HOGAN LOVELLS US LLP

\\DC - 057212/001058 - 6654231 v3 BEFORE THE FEDERAL AVIATION ADMINISTRATION

___________________________________________________

Chubb & Son, a division of Federal Insurance Company,
Petitioner. Docket No. FAA-2015-_____

PETITION OF CHUBB & SON, A DIVISION OF FEDERAL INSURANCE COMPANY, FOR AN EXEMPTION FROM CERTAIN FEDERAL AVIATION REGULATIONS TO PERMIT UNMANNED AIRCRAFT SYSTEMS (UAS) OPERATIONS

E. Tazewell Ellett Patrick R. Rizzi Hogan Lovells US LLP 555 13 th Street, N.W. Washington, DC 20004 Phone: 202-637-8644 / -5659 Fax: 202-637-5910 tazewell.ellett@hoganlovells.com patrick.rizzi@hoganlovells.com COUNSEL FOR CHUBB & SON, A DIVISION OF FEDERAL INSURANCE COMPANY

DATE: November 20, 2015HOGAN LOVELLS US LLP

\\DC - 057212/001058 - 6654231 v3 TABLE OF CONTENTS Page
1. BACKGROUND INFORMATION: THE PETITIONER .................................................................. - 1 -
2. PROPOSED UAS OPERATIONS: THE EXEMPTION REQUEST ............................................... - 1 -
3. PROPOSED UAS AND CONDITIONS AND LIMITATIONS.......................................................... - 2 -
3.1 Conditions and limitations regarding the proposed UAS............................................ - 3 -
3.2 Conditions and limitations regarding the proposed UAS operations ........................ - 3 -
3.3 Conditions and limitations regarding the Pilot in Command and other crewmember qualifications and training ....................................................................... - 7 -
3.4 Conditions and limitations regarding Chubb manuals related to UAS operations ......................................................................................................................... - 8 -
4. REQUEST FOR DETERMINATION UNDER SECTION 333 OF FMRA........................................ - 9 -
5. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITION FOR EXEMPTION........................................................................................................................... - 10 -
5.1 Contact information ......................................................................................................... - 10 -
5.2 The specific section or sections of the FAR from which Chubb seeks an exemption .................................................................................................................... - 10 -
5.3 The extent of relief sought and the reason relief is sought......................................... - 11 -
5.4 Reasons why granting the request would be in the public interest ........................... - 25 -
5.5 Reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which exemption is sought.......................... - 27 -
5.6 Summary that can be published in Federal Register, including the rule from which exemption is sought, and a brief description of the nature of the exemption sought. ................................................................................................ - 28 -
5.7 Additional information that supports request............................................................... - 28 -
5.8 Request to exercise the privileges of the exemption outside the U.S........................ - 29 -
5.9 Attachments...................................................................................................................... - 29 -
6. CONCLUSION ................................................................................................................................ - 29 -HOGAN LOVELLS US LLP

\\DC - 057212/001058 - 6654231 v3 1. BACKGROUND INFORMATION: THE PETITIONER Chubb & Son, a division of Federal Insurance Company (“Chubb”), manages the member insurers of the Chubb Group of Insurance Companies. Chubb and the other insurance companies managed by Chubb deliver exceptional property and casualty insurance products and services to
businesses and individuals.

2. PROPOSED UAS OPERATIONS: THE EXEMPTION REQUEST Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”) and 14 C.F.R. (“FAR”) §§ 11.61(b), 11.63(a), and 11.81, Chubb requests that the FAA grant Chubb an exemption from certain sections of the FAR (detailed below in Sections 5.2 and 5.3) so that Chubb may operate one or more small UAS for aerial data collection, including aerial inspection, risk management, damage assessment, and other data collection operations related to the insurance industry. Such operations would include researching how UAS could be used to perform aerial surveys and to replace or supplement physical inspections and risk assessments in hazardous and other locations (e.g., rooftops, manufacturing plants, houses/infrastructure), as well as assessments of damage to property caused by natural disasters and other catastrophes. All these proposed operations involve aerial data collection, consistent with previously granted summary grant exemptions. As explained below, Chubb’s proposed UAS operations, as conditioned and limited herein, will not adversely affect safety, but rather will provide an equivalent or greater level of safety than that provided by the current rules, large manned aircraft operations, and other current methods of collecting these data. See FAR § 11.81. Chubb respectfully requests that the FAA grant the requested exemption on an expedited basis. To that end, as detailed below, Chubb agrees to comply with the conditions and limitationsHOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 imposed in recent summary grant exemptions, including exemptions related to insurance industry activities. See, e.g., Exemption No. 11494 (May 5, 2015; Docket FAA-2015-0304) (“Travelers Exemption”); Exemption No. 11741 (June 5, 2015; Docket FAA-2015-0892) (“Witt Tech Exemption”); Exemption No. 11691 (May 26, 2015; Docket FAA-2015-0119) (“OpenSky Drones Exemption”). Given Chubb’s agreement to comply with these conditions and limitations, and given that this Petition is similar in all material respects to previously filed petitions that have been granted on a summary grant basis, and that the proposed UAS use falls within the “aerial data collection” category of uses permitted by numerous summary grant exemptions, no new precedent would be set by granting the requested exemption, and any delay in the FAA’s acting on this Petition would be detrimental to Chubb and delay its research and implementation of these use cases. Accordingly, as with the Travelers Exemption, at 1, the Witt Tech Exemption, at 1, and the OpenSky Drones Exemption, at 1, good cause exists for the FAA to move forward with consideration of this Petition and the grant of this exemption without publishing a summary of the Petition in the Federal Register.

3. PROPOSED UAS AND CONDITIONS AND LIMITATIONS The small UAS operations proposed in this Petition will be subject to the following conditions and limitations. As noted above, these conditions and limitations are the same conditions and limitations as those contained in previously granted small UAS Section 333 exemptions, including recent summary grant exemptions. To facilitate the FAA’s review of this Petition, Chubb provides a chart at the end of this Section 3 cross-referencing the conditions and limitations from the Travelers Exemption, OpenSky Drones Exemption
, and the Measure Exemption (cited below) with the corresponding conditions and limitations outlined below. Collectively, these conditions and limitations ensure that the proposed small UAS operations will not adversely affect safety and will provide at least an equivalent level of safety to that provided by the current rules, large manned aircraft operations, and other current methods of collecting these data.HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 3.1 Conditions and limitations regarding the proposed UAS Chubb intends to operate a variety of small, lightweight, battery-powered UAS models under the requested exemption, all of which have been the UAS models designated to be used in previously granted exemptions and are set out in Attachment 1 to the Measure Exemption (appended to this Petition as Exhibit 1). See, e.g., Exemption No. 12646 (August 28, 2015; Docket FAA-2015-1602) (“Measure Exemption”) (granting exemption covering 324 UAS models). The flying unmanned aircraft part of the UAS (“the UA”) will typically carry a GoPro or similar camera. Each UAS operated under the exemption will be subject to the following conditions and
limitations:
3.1.1 Operations under the exemption will be limited to the UA approved by the Secretary of the Department of Transportation for operation under Section 333 when weighing less than 55 pounds including payload (Exhibit 1 hereto). 1 Proposed operations of any other UAS will require a new petition or a petition to amend this exemption. [Measure Exemption Limitation No. 1.]
3.1.2 The UA will not be operated at airspeeds greater than the maximum UA

operating speed recommended by the UA manufacturer, and in no event will it be operated at a speed exceeding 87 knots (100 miles per hour). [Travelers Exemption Limitation No. 3; OpenSky Drones Exemption Limitation No. 3.]
3.1.3 The UA will be identified by its serial number and registered with the

FAA in accordance with FAR Part 47. [Travelers Exemption Limitation No. 22; OpenSky Drones Exemption Limitation No. 22.]
3.1.4 The UA will have identification markings in accordance with FAR Part

45, with the markings being as large as practicable. [Travelers Exemption Limitation No. 22; OpenSky Drones Exemption Limitation No. 22.]

