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 Pursuant 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 Modernization and Reform Act 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 Regulations (“FARs”) and any other rules necessary 

to allow operation of small unmanned aircraft systems (“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 requests authorization to conduct small UAS operations 

related to its insurance business, including (but not limited to) roof inspections, underwriting, 

risk assessment, risk control, accident reconstruction and small UAS pilot training and 

development. As explained below, operations under 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 insurance companies in 

 1

 Travelers is filing this petition on behalf of itself and all of its respective parents, 

subsidiaries, affiliates, predecessors, successors and assigns. 
- 2 - 

the United States, Travelers has continuously kept up with developing 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-ever 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 Inspection of Private Property 

Travelers requests an exemption to use UAS to inspect, photograph and assess the nature 

and extent of damage to policyholders’ private property. Travelers would conduct these UAS 

operations only with the express written consent of the property owner. Travelers is specifically 

interested in studying how UAS can be used to obtain precise and detailed images of a 

policyholder’s roofing system and any other portions of the property that would normally require 

utilization of a ladder to acquire such information. This experience will give Travelers the 

necessary information in order to determine how best to implement this innovative technology to 

more rapidly adjust claims, enhance customer experience, and further Travelers’ overall goal of 

improving safety for its personnel, vendors and customers. 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’ customer experience and claim effectiveness, 

granting this petition would improve safety for 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 ladder assisted inspections per year. Generally, 

our claim practices require visual inspections of roof damage by ladder, which undeniably carries 

certain unavoidable risks. These inspections require that persons climb onto roofs from a ladder 

and traverse the roof, which is usually a downward pitched surface, in order to inspect and take 

pictures. The inherent risks associated with roof inspections include potential harm to the person 

carrying out the inspection if he or she fell; the potential harm to persons on the ground that may 

be impacted by a falling person or ladder; and the potential property damage that may be caused 

by a falling person or ladder. Travelers 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 and light weight, low operating altitude, and geofencing and other capabilities, and the operating parameters and comprehensive training that 

Travelers would require. Over the long term, granting this petition will undoubtedly save lives, 
- 3 - 

prevent serious injuries, and reduce collateral property damage that might have occurred utilizing 

even the strictest safety protocols. 

In addition, Travelers believes that, with appropriate process refinement, inspection via 

UAS will not only be safer than ladder inspections, but will be quicker and will result in an 

enhanced customer experience. While the benefits of efficiency are self-evident, they bear 

mention in this petition to demonstrate the significant public interests associated with Travelers’ 

proposed UAS integration. Frequently, roof inspections can take longer to coordinate than other 

types of inspections and, in many instances, do not take place during the first inspection of the 

property. As a result, the claim process takes longer, which means that it takes longer for repairs 

to take place and longer for customers’ lives to return to normal. Under Travelers’ proposed 

UAS model, more roof inspections would take place immediately and, in virtually every case, 

Travelers would be in a position to issue roof damage 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 Travelers’ 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 payments, timelier repairs and have the opportunity to 

more quickly recover from losses. Further, when considered within the context and scale of 

catastrophic events such as hurricanes, tornados or earthquakes, these 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 footprint around and above an individual 

structure. The vast majority of UAS work will take place just ten to fifteen feet above the roof’s 

surface. Since the UAS will be operated within close 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 lost-link and geo-fencing technology to best 

control against a fly away scenario. 

Travelers is requesting permission 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 provide Travelers and the FAA with a unique 

opportunity to partner in experimenting 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 altitude 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 would be conducted by individuals on ladders. As 

discussed above, while Travelers takes ladder safety seriously, there are always inherent risks to 

persons and property associated with roof inspections and those risks could be completely 

eliminated by use of UAS. 

Travelers proposes to fly UAS on 50 Agribusiness 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 policyholder 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 arising 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 inspections 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 further the overall goal of eliminating the inherent 

risks of ladder assisted inspections. When combined 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, Travelers’ operations would pose no threat to national airspace or 

neighboring persons or property. Further, Travelers would partner with the FAA to gain more 

valuable UAS experience while improving the overall safety of its operations by eliminating the 

risks inherent in ladder assisted inspections. 

