### State Farm Insurance Campanies®

JACK WEEKES, CPCU®, CLU®, ChFc® OPERATIONS VICE PRESIDENT

October 15,2014 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, D.C. 20590 ONE STATE FARM PLAZA BLOOMINGTON, ILLINOIS 61710·0001

Re: ExemptionRequest Pursuantto Section 333 ofthe FMRA and Part 11 ofthe Federal AviationRegulations, Seeking Exemption from 14 C.F.R. Part 21 Subpart H; 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.27; 14 C.F.R. §§ 61.1 f3(a) and (b); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.405(a); 14 CF.R. § 91.407(a)(l); 14C.F.R. §§ 91.409(a)O) and (2); 14 C.F.R. §§ 91.417(a) and (b).

Dear Sir orMadam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14

·C;F.R. Part 11, State Farm Mutual Automobile Insurance Company ("Petitioner" or "State Farm")**h~reby** applies for an exemptionfrom the listed Federal Aviation Regulations ("FARs") and any othernecessaryto allow its operation ofsmall UnmannedAircraft Systems ("UAS") to conductroofinspections, so long as such operations are conducted within andunder the conditions outlinedherein. The requested exemption wouldpermitthe operation ofthe UAS to obtainup-close images ofState Farmpolicyholders' roofs and perform an in-depth analysis of the images to determine the nature and extent ofdamage to the roofsurface withoutplacing claim adjusters atrisk. The State Farm claimrepresentative will be able to share promptly with the customerthe report and inspection images and reduce claimpaymenttime. State Farmwas founded in 1922 withthe vision ofoperating fairly and doing the right thing for its customers. In advancingthis vision and the goal ofprovidingthe best servicepossible, State Farm has committed to supporting innovation that improvesthe lives and safety ofits policyholders and the general public. This commitment in championing innovationto improve lives and safety has helped State Farm become the nation's leading insurer ofhomes and automobiles, in additionto being an industry leaderin other areas ofinsurance and financial services. Currently, State Farm has over 65,000 employees and 18,000 agents providing remarkable service intaking care ofover 27 millionhome policies (1 in 5 U.S. houses) and 44 million auto policies. Whetherproviding assistance after a majornatural disaster or looking for ways to help people manage everydayrisks, State Farm is there. By exploring the ability to use UAS, State Farmhas the opportunityto further champion innovationin orderto benefitthe wellbeing ofits policyholders andthe general public. 1

HOME OFFICES: BLOOMINGTON, ILLINOIS 61710·0001

### I. REQUEST FOREXEMPTIONTO USE UAS FORROOFINSPECTIONS A. Overview ofRequest to Use UAS for RoofInspections State Farm proposes to conduct roofinspections using small UAS including the Aerialtronics Altura Zenith ATX8. As described more fully below, the requested exemption would permitthe operation ofsmall UAS under controlled conditions in airspace that is 1) limited, 2) predetermined, and 3) controlled as to access. Operations will be limited to the customer's property and always occur within the line ofsight ofthe UAS operator. The property owner will be notified in advance ofthe date and time for inspection. The customer's privacy and their neighbors' privacy will be fully protected. State Farm's use ofUAS for roofinspections does not create a hazard to users ofthe national airspace orthe public orpose a threatto national security. In support ofthis exemptionrequest, State Farm is submitting an Operations Manual and Training Syllabus under separate cover and with a request for confidential treatment. 1 Grant ofthis request is warranted as use ofUAS will improve safety for State Farm's claim representatives. Currently, claim representatives need to physically climb onto a policyholder's roofusing ladders for inspection. Inspecting roofs is dangerous as evidencedby annual industrywide worker compensation claims. Each year, claimhandlers throughout the industry are injured in falls while performing the task. Byutilizing UAS, the claim handlers will be able to reduce their exposure to hazards and obtain accurate assessments ofthe roofwhile remaining safely onthe ground. B. Public Interest Benefits ofPermitting Use ofUAS for Rooflnspections Grant ofState Farm's request to use UAS for roofinspections is inthe public interest. While State Farm takes everyprecautionto keep its claim handlers safe, roofinspection conductedby humanbeings carries with it certain risks. Currently, State Farm claim handlers need to physically climb onto the roofusing ladders and other safety gearto conduct inspections. Sometimes, a two story/steep team is used, requiring two claimhandlers and special safety harnesses. The dangers ofinspecting any roofinclude losing one's footing, having a ladder slip, and being blown offa rooffrom wind shear. A recent news article noted that fatalities rates among roofers are the highest inthe constructiontrades. 2 In additionto safety concerns, inspecting a roofbyphysically climbing on it has the potential to damage the roof. Using UAS for roofinspections avoids all ofthese risks. Byutilizing UAS, State Farm's claimhandlers will be able to reduce their exposure to hazards and rapidly obtain accurate assessments ofthe roof while remaining safety onthe ground. Fasterroofdamage assessments will result in faster claims processing and repairs for affected policy holders.

