State Farm Corporate Headquarters 1State Farm Plaza Bloomington, IL 61710-0001

December23, 2014 U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE West Building Ground Floor Room W12-140 Washington, D.C. 20590 

# &StateFarm®

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") submitsthis letterfor the FAA's consideration in connection with State Farm's petition under Section 333 ofthe FAA Modernization and Reform Act of20121for 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 ofOperation. ALPA states that State Farm's petition does not define howthe area of operation will be limited or predetermined and does not offera meansto control the airspace or areas ofoperation. 3 State Farm's petition includes a requestto use UAS for R&D attest sites owned orcontrolled by State Farm. The petition describesthe characteristics ofsuch a test site-a minimum of 100 acres ofuninhabited rural farmland, located a minimum offive miles from any airport and within 50 miles ofState Farm's headquarters in Bloomington, Illinois, with access restricted to State Farm employees orconsultants engaged in test ortest related work. 4 The UAS testing will only occur in Class G airspace at altitudes of400 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 ofoperation. The petition notesthatthe operatorwill contactthe UAS FAA Modernization and Reform Act of2012, Pub.Law No. 112-95. 2 See Docket No. FAA-2014-0856; Summary Notice No. PE-2014-126. 3 Comments ofALPA, 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 at4. Providing Insurance andFinancial Services Home Office, Bloomington, ILIntegration Office, cognizant Flight Standards District Office; local AirTraffic Control Facility{ies), and Official-in-Charge ofon scene emergency response activities (or whomever FAA designates) to request "activation" ofits authority to conduct R&D operations atthe specified disaster location_? The operatorwill givethe applicable authorities the dates and times offlights, as well as a description offlight activity, including maps ordiagrams ofthe area overwhich operations are occurring and the essential altitudes. 8 Mitigation of Hazard to OtherAircraft. ALPA suggests that State Farm's petition does not ensure that the hazard ofother aircraft intruding on the operation is mitigated. 9 Both ALPA and NAAA raise concerns about howthe UAS will "sense and avoid" other aircraft. 10 State Farm's petition explains that hazards to other aircraft will be mitigated through a variety ofsafety measures.
• State Farm's UAS will only operate during daytime. 11

• UAS operations will always occurwithin the line ofsight ofthe UAS operator.12

• Fortest site R&D, the operatorwill request a Notice to Airmen ("NOT AM") not more than 72 hours in advance but not lessthan 48 hours priorto UAS operations. 13 For catastrophe R&D, the operatorwill request a NOT AM as early as practicable priorto operations. 14

• State Farm will ensure safety to first responder aircraft and helicoptertraffic. Upon notification from aircraft controllers orthrough visual identification ofaircraft, State Farm will immediately suspend the UAS flight until the airspace is cleared. 15 These requirements, which the FAA approved in its grant ofthe motion picture and television operator petitions,16 will ensurethat 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 subjectto 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 subjectto 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 andFinancialServices Home Office, Bloomington, ILsite orduring and after catastrophes does not create a hazard to other users ofthe national airspace. 

### Pilotand Observer Requirements. ALPA requests that both pilot and observer be able to maintain a visual observation of both the aircraft and the area ofoperation. 17 NAAA adds that the operator should be attending/monitoring the UAS at all times and thatthe observer must be present and able to communicate with the operatorfrom the most minimal distance possible. 18 State Farm's petition states thatthe UAS must be operated in the visual line ofsight ofthe pilot at all times, and the Operations Manual notesthatthe observer is responsible for keeping the vehicle in sight at all times. 19 The Petition also states that thatthe pilot and observer must be able to communicate verbally at all times.20 

### LostSignal Mitigations. ALP A's filing queries howthe UAS will safely land in the event ofa loss ofGPS.21 State Farm's Operations Manual details howthe UAS will respond in such a situation. The UAS has safetyfeatures which attemptto reacquire the lost signal and will help the UAS safely descend ifGPS is lost.22 ALPA'sfiling also states that mitigationsfor spectrum interference, terrain, and obstacles should be developed.23 State Farm's Operations Manual further describes safetyfeatures thatwill help maintain safe operations in the event of emergencies such as power loss, loss ofcommunications, loss ofvideo link, airspace incursion from other aircraft, and software crashes.24 For example: 

