State Farm Insurance Campanies® 

JACK WEEKES, CPCU®, CLU®, ChFc® 

OPERATIONS VICE PRESIDENT 

October 15,2014 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

ONE STATE FARM PLAZA 

BLOOMINGTON, ILLINOIS 61710·0001 

Re: Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the 

Federal Aviation Regulations, 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); 14 C.F.R. §§ 91.409(a)O) and (2); 14 C.F.R. 

§§ 91.417(a) and (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the 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 exemption from the listed Federal Aviation Regulations ("F ARs") 

and any other necessary to allow its operation of small Unmanned Aircraft Systems ("UAS") to 

conduct roof inspections, so long as such operations are conducted within and under the 

conditions outlined herein. The requested exemption would permit the operation of the UAS to 

obtain up-close images of State Farm policyholders' roofs and perform an in-depth analysis of 

the images to determine the nature and extent of damage to the roof surface without placing 

claim adjusters at risk. The State Farm claim representative will be able to share promptly with 

the customer the report and inspection images and reduce claim payment time. 

State Farm was founded in 1922 with the vision of operating fairly and doing the right thing for 

its customers. In advancing this vision and the goal of providing the best service possible, State 

Farm has committed to supporting innovation that improves the lives and safety of its 

policyholders and the general public. This commitment in championing innovation to improve 

lives and safety has helped State Farm become the nation's leading insurer of homes and 

automobiles, in addition to being an industry leader in other areas of insurance and financial 

services. Currently, State Farm has over 65,000 employees and 18,000 agents providing 

remarkable service in taking care of over 27 million home policies (1 in 5 U.S. houses) and 44 

million auto policies. Whether providing assistance after a major natural disaster or looking for 

ways to help people manage everyday risks, State Farm is there. By exploring the ability to use 

UAS, State Farm has the opportunity to further champion innovation in order to benefit the wellbeing of its policyholders and the general public. 

1 

HOME OFFICES: BLOOMINGTON, ILLINOIS 61710·0001 
I. REQUEST FOR EXEMPTION TO USE UAS FOR ROOF INSPECTIONS 

A. Overview of Request to Use UAS for Roof Inspections 

State Farm proposes to conduct roof inspections using small UAS including the Aerialtronics 

Altura Zenith ATX8. As described more fully below, the requested exemption would permit the 

operation of small U AS 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 of sight of the UAS operator. The property owner will 

be notified in advance of the date and time for inspection. The customer's privacy and their 

neighbors' privacy will be fully protected. State Farm's use ofUAS for roof inspections does 

not create a hazard to users of the national airspace or the public or pose a threat to national 

security. In support of this exemption request, State Farm is submitting an Operations Manual 

and Training Syllabus under separate cover and with a request for confidential treatment. 1 

Grant of this 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 

roof using ladders for inspection. Inspecting roofs is dangerous as evidenced by annual 

industrywide worker compensation claims. Each year, claim handlers throughout the industry 

are injured in falls while performing the task. By utilizing UAS, the claim handlers will be able 

to reduce their exposure to hazards and obtain accurate assessments of the roof while remaining 

safely on the ground. 

B. Public Interest Benefits of Permitting Use ofUAS for Rooflnspections 

Grant of State Farm's request to use UAS for roof inspections is in the public interest. While 

State Farm takes every precaution to keep its claim handlers safe, roof inspection conducted by 

human beings carries with it certain risks. Currently, State Farm claim handlers need to 

physically climb onto the roof using ladders and other safety gear to conduct inspections. 

Sometimes, a two story/steep team is used, requiring two claim handlers and special safety 

harnesses. The dangers of inspecting any roof include losing one's footing, having a ladder slip, 

and being blown off a roof from wind shear. A recent news article noted that fatalities rates 

among roofers are the highest in the construction trades.2 In addition to safety concerns, 

inspecting a roof by physically climbing on it has the potential to damage the roof. Using UAS 

for roof inspections avoids all of these risks. By utilizing UAS, State Farm's claim handlers will 

be able to reduce their exposure to hazards and rapidly obtain accurate assessments of the roof 

while remaining safety on the ground. Faster roof damage 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 under the Freedom oflnformation Act, 5 U.S.C. § 552. 

2 Alexandra Berzon and Kris Hudson, Fight Erupts Over Protecting Rooftop Workers, Wall Street Journal, 

Sept. 28, 2014 available at http://online.wsj.com/articles/builders-osha-square-off-on-rooftop-safety-14 l l 947843. 

