State Farm 

Corporate Headquarters 

1 State Farm Plaza 

Bloomington, IL 61710-0001 

December 23, 2014 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor 

Room W12-140 

Washington, D.C. 20590 

&State Farm® 

Re: Docket No. FAA-2014-0856; Summary Notice No. PE-2014-126 

State Farm Mutual Automobile Insurance Company; Petition for Exemption 

Dear Sir or Madam: 

State Farm Mutual Automobile Insurance Company ("State Farm") submits this letter for the 

FAA's consideration in connection with State Farm's petition under Section 333 of the FAA 

Modernization and Reform Act of 20121 for an exemption to allow operation of Unmanned 

Aircraft Systems ("UAS") for research and development ("R&D"). 2 Two commenters, the Air 

Line Pilots Association ("ALPA") and the National Agricultural Aviation Association ("NAAA"), 

filed in opposition to State Farm's petition citing various concerns. This filing explains how State 

Farm's proposed operations, as detailed in the company's petition for exemption, will be 

conducted to ensure safety to those on the ground and other aircraft. 

Area of Operation. ALPA states that State Farm's petition does not define how the area of 

operation will be limited or predetermined and does not offer a means to control the airspace or 

areas of operation. 3 State Farm's petition includes a request to use UAS for R&D at test sites 

owned or controlled by State Farm. The petition describes the characteristics of such a test 

site-a minimum of 100 acres of uninhabited rural farmland, located a minimum of five miles 

from any airport and within 50 miles of State Farm's headquarters in Bloomington, Illinois, with 

access restricted to State Farm employees or consultants engaged in test or test related work. 4 

The UAS testing will only occur in Class G airspace at altitudes of 400 feet or less. 5 State Farm 

will use gee-fencing as the means to control the area of operations.6 

State Farm's use of UAS for R&D during and after catastrophes will also occur in a limited and 

predetermined area of operation. The petition notes that the operator will contact the UAS 

FAA Modernization and Reform Act of 2012, Pub.Law No. 112-95. 

2 See Docket No. FAA-2014-0856; Summary Notice No. PE-2014-126. 

3 Comments of ALPA, Docket No. FAA-2014-0856 at 1 (filed Dec. 3, 2014) ("ALPA 

Comments"). 

4 State Farm Petition for Exemption, Docket No. FAA-2014-0856 at 2, 2 (filed Oct. 15, 

2014) ("State Farm Petition"). 

5 /d. 

6 State Farm Petition at 4. 

Providing Insurance and Financial Services Home Office, Bloomington, IL 
Integration Office, cognizant Flight Standards District Office; local Air Traffic Control Facility{ies), 

and Official-in-Charge of on scene emergency response activities (or whomever FAA 

designates) to request "activation" of its authority to conduct R&D operations at the specified 

disaster location_? The operator will give the applicable authorities the dates and times of flights, 

as well as a description of flight activity, including maps or diagrams of the area over which 

operations are occurring and the essential altitudes. 8 

Mitigation of Hazard to Other Aircraft. ALPA suggests that State Farm's petition does not 

ensure that the hazard of other aircraft intruding on the operation is mitigated.9 Both ALPA and 

NAAA raise concerns about how the UAS will "sense and avoid" other aircraft. 10 State Farm's 

petition explains that hazards to other aircraft will be mitigated through a variety of safety 

measures. 

• State Farm's UAS will only operate during daytime. 11 

• UAS operations will always occur within the line of sight of the UAS operator. 12 

• For test site R&D, the operator will request a Notice to Airmen ("NOT AM") not more than 

72 hours in advance but not less than 48 hours prior to UAS operations. 13 For 

catastrophe R&D, the operator will request a NOT AM as early as practicable prior to 

operations. 14 

• State Farm will ensure safety to first responder aircraft and helicopter traffic. Upon 

notification from aircraft controllers or through visual identification of aircraft, State Farm 

will immediately suspend the UAS flight until the airspace is cleared. 15 

These requirements, which the FAA approved in its grant of the motion picture and television 

operator petitions, 16 will ensure that State Farm's use of UAS for R&D at State Farm's own test 

7 State Farm Petition at 13-14. 

8 /d. 

