight. As a result, an equivalent level ofsafety will be metby granting this exemption. Petitionernotes thatthe Administratorhas granted relieffrom this section inprevious exemptions. 5. 14 C.P.R.§ 91.15l(a)(l) Fuel requirements for flight in VFR conditions. Section 91.151 (a) prohibits an individual from beginning "aflight in an airplane under VFRconditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly afterthat for at least 30 minutes." Complying withthe 30 minute reserve would severely limitthe length ofthe Petitioner's UAS flights and hamper operations. Giventhe limitations on the UAS's proposed flight area a longer time frame for flight in daylight conditions is reasonable. Operating the UAS in a tightly controlled area does notraise the type ofrisks thatthis section was intended to address, particularly giventhe size and speed ofthe UAS. Petitionerbelieves that an equivalent level of safety canbe achievedby limiting flights to 50 minutes or 20% ofbattery power, whichever happens first. Petitioner notes that the Administratorhas granted relieffrom this section in previous exemptions.

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### WILLIAMS MULLEN

U.S. Department ofTransportation, Docket Operations July 27, 2015 Page 7

6. 14 C.F.R. § 

### 91.405(a) Maintenance required; 14 C.F.R. § 91.407(a)(l) Operation after maintenance, preventive maintenance, rebuilding or alteration; 14 C.F.R. §§ 

### 91.409(a)(l) and (2) Inspections; 14 C.F.R. §§ 

### 91.417(a) and (b) Maintenance records. Maintenance will be accomplished by the operatorpursuantto the applicable Operational Documents. An equivalent level ofsafety will be achieved becausethe UAS are very limited in size and will carry a small payload and operate only inrestricted areas for limited periods of time. Ifmechanical issues arise, the UAS will be operating from no higher than 400 feet AGL and can immediately land. As provided inthe applicable Operational Documents, the operator will ensure that the UAS is in working orderprior to initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar withthe aircraft and best suited to maintainthe aircraft in an airworthy condition to provide the equivalent level ofsafety. As a result, an equivalent level ofsafety will be metby granting this exemption. Petitioner notes that the Administratorhas granted relief from this section inprevious exemptions. 7. Additional Relief. In addition to the exemptions listed above, the Petitionerrequests exemption from such otherrules and regulations as the FAA deems appropriate to enable the operations described herein. Since previous exemptions granted under Section 333 ofthe Reform Act have been effective for two years, the Petitioner also requests that ifthe FAA issues interim or final rules applicable to the operation ofany UAS included herein after the Petitionerreceives a Grant of Exemptionthat any conditions and limitations required in such Grant that are more burdensome than the newregulationbe appropriately modified orremoved. 8. Expedited Process. Given that this exemption is similarto those that have alreadybeen granted, Petitioner requests that, ifpossible, this request for exemption be considered on an expedited basis. IX. Operating Parameters for UAS Use 

### Petitionerproposes that ifthe requested exemptions are granted, it will operate the UAS under the following conditions:

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### 1. UAS operations will be conducted by a Pilot in Command (PIC). The PIC shall hold an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a currentFAA airman medical certificate or a valid U.S. driver's

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U.S. Department ofTransportation, Docket Operations July 27, 2015 Page 8**28620884~1** 