3.2 Conditions and limitations regarding the proposed UAS operations All UAS operations under the exemption will be subject to the following conditions and
limitations:
3.2.1 All UAS operations will be covered by an Air Traffic Organization (“ATO”)-issued Certificate of Waiver or Authorization (“COA”). All UAS

1 The UAS for which Chubb seeks an exemption herein are collectively referred to in this Petition as “these UAS”.HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 operations will be conducted in accordance with the airspace requirements in the ATO-issued COA. Should Chubb want to conduct operations that cannot be conducted under the terms of the blanket COA accompanying this exemption, Chubb will apply for a new or amended COA. [Travelers Exemption Limitation No. 21; OpenSky Drones Exemption Limitation No. 21.]
3.2.2 Operations for the purpose of closed-set motion picture and television

filming are not permitted under this exemption. [Travelers Exemption Limitation No. 2; OpenSky Drones Exemption Limitation No. 2.]
3.2.3 The UA will not operate within 5 nautical miles of an airport’s reference

point (“ARP”) as denoted in the current FAA Airport/Facility Directory, or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter agreement with that airport’s management is obtained or such an operation is otherwise permitted by a COA issued to Chubb. Chubb will make the letter agreement available to the FAA or any law enforcement official upon request. [Travelers Exemption Limitation No. 16; OpenSky Drones Exemption Limitation No. 16.]
3.2.4 The minimum crew for each UAS operation will consist of one Pilot in

Command (“PIC”) and one Visual Observer (“VO”). The PIC will be 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 for the VO. [Travelers Exemption Limitation No. 6; OpenSky Drones Exemption Limitation No. 6.]
3.2.5 The UA will be operated within the visual line of sight (“VLOS”) of the

PIC and VO at all times. The PIC will maintain VLOS with human vision unaided by any device other than corrective lenses as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. [Travelers Exemption Limitations No. 5, 6; OpenSky Drones Exemption Limitations No. 5, 6.] The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. [Travelers Exemption Limitation No. 6; OpenSky Drones Exemption Limitation No. 6.]
3.2.6 During each UAS operation, the PIC and the VO must be able to

communicate verbally with each other at all times. Electronic messaging or texting by the PIC and the VO is not permitted during UAS flight operations. [Travelers Exemption Limitation No. 6; OpenSky Drones Exemption Limitation No. 6.]
3.2.7 The PIC is prohibited from beginning a UAS flight unless (considering

wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or, if greater, with the reserve power recommended by the UA manufacturer. [Travelers Exemption Limitation No. 20; OpenSky Drones Exemption Limitation No. 20.]
3.2.8 Prior to each UA flight, the PIC will conduct a pre-flight inspection and

determine that the UAS (including the Ground Control Station) is in aHOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 condition for safe flight. The pre-flight inspection will account for all potential discrepancies, e.g., non-functioning components, items or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the UA is prohibited from operating until the necessary maintenance has been performed and documented, and the UAS is found to be in a condition for safe flight. [Travelers Exemption Limitation No. 10; OpenSky Drones Exemption Limitation No. 10.]
3.2.9 The operator is responsible for maintaining and inspecting the UAS to

ensure that it is in a condition for safe operation. [Travelers Exemption Limitation No. 9; OpenSky Drones Exemption Limitation No. 9.]
3.2.10 During each UAS operation, the UA will remain at or below 400 feet

above ground level (“AGL”). [Travelers Exemption Limitation No. 4; OpenSky Drones Exemption Limitation No. 4.]
3.2.11 Altitude reports made to ATC or other persons must be reported in feet

AGL. [Travelers Exemption Limitation No. 4; OpenSky Drones Exemption Limitation No. 4.]
3.2.12 All UAS operations will be conducted over properties owned or

controlled by Chubb as well as other private or controlled-access property with permission from the property owner/controller or authorized representative. For properties not owned or controlled by Chubb, permission from the property owner/controller or authorized representative will be obtained for each flight to be conducted. [Travelers Exemption Limitation No. 27; OpenSky Drones Exemption Limitation No. 27.]
3.2.13 The UA will operate at least 500 feet from all non-participating persons,

vessels, vehicles, and structures unless: (a) Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. Chubb must ensure that non-participating persons remain under such protection; and if a situation arises where non-participating persons leave such protection and are within 500 feet of the UA, flight operations mustcease immediately in a manner ensuring the safety of nonparticipating persons; and/or (b) The owner/controller of any vessels, vehicles or structures

has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees, and essential persons are not considered non-participating persons under this exemption. [Travelers Exemption Limitation No. 26; OpenSky Drones Exemption Limitation No. 26.]HOGAN LOVELLS US LLP

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3.2.14 All UAS operations will take place during visual meteorological

conditions (VMC) only. [Travelers Exemption Limitation No. 15; OpenSky Drones Exemption Limitation No. 15.]
3.2.15 Chubb will not operate UAS flights under Special Visual Flight Rules

(SVFR). [Travelers Exemption Limitation No. 15; OpenSky Drones Exemption Limitation No. 15.]
3.2.16 All UAS operations will take place during daylight hours. UAS

operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. [Travelers Exemption Limitation No. 15; OpenSky Drones Exemption Limitation No. 15.]
3.2.17 During each UAS operation, the UA will avoid, remain clear of, and

yield right-of-way to, all manned aviation operations and activities at all times. [Travelers Exemption Limitation No. 24; OpenSky Drones Exemption Limitation No. 24.]
3.2.18 The UA 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. [Travelers Exemption Limitation No. 17; OpenSky Drones Exemption Limitation No. 17.]
3.2.19 The UAS will not be operated by the PIC from any moving device or

vehicle. [Travelers Exemption Limitation No. 25; OpenSky Drones Exemption Limitation No. 25.]
3.2.20 Any UAS that has undergone maintenance or alterations that affect the

UAS operation or UA flight characteristics (e.g., replacement of a flight critical component) must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights will only be conducted by a PIC with a VO, and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. [Travelers Exemption Limitation No. 8; OpenSky Drones Exemption Limitation No. 8.]
3.2.21 If the UAS loses communications or its GPS signal during any

operation, the UA must return to a pre-determined location within the private or controlled-access property. [Travelers Exemption Limitation No. 18; OpenSky Drones Exemption Limitation No. 18.]
3.2.22 The PIC will adhere to the written emergency procedures in the

Manuals, and will abort the UAS operation and UA flight in the event of unpredicted obstacles or emergencies. [Travelers Exemption Limitation No. 19; OpenSky Drones Exemption Limitation No. 19.]
3.2.23 The documents used by the operator to ensure the safe operation and

flight of the UAS and any documents required under 14 C.F.R. §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS at any time the UA is operating, and will be made available to the FAA or any law enforcement official upon request. [TravelersHOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 Exemption Limitation No. 23; OpenSky Drones Exemption Limitation No. 23.]
3.2.24 Any incident, accident or flight operation that transgresses the lateral or

vertical boundaries of the 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”) per instructions contained on the NTSB website: www.ntsb.gov. [Travelers Exemption Limitation No. 28; OpenSky Drones Exemption Limitation No. 28.]

