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

June 15, 2015

U.S. Department of Transportation 1200 New Jersey Avenue, S.E.

Room W12-140 Washington, D.C. 20590

Re: The Travelers Companies, Inc. Request to Amend Exemption No. 11490, Docket No. FAA-2015-0307 Exemption No. 11494, Docket No. FAA-2015-0304

Dear Sir or Madam:

On May 5, 2015, the Federal Aviation Administ ration (“FAA”) granted to The Travelers Companies, Inc. (“Travelers”) Exemption Nos. 11490 and 11494 (the “Exemptions”) in Docket

Nos. FAA-2015-0307 and FAA-2015- 0304, respectively. The Exemptions allow Travelers to operate certain small unmanned aircraft system s (“UAS”) to perform aerial data collection. Travelers hereby respectfully requests an amen dment to each of the Exemptions to allow Travelers to operate an additional type of sm all UAS under the same conditions and limitations set forth in the Exemptions.

In addition to the two types of small UAS already authorized by the Exemptions (i.e., DJI

Phantom 2 and 3D Robotics IRIS+ ai rcraft), Travelers wishes to amend the Exemptions to also allow Travelers to operate the 3D Robotics Solo aircraft. The 3DR Solo is a small (micro) UAS; it weighs 3.3 pounds (1.5 kg.) without payloa d and 3.9 pounds (1.8 kg.) with payload (camera and gimbal). It is 10 inches tall and 18 inches wide. Its maximum speed is 55 miles per hour, well within the prescribed limitation of 100 miles per hour. Its range is roughly 0.5 miles, and its maximum flight time is about 20 minutes. Li ke the small UAS that Travelers is already permitted to operate, the 3DR Solo has geo-fenc ing and flight programming capabilities and a flight termination system. If the UAS loses comm unications or its GPS signa l, it will return to a pre-determined location within the planned operating area and land or be recovered in

accordance with Travelers’ Unmann ed Aircraft System Operating Procedures, Safety Code and Training Syllabus (“Manual”).Travelers’ Manual is already on file with FAA; it was submitted confidentially with Travelers’ original petitions in the above-referenced dockets. The manufacturer’s user manualand preflight checklist for the 3DR Solo are available at: http://3drobotics.com/wpcontent/uploads/2015/06/DraftB.pdf. Travelers will operate the 3DR Solo in accordance with its Manual (as revised from time to time) and the manufacturer’s manual and checklist.

Travelers respectfully submits that good cause exists for not publishing a summary of this request in the Federal Register and for gran ting the requested amendments expeditiously. Travelers asks only to amend its existing Exemp tions to add another t ype of small UAS. Its request would not set any precedent, and any delay in acting on the request would harm Travelers, which intends to begin conducting ope rations using the 3DR Solo as soon as possible after the requested amendments are approved.

Please do not hesitate to cont act Travelers’ outside counsel, Carol Gosain, with any questions about this filing.

Sincerely,



## Pat Ge e

Carol Gosain Steptoe & Johnson LLP 1330 Connecticut Avenue, N.W. Washington, D.C. 20036 (202) 429-6461 cgosain@steptoe.com Patrick C. Gee

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