### license issued by a state, the District ofColombia, Puerto Rico, a territory, a possession, or the Federal government. The UAS will be in visual line ofsite (VLOS) ofthe PIC at all times. 2. All UAS operations will utilize a visual observer ("VO"). The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding air traffic and other ground-based obstacles/obstructions. 3. The PIC and VO will be able to communicate verbally at all times. 4. Petitioner will rely on qualified vendors to provide apilot qualification program, including a training program incorporating proper aircraft operations and safety standards. The PIC and the VO will have obtained the necessary qualifications/training. A record ofcompletion ofthis qualification process will be documented and made available to the Administrator upon request. 5. UAS will not be flown at ground speeds exceeding 100 mph. 6. Flights will be operated at an altitude ofno more than 400 feet above ground level. 7. Each UAS operation will be completed within 50 minutes flight time or with 20% battery power remaining, whichever occurs first. At 30% batterythe UAS will enter areturn and land sequence; at 20% it will land immediately. 8. UAS will not be operated over any person (other than participating personnel) at an altitude that is hazardous to persons or property onthe surface in the event ofa UAS failure or emergency. UAS will be operated at a distance from participating buildings ofat least 10 feet. Operations will be conducted at least 500 feet from nonparticipating persons orbuildings, unless barriers are in placeto provide adequate protection. 9. The UAS will abort the flight in the event ofunpredicted obstacles or emergencies in accordance with the applicable Operational Document. 10. The UAS will remain clear and yield the right ofwayto all other manned operations and activities at all times. 11. UAS operations will not be conducted during night. 12. The UAS will notbe operated bythe PIC from any moving device orvehicle.

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13. The UAS will 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. 14. The applicable Operational Documents and all documents required under 14 C.P.R. § 91.9 and 91.203 will be available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating. These documents will be made available to the Administratoruponrequest. 15. Any incident, accident, orflight operationthat transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB). 16. The operator will follow the procedures as outlined in its applicable Operational Documents. 17. Priorto each flight, pilotwill inspectthe UAS to ensure it is in condition for safe flight. Ifthe inspectionreveals a discrepancy, the aircraft will be prohibited from operating until the necessary maintenance has beenperformed and the UAS is found to be in a condition for safe flight. 18. All operations will be conducted overprivate or controlled-access property with permission from the land-owner/controller or authorized representative. Permission from the land-owner/controller or authorized representative will be obtained for each flight to be conducted. 19. All maintenance and alterations will be properly documented inthe aircraftrecords. 20. Any UAS that undergoes maintenance or alterations that affect the UAS operation or flight characteristics will undergo a functional flight test in accordance with the applicable Operational Documents. 21. Petitioner will institute a rigorous maintenanceprogram to ensure airworthiness ofthe UAS. Operator will follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 22. Each UAS will comply with all manufacturer Safety Bulletins. X. Summary to be Published in Federal Register Petitioner: Nationwide Insurance

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Sections of 14 C.F.R. Affected: § 61.23(a), § 61.23(c), § 61.101(e)(4), § 61.101(e)(5), § 61.113(a), § 61.315(a) § 91.7(a); § 91.119(c); § 91.121; § 91.151(a)(l); § 91.405(a); § 91.407(a)(l); §§ 91.409(a)(l) and (2); §§ 91.417(a) and (b). Description of Relief Sought: Petitioner seeks relieffrom the requirements of 14 C.F.R. § 61.23(a); 14 C.F.R. § 61.23(c); 14 C.F.R. § 61.101(e)(4); 14 C.F.R. § 61.101(e)(5); 14 C.F.R. § 61.113(a); 14 C.P.R.§ 61.315(a); § 91.7(a);14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. §91.151(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b) to (i) inspect commercial and residential buildings to assist ininsurance underwriting and determining insurance claims and (ii) collect information critical to policyholders and first responders immediatelypriorto and following a natural disaster. 

### XI. Conclusion Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Actregarding size, weight, speed, operating capabilities, proximity to airports and populated areas, operationwithin visual line ofsight, and national security, provide more than adequatejustificationfor the grant ofthe requested exemption allowing operation ofPetitioner's UAS for inspection ofcommercial and residential buildings. Please contact Petitioner's outside counsel, Kevin D. Pomfret at 703- 760-5204 orkpomfret@williamsmullen.com with any questions about this filing. Sincerely, 

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Kevin D. Pomfret

KDP/kmb Attachments: Confidential Treatment is requested.

28620884_1 A. DJI Phantom 2 Vision+ User Manual B. DJI Inspire 1User Manual, Safety Guidelines C. Microdrone md4-1000

- Operators Handbook, Training Description and Flight Operation Checklist D. AlturaZenithATX8- Operations Manual