3.3 Conditions and limitations regarding the Pilot in Command and other crewmember qualifications and training The PIC and other crewmembers for each UAS operation under the requested exemption will be subject to the following conditions and limitations:

3.3.1 The PIC must hold (i) either an ATP, commercial, private, recreational

or sport pilot certificate; and (ii) a current FAA airman medical certificate or a valid driver’s license issued by a State, the District of Columbia, Puerto Rico, a U.S. territory/possession, or the Federal Government. The PIC must satisfy the flight review requirements of 14 C.F.R. § 61.56 in an aircraft for which the PIC is rated on his or her pilot certificate. [Travelers Exemption Limitation No. 13; OpenSky Drones Exemption Limitation No. 13.]
3.3.2 The operator will not permit any PIC to operate the UAS unless the PIC

demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes oftraining Chubb’s PICs and VOs (training, proficiency, and experiencebuilding) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. These training operations, however, may only be conducted during dedicated training sessions. [Travelers Exemption Limitation No. 14; OpenSky Drones Exemption Limitation No. 14.]
3.3.3 During training, proficiency, and experience-building flights, all persons

not essential for flight operations are considered non-participants, andthe PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. [Travelers Exemption Limitation No. 14; OpenSky Drones Exemption Limitation No. 14.]HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 3.4 Conditions and limitations regarding Chubb manuals related to UAS operations Chubb will have manuals and checklists for each of the UAS models it will operate under the requested exemption (collectively, the “Manuals”). The Manuals will be subject to the following
limitations and conditions:

3.4.1 The Operating Documents 2 must be accessible during UAS operations

and made available to the FAA upon request. If a discrepancy exists between the conditions and limitations in the exemption and the procedures outlined in the other Operating Documents, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, Chubb must follow the procedures as outlined in the Operating Documents. [Travelers Exemption Limitation No. 7; OpenSky Drones Exemption Limitation No. 7.]
3.4.2 Chubb may update or revise its Operating Documents, and it is

Chubb’s responsibility to track such revisions and present updated and revised Operating Documents to the FAA or any law enforcement official upon request. Chubb must also present updated and revised Operating Documents if it petitions for an extension or amendment of the exemption. If Chubb determines that any update or revision would affect the basis upon which the FAA granted the requested exemption, then Chubb must petition for an amendment to the exemption. Chubb will contact the FAA’s UAS Integration Office (AFS-80) if questions arise regarding updates or revisions to the Operating Documents. [Travelers Exemption Limitation No. 7; OpenSky Drones Exemption Limitation No. 7.]
3.4.3 Each UAS operated under the exemption will comply with all

manufacturer safety bulletins. [Travelers Exemption Limitation No. 12; OpenSky Drones Exemption Limitation No. 12.]
3.4.4 Chubb will follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the UAS and UAS components. [Travelers Exemption Limitation No. 11; OpenSky Drones Exemption Limitation No. 11.]
In sum, Chubb’s operations under this exemption will be subject to the same conditions and limitations imposed in the summary grant Travelers Exemption, OpenSky Drones Exemption, and Measure Exemption.

2 “Operating Documents” means this exemption, the Manuals, and all other documents needed by Chubb to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption. [Travelers Exemption Limitation No. 7; OpenSky Drones Exemption Limitation No. 7.]HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 CROSS-REFERENCES

Travelers Exemption Limitation No. OpenSky Drones Exemption Limitation No. Measure Exemption Limitation No. Petition Limitation No.

1 3.1.1 2 3.2.2 3 3.1.2 4 3.2.10, 3.2.11 5 3.2.5 6 3.2.4, 3.2.5, 3.2.6 7 3.4.1, 3.4.2 8 3.2.20 9 3.2.9 10 3.2.8 11 3.4.4 12 3.4.3 13 3.3.1 14 3.3.2, 3.3.3 15 3.2.14, 3.2.15, 3.2.16 16 3.2.3 17 3.2.18 18 3.2.21 19 3.2.22 20 3.2.7 21 3.2.1 22 3.1.3, 3.1.4 23 3.2.23 24 3.2.17 25 3.2.19 26 3.2.13 27 3.2.12 28 3.2.24

4. REQUEST FOR DETERMINATION UNDER SECTION 333 OF FMRA In accordance with FMRA Section 333, Chubb requests that the Secretary of Transportation determine that Chubb’s proposed small UAS operations (i) do not create a hazard to users of the National Airspace System or the public, and (ii) do not pose a threat to national security. Chubb further requests that, based on the Secretary’s determination, the FAA determine – as it did in the Measure Exemption, the Travelers Exemption, and the OpenSky Drones Exemption –HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 that relief from FAR Part 21 and any associated noise certification and testing requirements of FAR Part 36 is not necessary for the UAS operations proposed in this Petition. 3

5. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITION FOR EXEMPTION As required by FAR § 11.81, Chubb provides the following information in support of this
Petition: 5.1 Contact information:

Name: Chubb & Son, a division of Federal Insurance Company, submits this Petition for Exemption, through counsel, E. Tazewell Ellett and Patrick R. Rizzi. Mailing address: E. Tazewell Ellett

Patrick R. Rizzi Counsel for Chubb & Son, a division of Federal Insurance Company Hogan Lovells US LLP 555 13 th Street, NW Washington, DC 20004
Telephone/Facsimile number: (T) 202-637-8644 (Ellett) / 202-637-5659 (Rizzi) (F) 202-637-5910
E-mail addresses: tazewell.ellett@hoganlovells.com patrick.rizzi@hoganlovells.com

5.2 The specific section or sections of the FAR from which Chubb seeks an exemption: FAR § 61.23(a) and (c) – Medical certificates: Requirement and Duration. FAR § 61.101(e)(4) and (5) – Recreational pilot privileges and limitations. FAR § 61.113(a) and (b) – Private pilot privileges and limitations: Pilot in command. FAR § 61.315(a), (c)(2), and (c)(3) – What are the privileges and limitations of my sport pilot certificate? FAR § 91.7(a) – Civil aircraft airworthiness. FAR § 91.119(c),(d) – Minimum safe altitudes: General. FAR § 91.121 – Altimeter settings.

3 Measure Exemption, at 2; Travelers Exemption, at 2; OpenSky Drones Exemption, at 2. If the FAA concludes that the UAS operations proposed in this Petition require an exemption from FAR Parts 21 and/or 36, then Chubb requests that the FAA include that relief in the exemption.HOGAN LOVELLS US LLP

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FAR § 91.151 – Fuel requirements for flight in VFR conditions. FAR § 91.405(a) – Maintenance required. FAR § 91.407(a)(1) – Operation after maintenance, preventive maintenance, rebuilding, and inspections. FAR § 91.409(a)(1) and (2) – Inspections. FAR § 91.417(a) and (b) – Maintenance records.

5.3 The extent of relief sought and the reason relief is sought: Chubb proposes to conduct commercial small UAS operations, as described herein, by operating one or more small UAS for aerial data collection, including aerial inspection, risk management, damage assessment, and other data collection operations related to the insurance industry. In order to be able to conduct these UAS operations, Chubb petitions the FAA, pursuant to FAR §§ 11.61(b), 11.63(a), and 11.81(b), for an exemption from the following FAR for the reasons
noted:
FAR § 61.23(a) and (c) -– Medical certificates: Requirement and Duration.
FAR § 61.101(e)(4) and (5) – Recreational pilot privileges and limitations.
The regulation states, in relevant part :

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft— . . . (4) For compensation or hire; (5) In furtherance of a business; . . . . FAR § 61.113(a) and (b) – Private pilot privileges and limitations: Pilot in command. The regulation states, in relevant part:

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; andHOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 (2) The aircraft does not carry passengers or property for compensation or hire. (c) ****. FAR § 61.315(a) and (c)(2), (c)(3) – What are the privileges and limitations of my sport pilot certificate? The regulation states, in relevant part:

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, except as specified in paragraph (c) of this section. . . .

