Carol R. Gosain
202 429 6461 cgosain@steptoe.com 1330 Connecticut Avenue, NW Washington, DC 20036-1795 202 429 3000 main www.steptoe.com Patrick C. Gee Sr. Vice President Personal Insurance Claim The Travelers Companies, Inc. One Tower Square, 4MS Hartford, CT 06183 860-277-7660 TEL 866-697-5592 FAX

February 6, 2015

U.S. Department of Transportation 1200 New Jersey Avenue, S.E. Room W12-140 Washington, D.C. 20590

Re: Travelers Request for Exemptions Pu rsuant to FMRA Section 333 and Part 11 of the FARs to Use Small Unmanned Aircraft Systems in the Property and Casualty Insurance Industry

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modern ization and Reform Ac t of 2012 (“FMRA”) and 14 C.F.R. Part 11, The Travelers Companies, Inc. (“Travelers”) 1 hereby petitions for exemptions from the listed Federal Aviation Regul ations (“FARs”) and any other rules necessary to allow operation of small unmanned aircraft sy stems (“UAS”) under the conditions set forth in this petition. FMRA Section 333 grants the FAA authority to allow the operation of certain UAS within the national airspace. Travelers reques ts authorization to conduct small UAS operations related to its insurance busine ss, including (but not limited to ) roof inspections, underwriting, risk assessment, risk control, accident r econstruction and small UAS pilot training and development. As explained below, operations u nder the requested exemptions will be conducted under strict operating requirements and conditions to ensure safety.

Travelers is one of the country’s largest insurance companies, providing commercial and personal property and casualty insurance products to its customers. The company’s diverse business lines offer its global customers a wide range of coverage sold primarily through independent agents and brokers. A component of the Dow Jones Industrial Average, Travelers has more than 30,000 employees and 13,000 independent agents. The company generated revenues of $26 billion in 2013. Founded in 1853, as one of the oldest in surance companies in

1 Travelers is filing this peti tion on behalf of itself and a ll of its respective parents, subsidiaries, affiliates, predecessors, successors and assigns.- 2 - the United States, Travelers has continuously kept up with developi ng technologies in the insurance marketplace. Travelers is committed to keeping pace with the ever-changing needs of our customers, for instance by offering the first-ev er space travel policy and hybrid car discount. The use of UAS will allow Travelers to further advance innovative technologies to benefit its policyholders and the general public.

I. Types of Operation

A. Request to Use UAS for In spection of Private Property

Travelers requests an exemption to use UAS to inspect, photograph and assess the nature and extent of damage to policyholders’ priv ate property. Travelers would conduct these UAS operations only with the express written consent of the property owner. Trav elers is specifically interested in studying how UAS can be used to obtain precise and detailed images of a policyholder’s roofing system a nd any other portions of the prope rty that would normally require utilization of a ladder to acqui re such information. This experience will give Travelers the necessary information in order to determine how best to implement th is innovative technology to more rapidly adjust claims, enhance customer e xperience, and further Tr avelers’ overall goal of improving safety for its personnel, vendors and cu stomers. This exemption will also provide Travelers pilots with real-world training and experience on UAS and will generate valuable data about the operation and safety of UAS that can be beneficial to the FAA with respect to the upcoming small UAS rulemaking and public comment on the proposed rule.

In addition to improving Travelers’ custom er experience and claim effectiveness, granting this petition would improve safety fo r our claim professionals and vendors and reduce the risk of damage to customer property by virtue of eliminating visual inspections by ladder. Travelers estimates that it conducts about 60,000 ladde r assisted inspections per year. Generally, our claim practices require visual inspections of roof damage by ladder, which undeniably carries certain unavoidable risks. These inspections re quire that persons climb onto roofs from a ladder and traverse the roof, which is usually a downwar d pitched surface, in order to inspect and take pictures. The inherent risks associated with roof inspections include pote ntial harm to the person carrying out the inspection if he or she fell; the po tential harm to persons on the ground that may be impacted by a falling person or ladder; and the potential propert y damage that may be caused by a falling person or ladder. Trav elers is an industry leader in ladder safety and we pride ourselves on our commitment to safety in what is an essential aspect of our business. By utilizing UAS technology, Travelers will be able to eliminate the need for thousands of ladder inspections. However, by comparison, the risks posed by the type of UAS roof inspections proposed in this petition are minimal due to the characteristics of the small UAS that Travelers will use, including their extremely small size an d light weight, low operating altitude, and geofencing and other capabilities, and the operating parameters a nd comprehensive training that Travelers would require. Over the long term, gr anting this petition will undoubtedly save lives,- 3 - prevent serious injuries, and reduce collateral prope rty damage that might have occurred utilizing even the strictest safety protocols.

