July 14, 2015

Exemption No. 12030 Regulatory Docket No. FAA

– 20 15

– 1380

Mr. Paul Choi

National Claims Product Director American Family Mutual Insurance Company 6000 American Parkway Madison, WI 53783

Dear Mr. Choi :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated May 1, 2015 , you petitioned the Federal Aviation Administration (FAA) on

behalf of American Family Mutual Insurance Company ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to

conduct aerial photography and videography and to conduct research and development on catastrophe response

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition

in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision+ and DJI Inspire 1

.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria2

provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secretary of Transportation has determined that this aircraft

meets the conditions of Section 33 3. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced s afety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives th e FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, American Family Mutual Insurance Com pany is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the p etitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations

listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surv eying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, American Family Mutual Insurance Company is hereafter referred

to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limite d to the DJI Phantom 2 Vision+ and DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to

amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than

corrective le nses, as specified on the PIC’s FAA

- issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC

must be de signated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its

op erations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the4

Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator mus t follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any l aw enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon w hich the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

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 prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other p eople. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Pr ior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable components, items, or equipment. If the

ins pection 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.

11. The operator must follow the UA S manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

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

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.5

14. The operator may not perm it any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from pers ons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- build ing) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedic ated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accord ance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current

FAA

- publi shed aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses it s GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air T raffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be con ducted under the terms of the attached COA

.6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR pa rt 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear a nd give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, v ehicles, 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 must ensure that nonparticipating persons remain under such protectio n. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator t rainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative.

P ermission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standa rds District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and p hone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certifica te number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes

essentia l to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.8

This exemption terminates on July 31, 2017 , unless sooner superseded or re scinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

EnclosuresJennifer E. Trock Jennifer.trock@pillsburylaw.com May 1, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant to Se ction 333 of the FAA Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

On behalf of American Family Mutual Insura nce Company (“American Family”), pursuant to

Section 333 of the FAA Modernization and Refo rm Act of 2012 (the “Reform Act”) (“Section 333”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, we request an exemption from the Federal Aviation Administration regula tions listed below and di scussed in Appendix A to allow American Family to conduct commerci al operations with the DJI Phantom 2 Vision+ (“Phantom”) 1 and the DJI Inspire 1 (“Inspire”) 2 small unmanned aircraft systems (“sUAS”) for aerial photography and videography in connecti on with homeowner and private-property insurance inspections for policyholders of American Family or its subsidiaries, 3 and to conduct research and development operations to explor e the use of sUAS to improve catastrophe

response. 4

Conducting the requested sUAS operations — building and private property inspection and research and development — can be done safely in the National Airspace System (“NAS”) and is in the public interest for several reasons, whic h are detailed further herein and include: (1) removing safety risks associated with requiring both underwriters and claims adjustors to access and inspect potentially dangerous areas, includi ng slippery or unstable roofs, (2) reducing the risks associated with performing inspections of catastrophe areas with manned aircraft, (3)

1 The Phantom already has been approved for commercial use in similar contexts. See Exemption Nos. 11138,

11153, 11189, 11191, 11195.

2 The Inspire is similar in form and function to the DJI Phantom but is equipped with more sophisticated safety

features (explained below).

3 The FAA has granted similar exemptions. See Exemption 11175, 11293.

4 The FAA has granted similar exemptions. See Exemption 11188, 11309. Pillsbury Winthrop Shaw Pittman LLP 1200 Seventeenth Street, NW | Washington, DC 20036 | tel 202.663.8000 | fax 202.663.8007May 1, 2015 Page 2

reducing time required to complete underwriting and pay claims, (4) improving the efficiency of American Family’s business operations.