. . . . (c) You may not act as pilot in command of a light-sport aircraft: . . . (2) For compensation or hire. (3) In furtherance of a business. . . .
Chubb requests an exemption from these regulations to the extent necessary to permit Chubb to conduct UAS operations using PICs who hold (i) an FAA private pilot, recreational pilot, or a sport pilot certificate, and (ii) an FAA airman medical certificate or a state driver’s license. While Chubb recognizes that the FAA normally requires a PIC to hold a commercial pilot certificate where there is compensation either to the pilot or for the operation, Chubb requests that the FAA exempt Chubb and its PICs from this requirement since the use of at least a sport pilot as the PIC for the UAS operations under this exemption will be more safe than the use of a commercial pilot for manned aircraft operations. Unlike conventional aircraft, these small UAS are lightweight, remotely controlled, and battery-powered (not fuel/gas), and they have no crew or passengers. The fulfillment of the additional requirements for a sport, recreational or private pilot to become qualified as a commercial pilot would not lead to any additional safety benefits when UAS operations are involved. The differences between the aeronautical knowledge and aeronautical experience requirements for sport pilots and for commercial pilots are significant in the traditional world of manned aircraft. However, no aspect of this incremental additional knowledge or aeronautical experience is significant for the daytime, VMC, low-altitude, visual-line-of-sight, small UAS operations over private or controlled access properties with property owner/controller permission asHOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 proposed in this Petition. Put another way, there are stark and fundamental differences between the type of experience and aeronautical knowledge that the PIC of a commercial manned aircraft with passengers and property should have, versus the type of experience and aeronautical knowledge that the PIC of a small UAS should have, in order to avoid imperiling passengers or property. In Chubb’s case, the small amount of property carried aboard the UA will be Chubb’s property. While the PIC will be compensated, all risk of damage to the property (in fact to the UAS itself) will be borne by Chubb. There is no expectation or need for the PIC of the small UA to have the type of experience or aeronautical knowledge that a commercial pilot for a manned aircraft would have. Similarly, the differences between the flight proficiency requirements for sport pilots and commercial pilots are not substantively significant here where the operations will be conducted strictly during daylight VMC conditions, within VLOS, at altitudes no higher than 400 feet AGL. In addition, Chubb has a training program to ensure that the experience, knowledge, and flight proficiency needed to operate these small UAS safely are achieved for its PICs. Accordingly, there is no reason to require the UAS PIC to have more aeronautical knowledge, experience, and flight proficiency than that required for a sport pilot certificate. Given that Chubb plans to operate these small UAS over private or controlled-access property and at low altitudes during daytime in VMC, the parallel nature of sport pilot aeronautical knowledge requirements to those of commercial requirements, the limited airmanship skills necessary to operate these small UAS, and the lack of additional safety benefits for the proposed UAS operations here resulting from commercial pilot experience, the PIC under this exemption should only be required to hold, at most, a sport pilot certificate. Such a condition would be consistent with the certificate requirements imposed on the PIC in the Measure Exemption, the Travelers Exemption, and the OpenSky Drones Exemption. For these reasons, and consistent with recent summary grant exemptions, Chubb requests that the FAA grant an exemption to permit Chubb to use as PIC of its proposed UAS operations pilots who hold at least a sport pilot certificate and either an FAA third-class airman medicalHOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 certificate or a state driver’s license, so long as they satisfy the conditions and limitations proposed in this Petition, including the PIC qualification and training requirements.
FAR § 91.7(a) – Civil aircraft airworthiness. The regulation states in relevant part: (a) No person may operate a civil aircraft unless it is in an airworthy condition. . . . Chubb requests an exemption from this provision to the extent necessary to permit Chubb to conduct its UAS operations as proposed in this Petition. 4 These small UAS will not require an airworthiness certificate under FAR Part 21, Subpart H, and thus relief is requested from this regulation. See Exemption No. 11110 (December 10, 2014; Docket FAA-2014-0367) (“Trimble Exemption”), at 16. An exemption is warranted because Chubb understands that, notwithstanding the lack of an airworthiness certificate, the FAA will consider its “compliance with [Chubb’s Manuals] to be sufficient means for determining an airworthy condition” and that Chubb must still determine the UA’s airworthiness prior to each flight based on compliance with such Manuals. Trimble Exemption, at 16.
FAR § 91.119(c) and (d)(1) – Minimum safe altitudes: General. The regulation states: Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

4 Chubb requests exemption from FAR § 91.7(a) based on the relief granted in the Trimble Exemption, at 16, 21. However, Chubb notes that the FAA determined that no such exemption was needed in Exemption No. 11062 (September 25, 2014; Docket FAA-2014-0352) (“Astraeus Exemption”) at 19, 22.HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 (c) Over other than congested areas. 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. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted without hazard to persons or property on the surface— (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parachute or weight-shift-control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section. Chubb requests an exemption from this regulation to the extent necessary to permit Chubb to conduct its UAS operations at altitudes lower than those permitted by FAR § 91.119, since such altitudes are one of the key benefits of using small UAS for these flights. Even at these low altitudes, Chubb’s UAS operations will be conducted at a level of safety at least equal to that which would be achieved if larger manned aircraft were to be used at the altitudes required by FAR §
91.119. With respect to paragraph (a), Chubb intends to comply with this requirement to the same extent as would a manned aircraft, meaning that the UA must operate at an altitude such that the loss of a single power unit aboard the UA or used by the UAS would still permit an emergency landing “without undue hazard to persons or property on the surface.” Chubb agrees with the FAA’s reasoning on this issue in the Astraeus Exemption, at 20, and therefore does not believe that relief is required from paragraph (a). With respect to paragraph (b), Chubb plans to operate these small UAS over properties that Chubb owns or controls and other private or controlled-access properties (with owner/controller permission) in areas that are not congested or densely populated. Accordingly, Chubb does not believe that an exemption is necessary from this paragraph (b) covering “congested areas”.HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 With respect to paragraph (c), Chubb requests an exemption to allow UAS operations down to the surface, both in sparsely populated areas and in “other than congested” areas. Chubb’s UAS operations require lower-level flying, but have a number of self-imposed restrictions to ensure at least an equivalent level of safety. For example,

 All operations will be conducted over private or controlled access property.

 For properties not owned or controlled by Chubb, permission from the property owner/controller will be obtained prior to the beginning of each UA flight.