9 See ALPA Comments at 1. 

10 ALPA Comments at 3; Comments of NAAA, FAA Docket No. FAA-2014-0856 at 1-2 

{filed Dec. 4, 2014) ("NAAA Comments"). 

11 State Farm UAS Operations Manual, FAA Docket No. FAA-2014-0856, at 4-4 (filed Oct. 

15, 2014) {"Operations Manual"). 

12 State Farm Petition at 6, 10. NAAA's comments also specifically request that UAS 

operators be subject to the requirement to maintain line-of-sight operations. NAAA Comments 

at 2. 

13 State Farm Petition at 7, 10. NAAA's comments also specifically request that UAS 

operators be subject to this NOT AM requirement. NAAA Comments at 2. 

14 State Farm Petition at 6. 

15 State Farm Petition at 11. 

16 See, e.g. FAA, Grant of Exemption, Astraeus Aerial, FAA Docket No. FAA-2014-0352, 

Exemption No. 11062 (Sept. 25, 2014) ("Astraeus Grant"). 

Providing Insurance and Financial Services Home Office, Bloomington, IL 
site or during and after catastrophes does not create a hazard to other users of the national 

airspace. 

Pilot and Observer Requirements. ALPA requests that both pilot and observer be able to 

maintain a visual observation of both the aircraft and the area of operation. 17 NAAA adds that 

the operator should be attending/monitoring the UAS at all times and that the observer must be 

present and able to communicate with the operator from the most minimal distance possible.18 

State Farm's petition states that the UAS must be operated in the visual line of sight of the pilot 

at all times, and the Operations Manual notes that the observer is responsible for keeping the 

vehicle in sight at all times. 19 The Petition also states that that the pilot and observer must be 

able to communicate verbally at all times.20 

Lost Signal Mitigations. ALP A's filing queries how the UAS will safely land in the event of a 

loss of GPS. 21 State Farm's Operations Manual details how the UAS will respond in such a 

situation. The UAS has safety features which attempt to reacquire the lost signal and will help 

the UAS safely descend if GPS is lost.22 ALP A's filing also states that mitigations for spectrum 

interference, terrain, and obstacles should be developed.23 State Farm's Operations Manual 

further describes safety features that will help maintain safe operations in the event of 

emergencies such as power loss, loss of communications, loss of video link, airspace incursion 

from other aircraft, and software crashes.24 For example: 

• 

• 

• 

• 

17 

18 

19 

20 

21 

22 

23 

24 

Loss of power to the propulsion systems will result in a controlled landing at an 

emergency decision site and the UAS will continue to operate with the communications 

link and flight controls; 

If a loss of communications occurs, a communications strength indicator on the ground 

station will alert the operator, then the UAS will navigate to the home way point which is 

uploaded before takeoff. The UAS will continue to re-acquire link while it navigates 

through the landing procedure and loiter along a tangential path to the touchdown spot; 

If a loss of video link occurs, the manual has a checklist of systems to check and verify 

settings; 

In the event of airspace incursion from another aircraft, the pilot and observer should 

direct the UAS to safe altitudes and locations to maintain safe separation and continue 

to monitor incurring aircraft for direction, speed, and altitude. If a collision appears 

eminent, the operator is instructed to manually down the vehicle; 

ALPA Comments at 1. 

NAAA Comments at 2-3. 

State Farm Petition at 10; Operations Manual at 3-3. 

State Farm Petition at 9. 

ALPA Comments at 2. 

Operations Manual at 9-1 - 9-2. 

ALPA Comments at 2. 

Operations Manual at 9-1 - 9-5. 

Providing Insurance and Financial Services Home Office, Bloomington, IL 

! 
• In the event of a software crash, the UAS operator will immediately turn off the comm 

box to ensure that the UAS loses command and control and will begin to perform its loss 

of communication procedure. 25 

Hazard to Low-Level Pilots. NAAA notes its concern that State Farm's UAS will present a 

hazard to low-level pilots. 26 State Farm's proposed R&D operations at the test sites and at 

catastrophe areas will occur at a maximum ceiling of 400 feet AGL.27 The FAA and other 

aircraft will have advance notice of the flight area due to the NOT AM. It is therefore highly 

unlikely that State Farm's use of UAS will create a hazard to low-level aircraft conducting aerial 

application of pesticides. 