Applicant Information:

The names of the applicant: American Family Mutual Insurance Company

The primary contact for this application, with a copy to me at the address above and American Family Corporate Legal at the address below, is:

Paul Choi Corporate Legal

National Claims Product Director Ameri can Family Mutual Insurance Company 6000 American Parkway 6000 American Parkway Madison, WI 53783 Madison, WI 53783 Phone: (608) 242-4100

Exemptions Requested

American Family requests exemptions from the following regulations:

14 C.F.R. Part 21, Subpart H; 14 C.F.R. 61.23(a) and (c); 14 C.F.R. 61.101(e)(4) and (5); 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 61.315(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(1) and (2); 14 C.F.R. 91.417(a) and (b).May 1, 2015 Page 3

Airworthiness of the sUAS

Both the Phantom and Inspire are quadcopters with gimbal-mounted cameras manufactured by DJI, a market leader in sUAS. The Phanto m has been authorized to conduct commercial operations, including property inspections , under several Section 333 exemptions. 5 The Inspire

is DJI’s newer model with enhanced features.

Technical specifications for the Phantom and the Inspire are summarized in the table below.

DJI Phantom 2 Vision+ DJI Inspire 1

Size ~1 foot x 1 foot ~1 foot x 1 foot Total Weight 1242 g (2.74 lbs) 2935 g (6.47 lbs) Max Ascent Speed 6 m/s (12 knots) 5 m/s (10 knots) Max Descent Speed 2 m/s (4 knots) 4 m/s (8 knots) Max Flight Speed 15 m/s (29 knots) 22 m/s (43 knots) Hover Accuracy:

Vertical / Horizontal .8 m (2.6’) / 2.5 m (8.2’) .5 m (1.6’) / 2.5 m (8.2’)

Controller Frequency (Main Channel) 5.725-5.825 GHz (FCC Compliant) 5.725-5.825 GHz (FCC Compliant) Controller Range 800 m (.5 mi) 2 km (1.24 mi)

Communications (Second Channel) 2.4 GHz Wi-Fi (No Interference) 2.4 GHz Wi-Fi (No Interference)

DJI provides a comprehensive suite of training manuals, maintenance procedures and user’s guides for the Phantom and Inspire. 6 Collectively, these documents will be referred to as “Operating Documents” for each specific sUAS model. PICs will be required to comply with all maintenance and inspection procedures out lined in the Operating Documents.

5 See Exemption Nos. 11138, 1115 3, 11189, 11191, 11195.

6 The Phantom Operating Documents are a ttached in Appendix C. The Inspire Operating Documents are attached in

Appendix D. The Phantom Operating Documents are available at http://www.dji.com/product/phantom-2-

vision/download , and the Inspire Operating Documents are available at http://www.dji.com/product/inspire1/download

.May 1, 2015 Page 4

Operating Conditions

American Family requests an exemption subject to the conditions listed in Appendix B, which are similar to the operating conditions required fo r the FAA’s previous grants of exemptions

under Section 333.

In accordance with the conditions approved in prev ious exemption grants, American Family is requesting authority to operate the Phantom and In spire within visual line of sight and below 400 feet AGL, except as provided by FAA Air Traffic Control via COA. These operating conditions, along with those listed in Appendix B, and the s UAS safety features listed below provide an equivalent level of safety.

The following safety features are incorporated in to both the Phantom and In spire to ensure public safety and safe integration into the NAS:

 Stability Control with Auto-Takeoff and Auto -Land: The automated flight-control system can take off and land automatically, and the sy stem autocorrects the aircraft’s position to adjust for environment disturbances such as wind.

 Intelligent Orientation Control (IOC) and In ertial Measurement Unit (IMU): The built-in

inertial sensor and barometric altimeter meas ures orientation and altitude, respectively,

and communicates this data back to the controller.

 Live Map and Radar with Failsafe & Battery Warnings: The contro ller displays a live map and radar to show the aircraft’s recent flight path, heading, bearing and distance from “home” (a predetermined start location within the boundaries of the privately owned property) for complete situation awareness. It also illustrates ba ttery status and lowbattery warnings with estimated time to return “home” to alert the PIC and ensure that the aircraft does not power down unexpectedly during use.

 LED Flight Indicators: LED lights are mounted to the four rotor arms of each model to visually indicate aircraft orientation (attitude ) and status of the f light control system, alerting the PIC of possible issues.

 Maximum Height and Radius Limits: Befo re beginning flight, the PIC may set a maximum altitude and distance that prevent the sUAS from exceeding altitude limits and

distance from “home.”

