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 Administration (“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 systems (“UAS”) to perform aerial data collection. 

Travelers hereby respectfully requests an amendment to each of the Exemptions to allow 

Travelers to operate an additional type of small 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+ aircraft), 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 payload 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. Like the small UAS that Travelers is already 

permitted to operate, the 3DR Solo has geo-fencing and 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 Travelers’ Unmanned 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 manual 

and 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 granting the requested amendments expeditiously. 

Travelers asks only to amend its existing Exemptions to add another type 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 operations using the 3DR Solo as soon as possible 

after the requested amendments are approved. 

Please do not hesitate to contact Travelers’ 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