2 
In 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-avoiding interference 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 over private property with the owner's consent. In addition, the 

UAS will have a geo-fence around the owner's property line to prevent the UAS from flying 

where it should not be. Finally, operation will not pose a threat to national security. The UAS 

poses no credible threat to national security due to its size, speed, of operation, location of 

operation, lack of explosive materials or flammable jet fuels, and inability to carry a substantial 

external load. 

II. THE FAA'S LEGAL AUTHORITY TO GRANT THIS EXEMPTION REQUEST 

This exemption request will help the FAA to fulfill Congress' goal in passing Section 333 of the 

FMRA. Section 333 directs the Secretary of Transportation to consider whether certain UAS 

may operate safely in the national airspace system (NAS) before completion of the rulemaking 

required under Section 332 of the FMRA. The Secretary is required to determine which types of 

UAS do not create a hazard to users of the NAS or the public or pose a threat to national security 

in light of the UAS's size, weight, speed, and operational capability and whether operation will 

occur near airports or populated areas and within the visual line of sight of the operator. 3 The 

FMRA illustrates Congress' intent to have the FAA issue exemptions and allow civil UAS, so 

long as they operate within the necessary safety parameters. 

In addition, the Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is defined 

under§ 40101 of the Act, that includes UAS, from the requirement that all civil aircraft must 

have a current airworthiness certificate. The Administrator may grant an exemption from a 

requirement of a regulation prescribed under§§ 44701(a) or (b) or in§§ 44702-44716 of the Act 

if the Administrator finds the exemption in the public interest.4 

III. APPLICATION INFORMATION 

The name and address of the applicant is: 

Todd Binion 

Innovation Manager 

State Farm Mutual Automobile Insurance Company 

3 State Farm Plaza South 

Bloomington, IL 61 791 

todd.binion.hkoO@statefarm.com 

309-735-8633 

Regulations from which the 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). 

3 
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. §§ 61.113(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 Altura Zenith ATX8. The Altura Zenith ATX8 is a multi-rotor aircraft built with a 

monocoque carbon airframe. The Zenith has a 5.6 kg take-off weight and a maximum payload 

of 2.9 kg. The Zenith carries a 16.600 mAh battery, which facilitates up to 45 minutes offlighttime with total payloads of up to 6.4 lbs. for the ATX8. It can be flown with either a radio or 

tablet and carries a variety of payloads. The Zenith has a maximum cruise speed of 20 mis. It 

features auto-takeoff and 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., without payload (less than 15 lbs. with payload) 

State Farm agrees that any UAS it uses for roof inspections will include, at minimum: geofencing at a maximum ceiling of 200' AGL, flight programming capabilities, a flight termination 

link available to the operator to prevent a "fly away," and safe abort procedures. If the UAS 

loses communications or its GPS signal, the UAS will return to a pre-determined location and 

land or be 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's UAS 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 of our vehicles. 

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 best practices and decades of experience. The system has been developed using modelbased-design for the core control algorithms and robust CIC++ at the application and OS level. 

The autopilot system is built on top of a 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 

4 
verification, unit testing, and integration testing 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 of contingency management functions, user 

and flight plan management and approval functionality, amongst others. 

V. OPERA TING PARAMETERS 

Petitioner proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at 

least an equivalent 'or even higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to the already safe 

operations conducted with conventional aircraft. Further details about the aircraft and operating 

procedures are available in the 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 an FAA issued exemption include: 

A. UAS Pilot and Observer 

1. UAS operations will be conducted by, at minimum, pilots holding a 

private pilot certificate and at least a current third-class medical certificate. 

2. All UAS operations must utilize a visual observer ("VO"). 

3. The pilot-in-command ("PIC") and VO must be able to communicate 

verbally at all times. 

4. The PIC will be wearing a safety vest that identifies him or her as the 

pilot. 

5. Prior to operations, the pilot must have accumulated and logged a 

minimum of 200 flight cycles, or more as required by the FAA, and 25 

hours of total time as a UAS rotorcraft pilot. The pilot must also have 

accumulated and logged prior to operations at least ten hours as a UAS 

pilot with a similar UAS type (single blade or multi-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 

conducted under the FAA' s grant of exemption to accomplish the 

required flight cycles and flight time. 

b. During training, 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. 