In addition, Travelers believes that, with appropriate proces s refinement, inspection via UAS will not only be safer than ladder inspection s, but will be quicker and will result in an enhanced customer experience. While the benefi ts of efficiency are se lf-evident, they bear mention in this petition to demonstrate the signifi cant public interests associ ated with Travelers’ proposed UAS integration. Frequently, roof inspectio ns can take longer to coordinate than other types of inspections and, in many instances, do no t take place during the first inspection of the property. As a result, the claim process takes long er, which means that it takes longer for repairs to take place and longer for customers’ lives to return to normal. Unde r Travelers’ proposed UAS model, more roof inspecti ons would take place immediately and, in virtually every case, Travelers would be in a position to issue roof da mage payments on site after inspection. As a result, our customers will be able to immediately effectuate repairs and more quickly return to their busy lives. When considered across Travel ers’ entire book of business and over the long haul, the benefits of UAS integration will positively impact the lives of millions of customers who will receive faster service, quicker paymen ts, timelier repairs and have the opportunity to more quickly recover from losses. Further, wh en considered within th e context and scale of catastrophic events such as hurri canes, tornados or earthquakes, th ese efficiencies will translate into quicker recoveries for our neighborhoods , communities, municipalities and beyond.

Travelers’ UAS model poses no meaningful risk to the national airspace. In the materials supporting this petition, Travelers will present an operating model that will require UAS inspections take place within a very confined, tight footprin t around and above an individual structure. The vast majority of UAS work will ta ke place just ten to fifteen feet above the roof’s surface. Since the UAS will be operated within cl ose proximity of low lying structures, the UAS will pose no greater risk to the national airspace than essentially the buildings themselves. The only conceivable concern would be a “fly away ” scenario; however, in light of the UAS Travelers has selected and the protocols it will put in place, there should no risk of this happening. Specifically, Travelers will employ lo st-link and geo-fencing technology to best control against a fly away scenario.

Travelers is requesting permi ssion to integrate UAS technology into its claim handling workflow by way of a three phased approach.

1. Phase 1 - Agribusiness

Travelers requests an exemption to use UAS to conduct private property inspections in connection with claims arising out of its Agribusiness Program. Travelers is one of the largest countrywide writers of farm and ranch business coverage in the U.S. The properties insured- 4 - under this program are large farms and ranches that are situated in remote, sparsely populated areas. Use of UAS in this setting would pr ovide Travelers and the FAA with a unique opportunity to partner in experi menting with UAS in sparsely populated areas without risk to neighboring persons or property. When combined with Travelers’ operational “tight footprint,” i.e., small UAS (under 5.5 lbs.), low operating altit ude of 100 feet or less, lost-link, geo-fencing and additional safety protocols, Travelers’ operations would pose no threat to national airspace or neighboring persons or property.

Use of UAS in this setting would further the goal of improving overall safety. Under current protocols, each such inspection woul d be conducted by individuals on ladders. As discussed above, while Travelers ta kes ladder safety seriously, there are always inherent risks to persons and property associated with roof inspections and thos e risks could be completely eliminated by use of UAS.

Travelers proposes to fly UAS on 50 Agribusin ess claim inspections before moving on to Phase 2 operations. Travelers would be using the UAS to inspect damage or loss above ground level and/or to make a visual inspection and take measurements of policyh older private property.

2. Phase 2 - One Acre or More

Travelers requests an exemption to use UAS to conduct private property inspections in
connection with Personal and Business insurance claims aris ing on properties located on one acre of land or more. Operations conducted on properties one acre or larger would enhance safety and would pose little to no threat to neighboring persons or property. Similar to operations on Agribusiness claims, roof inspect ions of these properties would normally be conducted by persons on ladders. Use of UAS on these claims, which make up a more voluminous amount of Travelers work, would furthe r the overall goal of elim inating the inherent risks of ladder assisted inspections. When combin ed with Travelers’ “tight footprint,” i.e., small UAS (under 5.5 lbs.), low operating altitude of 100 feet or less, lost -link, geo-fencing and additional safety protocols, Trav elers’ operations would pose no th reat to national airspace or neighboring persons or property. Further, Travelers would partne r with the FAA to gain more valuable UAS experience while improving the over all safety of its operations by eliminating the
risks inherent in ladder assisted inspections.

Travelers proposes to fly UAS on 50 Pers onal and Business insurance claims on properties located on at least one acre of land before moving on to Phase 3 operations. Travelers would be using the UAS to inspect damage or lo ss above ground level and/or to make a visual inspection and take measurements of policyholder private property.- 5 - 3. Phase 3 - Non Metropolitan Areas

Travelers requests an exemption to use UAS to conduct private property inspections in
connection with Personal and Business insurance claims aris ing on properties located in nonmetropolitan areas. Once Travelers has demonstr ated to the FAA’s satisfaction that it has mastered safe UAS operations under Phases 1 an d 2, Travelers would like to partner with the FAA to take the next step and conduct UAS inspec tions that could potentially reach the majority of its claim inventory. Travelers expects to estab lish a strong safety record in Phases 1 and 2 and will carry over the learnings and improvements fr om those UAS operations to Phase 3. These operations would encompass by far the largest volume of Travelers’ roof inspections and, accordingly, would have the largest impact on safe ty by eliminating the majority of Travelers’ ladder assisted roof inspections.