# •

•

•

•

17 18 19 20 21 22 23 24 Loss ofpowerto 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; Ifa loss ofcommunications occurs, a communications strength indicatoron 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 continueto re-acquire link while it navigates through the landing procedure and loiter along a tangential path to the touchdown spot; If a loss ofvideo link occurs, the manual has a checklist ofsystems to check and verify settings; In the event ofairspace incursion from another aircraft, the pilot and observer should directthe UAS to safe altitudes and locations to maintain safe separation and continue to monitor incurring aircraftfor direction, speed, and altitude. Ifa 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 andFinancial Services Home Office, Bloomington, IL !• In the event ofa software crash, the UAS operatorwill immediatelyturn offthe comm box to ensurethat the UAS loses command and control and will begin to perform its loss ofcommunication 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 atthe test sites and at catastrophe areas will occurat a maximum ceiling of400feet AGL. 27 The FAA and other aircraft will have advance notice ofthe flight area dueto 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. NAAAalso suggeststhat ifan agricultural orothertype oflow-flying aircraft is within two miles, the UAS operator procedure should beto immediately ground the UAS as soon as practicable.28 State Farm's petition requires the UAS to yield right ofwayto all manned aircraft, and to ensure safety to first responderaircraft and helicoptertraffic.29 Further, upon notification from manned aircraft controllers orthrough visual identification ofmanned aircraft, State Farm will immediately suspend the UAS flight until the airspace is cleared.30 Finally, NAAAstatesthat UAS conducting low-level aerial applicationwork must complywith 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 proposethat 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 dueto the UAS safetyfeatures and its size, weight, speed, and operating area. Pilots License and Medical Certificate. ALPA and NAAA's comments both statethatthe 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 grantsto the motion picture and television operators. The FAA analyzed the UAS's separation from manned aircraft operations, the current aeronautical knowledge requirements fora private pilot compared to a commercial pilot, and the specific airmanship skills required for operation ofa

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 andFinancialServices Home Office, Bloomington, ILUAS. 35 Given those considerations, the FAAfound 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 underthe direct, in-person supervision ofa pilot holding both a private pilot certificate and a third-class medical certificate.38 Because ofthis 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 aboutthe qualifications ofthe persons who may be providing flight instruction.39 State Farm's Operations Manual specifiesthat 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 manufacturerapproved training; at least 100flight 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 attachmentto 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 400feet above ground level.43 For R&D at State Farm'stest sites, the UAS will be operated in a restricted-access area, where buildings and peoplewill 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 occuratsafe altitudes with respect to manned aircraft. Altimeter Settings. ALPA raises the concern that, due the lack ofa barometric altimeteron the UAS, processes or mitigationsforsystem and equipmentfailures must be in place.46 The FAA's

35 See, e.g. Astraeus Grant at 17-18. 36 

### /d. at25. 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 ALPAComments 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 andFinancialServices Home Office, Bloomington, ILgrants to the motion picture and television operators permitted use ofa GPS altitude readout instead ofa barometric altimeter, finding that this alternative means ofcompliance with the FAA's rules would not adversely affect safetyY State Farm's petition notes thatthe UAS may have a GPS altitude readout and the Operations Manual details thefailsafe systems and safety features ofthe 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 thatthe UAS be properly maintained.5° State Farm's petition notes that the company will institute a rigorous maintenance program and the operatorwill 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 ofthe UAS. UAS Markings. NAAA believes that UAS should be painted in colors to makethem readily distinguishablefrom the background and thatthe UAS and ground vehicle should have strobe lighting.54 State Farm's UAS operations will ,only occurduring daytime, eliminating the need for special color painting orstrobe lighting.55 NAAAfurther suggests that the UAS should have a registered N-numberon an indestructible and unmovable plate attached to the UAS.56 State Farm's petition already includes the commitmentthat the UAS will have markings identifying the serial numberand N-numberas large as practicable.57 FAAOversight. As afinal matter, ALPA notes its concern thatthe use ofwaiver requests could tax the FAA's resources and that the request is notfor a single specific operation or location, increasing the FAA's oversighttask.58 First, the Section 333 exemption process is the interim policy thatthe FAA has chosen to establish until the small UAS rule is adopted. The FAA has noted that it is anticipated thatthis activitywill result in significant economic benefits, and the FAAAdministrator has identified this activity as a high priority project.59 The FAA is moving forward carefully with granting these requests and there is no reason to doubtthe

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 at8. ALPA Comments at 3-4. FAA, Section 333, available athttps://www.faa.gov/uas/legislative programs/section 333/.

Providing Insurance andFinancialServices Home Office, Bloomington, ILagency's abilityto 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 ofall flights and a description of flight activity, including maps and diagrams ofthe area overwhich operationswill be occurring.60 These commitments will help simplifythe FAA's oversightfunctions 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 bythe Small UAV Coalition. 61 State Farm respectfully requests that the FAA move expeditiouslyto grantthe 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 ofSmall UAV Coalition, Docket No. FAA-2014-0856 (filed Dec. 3, 2014).

Providing Insurance andFinancialServices Home Office, Bloomington, IL