 The UA will operate at least 500 feet from all non-participating persons, vessels, vehicles, and structures unless:

o Barriers or structures are present that sufficiently protect non-participating persons from the UA and/or debris in the event of an accident. Chubb will ensure that non-participating persons remain under such protection; and if a situation arises where non-participating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediately in a manner ensuring the safety of the non-participating persons; and/or

o The UA is operated near vessels, vehicles or structures where the property owner/controller has granted permission, and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. Even with a grant of this exemption, the UAS operations will be at least as safe as operations by manned aircraft that comply with this paragraph. Flying a manned aircraft, given its weight, size, speed, and fuel load, would pose a significant risk relative to the use of a small UA, with a much smaller size and lighter weight, operating at much slower speeds, with batteries rather than a significant fuel load, at all times within VLOS of the PIC on the ground who has a wide view. Accordingly, as the FAA determined in the Trimble Exemption, at 17-18, relief is warranted here provided that Chubb adheres to its Manuals and the additional conditions and limitations outlined above and in the exemption. For these reasons, Chubb requests relief from the entirety of paragraph (c), as was recently granted in the Travelers Exemption, at 2, and the OpenSky Drones Exemption, at 2. To the extent necessary, Chubb also requests relief from paragraph (d)(1), which applies only to helicopters and allows operation at lower altitudes only if on a prescribed helicopter route. Flying a manned helicopter would pose a significantly greater risk than using a small UA for theHOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 proposed operations, even if the helicopter is on a specific route or at a specific low height prescribed by the FAA. A manned helicopter is much heavier, larger, and faster than a small UA. Moreover, unlike an unmanned, battery-powered small UA, the helicopter has people on-board and a fuel load. The operation of a small UA at all times within the VLOS of the PIC on the ground would be at least as safe as a manned helicopter operation operating in conformity with the requirements of paragraph (d)(1), and therefore an exemption from Section 91.119(d)(1) is warranted.
FAR § 91.121 – Altimeter settings. The regulation states, in relevant part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating— (1) Below 18,000 feet MSL, to— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or ( 2 ) A t o r a b o v e 1 8 , 0 0 0 f e e t M S L , t o 2 9

. 9 2 ′′ H g

. (b) * * * *. It is not clear to Chubb that an exemption from this section is required, because, although the regulation expressly applies only to aircraft maintaining a “cruising altitude” and dictates the altimeter setting that must be used while at that cruising altitude, cruising altitudes for VFR flights do not begin – according to FAR § 91.159 – until “more than 3,000 feet above the surface”. 5 Nonetheless, Chubb requests an exemption from FAR § 91.121 to the extent necessary to permit Chubb to conduct the

5 FAR § 91.159; see also Aeronautical Information Manual, at Chpt. 3, Sec. 1, Tbl. 3-1-1, para. 3-1- 2. (July 24, 2014).HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 small UAS operations described in this Petition. See, e.g., Travelers Exemption, at 2; OpenSky Drones Exemption, at 2; Astraeus Exemption, at 21-22. Chubb recognizes the critical importance of ensuring that any UA operated by Chubb maintains altitude to an accurate reference such that other aircraft and the FAA may rely on Chubb’s UAS to be operating as proposed. The PIC will check the UA altitude reading prior to each takeoff, and will effectively zero the UA’s altitude at the point of takeoff, to ensure that measurements of the UA’s altitude are as accurate as possible relative to the local elevation. To the extent that this methodology does not satisfy FAR § 91.121 or any other regulation, Chubb requests an exemption to permit UAS operations using this methodology.
FAR § 91.151 – Fuel requirements for flight in VFR conditions. The regulation states: (a) No person may begin 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. (b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes. Chubb requests an exemption from FAR § 91.151 to permit Chubb to plan its UAS operations as described above. The small UAS operations proposed in this Petition will (i) involve operations in which one or more UAS is transported by means other than its own power to the operational location, and (ii) begin and end at the operational site, with the takeoff, entire flight, and landing all taking place within the immediate proximity of each other while remaining at all times within VLOS of the PIC. The goal of FAR § 91.151 is to ensure that pilots plan for an extra 20 or 30 minutes of fuel at their first intended point of landing in order to account for unexpected possible delays en route andHOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 at the first planned destination. Many of these delays that plague manned aircraft are simply not an issue with the proposed small UAS operations over private or controlled access property, because there is virtually no “en route” portion of the flight, and any problems at the point of landing are extremely unlikely to cause delays, since a UA can always land just a few feet away if the intended point of landing becomes unusable. Given the relatively short operating time for these small UAS, requiring a full 30 minutes of reserve “fuel” (battery power) could take up much, if not all, of the time available for these small UAS operations. Chubb believes that using a smaller reserve for UAS flight planning purposes will be at least as safe as using the reserves required by FAR § 91.151 for manned aircraft. To that end, and consistent with Travelers Exemption Limitation No. 20 and OpenSky Drones Exemption Limitation No. 20, the PIC under the requested exemption will be prohibited from beginning a UAS flight unless (considering wind and forecast weather conditions) there is enough power available for the UA to conduct the intended operation and to operate after that for at least five minutes or, if greater, with the reserve power recommended by the UA manufacturer. See Proposed Limitation 3.2.7. Such a battery reserve is more than sufficient, particularly in light of the FAA’s acceptance of a 5-minute reserve in the Travelers Exemption and the OpenSky Drones Exemption. Chubb believes that these limitations will further ensure that the proposed reserve planning and operational requirements that Chubb is requesting to use under this exemption will provide at least an equivalent level of safety. For these reasons, Chubb requests an exemption from FAR § 91.151 to permit it to plan and conduct UAS operations subject to the reserve power limitation explained above.
FAR § 91.405(a) – Maintenance required. The regulation states, in relevant part: Each owner or operator of an aircraft— (a) 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; (b) ****.HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 Chubb requests an exemption from FAR § 91.405(a) to permit Chubb to conduct the UAS operations proposed in this Petition without having to perform the inspections and discrepancy repairs required by FAR § 91.405(a). In the Astraeus Exemption and the Trimble Exemption, the FAA determined that the proposed UAS operations required exemption from FAR § 91.405(a), and that the achievement of an adequate level of safety required certain conditions and limitations. Chubb has proposed in Section 3 of this Petition several conditions and limitations related to maintenance and inspections which it believes provide a level of safety at least equivalent to that provided by FAR § 91.405(a). For this reason, and consistent with the exemptions granted from this section in the Travelers Exemption and the OpenSky Drones Exemption, Chubb requests an exemption from FAR § 91.405(a) to permit Chubb to conduct UAS operations as proposed in this Petition, subject to the conditions and limitations proposed above, without having to perform the inspections and discrepancy repairs required by FAR § 91.405(a). Chubb does not believe that an exemption from the remaining paragraphs of FAR § 91.405 is required, since Chubb will make appropriate logbook entries in aircraft maintenance records in accordance with paragraph (b), appropriately mark any inoperative instrument or item of equipment for which maintenance has been properly deferred in compliance with paragraph (c), and appropriately placard listed discrepancies that include inoperative instruments or equipment in compliance with paragraph (d).
FAR § 91.407(a)(1) – Operation after maintenance, preventive maintenance, rebuilding or alteration. The regulation states:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless— (1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and (2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been made.HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 . . . . Chubb requests an exemption from FAR § 91.407(a)(1) to permit Chubb to conduct UAS operations as proposed in this Petition without having to have the UAS approved for return to service by a person authorized under FAR § 43.7. In the Astraeus Exemption, the FAA determined that the proposed UAS operations required exemption from FAR § 91.407(a)(1), subject to certain conditions and limitations. Chubb has proposed in this Petition maintenance-related conditions and limitations which it believes provide a level of safety at least equivalent to that provided by FAR § 91.407(a)(1). For this reason, and consistent with the exemptions granted from this section in the Travelers Exemption and the OpenSky Drones Exemption, Chubb requests an exemption from FAR § 91.407(a)(1) to permit Chubb to conduct UAS operations as proposed in this Petition, subject to the proposed conditions and limitations, without having to have the UAS approved for return to service by a person authorized under FAR § 43.7. Chubb does not believe that an exemption from the remaining paragraphs of FAR § 91.407 is required, since Chubb will require that maintenance record entries are made as required in compliance with paragraph (a)(2), and since no persons will be carried following maintenance performed on the UAS, making paragraphs (b) and (c) moot.
FAR § 91.409(a)(1) and (2) – Inspections. The regulation states, in relevant part: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had— (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records.HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 (b)  . Chubb requests an exemption from FAR § 91.409(a)(1) and (2) to permit Chubb to conduct UAS operations as proposed in this Petition without having to obtain the annual inspection and airworthiness certificate inspection required by FAR § 91.409(a)(1) and (2). In the Astraeus Exemption, the FAA determined that the proposed UAS operations required exemption from FAR § 91.409(a)(1) and (2), and that achieving an adequate level of safety required certain conditions and limitations. Chubb has proposed in this Petition maintenance and inspection-related conditions and limitations which it believes provide a level of safety at least equivalent to that provided by FAR § 91.409(a)(1) and (2). For this reason, and consistent with the exemptions granted from this section in the Travelers Exemption and the OpenSky Drones Exemption, Chubb requests an exemption from FAR § 91.409(a)(1) and (2) to permit Chubb to conduct UAS operations as proposed in this Petition, subject to the proposed conditions and limitations, without having to obtain the annual inspection and airworthiness certificate inspection required by FAR § 91.409(a)(1) and (2).
FAR § 91.417(a) and (b) – Maintenance records. The regulation states, in relevant part: (a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information:HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. (c) ** **. Chubb requests an exemption from FAR § 91.417(a) and (b) to permit Chubb to conduct UAS operations as proposed in this Petition without having to keep the records described in FAR § 91.417(a) and (b). The FAA determined in the Astraeus Exemption that the proposed UAS operations required exemption from FAR § 91.417(a) and (b), and that an adequate level of safetyHOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 required certain conditions and limitations. Chubb has proposed in this Petition maintenance, inspection, and records-related conditions and limitations which it believes provide a level of safety at least equivalent to that provided by FAR § 91.417(a) and (b). For this reason, and consistent with the exemptions granted from this section in the Travelers Exemption and the OpenSky Drones Exemption, Chubb requests an exemption from FAR § 91.417(a) and (b) to permit Chubb to conduct UAS operations as proposed in this Petition, subject to the proposed conditions and limitations, without having to keep the records described in FAR § 91.417(a) and (b).