When combined with Travelers’ “tight foot print,” i.e., small UAS (under 5.5 lbs.), low operating altitude of 100 feet or less, lost-link, geo-fencing an d additional safety protocols, Travelers’ operations would pose no threat to national airspace or neighboring persons or property. Further, Travelers woul d partner with the FAA to gain more valuable UAS experience while improving the overall safety of its operati ons by eliminating the risks inherent in ladder assisted inspections.

Travelers would be using the UAS to insp ect damage or loss above ground level and/or to make a visual inspection and take meas urements of policyholder private property.

B. Request to Use UAS for R&D, Traini ng and Certification Development at Sites Owned or Controlled by Travelers

Travelers also requests an exemption to us e UAS to perform R&D, training and develop pilot certification at Travelers’ ow n facilities on property it either owns or leases. As discussed in more detail below, Travelers would like to partner with the FAA to develop a pilot certification program that focuses on the skills , knowledge and expertis e required to operate small UAS of the type Travelers intends to operate, i.e., 5.5 lbs. or less, at low altitudes (i.e., 100 feet or less). Travelers would dedicate its Claim University f acility, located at 99 Lamberton Rd., Windsor, CT 06095, for the purposes of deve loping and implementing a pilot certification program. Our Claim University facility is lo cated in a sparsely populated area on 50 acres of land that is completely controlled by Travelers. The testing facil ity will not be open to the public
and access will be restricted to Trav elers employees or consultants engaged in test or test-related work. The test site may at times contain structur es, which will enable Tr avelers to test how UAS will operate and capture images over various types of buildings. Since the test site is located within 5 nautical miles of Bradley International Airport (BDL), Travelers will obtain a letter of- 6 - agreement with the airport’s management and will conduct its operations in accordance with a NOTAM as required by any applicable COA. When combined with Travelers’ operational “tight footprint,” i.e., small UAS (under 5.5 lbs.), low op erating altitude of 100 f eet or less, lost-link, geo-fencing and addition al safety protocols, Travelers’ operations on secure property in a sparsely populated area would pose no threat to national airspace or neighboring persons or
property.

C. Request to Use UAS for Risk A ssessment, Risk Control, Accident Reconstruction, Underwriting and Other Business Related Activities

Travelers also requests an exemption to use UAS to perform risk assessment, risk control, accident reconstruction, and underwriti ng evaluations for its Business and Personal insurance property policyholde rs. In particular, Trav elers anticipates that UAS could be used to carry out inspections and evaluations of elevat ed portions of structur es including roofs that provide unique challenges and risks. In the risk control cont ext, these inspections are currently conducted by persons on ladders with the attenda nt risks associated with such work. Other potential beneficial uses for UAS could include, but would not be limited to, inspection of loss sites that are otherwise unsafe for human entry and accident reconstruction. In general, use of UAS for these purposes would significantly enha nce safety as well as improve overall risk control and underwriting efficiency and accura cy to the benefit of our policyholders.

II. Pilot Requirements

Travelers would like to partne r with the FAA to design a pilot certification program that focuses on the skills, knowledge and expertise required to operate sm all UAS of the type Travelers intends to operate, i.e., 5.5 lbs. or less. Travelers intends to work with an on-staff commercially licensed pilot to design and im plement a practical, hands–on training program focused on operation of small lightweight UAS. While there may be some overlap in knowledge and skill associated with traditional private or commercial certification requirements, Travelers believes that its pilots and the public would be better served by a training regimen that is specifically designed to certify th e safe operation of small UAS. Further, Travelers believes that there is a significant difference between small UAS of the type it plans to operate, i.e., under 5.5 pounds, and heavier unmanned aircraft still cons idered “small” by the FAA, i.e., up to 55 pounds. The program Travelers intends to design w ill be tailored to address the safety concerns specific to very lightweight UAS, wh ich -- at 4.4 or 5.4 lbs. -- pose li ttle to no risk to the national airspace and neighboring pe rsons or property.