Travelers proposes to fly UAS on 50 Personal 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 loss 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 arising on properties located in nonmetropolitan areas. Once Travelers has demonstrated to the FAA’s satisfaction that it has 

mastered safe UAS operations under Phases 1 and 2, Travelers would like to partner with the 

FAA to take the next step and conduct UAS inspections that could potentially reach the majority 

of its claim inventory. Travelers expects to establish a strong safety record in Phases 1 and 2 and 

will carry over the learnings and improvements from 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 safety by eliminating the majority of Travelers’ 

ladder assisted roof inspections. 

When combined 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, 

Travelers’ operations would pose no threat to national airspace or neighboring persons or 

property. Further, Travelers would partner with the FAA to gain more valuable UAS experience 

while improving the overall safety of its operations by eliminating the risks inherent in ladder 

assisted inspections. 

 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 policyholder private property. 

 

B. Request to Use UAS for R&D, Training and Certification Development at 

Sites Owned or Controlled by Travelers 

Travelers also requests an exemption to use UAS to perform R&D, training and develop 

pilot certification at Travelers’ own 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 expertise 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 facility, located at 99 Lamberton 

Rd., Windsor, CT 06095, for the purposes of developing and implementing a pilot certification 

program. Our Claim University facility is located in a sparsely populated area on 50 acres of 

land that is completely controlled by Travelers. The testing facility will not be open to the public 

and access will be restricted to Travelers employees or consultants engaged in test or test-related 

work. The test site may at times contain structures, which will enable Travelers 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 operating altitude of 100 feet or less, lost-link, 

geo-fencing and additional 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 Assessment, 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 underwriting evaluations for its Business and Personal 

insurance property policyholders. In particular, Travelers anticipates that UAS could be used to 

carry out inspections and evaluations of elevated portions of structures including roofs that 

provide unique challenges and risks. In the risk control context, these inspections are currently 

conducted by persons on ladders with the attendant 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 enhance safety as well as improve overall risk 

control and underwriting efficiency and accuracy to the benefit of our policyholders. 

II. Pilot Requirements 

 Travelers would like to partner with the FAA to design a pilot certification program that 

focuses on the skills, knowledge and expertise required to operate small 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 implement 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 the 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 considered “small” by the FAA, i.e., up to 55 

pounds. The program Travelers intends to design will be tailored to address the safety concerns 

specific to very lightweight UAS, which -- at 4.4 or 5.4 lbs. -- pose little to no risk to the national 

airspace and neighboring persons or property. 

Travelers will be submitting a training program designed by an on-staff commercially 

certificated pilot that has an extensive security 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 fully 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 pilot to: (a) successfully complete 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 and model of UAS to be utilized for operations 

under this exemption; (d) certify that he or she has no medical defect that 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 take place under the direct supervision and control 

of a person holding an FAA commercial or private pilot certificate.4

 

III. Public Interest Benefits

 Approval of Travelers’ request to use UAS to inspect policyholders’ private property is in 

the public interest. Granting this petition advances Congress’ goal of integrating civil UAS into 

the national airspace safely and expeditiously. Allowing Travelers to conduct the inspections 

proposed herein is a necessary step toward realizing the consumer benefits of using UAS in the 

insurance industry. Travelers 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 available 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 balloons without a medical certificate. 

Travelers’ operations would pose less threat to national airspace or neighboring persons or 

property than gliders and balloons, which are heavier and operated at higher altitudes. 

4

 Travelers recognizes that the FAA has concluded that it does not have 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 Travelers, would develop a pilot 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 FAA reconsider its decision in this 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 any 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 the model for FAA’s small UAS rulemaking. 