Additional FAR Provisions

. The Petition does not seek exemption from certain regulations based on the reasoning and FAA precedent outlined below in the footnote. 6 However, Chubb also requests that, to the extent that the FAA concludes that an exemption from one or more other provisions of the FAR would be

6 This Petition does not seek exemption from: > FAR Part 21 or 36, based on the reasoning in the Astraeus Exemption, at 14. > FAR § 91.7(b), based on the reasoning in the Trimble Exemption, at 17. > FAR §§ 91.9(b)(2) and 91.203(a) and (b), based on the reasoning in the FAA’s August 8, 2014 Memorandum titled “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station” (“FAA’s August 8, 2014 Memorandum”), the Astraeus Exemption, at 19-20, 22, and the Trimble Exemption, at 17, 20. > FAR §§ 45.23(b) and 91.9(c), based on the reasoning in the Astraeus Exemption, at 14, and the Trimble Exemption, at 14, related to FAR § 45.23(b), and assuming that the markings on the UA used to comply with FAR Part 45, Subpart C requirements are as large as practicable. > FAR §§ 47.3(b)(2) and 47.31(c), based on the reasoning in the FAA’s August 8, 2014 Memorandum, and assuming that all UA are registered in accordance with FAR Part 47. > FAR § 91.103(b)(2), based on the FAA’s reasoning in the Astraeus Exemption, at 20, which concluded that an exemption from the preflight action requirements is not necessary when the grant of an exemption for UAS operations includes conditions that satisfy preflight action requirements. Chubb proposes such conditions in this Petition. > FAR § 91.109, based on the FAA’s reasoning in the Astraeus Exemption, at 20, which concluded that an exemption from the requirement for dual flight controls for flight or simulator training or for flight testing is not necessary when there is no indication that dual flight controls will be used during any flight or simulator training or flight testing.HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 required to permit the UAS operations described in this Petition, the FAA grant an exemption from those FAR provisions as necessary to permit the UAS operations described in this Petition. 7

5.4 Reasons why granting the request would be in the public interest: A grant of the requested exemption for small UAS aerial inspection, assessment, and data collection would be in the public interest for several reasons. First, the ability to use a small UAS as described herein, subject to the conditions and limitations proposed in this Petition, would enable Chubb to test and conduct these aerial data collection operations, thereby directly supporting the development, use, and safety of small UAS for insurance industry use cases. Second, the exemption would allow Chubb to determine how UAS could potentially be used, instead of manned helicopters/aircraft or employees, in high hazard areas to perform inspections of property, plant, and equipment and to assist in mitigating hazards that may result in significant property loss. As the FAA acknowledged in the Total Safety Exemption 8 : “The [Chubb] pilot and crew will be remotely located from the aircraft. The limited weight and restricted sterile area significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event of an incident or accident. The risk to an onboard pilot and crew during an incident or accident is eliminated with the use of a UA for the inspection operation. In addition, utilizing UAS to conduct flare stack inspections will reduce the need for inspection personnel to perform this hazardous [inspection] activity. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. [This small UAS] carries no fuel [it is battery-powered], and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated.”
These small UAS operations would also be much less risky than having employees undertake the inspections directly by climbing on roofs or other structures, traversing hazardous areas, or flying manned helicopters/aircraft. To this point, the FAA has concluded – in the context of bridge inspections (which are “typically conducted by personnel who physically inspect the bridge”) – that an appropriately tailored and limited exemption for small UAS operations would be in the public

7 Chubb would be happy to provide follow-on documentation providing the rationale underlying any such additional exemptions. 8 Exemption No. 11156 (January 29, 2015; Docket FAA-2014-0610) at 11-12.HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 interest because “utilizing UAS to conduct bridge inspections will reduce the need for inspection personnel to perform this hazardous activity as well as traffic hazards related to blocking lanes on the roadway.” Asymmetric Technologies Exemption, 9 at 8-9. The FAA has reached similar conclusions in the context of tower/structure inspections and flare stack inspections. “Tower and structure inspections are hazardous and present unique difficulties for persons conducting inspections and maintenance of this infrastructure. The inspections are normally conducted utilizing personnel to physically inspect the tower and structure. Manned helicopters may also be used to transport inspection personnel to the top of the tower so that a physical inspection may be conducted. The petitioner plans to utilize a UAS to provide high definition aerial photography to minimize the need for inspectors to personally climb such structures. Manned helicopters assisting in tower and structure inspections can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. . . . [U]tilizing UAS to conduct tower inspections will reduce the need for inspection personnel to perform this hazardous activity. . . .” LowCountryRC Exemption, 10 at 2-3. Third, use of small UAS under this exemption to assist Chubb’s risk mitigation efforts would also greatly benefit the public by enhancing its ability to assess risks and undertake preventative actions. Any avoidance of fire or other losses reduces the direct exposure of emergency services personnel and policy holders to hazardous conditions. Fourth, Chubb’s proposed small UAS operations would enable Chubb to examine how UAS could be used to assess damage to property caused by natural disasters and other catastrophes and develop quicker responses to those affected. This could avoid disruption of other emergency responses, reduce the number of emergency service personnel at risk, and expedite assessments and payments on resulting losses, thereby minimizing economic disruption and expediting recovery efforts. In sum, the small UAS aerial inspection, risk mitigation, damage assessment, and other data collection operations proposed in this Petition would be far less risky than if conducted with larger,