Petitioner submits its Operations Manual and Training Syllabus as Confidential documents under 14 C.F.R. § l l .35(b) as they contain proprietary information that Petitioner has not and will not share with others. The documents contain operating conditions and procedures that are not available to the public and are protected from release underthe Freedom oflnformation Act, 5 U.S.C. § 552. 2 Alexandra Berzon and Kris Hudson, Fight Erupts OverProtecting Rooftop Workers, Wall Street Journal, Sept. 28, 2014 available at http://online.wsj.com/articles/builders-osha-square-off-on-rooftop-safety-14l l947843. 2In addition, as described in more detail below, operation will not create a hazard to aviation or the public. Flights will be conducted under 200 feet AGL-avoidinginterference with users of the national airspace system. Operation will also not create a hazard to the public as State Farm will only operate the UAS only overprivate property withthe owner's consent. In addition, the UAS will have a geo-fence around the owner's property line to preventthe UAS from flying where it should not be. Finally, operation will notpose a threat to national security. The UAS poses no credible threat to national security due to its size, speed, ofoperation, location of operation, lack ofexplosive materials or flammablejetfuels, and inability to carry a substantial external load. 

### II. THE FAA'S LEGAL AUTHORITY TO GRANT THIS EXEMPTION REQUEST This exemptionrequest will help the FAA to fulfill Congress' goal inpassing Section 333 ofthe FMRA. Section 333 directs the Secretary ofTransportation to consider whether certain UAS may operate safely inthe national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe FMRA. The Secretary is requiredto determine which types of UAS do not create a hazard to users ofthe NAS or the public orpose a threatto national security in light ofthe UAS's size, weight, speed, and operational capability and whether operationwill occurnear airports orpopulated areas and within the visual line ofsight ofthe operator.3 The FMRA illustrates Congress' intentto have the FAA issue exemptions and allow civil UAS, so long as they operate withinthe necessary safety parameters. In addition, the Federal Aviation Act expressly grants the FAAthe authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under§ 40101 ofthe Act, that includes UAS, from the requirementthat all civil aircraft must have a current airworthiness certificate. The Administratormay grant an exemption from a requirement ofa regulationprescribed under§§ 44701(a) or (b) or in§§ 44702-44716 ofthe Act ifthe Administrator finds the exemption in the public interest.4 

### III. APPLICATION INFORMATION The name and address ofthe applicant is: Todd Binion Innovation Manager State Farm Mutual Automobile Insurance Company 3 State Farm Plaza South Bloomington, IL 61791 todd.binion.hkoO@statefarm.com 309-735-8633 Regulations from whichthe exemption is requested:

FAA Modernization and Reform Act of2012, Pub. L. No. 112-95, 126 Stat. 75-76 (codified as a Note to 49 

### u.s.c. §40101). 4 49 U.S.C. § 44701(t). See also 49 U.S.C. § 4471J(a);49 U.S.C. § 44704; 14 C.F.R. § 91.203(a)(l). 314 C.F.R. Part 21 Subpart H; 14 C.F.R. 