 Flight-limited Safety Zones: The sUAS flight software comes loaded with a list of

restricted areas that are divide d into one of three categories: category A, category B, or no fly. Category A areas include major international airports; Category B is comprised ofMay 1, 2015 Page 5

smaller airports; and the no-fly zones are sensitive national security areas such as the White House. Each restricted area is comp rised of a no-fly zone in which the sUAS cannot be operated and a warn ing zone surrounding the no-fly zone in which the PIC is alerted to the sUAS’ proximity to a restricted area. Category A areas also include larger

restricted-altitude zones in which the sUAS will only fly below a certain altitude. Additional details regarding the safety zone s can be found in the Phantom and Inspire manuals, attached as Appendices C and D.

 Loss of link. The built-in GPS system that ai ds in stability control will automatically

return the sUAS to “home” if communication between the cont roller and aircraft is lost.

The sUAS will enter failsafe mode when connec tion with the controller is lost and will wait 3 seconds before either landing or re turning to a home point to land, depending on whether the sUAS is operating in GPS mode. When in non-GPS mode, the sUAS automatically lands after 3 seconds. In GPS mode, the aircraft auto matically returns to home and lands. When flying back to home, the aircraft first will ascend to pre-set

altitude to avoid obstacles. If the aircraft is above the pre-set altitude when loss of link occurs, it will fly directly back to the home point.

 Loss of GPS. If a loss of GPS occurs, the PI C maintains positive control of the aircraft and can either land the sUAS, hover in pl ace until GPS is reacquired, or continue the flight. Additionally, the sUAS have the ability to abort a flight in the event of unpredicted obstacles or emergencies.

Operator Requirements

As a condition to the grant of the exemptions, American Family will require that the PIC hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC

will also hold a current FAA airman medical certific ate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC will meet the flight review requirements specified in 14 CFR § 61.56 in an

aircraft in which the PIC is rate d on his or her pilot certificate.

At the conclusion of the training, the PIC will be able to safely operate the sUAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and structures. This training will include the follo wing, to the extent necessary for the operations:

1) Perform an appropriate number of flights with the specific sUAS to be operated to obtain proficiency.May 1, 2015 Page 6

2) Successfully learn and demonstrate all relevant flight maneuvers in the Phantom 2 Vision Pilot Training Guide. 7

3) Study and be knowledgeable of all relevant sections of the model-specific User’s Manual, Safety Guidelines, Battery Safety Guidelines , and other relevant applicable manuals, updates, alerts, warnings and safety bulletins provided by DJI for the specific sUAS to be operated.

4) Study and be knowledgeable of a ll relevant sections of the Inspire 1 Maintenance Manual

and the Guide to the Phantom 2 Vision & Vision+. 8

5) Understand and demonstrate relevant evasiv e maneuvers outlined in the “Always be Prepared for the Worst” scenarios outlined in the Guide to the Phantom 2 Vision & Vision+ (applicable for operators of both the Phantom and the Inspire 1).

Training flights will be conducted over private or controlled-acce ss property, including but not limited to American Family’s headquarters, wh ich is located at 6000 American Parkway in Madison, Wisconsin. Training flights will be logged for each PIC in training in a manner consistent with 14 CFR § 61.51(b).

American Family respectfully submits that th e operator qualifications take into account the operating conditions and charac teristics of the sUAS.

Public Interest

American Family respectfully submits that using sUAS to inspect roof t ops in lieu of requiring its employees to visually inspect roofs and to conduct research and deve lopment into catastrophe support operations offers a net safety benefit and will achieve an enhanced level of safety, as mandated under Section 333(c) of the Reform Act. Approval of this appli cation also will benefit the public interest by providing faster and more cost-efficient insuranc e claim processing and insurance underwriting.

7 Since the maneuvers are universal, the Phantom Training Guide will be used for training PICs on both the Inspire

1 and the Phantom.