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6. State Farm will rely on the 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 

vendor training program and qualification process and the State 

Farm training process, as outlined in the Operations Manual and 

Training Syllabus. 

b. The qualification test will be developed and implemented by a 

qualified person designated at the sole discretion of State Farm. 

c. A record of completion of this qualification process must be 

documented and made available to the Administrator upon request. 

7. State Farm will require all pilots conducting UAS operations to provide 

proof of pilot and third-class medical certification as well as proof of 

completion of the applicable vendor's training program. 

B. Operational Parameters 

1. Aircraft will not carry pilots or passengers, and aircraft will not carry 

explosive materials or flammable liquid fuels. 

2. UAS must be operated within visual line of sight of the pilot at all times. 

3. UAS may not be flown at ground speeds exceeding 50 knots. 

4. Flights will be operated at an altitude of no more than 200 feet above 

ground level. 

5. Each UAS operation will be completed within 60 minutes flight time or 

with 25% battery power remaining, whichever occurs first. At 30% 

battery the UAS will enter a return and land sequence; at 20% it will land 

immediately. 

6. UAS will not be operated over any person (other than participating State 

Farm personnel) at an altitude that is hazardous to persons or property on 

the surface in the event of a UAS failure or emergency. 

a. Distance from participating persons will be specified in the 

Operations Manual. 

b. Operations will be conducted as far as practicable from nonparticipating persons. 

7. The UAS will abort the flight in the event of unpredicted obstacles or 

6 
emergencies in accordance with the Operations Manual. 

8. Prior to operations, a flight demonstration, administered by an operatorapproved and qualified pilot will be successfully completed and 

documented. Documentation will be made available for review by 

Administrator upon request. 

9. The operator must obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any 

operations under this grant of exemption. 

a. This COA will also require the operator to request a Notice to 

Airmen (NOTAM) not more than 72 hours in advance, but not less 

than 48 hours prior to the operation. 

10. Operations will be limited to the property of consenting State Farm 

policyholders. 

11. Petitioner will display signage notifying the public of U AS 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 prior to UAS operations. An area will be 

marked off as the UAS "landing zone." Petitioners will also display 

signage notifying the public that UAS operation is in progress once 

operations begin. 

12. Before conducting operations, the radio frequency spectrum used for 

operation and control of the 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 

periodically review safety procedures and other operations to further 

enhance safety. Under normal circumstances, the operator will submit a 

written Plan of Activities to the local FSDO at least 48 hours prior to 

conducting operations. In an emergency situation, the operator will 

submit a written Plan of Activities 24 hours prior to conducting 

operations, unless sooner authorized by the FSDO. The Plan of Activities 

will include: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS and for the 

person responsible for on-site operations; 

c. Make, model, and serial or N-number of UAS; 

d. Name and certificate number of pilot(s); 

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e. Signature of exemption holder or representative; 

f. Description of flight activity, including maps/diagrams of area 

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 of the 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 must remain clear and yield the right of way to all other manned 

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 or through 

visual identification of manned aircraft, State Farm 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 not be 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, or D airspace without approval 

from the FAA. The UAS may not operate within 5 nautical miles of the 

geographic center of a non-towered airport as denoted on a current FAApublished aeronautical chart unless 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, or flight operation that transgresses the lateral or 

8 
vertical boundaries of the operational area as defined by the applicable 

COA must be reported to the FAA's UAS Integration Office (AFS-80) 

within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. Further flight operations may not be 

conducted until the incident, accident, or transgression 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 must be maintained and made available to the 

Administrator upon request. 

D. Pre-Flight Inspections and Maintenance 

1. Prior to each flight, pilot will inspect UAS to ensure it is in condition for 

safe flight. If the inspection reveals 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 in the 

aircraft records. 

3. Any U AS that undergoes maintenance or alterations that affect the U AS 

operation or flight characteristics will undergo a functional flight test in 

accordance with the Operations Manual. 

4. Petitioner will institute a rigorous maintenance program to ensure 

airworthiness ofUAS. Operator will follow the manufacturer's UAS 

aircraft/component, maintenance, overhaul, replacement, inspection, and 

life limit requirements. 

a. When unavailable, requirements must be established in the 

Operations Manual, including for the following: 

1. Actuators I Servos; 

11. Transmission (single rotor); 

m. Powerplant (motors); 

1v. Propellers; 

v. Electronic speed controller; 

9 
v1. Batteries; 

VIL Mechanical dynamic components (single rotor); 

v111. Remote command and control; 

Ix. Ground control station (if used); and 

x. Any other components as determined by the operator. 