9 Exemption No. 11171 (February 10, 2015; Docket FAA-2014-0816) (“Asymmetric Technologies Exemption”). 10 Exemption No. 11184 (February 23, 2015; Docket FAA-2014-0803) (“LowCountryRC Exemption”).HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 faster, heavier, combustible fuel-powered manned aircraft, or by on-site physical assessments by Chubb personnel.
5.5 Reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which exemption is sought: Throughout this Petition, Chubb has discussed many reasons why granting an exemption from each section of the FAR from which relief is sought would result in UAS operations that provide a level of safety equal to, or greater than, that provided by the rule from which exemption is sought. Moreover, the many conditions and limitations proposed in this Petition, coupled with the operational protocols for these small UAS, also would ensure at least an equivalent level of safety, as the FAA concluded in the LowCountryRC Exemption, the Total Safety Exemption, the Travelers Exemption, the OpenSky Drones Exemption, and the Trimble Exemption, among others. In general, the risks of any small UAS operation proposed in this Petition interfering with a manned aircraft would be minimized by numerous factors, including but not limited to:  the low altitude at which the UAS would operate;  the locations at which the UAS would operate (e.g., remote areas; private or controlled access property; away from airports);
 the small size, light weight, and relatively slow speed of these small UAS;  the restriction on UAS operations to VMC and daytime conditions; and  the requirement for the UA to be operated within VLOS of the PIC and VO at all times. Importantly, these small UAS have several other safety-related protocols. For example, depending on the specific model, these UAS have several other safety-related protocols including a configuration control program (with configurable “electric fences”), loiter and return home capabilities, Lost Link procedures (return to launch), back up communications, a redundant “flight ending” system, and “follow me” functionality through the Droid Planner App. The risks to persons or property on the ground would be substantially mitigated – if not eliminated – by these same factors, as well as the 500-foot set-off from non-participating persons, vehicles, and structures absent additional safeguards. Per the conditions and limitations proposedHOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 in this Petition, (i) the PIC will suspend/abort the UAS operation and UA flight in the event of unpredicted obstacles or emergencies in accordance with the Manuals; and (ii) Chubb will coordinate extensively, as warranted, with the FAA, with local airports, and with property owners to ensure that all UAS operations under the exemption are at least as safe as would be manned aircraft operations used for similar purposes. The conditions and limitations proposed in this Petition (which have been found by the FAA to be acceptable for other summary grant exemptions) and the operational safety features of these small UAS provide substantial protection against interference with manned aircraft operations or with the safety of persons or property on the ground. For these reasons, granting an exemption from each section of the FAR from which relief is sought would not adversely affect safety, and would provide a level of safety at least equal to, or greater than, that provided by the rule from which exemption is sought.

5.6 Summary that can be published in Federal Register, including the rule from which exemption is sought, and a brief description of the nature of the exemption sought: Chubb proposes that the FAA use the following as the summary: Docket No.: FAA-2015-______
Petitioner: Chubb & Son, a division of Federal Insurance Company Sections of 14 CFR: 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.315(a), (c)(2), and (c)(3), 91.7(a), 91.119(c) and (d)(1), 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b). Description of Relief Sought: Petitioner seeks an exemption to conduct small UAS operations for aerial inspections, risk mitigation, damage assessments, and other data collection related to the insurance industry.

5.7 Additional information that supports request: Chubb is prepared to provide additional information that the FAA might find helpful, or to answer questions in response to any FAA requests.HOGAN LOVELLS US LLP

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\\DC - 057212/001058 - 6654231 v3 EXHIBIT 1

List of Previously Approved Small UAS from the Measure Exemption10 Attachment 1
1. 2AgEagle 2. 3D Robotics Aero

- M 3. 3D Robotics Iris 4. 3D Robotics Iris+ 5. 3D Robotics X8 6. 3DRobotics Fixed Wing 7. 3DRobotics Multirotor 8. 3DRobotics Quadrotor 9. 3DR Solo 10. 3DR Spektre 11. 3DRobotics Spektre Industrial Multi

- Rotor Aerial Vehicle 12. 3D Robotics Solo 13. 3DRobotics X8+ 14. 3D Robotics X8

- M 15. 3D Robotics Y6 16. Aerial Mob Heavy Lifter 17. Aerial Mob Light Lifter 18. Aerial Remote Mineral Detection System (ARMDS) 19. Aerialtronics Zenith with intergrated Airware system 20. Aerialtronics Altura Zenith ATX8 21. Aerigon 22. Aerobo 23. AeroCine Kopterworx Hammer X12 24. Aeromao AeroMapper 300 2 5. Aeromao Talon 26. Aeromao Aeromapper 300 27. Aeromao Aeromapper EV

- 2 28. AeroVironment Shrike 29. AeroVironment Puma 30. Aeronavics X4 Titanium 31. Aeryon Sky Ranger 32. Aervonics Sky Jib frame with a DJI A2 flight system 33. Aero

- M 34. Aeryon S cout 35. Aeryon SkyRanger 36. AgEagle 37. AgEagle Robotic 38. AgScout 39. AgScout Mini 40. Agribotix Hornet Drone 41. Agribotix Enduro Quad 42. AgriView VK Ranger EX11

43. Aibot 44. Aibotix X

- 6 45. Air Rover AR

- 3000 46. AirCover QR

- 425s 47. AirRobot AR 180 48. AirRobot AR 100 49. AirRobot AR200 50. Air

- X 51. Align M690 52. Altavian Nova 53. Altavian Nova F6500 54. Altavian Nova R8400 55. Altus X

- 4 56. Altus X

- 8 57. American Drones, LLC Eagle 58. Apprentice 59. Arch Aerial OCTO multi

- rotor UAS 60. Arris h exacoper 61. AR

- 960 Hex Rotor 62. AR

- 540 Quad Rotor 63. ARF

- MikroKopter OktoXL 64. ARF

- MikroKopter OktoXL + 65. ArrowLite 66. AscTec Falcon 67. AscTec Falcon 8 68. Astraeus Aerial Cinema System V.3CS 69. Atlantic RC Aircraft LC04 70. Auburn Trimble UX5 71. Auburn War Eagle 72. Auburn EasyStar 73. Auburn 74. AV44 75. Bixler 3DR Plane 76. Blade 350QX 77. Bixler 2 78. Boomerang Carbon Fiber Frame (The Identified System) 79. Bormatec Maja UAV 80. BOSH Technologies Super Swiper 81. Bumblebee

- S 82. C

- Astral Bramor gEO 83. CarbonCore Octocopter 1000 84. Carbon Core Cortex Quadcopter 85. CCO w/Wkm M 86. Chameleon Pro12

87. CinesStar 88. Cinestar 6 89. Cinestar X8 90. Cinestar 8 91. Cinestar 8 HL 92. Cinestar 8 Okto XL 93. Coaxial Quad Multirotor VAO1