Travelers will be submitting a training pr ogram designed by an on-staff commercially certificated pilot that has an extensive secur ity background as well as considerable experience- 7 - with UAS, rotary winged and fixed winged aircraft. 2 Travelers would like to partner with the FAA to improve and refine the training to fu lly address all necessary skill and safety requirements that make sense for piloting small, lightweight UAS. While the program is still under development, Travelers will require each pilo t to: (a) successfully co mplete training that combines the aspects of private pilot ground school that are relevant to small UAS with handson small UAS training; (b) pass a certification examination designed for small UAS operators; (c) have accumulated and logged at least 10 hours total time as a UAS pilot, including at least 5 hours logged as a UAS pilot operating the make a nd model of UAS to be utilized for operations under this exemption; (d) certify that he or she has no medical defect th at would make him or her unable to pilot a small UAS in a safe manner; 3 and (e) clear a criminal background check and drug test. All pilot certification training will ta ke place under the direct supervision and control of a person holding an FAA commerc ial or private pilot certificate. 4

III. Public Interest Benefits

Approval of Travelers’ request to use UAS to inspect policyhol ders’ private property is in the public interest. Granting th is petition advances Congress’ goa l of integrating civil UAS into the national airspace safely and expeditiously. Allowing Travelers to conduct the inspections proposed herein is a necessary step toward realiz ing the consumer benefits of using UAS in the insurance industry. Traveler s would like to partner with the FAA in the design and

2 Travelers is submitting the resume of its on-staff commercially certificated pilot to FAA confidentially with a request for confidential treatment. The resume contains confidential personal information that has not been made avai lable to the public and that is protected under the Freedom of Information Act, 5 U.S.C. § 552, et seq.

3 FAR 61.23 permits piloting of gliders and ba lloons without a medi cal certificate. Travelers’ operations would pose less threat to national airspace or neighboring persons or property than gliders and balloons, which are heav ier and operated at higher altitudes.

4 Travelers recognizes that the FAA has conclu ded that it does not ha ve the authority to grant an exemption from the statutory requirement in 49 U.S.C. § 44711 that a pilot must hold an airman certificate. Travelers’ proposal does not require an exemption since it contemplates that the FAA, partnering with Traveler s, would develop a pilo t certificate applicable specifically to operators of very small, lightweight unmanned aircraft. Moreover, Travelers respectfully submits that FAA does in fact have the authority to exempt persons from the airman certificate requirement and requests that F AA reconsider its decision in th is regard. Section 44701(f) authorizes FAA to grant exemptions from “a requirement of a regulation prescribed under subsection (a) or (b) of this section or a ny of sections 44702–44716 of this title if the Administrator finds the exemption is in the public interest.” Section 44711 is included within the sections from which FAA may grant an exemption.- 8 - implementation of a small UAS pilot certification program that is specifically tailored to maximize safe operations of small UAS, i.e., under 5.5 pounds. This partnership would benefit the FAA and the public at large in designing an appropriate, safe, economically sensible certification program that could serve as th e model for FAA’s small UAS rulemaking.

Further, Travelers’ petition seeks to imple ment UAS inspections in a gradual, stairstepped process so that we can work with th e FAA to develop and refine our operations, under strictly controlled conditions, that will lead to continuously improvi ng flight protocols. Travelers will share its experience, data and process enhanc ements with the FAA, which will benefit the public with respect to FAA rulemaking and comm ent on small UAS. Travelers should be in a position to provide a considerable amount of mean ingful knowledge and data within a relatively short period of time.

In addition to improving UAS operational safe ty, granting this petition would improve safety for our claim professionals and vendors as well as reduce the risk of damage to customer property by eliminating the need for many ladder assisted roof inspections. As mentioned, Travelers conducts over 60,000 ladder assisted inspections per year. By utilizing small UAS and the “tight footprint” described above, Travelers w ill be able to eliminate th e risks associated with ladder inspections and improve overall safety to persons and property. As an added benefit, Travelers believes that inspection via UAS will no t only be safer than ladder inspections, but may also be quicker and more accurate. Traveler s also believes that these benefits will carry over to other areas of the company such as risk control and underwriting a nd that these benefits will positively impact our customers.

IV. Operating Parameters, Operations, Inspection and Maintenance Manual

A. Operating Parameters

The proposed operating limitations describe how Travelers’ UAS operations will be safely conducted to minimize risk to the nati onal airspace or to persons and property on the ground:

1. The operations will be conducted using a 3DR IRIS+ aircraft and a DJI Phantom 2, 5 which are small UAS weighing approximately 4.4 pou nds and 5.4, respectively, with payload.

2. Flights will be operated at all times within visual line of sight of a pilot unaided by any device
other than corrective lenses.

5 FAA is familiar with the DJI Phantom 2 airc raft and has previously granted exemptions approving use of the DJI Phantom 2 airc raft for commercial operations. See Exemption Nos. 11138, 11153 and 11157.- 9 - 3. The UAS will not carry persons, explosiv e materials or flammable liquid fuels.