5. Operator will develop procedures to document and maintain a record of 

the UAS maintenance, preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the 

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 enable the 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 of airworthiness certificates. Given the size and limited operating area associated with 

the aircraft to be utilized, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act5 and Section 333 of the FMRA both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. In 

all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the proposed environments and under the conditions proposed will 

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with 

an airworthiness certificate without the restrictions and conditions proposed. 

The Zenith UAS to be operated hereunder is less than 15 pounds including payload, carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and will 

operate exclusively within the parameters stated in the Operations Manual. Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored by both the 

operator and under the requirements and in compliance with local public safety requirements, to 

provide security for the area of operation. The FAA will have advance notice of all operations 

via notices to airmen (NOTAMS). Finally, these UAS, as a result of their size, weight, speed, 

5 49 u.s.c. § 4470J(t). 

10 
operational capability, and operation within visual line of sight do not create a hazard to users of 

the national airspace system or the public or pose a threat to national security. 

B. 14 C.F.R. § 45.23(b) Display of marks; 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. Section 45.27 

requires that each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by§ 45.23. 

Given the size of the 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 can be placed. An 

equivalent level of safety will be achieved by having any required words displayed on the 

aircraft, as applicable, in letters of legible size, in a location where the pilot, observer, and others 

working with the UAS will see the identification. The FAA has 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 pilot privileges and limitations 

Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring 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 of operation is controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the Operations Manual. The level of safety provided by the 

requirements included in the Operations Manual exceeds that provided by a single individual 

holding a commercial pilot's certificate operating a conventional aircraft. The risks associated 

with the operation of the UAS are so diminished from the level ofrisk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations of the 

UAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 

14 C.F.R. §§ 61.113 (a) and (b). The FAA issued an exemption to this regulation in Exemption 

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 of civil aircraft over areas other than 

congested areas. State Farm requests relief from this section with respect to those participating 

persons, vehicles, and structures directly involved with R&D. The UAS will never operate at 

higher than 200 AGL. It will be operated in a restricted area, where buildings and people will not 

be exposed to operations without their pre-obtained consent. Relief from this provision is 

warranted as operations will be conducted with the safety provisions as outlined herein and in the 

Operations Manual. The FAA issued an exemption to this regulation in Exemption No. 11062. 

E. 14 C.F.R. § 91.121 Altimeter Settings 

11 
This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set " ... to the elevation of the 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 of safety 

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 Exemption No. 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 "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." 

Complying with the 30 minute reserve requirement in 14 C.F.R. § 91.151, would unnecessarily 

limit the length of State Farm's UAS flights. The battery powering the Zenith provides 

approximately 45 minutes of flight time. To meet the 30 minute reserve requirement in 14 

C.F .R. § 91.151, U AS flights would be limited to approximately 15 minutes in length. Given the 

limitations on the UAS' s proposed flight area and the location of its 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 of the small UAS. Additionally, limiting UAS flight minutes would 

reduce the utility of the flights for the roof inspections for which the exemption will be granted. 

State Farm believes that an equivalent level of safety can be achieved by limiting flights to 60 

minutes or 25% of battery power, whichever happens first. The FAA issued an exemption to this 

regulation in Exemption No. 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 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. .. ," and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these 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 of safety will be achieved because these 

small UAS are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If mechanical 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 order prior to initiating flight, perform required 

12 
maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person 

most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to 

provide the equivalent level of safety. The FAA issued an exemption to these regulations in 

Exemption No. 11062. 

H. Such other relief as the FAA deems appropriate to enable the requested operations 

State Farm also requests exemption from such other F ARs as the FAA deems appropriate to 

enable the requested operations. If, during the effective dates of any Grant of Exemption issued 

pursuant to this Petition, the FAA issues interim or final rules for small UAS, State Farm 

requests that it be relieved of the requirements of any conditions and limitations of said 

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 relief from 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) roof inspections subject to operating procedures 

that meet or exceed those that FAA requires for similar operations. 

VIII. CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the FMRA regarding size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of 

sight, and national security, provide more than adequate justification for the grant of the 

requested exemption allowing operation of Petitioner's UAS for roof inspections pursuant to the 

Operations Manual. Please do not hesitate 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. 

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Sincerely, 

Attachments: Confidential Operations Manual and Training Syllabus 

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