### §45.23(b); 14 C.F.R. 

### §45.27; 14 C.F.R. 

### §§ 61.113(a) and (b); 14 C.F.R. 

### §91.119(c); 14 C.F.R. 

### § 91.121; 14 C.F.R. 

### § 91.151(a); 14 C.F.R. 

### § 91.405(a); 14 C.F.R. 

### §91.407(a)(l); 14 C.F.R. 

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

### §§ 91.417(a) and (b). 

### IV. THE AIRCRAFT State Farm specifically proposes to conduct UAS operations using small UAS including the Aerialtronics AlturaZenith ATX8. The Altura Zenith ATX8 is a multi-rotor aircraft built with a monocoque carbon airframe. The Zenith has a 5.6 kg take-offweight and a maximumpayload of2.9 kg. The Zenith carries a 16.600 mAh battery, which facilitates up to 45 minutes offlighttime with total payloads ofup to 6.4 lbs. for the ATX8. Itcanbe flown with either a radio or tablet and carries a variety ofpayloads. The Zenith has a maximum cruise speed of20 mis. It features auto-takeoffand landing, auto go home and landing, GPS waypoint navigation, direction lock, and GIS mapping. Specifications include:

• Length x Width: 23.6" x 23.6"

• Height : 13.7"

- 21.6" tall

• Weight : 7.7 lbs., withoutpayload (less than 15 lbs. withpayload) State Farm agrees that any UAS it uses for roofinspections will include, at minimum: geofencing at a maximum ceiling of200' AGL, flight programming capabilities, a flight termination link available to the operator to prevent a "fly away," and safe abort procedures. Ifthe UAS loses communications or its GPS signal, the UAS will returnto a pre-determined location and land orbe recovered in accordance with the Operations Manual. The UAS will have markings identifying the serial number and identification (N-number) markings as large as practicable. Further, State Farm'sUAS operation will comply with all manufacturer Safety Bulletins. Any UAS to be used will weigh less than 55 pounds and would be specifically authorized by the FAA. UAS operations will occur only during daytime. State Farm will incorporate Airware's flight control systems across the range ofourvehicles. Airware's systems are designed to enable safe and reliable commercial UAS applications and have been built from the ground up by leading engineers from the aerospace industry utilizing industry bestpractices and decades ofexperience. The system has been developed using modelbased-design for the core control algorithms and robust CIC++ atthe application and OS level. The autopilot system is built ontop ofa real-time embedded operating system which has been certified to D0-178B. Airware uses rigorous design, development, review, and testing processes, using strict compiler checking, formal verification methods, MISRA compliance 4verification, unittesting, and integrationtesting with test coverage verification. In addition to aerospace quality hardware and software, safety features include geofencing for ensuring vehicles stay within pre-defined areas, a full suite ofcontingencymanagement functions, user and flight planmanagement and approval functionality, amongst others. 

### V. OPERATING PARAMETERS Petitionerproposes that the exemptionrequested herein apply to civil aircraft that have the characteristics andthat operate with the limitations listed herein. These limitations provide for at least an equivalent'or evenhigher level ofsafety to operations underthe currentregulatory structure because the proposed operations represent a safety enhancementto the already safe operations conducted with conventional aircraft. Further details about the aircraft and operating procedures are available inthe Operations Manual and Training Syllabus. The limitations and conditions to which State Farm agrees to be bound when conducting R&D for commercial operations under anFAA issued exemption include: A. UAS Pilot and Observer 1. UAS operations will be conducted by, at minimum, pilots holding a privatepilot certificate and at least a currentthird-class medical certificate. 2. All UAS operations mustutilize a visual observer ("VO"). 3. Thepilot-in-command ("PIC") and VO mustbe able to communicate verbally at all times. 4. The PIC will be wearing a safety vestthat identifies him orher as the pilot. 5. Priorto operations, the pilotmusthave accumulated and logged a minimum of200 flight cycles, ormore as required bythe FAA, and 25 hours oftotal time as a UAS rotorcraftpilot. The pilot must also have accumulated and logged priorto operations at leasttenhours as a UAS pilot with a similarUAS type (single blade ormulti-rotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement.

a. Training, proficiency, and experience-building flights can also be conductedunderthe FAA's grant ofexemptionto accomplishthe required flight cycles and flight time. b. Duringtraining, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the pilot must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

56. State Farm will rely onthe UAS vendor(s) to provide a pilot qualification program, including a training program incorporating proper aircraft operations and safety standards.

a. Prior to any flight operations authorized by this grant of exemption, the PIC and VO must have successfully completed the vendortraining program and qualification process and the State Farmtraining process, as outlined inthe Operations Manual and Training Syllabus. b. The qualification test will be developed and implementedby a qualified person designated at the sole discretion ofState Farm.