- V1 94. Co axial Quad Multirotor VAO2

- V2 95. CopelandRED LLC Delta Wing Aircraft 96. CyberQuad Maxi 97. DJI Flame Wheel F450 98. DJI Flame Wheel F550 99. DAx8 100. DJI Inspire 101. DJI Inspire 1 102. DJI Inspire 2 103. DJI M P330z 104. DJI Phantom 105. DJI Phantom 1 106. DJI Phantom 2 107. DJI Phantom 2+ 108. DJI Phantom 2 Vision 109. DJI Phantom 2 Vision+ 110. DJI Phantom Vision + 111. DJI Phantom 3 112. DJI Phantom FC40 113. DJI Spreading Wings S900 114. DJI Spreading Wings S1000 115. DJI Spreading Wings S10 00+ 116. DJI S800 117. DJI S800 EVO 118. DJI T600 119. Draganflyer Guardian 120. Draganflyer X4ES 121. Draganflyer X4P 122. Draganflyer X6 123. DT

- 18 124. DYS D800

- X8 125. Eagle VTOL 126. Eagle V2 127. E

- Flite Apprentice 128. Event 38 E384 129. F

- 450 130. Falcon VTOL13

131. Fire Fly 6 132. First Aerial Responder UAV 133. Flame Wheel G4 7.8 Skycrane 134. Flying

- Cam 3.0 SARAH 135. Foxtech Kraken 130 V2 136. FreeFly Systems ALTA RTF 137. FreeFly Systems Octocopter Airframe (Legacy) 138. G4 139. G4 models 140. GeoStar 141. GerMAP G220 142. GerMAP G180 143. goFarm GF

- 1 144. Gryphon Dynamics X8 145. GT80X 146. Harris 18 HL 147. HEFF 148. Helicopters West DJI Inspire 149. Helicopters West SkyJib 8 150. Helios 960 151. Hawkeye Mk

- III 152. HexaCrafter HC

- 1100 8 5. 153. HexaCrafter HO

- 1250 154. HH Blade 350QX2 AP 155. Hobbyking “Bixler” Fixed Wing Trainer 156. HoneyComb AgDrone 157. Horizon Hobby Blade 350 Qx2 quadcopter 158. Hoverfly LiveSky, BigSky 60 and H

- Frame 159. Hubsan X4 micro drone 160. HVP 14301 Multi Rotor 161. Identified System 162. IMT Global xFold Cinema 163. Indago 164. InovalDrone:Inova One 165. InstantEye Mk

- 2 166. InstantEye Mk

- 2 Gen2 167. Intuitive Aerial Aeragon 168. K130 Octocopter 169. KongCopter X8 170. Kopterworx Hammer X12 171. Latitude HQ

- 4 Hybrid Multirotor 172. LB700 173. Leading Edge Precision Vision 10 174. Leptron Avenger14

175. Lewis Realty Associates Hexacopter 650 176. Liberty 1 177. Lockheed Martin Desert Hawk III 178. Lockheed Martin Indago 179. Matrix quad copter 180. MaxFligh t 181. MD4

- 200 182. MD4

- 1000 183. Mikrokopter 2.5 184. MLB Company Super Bat 185. MU

- 1H 186. Multirotor G4 7.8 Skycrane 187. Nighthawk 188. Nighthawk VTOL 189. OktoXL 6S12 190. PAG X4 191. Parksone Radian RTF 192. Parrot Bebop drone 193. Parrot PF 725100 Bebop Drone 14MP 194. Parrot Skycontroller 195. Patriot X4 196. Patriot X8 197. Finwing Penguin V2 198. Birdseyeview FireFly 6 199. Phoenix 200. Phoenix VTOL 201. Phoenix 60 202. Phoenix 60LE 203. Pixhawk 204. Precision Drone Pacesetter 2 05. PrecisionHawk 206. PrecisionHawk Hawkeye Mk

- III 207. PrecisionHawk Lancaster 208. Precision Lancaster MK3 209. Prioria Hex 210. Prioria’s Maveric 211. Pulse Aerospace, PA 01 Vapor 212. Pulse Aerospace Pulse Vapor 35 213. Pulse Vapor 214. Puma AE DDL 215. PV 14817 Multi Rotor 216. PV HL1 217. PV HL2 218. Q115

219. Quadcopter LLC MikroKopter 220. Quiet UAV 221. Qube 222. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo Heavy Lift Prof. Multi Rotor 223. Frame Ronin Edition Microdrones:M D4

- 1000 224. RCTimer Hexacopter 225. RDASS 226. REHawk 500 227. REHawk 680 228. RF

- 70 229. Riegl RiCopter 230. RITEWING Z3 Spade 47” 231. Ritewing Drake 60” 232. RITEWING Z3 Spade 70” 233. RITEWING Z4 Spade 52” 234. RMAX 235. Roboflight 236. Rotomotion SR

- 15 237. RV Jet 238. Scout X4 239. SD02 240. Seahawk 1.2 241. SelectTech Geospacial’s EH

- 4 242. SenseFly eBee 243. SenseFly eBee RTK 244. SenseFly eXom 245. Sensurion Magpie MP

- 1 246. Service

- Drone Recon One 247. Service

- Drone Blackbird 248. SH 900 249. ShadowHawk 250. Shrike 251. Sirius 252. SkyCatch 253. SkyJib 8 v.2 Heavy Lifter 254. SkyPhilly MI 255. Skywalker Aero 256. Skywalker Flying Wing X8 257. SnapRoll Media SUAS 258. Solutions Phoenix 30 259. SteadiDrone 260. Steadidrone Quad 261. Steadydro ne QU4D16

262. Steadidrone Mavik 263. SuperX/P2 Multirotor 264. Swift Radioplanes Lynx 265. Tali 500 266. Talon 120LE 267. Tarot FY690S Hexacopter 268. Tarot quadcopter 269. Tarot 680pro 270. Tarot 690 271. Tarot 900 272. Tarot 960 273. Tarot T

- 15 274. Tarot T15 C/F Folding Octocopter 275. Tarot T18 UAV 276. Tarot T690 277. Tarot T810 278. Tarot T960 279. Tarsier Systems MoAC 280. Tayzu Robotics Titan X8 281. TBS Discovery Pro 282. Team Black Sheep Discovery Pro Tarot T15 283. T

- Rex 700E F3C 284. TREX 800E DFC PRO 285. Trimble UX5 286. Trimble UX5 hp 287. Trimble ZX5 288. Turningy Talon 500 289. TUP X8

- 800 290. Turbo Ace CINEWING 6 291. TurboAce Matrix

- G quadcopter 292. Turbo Ace matrix

- E 293. Turbo Ace MATRIX

- 1 294. UAV Solutions Phoenix 60 295. Unive rseye Penguin 296. Unmanned Flying Rolling Orb “UFRO” 297. US2 GreenHawk 298. UtiliCopter ITX8 299. VA03

- v1 300. VA04

- v1 301. VA07

- v1 302. Viking UAS Multicopter (VTOL) 303. Viking UAS FF

- X4/X8 304. VK

- Patriot X4/X8 305. Viking UAS Patriot X4/X8 Multirotor17

306. Viking UAS X6 Model 800 307. Viking UAS Viking ONE 308. VK

- 450 309. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX 310. Viking VK

- FF

- X4 311. VK

- Ranger EX

- SAR Fixed Wing UAS 312. Volantex Raptor Tarot T

- 18 313. Volt Aerial Robo tics Octane 314. Vulcan frame controlled by a DJI A2 flight controller 315. Vulcan Mantis 316. Vulcan Octocopter 317. Vulcan Raven 318. Vulcan UAV 319. Walkera TALI H500 320. Walkera Scout X4 321. Wookong DJI 5800 322. xCel Drones XD550CDR 323. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter and x12 Copter 324. X8

- M