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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 13th 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, 2015
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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 -
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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 limitations
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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.
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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”.
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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 a
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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 must

cease 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.]
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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. [Travelers
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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 of

training 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, and

the 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.]
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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 Documents2 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.]
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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 –
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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 13th 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.
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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; and
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(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 as
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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 medical
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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.4These 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.
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(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”.
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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 the
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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) At or above 18,000 feet MSL, to 29.92′′ Hg.

(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).
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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 and
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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) ****.
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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.
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. . . .

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.
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(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:
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(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 safety
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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.
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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 Exemption8:

“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.
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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,9at 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”).
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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 proposed
HOGAN LOVELLS US LLP

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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.

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EXHIBIT 1

List of Previously Approved Small UAS from the Measure Exemption
10

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 25. 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 Scout

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 EX
11

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 hexacoper

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 Pro
12

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. Coaxial 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 S1000+

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 VTOL
13

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 85.

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 Avenger
14

175. Lewis Realty Associates Hexacopter 650

176. Liberty 1

177. Lockheed Martin Desert Hawk III

178. Lockheed Martin Indago 

179. Matrix quad copter

180. MaxFlight

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 205. 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. Q1 
15

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:MD4-1000

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. Steadydrone QU4D 
16

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. Universeye 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 Multirotor
17

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 Robotics 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