8 The Guide to the Phantom 2 Vision & Vision+ contains maintenance information and technical and safety-related

guidelines. It is included in Appendix C. The Guide to the Phantom 2 Vision and Vision+ also is available at https://www.dro pbox.com/s/mv8d1hohc3mceym/DJI%20Phantom%2 0Vision%20Summary%20Guide.pdf?dl=0.May 1, 2015 Page 7

Inspection operations over catastrophe areas wi th conventional manned aircraft involve very heavy aircraft, transiting to the operational location, carrying signi ficant quantities of combustible fuels, and a multi-person crew in piloting and observation roles. By contrast, the sUAS weigh less than seven pounds, use a battery for power , are carried to and from the area of activity, remove the need for ai rborne pilots and observers, a nd pose less risk to people and infrastructure on the ground, as well as other aircraft.

Additionally, no national security issue is raised by the grant of the requ ested exemption due to the sUAS’ small size and load-carrying capacity, as well as their operational limitations and lack

of flammable fuel. All PICs will have been scre ened by the Department of Homeland Security.

The grant of the requested exemption is in the public interest based on the clear direction in Section 333 and 49 U.S.C. § 44701(f), 9 the equivalent and enhanced level of safety of the proposed operations, and the significan t public benefit, and cost saving s to be realized as a result

of the use of sUAS for aerial in spections. Accordingly, the applic ant respectfully requests that the FAA grant the requested exemption without delay.

Privacy Concerns

The proposed operations will take place only over private or controlled-access property and only after obtaining written or verbal consent from the individual who owns or controls the property or is the property owner’s authorized representa tive before each flight. No privacy issues are raised by this application.

Federal Register Summary

Pursuant to 14 C.F.R. § 11.81(f), the following summary is provided for publication in the Federal Register, should the FAA dete rmine that publication is needed:

Docket No.: No. FAA-2015-____ Petitioner: American Family Mutual Insurance Company Section of 14 CFR: Part 21, Subpart H, § 61.23(a) and (c), § 61.101(e)(4) and (5), § 61.113(a) and (b), § 61.315(a), § 91.7( a), § 91.119(c), § 91.121, § 91.151(a), § 91.405(a), § 91.407(a)(1), § 91.409(a)(1) a nd (2), and §91.417(a) and (b).

9 Pursuant to 49 U.S.C. § 44701(f), the “Administrator may grant an exemption 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.”May 1, 2015 Page 8

Description of Relief Sought: American Family seeks an exemption to conduct commercial building and private property in spection operations using a small unmanned aircraft (55 pounds or less).

Sincerely,

Jennifer E. Trock

cc: Mark V. Afable, Chief Legal Officer, Am erican Family Mutual Insurance Company Scott J. Seymour, Corporate Legal & Regulator y Affairs Vice President, American Family Mutual Insurance CompanyMay 1, 2015 Page 9

APPENDIX A

EXEMPTION REQUEST AND EQUI VALENT LEVEL OF SAFETY

SHOWINGS UNDER APPLICABLE RU LES SUBJECT TO EXEMPTION

American Family requests an exemption from the following regulations as well as any additional regulations that the FAA deems necessary to the operation of the DJI Phantom Vision 2+ and DJI Inspire 1 sUAS:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

Tile 14, Part 21, Subpart H of th e Code of Federal Regulations establishes the procedural requirements for the issuance of airworthiness ce rtificates as required by § 91.203(a)(1). Given the size and weight of the aircraft, the opera ting conditions, design safety features, and the proposed conditions and limitations, it is unnecessary to go thro ugh the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels. Such an exemption meets the requirements of an equivale nt level of safety unde r Part 11 and Section

333. Section 333 authorizes the FAA to exempt aircraft from the requirement for an

airworthiness certific ate, upon consideration of the size, weight, spee d, operational capability, and proximity to airports and populat ed areas of the sUAS involved.

In this case, an analysis of these criteria demons trates that the sUAS operated without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or roto rcraft) with an airworthiness certificate. The Phantom and Inspire weigh 2.74 and 6.47 pounds, resp ectively. They will not carry a pilot,passenger or flammable fuel. They will operate exclusively within a controlled area predisclosed and in compliance with the condition s set forth herein. Unlike other civil manned aircraft operations, operations under this exempt ion will be tightly c ontrolled and monitored by the PIC and visual observer, pursuant to the co nditions set forth in A ppendix B, the Operating Documents, and local public safety requirement s. The FAA will have advance notice of all operations, to the extent required, through the fili ng of NOTAMs. The lack of flammable fuel

and the fact that the aircraft are carried to the location and not flown there all establish an equivalent level of safety. The s UAS provide at least an equivalent level of safe ty to that of such operations being conducted with conventional aircra ft that would be orders-of-magnitude larger and would be carrying passengers, cargo, and flammable fuel.