Further, Travelers’ petition seeks to implement UAS inspections in a gradual, stairstepped process so that we can work with the FAA to develop and refine our operations, under 

strictly controlled conditions, that will lead to continuously improving flight protocols. Travelers 

will share its experience, data and process enhancements with the FAA, which will benefit the 

public with respect to FAA rulemaking and comment on small UAS. Travelers should be in a 

position to provide a considerable amount of meaningful knowledge and data within a relatively 

short period of time. 

In addition to improving UAS operational safety, 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 will be able to eliminate the risks associated with 

ladder inspections and improve overall safety to persons and property. As an added benefit, 

Travelers believes that inspection via UAS will not only be safer than ladder inspections, but 

may also be quicker and more accurate. Travelers also believes that these benefits will carry 

over to other areas of the company such as risk control and underwriting and 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 national 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 pounds 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 aircraft and has previously granted exemptions 

approving use of the DJI Phantom 2 aircraft for commercial operations. See Exemption Nos. 

11138, 11153 and 11157. 
- 9 - 

3. The UAS will not carry persons, explosive 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 altitude 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. The ground control station must be included in the 

preflight inspection. All maintenance and alterations 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., replacement 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 Manual includes the requirement that the preflight 

inspection must account for all discrepancies, i.e., inoperable components, items or equipment, 

etc. 

10. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection and life limit requirements. 

11. The operator must carry out its maintenance, inspections and recordkeeping requirements in 

accordance with the Manual. Maintenance, inspection and alterations must be noted in the 

aircraft records, including total flight hours, description of work accomplished and the signature 

of the authorized person returning the UAS to service. 

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

bulletins. 

 6

 Travelers is submitting its Unmanned Aircraft System Operating Procedures, Safety 

Code and Training Syllabus (“Manual”) to FAA confidentially with a request for confidential 

treatment pursuant to 14 CFR Section 11.35(b). The Manual contains confidential, proprietary 

and commercially sensitive information that has not been made available to the public and that is 

protected under the Freedom 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 designed for small UAS operators; (c) 

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 and model 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 small 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 operations 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 accomplished three takeoffs and landings in the preceding 

90 days. 

16. All operations shall be conducted over private or controlled-access property with permission 

from the land owner/controller or authorized representative. Permission from the land 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

17. Flight operations will be conducted at least 50 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. The operator will ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 50 feet of the UA, flight 

operations must cease immediately; and/or 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller 

of such vessels, vehicles or structures has granted permission and the pilot has made a 

 7

 FAR 61.23 permits piloting of gliders and balloons without a medical certificate. 

Travelers operations would pose less threat to national airspace or neighboring persons or 

property than gliders and balloons, which are heavier and operated at higher altitudes. 
- 11 - 

safety assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard; and 

c. Operations nearer to the pilot, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a). 

18. A geo-fencing perimeter will be established 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 safely operate the UAS in a manner consistent 

with how the UAS will be operated under the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

23. All operations must be conducted under visual meteorological conditions (VMC) and during 

daylight hours. 

24. Before operations begin under the exemption, 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 feet 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 occur in Class G airspace except to the extent that FAA has 

approved operations in Class B, C, D or E airspace. The UAS may not operate within 5 nautical 

miles of the geographic center of an airport as denoted on a current 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 letter of agreement with the airport management 

will be made available to FAA upon request. 

27. All aircraft operated in accordance with the exemption will be identified by serial 

number, registered in accordance with 14 CFR Part 47, and have identification (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 and 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 law 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 pilot from any moving device or vehicle. 

31. In the event a Certificate of Authorization (COA) is required, any incident, accident, or 

flight operation that transgresses the boundaries of the operating area as defined by the 

applicable COA must be reported to the FAA’s UAS Integration Office within 24 hours. 

Accidents must be reported to the National Transportation Safety Board (NTSB) in accordance 

with federal regulations. 