NAAA also suggests that if an agricultural or other type of low-flying aircraft is within two miles, 

the UAS operator procedure should be to immediately ground the UAS as soon as practicable. 28 

State Farm's petition requires the UAS to yield right of way to all manned aircraft, and to ensure 

safety to first responder aircraft and helicopter traffic.29 Further, upon notification from manned 

aircraft controllers or through visual identification of manned aircraft, State Farm will 

immediately suspend the UAS flight until the airspace is cleared. 30 

Finally, NAAA states that UAS conducting low-level aerial application work must comply with 14 

C.F.R. Part 137.31 This proposal is not applicable to State Farm's UAS, which will not be 

conducting low-level aerial application work. 

Airworthiness Certificate. ALPA and NAAA propose that State Farm's UAS be required to 

have an airworthiness certificate. 32 State Farm notes that the requirement to have an 

airworthiness certificate was waived in the FAA's previous Section 333 grants to the motion 

picture and television operators. 33 The State Farm petition merits the same exemption due to 

the UAS safety features and its size, weight, speed, and operating area. 

Pilots License and Medical Certificate. ALPA and NAAA's comments both state that the UAS 

pilot should hold at least a current FAA commercial pilot certificate and a current 2nd class FAA 

medical certificate. 34 The FAA addressed this issue in its previous Section 333 grants to the 

motion picture and television operators. The FAA analyzed the UAS's separation from manned 

aircraft operations, the current aeronautical knowledge requirements for a private pilot 

compared to a commercial pilot, and the specific airmanship skills required for operation of a 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

/d. 

NAAA Comments at 1. 

State Farm Petition at 2, 3. 

NAAA Comments at 2. 

State Farm Petition at 11. 

/d. 

NAAA Comments at 3. 

ALPA Comments at 2; NAAA Comments at 2. 

See, e.g. Astraeus Grant at 14. 

ALPA Comments at 2; NAAA Comments at 2. 

Providing Insurance and Financial Services Home Office, Bloomington, IL 
UAS. 35 Given those considerations, the FAA found that its safety objectives would be met by 

only requiring a pilot to possess a private pilot certificate and at least a third-class medical 

certificate. 36 

Accordingly, State Farm pilots during "Phase I" of R&D at State Farm's test sites and during and 

after catastrophes will hold at least a private pilot certificate and a third class medical 

certificate. 37 During "Phase II" of R&D at State Farm's test sites, UAS operations will be 

conducted by appropriately-trained persons holding third-class medical certificates under the 

direct, in-person supervision of a pilot holding both a private pilot certificate and a third-class 

medical certificate. 38 Because of this direct, in-person supervision by a qualified pilot, Phase II 

R&D will be essentially as low-risk as Phase I. 

Flight Instruction. ALPA requests information about the qualifications of the persons who may 

be providing flight instruction.39 State Farm's Operations Manual specifies that a certified 

instructor is a qualified pilot-in-command who has more than 100 hours flying the specific UAS 

and has been with State Farm for over 18 months.40 The credentials for a certified instructor 

are: Class 3 Medical; FAA Ground school; successful completion of manufacturer approved 

training; at least 100 flight cycles; at least 25 hours UAS operations; a FAA private pilot 

certificate; and manned currency (three flights within the previous 90 days).41 State Farm also 

· filed its Training Syllabus with the FAA as an attachment to the exemption request. 

Minimum Safe Altitudes. ALP A's position is that all aircraft in the national airspace system 

("NAS") must maintain minimum safe altitudes as required in 14 C.F.R. § 91.113.42 As noted 

above, State Farm's UAS will operate at no more than 400 feet above ground level.43 For R&D 

at State Farm's test sites, the UAS will be operated in a restricted-access area, where buildings 

and people will not be exposed to operations without their pre-obtained consent.44 The FAA 

previously granted an exemption to Section 91.119( c) on minimum safe altitudes in the motion 

picture and television operator grants.45 State Farm's UAS operations will occur at safe 

altitudes with respect to manned aircraft. 

Altimeter Settings. ALPA raises the concern that, due the lack of a barometric altimeter on the 

UAS, processes or mitigations for system and equipment failures must be in place.46 The FAA's 

35 See, e.g. Astraeus Grant at 17-18. 

36 /d. at 25. 