c. A record ofcompletion ofthis qualification process mustbe documented and made available to the Administrator uponrequest. 7. State Farm will require all pilots conducting UAS operations to provide proofofpilot and third-class medical certification as well as proofof completion ofthe applicable vendor'strainingprogram. B. Operational Parameters 1. Aircraft will not carry pilots orpassengers, and aircraft will not carry explosive materials or flammable liquid fuels. 2. UAS mustbe operated within visual line ofsight ofthe pilot at all times. 3. UAS may not be flown at ground speeds exceeding 50 knots. 4. Flights will be operated at an altitude ofno more than 200 feet above ground level. 5. Each UAS operation will be completed within 60 minutes flight time or with 25% battery powerremaining, whichever occurs first. At 30% battery the UAS will enter a return and land sequence; at 20% it will land immediately. 6. UAS will notbe operated over any person (other thanparticipating State Farmpersonnel) at an altitude that is hazardous to persons orproperty on the surface in the event ofa UAS failure or emergency.

a. Distance from participatingpersons will be specified in the Operations Manual. b. Operations will be conducted as far as practicable from nonparticipating persons. 7. The UAS will abortthe flight in the event ofunpredicted obstacles or 6emergencies in accordance with the Operations Manual. 8. Priorto operations, a flight demonstration, administered by an operatorapproved and qualifiedpilot will be successfully completed and documented. Documentation will be made available for review by Administrator upon request. 9. The operatormust obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver orAuthorization (COA) prior to conducting any operations under this grant ofexemption.

a. This COA will also require the operator to request a Notice to Airmen (NOTAM) not more than 72 hours in advance, butnot less than 48 hours priorto the operation. 10. Operations will be limited to the property ofconsenting State Farm policyholders. 11. Petitioner will display signage notifying the public ofUAS operations before beginning operations. Signs will be approximately 18" x 24" in size and will be placed in locations that will be visible from adjacent roadways at least 5 minutes priorto UAS operations. An area will be marked offas the UAS "landing zone." Petitioners will also display signage notifying the public thatUAS operation is inprogress once operationsbegin. 12. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAS will comply with the FCC or other appropriate government oversight agency requirements. 13. The UAS pilot will establish a working relationship with a representative at the local Flight Standards District Office ("FSDO") with which to periodicallyreview safety procedures and other operations to further enhance safety. Undernormal circumstances, the operator will submit a written Plan ofActivities to the local FSDO at least48 hours priorto conducting operations. In an emergency situation, the operator will submit a written Plan ofActivities 24 hours priorto conducting operations, unless sooner authorized by the FSDO. The Plan ofActivities will include:

a. Dates and times for all flights; b. Name and phone number ofthe operator for the UAS and for the personresponsible for on-site operations;

c. Make, model, and serial orN-number ofUAS; d. Name and certificate number ofpilot(s); 7

### e. Signature ofexemption holder orrepresentative; f. Description offlight activity, including maps/diagrams ofarea over which operations are occurring and essential altitudes. 14. The documents required under 14 C.F.R. § 91.9 must be available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 15. The UAS mustremain clear and yield the right ofway to all othermanned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 16. State Farm will ensure safety to first responder aircraft and helicopter traffic. Upon notification from manned aircraft controllers orthrough visual identification ofmanned aircraft, StateFarm will immediately suspend the UAS flight until the airspace is cleared. 17. UAS operations may not be conducted during night, as defined in 14 C.F.R. 

### § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 18. The UAS may notbe operated by the PIC from any moving device or vehicle. 19. The UAS may 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. 20. The UAS may not operate in Class B, C, orD airspace without approval from the FAA. The UAS may not operate within 5 nautical miles ofthe geographic center ofa non-towered airport as denoted on a current FAApublished aeronautical chartunless an agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the Operator's COA. The letter of agreement with the airport management should be made available to the Administrator upon request. 21. Altitude information will be provided to the UAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. The UAS may have a GPS altitude readout. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the PIC. 22. Any incident, accident, orflight operation that transgresses the lateral or 8vertical boundaries ofthe operational area as defined bythe applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents mustbe reported to the National Transportation Safety Board (NTSB) perinstructions contained onthe NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, ortransgression is reviewed by AFS-80 and authorization to resume operations is provided. C. Operations Manual 1. The Operator must follow the procedures as outlined in its Operations Manual. 2. The Operations Manual mustbe maintained and made available to the Administrator upon request. D. Pre-Flight Inspections and Maintenance 1. Priorto each flight, pilot will inspect UAS to ensure it is incondition for safe flight. Ifthe inspectionreveals a discrepancy, aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 2. All maintenance and alterations will be properly documented inthe aircraft records. 3. AnyUAS that undergoes maintenance or alterations that affect the UAS operation orflight characteristics will undergo a functional flight test in accordance with the Operations Manual. 4. Petitionerwill institute a rigorous maintenance program to ensure airworthiness ofUAS. Operator will follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements.