14 C.F.R. § 61.23 (a) & (c)

Section 61.23(a) requires a person exercising the priv ileges of a transport p ilot certificat e to hold a first-class medical certificate, the privileges of a commercial pilot certificate to hold a secondclass medical certificate, and the privileges of a private or recreational pilot certificate to hold aMay 1, 2015 Page 10

third-class medical certificate. Section 61.23(c) requires a person to hold a medical certificate or U.S. driver’s license when exercising the privileg es of a sport pilot certificate in a light-sport

aircraft other than a glider or balloon.

The operations proposed herein will provide an equivalent level of safety by complying with the conditions and limitations of this exemption. The FAA has found that these conditions and limitations provide an equivalent level of safety in numerous previous exemptions, including but not limited to Exemptions 11213, 11252, 11275, 11277, and 11278.

14 C.F.R. § 61.101 (e)(4) & (5): Re creation Pilot Privilege a nd Limitations; 14 C.F.R. § 61.315(a): What are the privileges and limits of my sport pilot certificate

Section 61.101(e)(4) prohibits a recreational pilot from acting as pilot in command of an aircraft for compensation or hire. Section 61.101(e)(5) prohi bits a recreational pilo t from acting as pilot

in command of an aircraft in furtherance of a business. Section 61.315(a) authorizes persons holding a sport pilot certificate to act as pilot in command of a light-sport aircraft.

As with previous Section 333 exemptions, 10 an equivalent level of sa fety is established because (1) the aeronautical knowledge requirements that would be applicable to UAS operations for a recreational pilot and sport pilot certificate were s ubstantially similar as those for a private pilot certificate; (2) holders of recreati onal and sport pilot certificates are subject to security screening by the Department of Homeland Security; and (3) risk was mitigated through conditions and limitations regarding PIC training.

14 C.F.R. §§ 61.113(a) & (b): Commercial Pilot Privileges

Sections 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a

conventional aircraft that carries a pilot, passengers, and cargo, the UAS are remotely controlled with no passengers or property of others on board. The area of operation is controlled and restricted, and all flights are planned and coordi nated in advance as set forth in the Operating Documents. In conjunction with the PIC’s require d training, the level of safety provided by the requirements included in the Operating Docume nts meets or exceeds that provided by a single individual holding a commercial pilot certificate operating a conve ntional aircraft. The proposed operations will achieve at least an equivalent level of safety.

10 See, e.g., Exemption Nos. 11310, 11311, 11312, 11313, 11315.May 1, 2015 Page 11

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Section 91.7(a) prohibits an indivi dual from operating a civil aircra ft unless it is in an airworthy

condition. No FAA standard exists for determ ining an aircraft’s airworthiness when an

airworthiness certificate is not issued. As th e FAA has done with previous exemption grants, 11
airworthiness will be ensured and an equivalent level of safety will be achieved by compliance with the Operating Document s prior to every flight.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for oper ation of civil aircraft . Specifically, Section 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sp arsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehi cle, or structure. Because the aerial photography and videography wo rk must be accomplished at altitudes less than 500 feet AGL an exemption is required.

The equivalent level of safety will be ach ieved given the sUAS’ size, weight, speed, and proposed operating conditions. sUAS operations will be conducted over private or controlledaccess property with consent granted by th e property owner/contro ller or authorized representative prior to each operation.

14 C.F.R. § 91.121: Altimeter Setting

Section 91.121 requires each person operating an ai rcraft 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.” The Phantom’s and Inspires’ Inertial Measurement Units have barometric altimeters, but they ca nnot be set to the elevation of the departure location. Rather, upon initialization, the sUAS calibrate their posi tions without user input and transmit a single altitude measurement to the gr ound station. Thus, an ex emption is required. An equivalent level of safety will be achie ved by the operator, pursuant to the Operating Documents, confirming the altitude of the launc h site shown on the altitude indicator before flight.