37 State Farm Petition at 8. 

38 /d. 

39 ALPA Comments at 3. 

40 Operations Manual at 3-4. 

41 Operations Manual at 3-5. 

42 ALPA Comments at 3. 

43 State Farm Petition at 10. 

44 State Farm Petition at 16. 

45 See, e.g. Astraeus Grant at 20. 

46 ALPA Comments at 3. 

Providing Insurance and Financial Services Home Office, Bloomington, IL 
grants to the motion picture and television operators permitted use of a GPS altitude readout 

instead of a barometric altimeter, finding that this alternative means of compliance with the 

FAA's rules would not adversely affect safetyY State Farm's petition notes that the UAS may 

have a GPS altitude readout and the Operations Manual details the failsafe systems and safety 

features of the UAS.48 

Maintenance. ALPA states that FAA certified professionals should perform all inspections and 

owner/operators should keep records verifying certain maintenance is in compliance.49 NAAA 

also suggests requiring that the UAS be properly maintained. 5° State Farm's petition notes that 

the company will institute a rigorous maintenance program and the operator will develop 

procedures to document and maintain a record of UAS maintenance. 51 State Farm requires that 

all maintenance and alterations be properly documented in the aircraft records. 52 Further, 

operators will develop UAS technician qualification criteria, which will be added to the 

Operations Manual. 53 State Farm's commitments promote safe, regular maintenance of the 

UAS. 

UAS Markings. NAAA believes that UAS should be painted in colors to make them readily 

distinguishable from the background and that the UAS and ground vehicle should have strobe 

lighting. 54 State Farm's UAS operations will ,only occur during daytime, eliminating the need for 

special color painting or strobe lighting. 55 NAAA further suggests that the UAS should have a 

registered N-number on an indestructible and unmovable plate attached to the UAS.56 State 

Farm's petition already includes the commitment that the UAS will have markings identifying the 

serial number and N-number as large as practicable. 57 

FAA Oversight. As a final matter, ALPA notes its concern that the use of waiver requests 

could tax the FAA's resources and that the request is not for a single specific operation or 

location, increasing the FAA's oversight task. 58 First, the Section 333 exemption process is the 

interim policy that the FAA has chosen to establish until the small UAS rule is adopted. The 

FAA has noted that it is anticipated that this activity will result in significant economic benefits, 

and the FAA Administrator has identified this activity as a high priority project. 5

9 The FAA is 

moving forward carefully with granting these requests and there is no reason to doubt the 

47 

48 

49 

50 

51 

52 

53 

54 

55 

56 

57 

58 

59 

See, e.g. Astraeus Grant at 21. 

State Farm Petition at 16; see e.g. Operations Manual at 9-1 - 9-5. 

ALPA Comments at 3. 

NAAA Comments at 3. 

State Farm Petition at 13. 

/d. 

./d. 

NAAA Comments at 2. 

Operations Manual at 4-4. 

NAAA Comments at 3. 

State Farm Petition at 8. 

ALPA Comments at 3-4. 

FAA, Section 333, available at https://www.faa.gov/uas/legislative programs/section 333/. 

Providing Insurance and Financial Services Home Office, Bloomington, IL 
agency's ability to oversee the operations it permits. Second, State Farm's proposed R&D 

operations at its test sites will occur over property controlled by State Farm in a designated 

area. For catastrophe location R&D, State Farm will be in contact with the UAS Integration 

Office and other officials to share with them the date and times of all flights and a description of 

flight activity, including maps and diagrams of the area over which operations will be occurring.60 

These commitments will help simplify the FAA's oversight functions with regard to State Farm. 

In conclusion, State Farm's petition to use UAS for R&D addresses the safety concerns voiced 

by ALPA and NAAA. The petition is supported by the Small UAV Coalition. 61 State Farm 

respectfully requests that the FAA move expeditiously to grant the State Farm petition. 

Sincerely, 

Todd Binion, CPC 

Innovation Manager 

State Farm Mutual Automobile Insurance Company 

309-735-8633 

todd.binion.hkoO@statefarm.com 

eo State Farm Petition at 13-14. 

61 Comments of Small UAV Coalition, Docket No. FAA-2014-0856 (filed Dec. 3, 2014). 

Providing Insurance and Financial Services Home Office, Bloomington, IL