a. Whenunavailable, requirements must be established inthe Operations Manual, including for the following:

1. Actuators I Servos;

11. Transmission (single rotor);

m. Powerplant (motors); 1v. Propellers;

v. Electronic speed controller;

9v1. Batteries; VIL Mechanical dynamic components (single rotor); v111. Remote command and control; Ix. Ground control station (ifused); and

x. Any other components as determined bythe operator. 5. Operator will develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul componentparts, and the total time in service ofthe UAS. These procedures will be added to the Operations Manual. 6. Operator will develop UAS technician qualification criteria. These criteria will be added to the Operations Manual. 

### VI. SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN EXEMPTION State Farm requests exemption from the following Federal Aviation Regulations ("FARs") to the extent necessary to enablethe requested UAS operations for the reasons detailed below. A. 14 C.F.R. Part 21 Subpart H Airworthiness Certificates Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates. Given the size and limited operating area associated with the aircraftto be utilized, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act5 and Section 333 ofthe FMRA both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports andpopulated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate, in the proposed environments and under the conditionsproposed will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) operating with an airworthiness certificate withouttherestrictions and conditions proposed. The Zenith UAS to be operated hereunder is less than 15 pounds including payload, carries neither a pilot norpassenger, carries no explosive materials or flammable liquid fuels, and will operate exclusively within the parameters stated inthe Operations Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitoredbyboththe operator and under the requirements and incompliance with local public safetyrequirements, to provide security for the area ofoperation. The FAA will have advance notice ofall operations via notices to airmen (NOTAMS). Finally, these UAS, as a result oftheir size, weight, speed,

5 49 

### u.s.c. §4470J(t). 10operational capability, and operation within visual line ofsight do not create a hazard to users of the national airspace system or the public orpose a threat to national security. B. 14 C.F.R. §45.23(b) Display ofmarks; general; 14 C.F.R. §45.27 Location of marks; non-fixed wing aircraft Section 45.23(b) requires markings in letters not less than 2 inches nor more than 6 inches high the words such as "limited, "restricted," and "experimental," as applicable. Section45.27 requires that each operator ofa rotorcraft must display onthat rotorcraft horizontally on both surfaces ofthe cabin, fuselage, boom, ortail the marks required by§ 45.23. Given the size ofthe UAS, two-inch lettering will not be feasible. The UAS will also have no entrance to the cabin, cockpit, or pilot station on which the applicable words canbe placed. An equivalent level ofsafety will be achieved byhaving any required words displayed onthe aircraft, as applicable, in letters oflegible size, in a location where the pilot, observer, and others working with the UAS will see the identification. The FAAhas issued exemptions to § 45.23 in Exemptions Nos. 10700, 8738, 10167, 10167A, and 11062. The FAA issued an exemption to 45.27 in Exemption No. 8496B. C. 14 C.F.R. §§ 61.113(a) and (b) Private pilotprivileges and limitations Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level of safety ofcurrent operations byrequiring the PIC operating the aircraft to have a private pilot's license rather than a commercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Operations Manual. The level ofsafety providedbythe requirements included in the Operations Manual exceeds thatprovidedby a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe UAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe UAS as requested with a private pilot as the PIC exceeds the present level ofsafety achieved by 14 C.F.R. §§ 61.113 (a) and (b). The FAA issued an exemptionto this regulation inExemption No. 11062. D. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas Section 91.119(c) establishes safe altitudes for operation ofcivil aircraft over areas otherthan congested areas. State Farm requests relieffrom this section with respect to those participating persons, vehicles, and structures directly involved with R&D. The UAS will never operate at higherthan 200 AGL. Itwill be operated in a restricted area, where buildings andpeople will not be exposed to operations without theirpre-obtained consent. Relieffrom this provision is warranted as operations will be conducted with the safety provisions as outlinedherein and inthe Operations Manual. The FAA issued an exemption to this regulation in ExemptionNo. 11062. E. 14 C.F.R. § 91.121 Altimeter Settings