32. The operator will comply with the operating, inspection, maintenance 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 maintained and will be made available to FAA upon 

request. Travelers also anticipates 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 this 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 time 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 termination system. If the UAS loses communications or 

its GPS signal, it will return to a pre-determined location within the planned operating area and 

land or be recovered in accordance with the 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 identification number (N-number) as large as 

practicable. UAS operations will comply 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 safety, like those proposed in this petition. 

 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 that term 

is defined under § 40101 of the Act, which includes UAS) from the requirement that all such 

aircraft must have a current airworthiness certificate and granting exemptions from the pilot 

certification requirements. The Administrator may grant an exemption from a requirement of a 

 8

 FAA Modernization and Reform Act 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 exemption 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 related to its insurance business, including (but 

not limited to) roof inspections, underwriting, risk assessment, risk control, accident 

reconstruction, catastrophe response and small UAS pilot training and development. 

VIII. Exemptions Sought by Petitioner 

 Travelers requests exemptions from the following 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 pilot privileges and limitations 

 Sections 61.113 (a) and (b) limit private pilots 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 already 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 have a private pilot’s 

license. 

Travelers respectfully submits that, given the characteristics of the 3DR IRIS+ and DJI 

Phantom 2 aircraft, the operating restrictions proposed in this petition, and Travelers’ proposal to 

team with FAA to develop a license applicable 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. They are advertised as “personal” UAS and 

are already widely flown by hobbyists and other recreational flyers. They operate both 

autonomously and manually. They have pre-programmable geofencing, lost-link, and lost-GPS 

capabilities. In the event of a loss of the communications link or GPS, the 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 aircraft, at which time it will land. The UAS will not 

carry a pilot, passengers or any flammable or explosive materials. The operating area is 

controlled and restricted, and all flights 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 pilot. 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 the 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 characteristics of the UAS (including their extremely small size, 

weight and payload capacity, very low operating altitude, and exceedingly short flight time 

capability) and the stringent operating 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 Section 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 conditions. 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 certain minimum altitudes for operation of civil 

aircraft. Section 91.119 provides, in pertinent part, that: “except when necessary for takeoff or 

landing, no person may operate an aircraft below the 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 highest obstacle within a horizontal 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 populated 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 since the UAS flights will operate at altitudes 

no higher than 100 feet AGL. Given the small size, light weight, low speeds and limited range 

of the UAS, and the fact that they carry no persons or explosive or flammable materials, the UAS 

flights may be safely operated at much lower altitudes than conventional 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 operating conditions outlined herein and in the 

Manual. The FAA issued an exemption from Section 91.119(c) in Exemption 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 departure 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 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....” 

 An exemption is needed because the UAS have a maximum flight time of less than 30 

minutes and thus cannot meet the 30-minute reserve 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 line of sight, restricted operating area, and the fact that they do 

not carry persons or any explosive or flammable materials, grant of the exemption is justified. 

An equivalent level of safety can be achieved 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 required 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 maintain the aircraft in compliance with Part 43. 

Because 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 manufacturer’s manual and the Manual. 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 for short periods of time. If mechanical issues arise, the UAS can 
- 18 - 

land immediately and will be operating from no higher 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. The 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, during 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 requirements of any conditions and limitations of the exemption and 

allowed to comply with any less burdensome applicable regulations that may have become 

effective. 

IX. Privacy 

The petition raises no privacy issues because all flights will occur over private or 

controlled-access property with the property owner’s (or controller’s) prior knowledge and 

consent. Additionally, Travelers’ strict privacy policies would apply to all UAS operations. 

X. National Security 

 No national security issue is presented by grant 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 payload capacity and carry no flammable, explosive or 

otherwise dangerous materials, the operations pose no threat to national security. 
- 19 - 

XI. Conclusion 

 For the reasons stated above, Travelers’ proposed 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. Petitioner’s proposed safety measures 

and operating parameters provide more than adequate 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 the same grant. Please do not hesitate to contact 

petitioner’s outside counsel, Carol Gosain, with any questions about this filing. 

Sincerely, 

 

Pat Gee

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 additional supporting materials.