4. The UAS will not be flown at ground speeds exceeding 15 knots.

5. Flights will be terminated at 25% battery power reserve.

6. Flights will be operated at an alti tude of no more than 100 feet AGL.

7. Prior to each flight, the pilot must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed, and the UAS is found to be in a condition for safe flight. Th e ground control station must be included in the preflight inspection. All maintenance and alte rations must be properly documented in the
aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., re placement of a flight critical component, must undergo a functional test flight in accordance with Travelers’ Manual. 6 The pilot who conducts the functional test flight must make an entry in the UAS aircraft records of the flight.

9. The preflight inspection section in the Manua l includes the requirement that the preflight inspection must account for all di screpancies, i.e., inoperable co mponents, items or equipment,

etc.

10. The operator must follow the UAS manuf acturer’s aircraft/component, maintenance, overhaul, replacement, inspecti on and life limit requirements.

11. The operator must carry out its maintenance, inspections and record keeping requirements in accordance with the Manual. Maintenance, insp ection and alterations must be noted in the aircraft records, including tota l flight hours, description of work accomplished and the signature of the authorized person retu rning the UAS to service.

12. Each UAS operated under the exemption must comply with all manufacturer safety
bulletins.

6 Travelers is submitting its Unmanned Aircra ft System Operating Procedures, Safety Code and Training Syllabus (“Ma nual”) to FAA confidentially with a request for confidential treatment pursuant to 14 CFR Section 11.35(b). Th e Manual contains conf idential, proprietary and commercially sensitive information that has no t been made available to the public and that is protected under the Fr eedom of Information Act, 5 U.S.C. § 552, et seq.- 10 - 13. The operator’s maintenance personnel must make a record entry in the UAS logbook or equivalent document of the corrective action taken against discrepancies discovered between inspections.

14. Each flight will be operated by a pilot that has: (a) successfully completed training that combines the aspects of private pilot ground school that are relevant to small UAS with hands-on small UAS training; (b) passed a certification examination designe d for small UAS operators; (c) accumulated and logged at least 10 hours total ti me as a UAS pilot, in cluding at least 5 hours logged as a UAS pilot operating the make and m odel of UAS to be utilized for operations under this exemption; (d) certified that he or she has no medical defect that would make him or her unable to pilot a small UAS in a safe manner; 7 and (e) cleared a criminal background check and drug test.

15. Each pilot will successfully complete a sm all UAS pilot certification program designed and overseen by an FAA-certificated pilot and approved by FAA. The program will focus on the skills, knowledge and expertise required to operate small UAS of the type Travelers intends to operate, i.e., under 5.5 lbs. Prior to any operation s for a commercial purpose, the PIC must have accumulated and logged 10 hours total time as a UAS pilot, including at least 5 hours logged as a UAS pilot operating the make and model of UAS to be utilized for operations under this exemption. The pilot must also have accomplishe d three takeoffs and landings in the preceding 90 days.

16. All operations shall be conduc ted over private or controlled- access property with permission from the land owner/controller or authori zed representative. Permission from the land owner/controller or authorized re presentative will be obtained fo r each flight to be conducted.

17. Flight operations will be conducted at l east 50 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protec t nonparticipating persons from the UA and/or debris in the event of an accident. The operator will ensure that nonparticipating persons remain under such protection. If a situ ation arises where nonparticipating persons leave su ch protection and are within 50 feet of the UA, flight operations must cease imme diately; and/or

b. The aircraft is operated near vessels, vehicles or structur es where the owner/controller of such vessels, vehicles or structures ha s granted permission and the pilot has made a

7 FAR 61.23 permits piloting of gliders and ba lloons without a medi cal certificate. Travelers operations would pose less threat to national airspace or neighboring persons or property than gliders and balloons, which are heav ier and operated at higher altitudes.- 11 - safety assessment of the risk of operating clos er to those objects and determined that it does not present an undue hazard; and

c. Operations nearer to the pilot, operator tr ainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

18. A geo-fencing perimeter will be establishe d at a maximum ceiling of 100 feet AGL, within the confines of the property being inspected.

19. The pilot will designate a landing zone from which the UAS will take off and land.

20. The pilot will abort the flight in the event of any unpredicted obstacles or emergencies as
detailed in the Manual.

21. If the communications link or GPS signal is lost, the UAS will return to a pre-programmed location, within the restricted area of operations, and land or be recovered in accordance with the
Manual.

22. Before conducting operations, a qualified UAS pilot will demonstrate and log in a manner consistent with 14 CFR 61.51(b) the ability to sa fely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropr iate distances from people, ve ssels, vehicles and structures.

23. All operations must be conducted under visual meteorological condi tions (VMC) and during daylight hours.

24. Before operations begin under the exemp tion, the radio frequency spectrum used for operation and control of the UAS will comply with Federal Communications Commission requirements.