11This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuant to the Operations Manual, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The FAA issued an exemption to this regulation in ExemptionNo. 11062. F. 14 C.F.R. § 91.151(a) Fuel requirements for flight in VFR conditions Section 91.151 (a) prohibits an individual from beginning "aflight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes." Complying with the 30 minute reserve requirement in 14 C.F.R. § 91.151, would unnecessarily limit the length ofState Farm's UAS flights. The battery powering the Zenithprovides approximately 45 minutes offlight time. To meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, UAS flights would be limited to approximately 15 minutes in length. Given the limitations on the UAS'sproposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight conditions is reasonable. Operating the small UAS in a tightly controlled area where only personnel and property owners will be present does not engender the type ofrisks that§ 91.15l(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flight minutes would reduce the utility ofthe flights for the roofinspections for whichthe exemption will be granted. State Farmbelieves that an equivalent level ofsafety canbe achieved by limiting flights to 60 minutes or 25% ofbattery power, whichever happens first. The FAA issued an exemption to this regulation inExemptionNo. 11062 and 10673. G. 14 C.F.R. § 91.405(a) Maintenance required; 14 C.F.R. § 91.407(a)(l) Operation after maintenance, preventive maintenance, rebuilding or alteration; 14 C.F.R. §§ 91.409(a)(l) and (2) Inspections; 14 C.F.R. §§ 91.417(a) and (b) Maintenance records These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter.

..," and others shall inspect ormaintain the aircraft in compliance with Part 43. Given thatthese sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the Petitioner. Maintenance will be accomplished by the operator pursuant to the Operations Manual. An equivalent level ofsafety will be achieved because these small UAS are very limited in size and will carry a small payload and operate only inrestricted areas for limited periods oftime. Ifmechanical issues arise, the UAS can land immediately and will be operating from no higher than 200 feet AGL. As provided in the Operations Manual, the operator will ensure that the UAS is in working orderpriorto initiating flight, perform required

12maintenance, andkeep a log ofany maintenance performed. Moreover, the operatoris the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. The FAA issued an exemptionto these regulations in ExemptionNo. 11062. H. Such otherreliefas the FAA deems appropriate to enable the requested operations State Farm also requests exemption from such other FARs as the FAA deems appropriate to enable the requested operations. If, during the effective dates ofany Grant ofExemption issued pursuantto this Petition, the FAA issues interim orfinal rules for small UAS, State Farm requests that it be relieved ofthe requirements ofany conditions and limitations ofsaid exemption and allowed to comply with any less burdensome applicable regulations that may have become effective. 

### VII. SUMMARY TO BE PUBLISHED IN FEDERAL REGISTER Petitioner: State Farm Mutual Automobile Insurance Company Sections of 14 C.F.R. Affected: Part 21 Subpart H; § 45.23(b); § 45.27; §§ 61.113(a) and (b); § 91.119(c); § 91.121; § 91.151(a); § 91.405(a); § 91.407(a)(l); §§ 91.409(a)(l) and (2); §§ 91.417(a) and (b). Description of Relief Sought: Petitioner seeks relieffrom the requirements of 14 C.F.R. Part 21 Subpart H; 14 C.F.R. § 21.191(a); 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.27; 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b) to conduct small unmanned aircraft systems (UAS) roofinspections subject to operating procedures that meet or exceedthose that FAArequires for similar operations. 

### VIII. CONCLUSION Satisfaction ofthe criteriaprovided in Section 333 ofthe FMRAregarding size, weight, speed, operating capabilities, proximityto airports and populated areas, operation within visual line of sight, and national security, provide more than adequatejustificationfor the grant ofthe requested exemption allowing operation ofPetitioner's UAS for roofinspectionspursuantto the Operations Manual. Please do nothesitate to contact Petitioner's outside counsel, R. Michael Senkowski at 202-719-7249 or msenkowski@wileyrein.com and Laura A. Foggan at 202-719- 3382 or lfoggan@wileyrein.com, with any questions about this filing.

13Sincerely,

Attachments: Confidential Operations Manual and Training Syllabus

14