11 Exemption Nos. 11156, 11158, 11159.May 1, 2015 Page 12

14 C.F.R. § 91.151(a): Fuel Requirement s for Flight in VFR Conditions

This regulation 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 cruisi ng speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that fo r at least 45 minutes.”

The Phantom and Inspire batterie s provide approximately 25 and 18 minutes of powered flight, respectively. Without an exem ption from 14 C.F.R. § 91.151, the sUAS flights would not be allowed. Given the limitations on its proposed opera tions, allowing the sUAS to operate without the required reserve fuel is reasonable a nd is consistent with prior exemptions. 12 An equivalent level of safety will be achieved because operatin g the sUAS without 30 minutes of reserve fuel does not engender the type of ri sks that Section 91.151(a) was mean t to prevent given the size and speed at which the sUAS operate. In the unlikely event that a sUAS should run out of battery power, it would simply land. Given th e sUAS’s weight and co nstruction material, the risks are less than contemplated by the curren t regulation. American Family will require the

UAS to return home and land when th e battery reaches 30% capacity.

14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) & (b): Maintenance Inspections

Section 91.405(a) requires that an ai rcraft operator or owner “shall ha ve 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 discrepancie s repaired as prescribed in part 43 of this chapter.” Section 91.407 simila rly makes reference to requirements in Part 43. Section 91.409(a)(2) requires an annual inspection for the issu ance of an air worthiness certificate. Section 91.417(a) requires the owner or operator to keep records showi ng certain maintenance work that has been accomplished by certificated m echanics, under Part 43, or licensed pilots and records of approval of the aircra ft for return to service.

An equivalent level of safety will be achieved by complying with the Operating Documents maintenance and inspection requirements because the sUAS will carry no external payload, will operate only in restricted predeter mined areas. In addition, the PIC will ensure that the sUAS is in working order prior to initiating flight, perf orm required maintenance, and keep a log of any

12 Exemption 10673 (allowing Lockheed Martin Corpora tion to operate without compliance with 91.151(a)); see also Exemptions 2689F, 5745, 10673 and 10808.May 1, 2015 Page 13

maintenance that is performed. Moreover, the PI C is the person most familiar with the aircraft

and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety.May 1, 2015 Page 14

405048798v1 APPENDIX B

AMERICAN FAMILY OPERATING LIMITATIONS

1) Operations authorized by the grant of exem ption are limited to the following aircraft:

DJI Phantom 2 Vision+ and DJI In spire 1, which weigh 2.74 and 6.47 pounds, respectively.

2) The DJI Phantom 2 Vision+ shall not be flow n at a speed exceeding 15 m/s. The DJJI Inspire 1 shall not be at flow n at a speed exceeding 22 m/s.

3) The sUAS will not be operated at an altitude more than 400 feet above. All altitudes reported to ATC shall be in feet AGL.

4) The sUAS must be operated within visual li ne of sight of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

5) All operations must use a VO. The VO an d PIC must be able to communicate verbally at all times. The PIC must be de signated before the flight. The PIC must ensure that the VO can perform the functi ons prescribed in the operating documents.

6) The operating documents and this grant of exemption must be accessible during UAS operations and made available to the Admi nistrator upon request. If a conflict exists

between the conditions and limita tions in the exemption and the procedures outlined in the operating documents, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, American Family must follow the procedures as outlined in its operating doc uments. American Family may update or revise its operating documents. It is Amer ican Family’s responsibility to track such revisions and present updated and revise d documents to the Administrator upon request. American Family must also pr esent updated and revised documents if it petitions for extension or amendmen t to this grant of exemption.

7) Prior to each flight th e PIC must inspect the sUAS to en sure that it is in a condition for safe flight. The PIC shall not operate the aircraft if the inspection reveals a condition that affects the safe operation of the sUAS until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be in cluded in the preflight inspection. All maintenance and alternations must be prope rly documented in the aircraft records.

8) Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics (e.g., repl acement of a flight critical component)May 1, 2015 Page 15

405048798v1 must undergo a functional test flight in acco rdance with the Operator’s Manual. The

PIC who conducts the functional te st flight must make an en try in the aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry shall be include d in the Operator’s Manual.

9) The pre-flight inspection must account for all discrepancies, e.g. inoperable components, items, or equipment, not alread y covered in the releva nt sections of the operating documents.

10) American Family must follow DJI’s airc raft/component, mainte nance, overhaul, replacement, inspection, a nd life limit requirements.

11) American Family must carry out its main tenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhau l component parts must be noted in the aircraft records, including total time in servic e, description of work accomplished, and the signature of the person authorized to return the sUAS to service.

12) Each sUAS operated under this exemption mu st comply with all manufacturer Safety

Bulletins.

13) The PIC must hold either an airline transpor t, commercial, private, recreational, or sport pilot certificate. The PIC must al so hold a current FAA airman medical

certificate or a valid U.S. driver’s license is sued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements speci fied in 14 CFR § 61.56 in an aircraft in

which the PIC is rated on hi s or her pilot certificate.

14) American Family may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demons trates the ability to safely operate the

sUAS in a manner consistent with how the sUAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels , vehicles and structures. 13 PIC qualification flight hours and currency must be logged in a manne r consistent with 14 C.F.R. § 61.51(b). The PIC must ensure that the VO is trained appropriately in order to fulfill his or her duties. A record of training and qualificat ion must be documented and made available

13 Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy

this requirement.May 1, 2015 Page 16

405048798v1 upon request by the Administrator. Flights for the purposes of tr aining the operator’s PICs and VOs (training, proficiency, a nd experience-building), are permitted under the terms of this exemption. However, trai ning operations may only be conducted during dedicated training sessions. During trai ning, proficiency, and experience-building flights, all persons not esse ntial for flight operations ar e considered nonparticipants, and the PIC must operate the UA with approp riate distance from nonparticipants in accordance with these operating conditions.

15) Operations may not be conduc ted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (“VMC”). Flights under special visual flight rules (“SVFR”) are not authorized.

16) The sUAS may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronauti cal chart unless a letter of agreement with that airport’s management is obt ained, and the operation is conducted in accordance with a NOTAM as required by Am erican Family’s COA. The letter of agreement with the airport management must be made available to the Administrator
upon request.

17) The sUAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18) If the sUAS loses communications or loses it s GPS signal, the sUAS must return to a pre-determined location within the pr ivate or controlled-access property.

19) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the Operator’s Manual.

20) The PIC will be prohibited from beginni ng a flight unless (considering wind and forecast weather conditions) there is enough po wer to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining in accordance with the operating documents.

21) All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.

22) All aircraft operated in accordance with the requested exemption must be identified by serial number, registered in accordance with 14 C.F.R. Part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings shall be as large as practicable.May 1, 2015 Page 17

405048798v1 23) The radio frequency spectrum used for ope ration and control of the sUAS must comply with Federal Communication (F CC) or other appropriate government oversight agency requirements.

24) The documents required under 14 C.F.R. §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the sU AS any time the aircraft is operating.

These documents shall be made available to the Administrator or any law enforcement official upon request.

25) The sUAS must remain clear and yield the ri ght of way to all other manned operations

and activities at all times.

26) The sUAS may not be operated from any moving device or vehicle.

27) The sUAS may not be operated over c ongested or densely populated areas.

28) Flight operations must be conducted at least 500 feet from all nonpart icipating persons, vessels, vehicles, struct ures, and public access roads unless:

a. Barriers or structures are present th at sufficiently protect nonparticipating persons from the sUAS and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the sUAS, flight ope rations must cease immediately and/or;

b. The owner/controller of any vessels, ve hicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

29) Operations nearer than 500 feet to the PIC, VO, operator trainees or essential persons as defined in the operating documents are permitted if those operations do not present an undue hazard to those persons per § 91.119(a) as determined by the PIC.

30) All operations must be conducted over private or controlled-access property.

31) Any incident, accident, or fli ght operation that transgress es the lateral or vertical boundaries of the operati onal area as defined by the app licable COA shall be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.