25. The UAS may not be operated less than 500 f eet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the pilot.

26. The flight operations will oc cur in Class G airspace except to the extent that FAA has approved operations in Class B, C, D or E airspa ce. The UAS may not operate within 5 nautical miles of the geographic center of an airport as denoted on a cu rrent FAA-published aeronautical chart unless an agreement with that airport’ s management is obtained, and the operation is
conducted in accordance with a NOTAM. The lette r of agreement with the airport management will be made available to FAA upon request.

27. All aircraft operated in accordance with th e exemption will be identified by serial number, registered in accordance with 14 CF R Part 47, and have id entification (N-Number)- 12 - markings in accordance with 14 CFR Part 45, Subpart C. Markings will be made as large as practicable.

28. The documents required under 14 CFR 91.9 a nd 91.203 will be available to the pilot at the ground control station of the UAS during flight operations. These documents must be made available to the Administrator or any la w enforcement official upon request.

29. The UAS must remain clear and yield the right of way to all other manned operations and
activities.

30. The UAS may not be operated by the pi lot from any moving devi ce or vehicle.

31. In the event a Certificate of Authorizati on (COA) is required, any incident, accident, or flight operation that transgre sses the boundaries of the opera ting area as defined by the applicable COA must be reported to the F AA’s UAS Integration Office within 24 hours. Accidents must be reported to the National Tr ansportation Safety Board (NTSB) in accordance with federal regulations.

32. The operator will comply w ith the operating, inspection, ma intenance and recordkeeping procedures set forth in the Manual.

B. Operations and Training Manuals

Travelers will follow the operating procedures set forth in the Manual that is submitted in support of this petition. The Manual will be main tained and will be made available to FAA upon request. Travelers also antic ipates partnering with the FAA to design and implement an acceptable small UAS pilot training curriculum, which will supplement this petition.

C. Inspection and Maintenance

Travelers will follow the procedures set forth in the Inspection and Maintenance sections of the Manual that is submitted in support of th is petition. The Manual will be maintained and will be made available to FAA upon request.

V. The Aircraft

Travelers proposes to conduct UAS operations using the 3DR IRIS+ and DJI Phantom 2. Without payload, the 3 DR IRIS+ has a weight of 1,282 grams (2.8 pounds) and a range of 300 meters. Its maximum flight time is 22 minutes. Without payload, the DJI Phantom has a weight of 1,160 grams (2.56 pounds) and a range of 300 meters. Its maximum flight ti me is 25 minutes.- 13 - Specifications include:

3 DR IRIS+ DJI Phantom 2

Length x Width x Height 24.5" x 19.5" x 12" 17" x 8.1" x 12.5"

Weight w/o camera 1,282 grams (2.8 pounds) 1,160 grams (2.56 pounds)

Weight with camera 1,996 grams (4.4 pounds) 2,460 grams (5.4 pounds)

Any UAS used by Travelers will include, at a minimum: geo-fencing at a maximum ceiling of 100 feet AGL and within the boundaries of the designed operating areas, flight programming capabilities, and a flight terminati on system. If the UAS loses communications or its GPS signal, it will return to a pre-determin ed location within the planned operating area and
land or be recovered in accordance with th e Manual. The UAS will carry a camera and will weigh approximately 4.4 or 5.4 pounds, depending on type, and will operate at speeds of no more than 15 knots. Operations will occur only during daylight hours. The UAS will have markings identifying the serial number and id entification number (N-number) as large as practicable. UAS operations will co mply with the manufacturer’s manual and safety bulletins.

VI. FAA Has Authority Under FMRA Section 333 to Grant the Requested Exemptions

Grant of this request for exemptions will promote Congress’ goal in enacting Section 333 of the FMRA. Section 333 directs the Secretary of Transportation to consider whether certain UAS may operate safely in the national airspace before completion of the rulemaking required under Section 332 of the FMRA. The Secretary is required to determine the kinds of UAS operations that do not create a hazard to users of the national airspace or the public or pose a threat to national security in light of the UAS’ size, weight, speed, operational capability and areas of operation and whether the operations will occur within the visual line of sight of the
operator. 8 Section 333 reflects Congressional intent that FAA will grant exemptions to allow small UAS operations under conditions that ensure sa fety, like those proposed in this petition.

In addition, the Federal Aviation Act expres sly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil ai rcraft (as that term is defined under § 40101 of the Act, which incl udes UAS) from the requirement that all such
aircraft must have a current airworthiness cert ificate and granting exemptions from the pilot certification requirements. The Administrator may grant an exem ption from a requirement of a

8 FAA Modernization and Reform Ac t of 2012, Pub. L. No. 112-95, 126 Stat. 75- 76 (codified as a Note to 49 U.S.C § 40101).- 14 - regulation prescribed under§§ 44701(a) or (b) or in §§ 44702-44716 of the Act if the Administrator finds the exemp tion in the public interest. 9

VII. Application Information

A. Applicant Information

The name and address of the applicant are:

The Travelers Companies, Inc. Patrick C. Gee Senior Vice President Personal Insurance Claim One Tower Square Hartford, CT 06183 pgee@travelers.com (860) 277-7660

B. List of Regulations from Which Exemption is Requested

14 C.F.R. §§ 61.113(a) and (b); 61.133(a) 14 C.F.R. §91.7(a) 14 C.F.R. §91.119(b) and (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)(1); 14 C.F.R. §§91.409(a)(1) and (2); 14 C.F.R. §§ 91. 417(a) and (b).

C. Federal Register Summary

Petitioner: The Travelers Companies, Inc.

Affected regulations: 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 61.133(a); 14 C.F.R. §91.7(a); 14 C.F.R. § 91.119(b) and (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).

Description: Petitioner seeks an exemption from the requirements of 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 61.133(a); 14 C.F.R. §91.7(a); 14 C.F.R. § 91.119(b) and (c); 14 C.F.R. §

9 49 U.S.C. § 44701(f); see also 49 U.S.C. § 44711(a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203(a)(l).- 15 - 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) to use small unmanned aircraft systems (UAS) in order to conduct small UAS operations re lated to its insurance business, including (but not limited to) roof inspections, underwriting, risk assessment, risk control, accident reconstruction, catastrophe re sponse and small UAS pilot training and development.

VIII. Exemptions Sought by Petitioner

Travelers requests exemptions from the followi ng regulations to the extent necessary to enable the requested UAS operations for the reasons detailed below.

A. 14 C.F.R. §§ 61.113(a) and (b): Private pilot privileges and limitations; 14 C.F.R. § 61.133(a): Commercial p ilot privileges and limitations

Sections 61.113 (a) and (b) limit private pi lots to non-commercial operations. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. FAA has alread y determined that it is appropriate to exempt small UAS pilots from the commercial pilot’ s license requirement in section 61.133(a) in situations analogous to those presented by this petition. See, e.g. , Exemption Nos. 11109, 11110, 11136 and 11138. However, to date, FAA has required such operators to ha ve a private pilot’s
license.

Travelers respectfully submits that, given th e characteristics of the 3DR IRIS+ and DJI Phantom 2 aircraft, the operating restrictions prop osed in this petition, an d Travelers’ proposal to team with FAA to develop a license applicab le specifically to small UAS operators, an equivalent level of safety will be achieved without requiring Travelers’ pilots to hold a private pilot’s certificate or a commercial pilot’s certificate.

The 3DR IRIS+ and DJI Phantom 2 aircraft are exceedingly small and lightweight -- 4.4 pounds and 5.4 pounds, respectively, with payload. Th ey are advertised as “personal” UAS and are already widely flown by hobbyi sts and other recreational fl yers. They operate both autonomously and manually. They have pre-pr ogrammable geofencing, lost-link, and lost-GPS capabilities. In the event of a loss of the commun ications link or GPS, th e aircraft automatically returns to a preprogrammed location. They also have an emergency flight termination system that allows the pilot to cut off power to the ai rcraft, at which time it will land. The UAS will not carry a pilot, passengers or a ny flammable or explosive materials. The operating area is controlled and restricted, and all fl ights are planned and coordinated in advance as set forth in the Manual. Travelers respectfully submits that the proposed operations can achieve an equivalent level of safety by requiring the pilot of these small, lightweight, low-altitude, low-speed, limited range of operations UAS to be trained in a UAS -specific certification program approved by FAA and designed and overseen by an FAA-certificated p ilot. The level of safety provided by the- 16 - requirements included in the Manual exceeds that provided by an individual holding a commercial pilot’s certificate and operating a conventional aircraft . The risks associated with the operation of these small UAS are lower than the level of risks associated with commercial operations contemplated by Part 61; allowing operation of th e UAS as requested therefore exceeds the level of safety achieved by 14 C.F.R. §§ 61.113(a) and (b).

B. 14 C.F.R. § 91.7(a): Civil aircraft airworthiness

Section 91.7(a) requires that no person may operate a civil aircraft unless it is in airworthy condition. Given the ch aracteristics of the UAS (incl uding their extremely small size, weight and payload capacity, very low operatin g altitude, and exceedingly short flight time capability) and the stringent opera ting restrictions and conditions proposed in this petition, an equivalent level of safety will be achieved by compliance with the Manual. Travelers therefore requests FAA to grant an exemption from Secti on 91.7(a) and find that the operator may ensure that the UAS are in an airworthy condition by complying with the Manual and the proposed operating restrictions and conditi ons. FAA has granted similar exemptions in Exemption Nos.
11136 and 11138.

C. 14 C.F.R. § 91.119(b) and (c ): Minimum safe altitudes

Section 91.119(b) and (c) establish certai n minimum altitudes for operation of civil aircraft. Section 91.119 provides, in pertinent part, tha t: “except when necessary for takeoff or landing, no person may operate an aircraft below th e following altitudes: ... (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 high est obstacle within a ho rizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populat ed areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.”

Travelers requests relief from this section si nce the UAS flights will operate at altitudes no higher than 100 feet AGL. Given the small si ze, light weight, low speeds and limited range of the UAS, and the fact that th ey carry no persons or explosive or flammable materials, the UAS flights may be safely operated at much lower altitudes than conventiona l aircraft. Travelers
intends to restrict all of its operations to an altitude of 100 feet and will utilize geo-fencing technology to prevent deviation. Relief from this rule is warranted because the operations will be conducted with the safeguards and under the ope rating conditions outlined herein and in the Manual. The FAA issued an exemption from Section 91.119(c) in Ex emption Nos. 11136 and
11138.- 17 - D. 14 C.F.R. § 91.121: Altimeter settings

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by
reference to an altimeter that is set “to the elevation of the depa rture airport or an appropriate altimeter setting available before departure.” An exemption may be needed because the UAS do not have a barometric altimeter, but instead have a GPS altitude read-out. An equivalent level of safety will be achieved by the operator, pursuant to the Manual, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The FAA issued an exemption to this regulation for UAS operations in Exemption Nos. 11136 and 11138.

E. 14 C.F.R. § 91.151(a): Fuel require ments for flight in VFR conditions

Section 91.151(a) prohibits an individual from beginning “a fl ight in an airplane under VFR conditions unless (considering wind and for ecast 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....”

An exemption is needed because the UAS ha ve a maximum flight time of less than 30
minutes and thus cannot meet the 30-minute reserv e requirement. Given the characteristics of the UAS including their small size, low weight and speed, limited range, ability to land very quickly, operation within visual lin e of sight, restricted operating ar ea, and the fact that they do not carry persons or any explosiv e or flammable materials, grant of the exemption is justified. An equivalent level of safety can be achieve d by terminating flights at 25% battery power reserve, which will occur before the 22 minute flight duration. The FAA issued an exemption to this regulation for UAS operations in Exemption Nos. 11062, 10673, 11136 and 11138.

F. 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 (i ) “shall have that aircraft inspected as prescribed in subpart E of this part and shall between require d inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...” and (ii) shall inspect or mainta in the aircraft in compliance with Part 43. Because these sections and Part 43 apply only to ai rcraft with an airworth iness certificate, these sections will not apply to the petitioner. Maintenance will be accomplished by the operator pursuant to the manufacturer’s manual and the Ma nual. An equivalent level of safety will be achieved because these UAS are very small in size and weight, will carry a tiny payload and operate only in restricted areas fo r short periods of time. If mechanical issues arise, the UAS can- 18 - land immediately and will be operating from no hi gher than 100 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform required 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 an equivalent level of safety. Th e FAA issued an exemption to these regulations in Exemption Nos. 11062, 11136 and 11138.

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

Travelers also requests exemption from such other FARs as the FAA deems appropriate to enable the requested operations. If, duri ng the effective dates of the exemption issued pursuant to this petition, the FAA issues interim or final rules for small UAS, Travelers requests that it be relieved of the requi rements of any conditions and limitations of the exemption and allowed to comply with any less burdensome ap plicable regulations that may have become effective.

IX. Privacy

The petition raises no privacy issues becau se all flights will occur over private or controlled-access proper ty with the property owner’s (or controller’s) pr ior knowledge and consent. Additionally, Travelers’ strict priv acy policies would apply to all UAS operations.

X. National Security

No national security issue is presented by gr ant of this exemption. Given that the UAS are exceedingly small and lightweight, have lost-link and geo-fencing capabilities, will operate at very low speeds, have an extremely low payloa d capacity and carry no flammable, explosive or otherwise dangerous materials, the operati ons pose no threat to national security.- 19 - XI. Conclusion

For the reasons stated above, Travelers’ pr oposed use of UAS satisfies the criteria in FMRA Section 333 regarding size, weight, speed , operating capabilities , operating areas, operation within visual line of sight, and national security. Peti tioner’s proposed safety measures and operating parameters provide more than adequa te justification for the grant of the requested exemptions allowing operation of UAS. Travelers therefore respectfully asks the FAA to grant the requested exemptions, either separately or in th e same grant. Please do not hesitate to contact petitioner’s outside counsel, Carol Gosain, with any que stions about this filing.

Sincerely,



## Pat Ge e

Carol Gosain Steptoe & Johnson LLP 1330 Connecticut Avenue, N.W. Washington, D.C. 20036 (202) 429-6461 cgosain@steptoe.com Patrick C. Gee Sr. Vice President Personal Insurance Claim The Travelers Companies, Inc. One Tower Square Hartford, CT 06183 (860) 277-7660 pgee@travelers.com

Attachments: Manual and additi onal supporting materials.