GREER, HERZ & ADAMS, L.L.P. 

A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 

MARC D. YOUNG 

409.797.3234 

866.422.4270 fax 

myoung@greerherz.com 

ATIORNEYS AT LAW 

January 27, 2016 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, D.C. 20590 

One Moody Plaza, 181

h Floor 

Galveston, Texas 77550 

www.greerherz.com 

Re: American National Insurance Company's Petition for an Exemption Pursuant to 

Section 333 ofthe FAA Modernization and Reform Act of2012 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the 

"Reform Act") and 14 C.F.R. Part 11, American National Insurance Company ("Petitioner" or 

"ANICO") hereby applies for an exemption from the Federal Aviation Regulation·s'{"FARs") 

described below and ·any other exemptions necessary to allow Petitioner to commercially operate 

small Unmm'med Aircraft Systems ("UAS") 'tinder the 'conditions set forth in'this petition. 

ANI CO requests authorization to use small l:JASs for (1) research and development, and· (2) 

aerial data collection in support of certain operations. As described below, operations under this 

requested .exemption will be conducted under operating requirements and conditions materially 

similar to those previously approved by the FAA. 1 ANI CO requests summary review of this 

petition. 

First chartered in 1905, American National Insurance Company and its family of 

affiliates strive to be a leading provider of financial products and services for current and future 

generations. Today, the company and its subsidiaries provide personalized service to more than 

five million policyholders throughout all 50 states, the District of Columbia, and Puerto Rico. 

Directly and through subsidiaries, the company offers a broad line of insurance products and 

services, including life insurance, annuities, health insurance, property and casualty, credit 

insurance, and pension plan services. 

The integration of unmanned aircraft into ANICO's operations will have an immediate 

and positive effect on ANICO policyholders, employees, contractors, and society-at-large. 

ANICO believes that UAS are a tool that can, among other benefits, (1) reduce risks to its 

employees and service providers, (2) enhance the accuracy and efficiency of its operations, and 

I See Exe~ption N~s. 1325l'.to:th1e Hartford crl~cket No. FAA-2015-3240), I 1857 to Liberty Mutual (Docket 

No. FAA-020 15-0513), 11309 to United Services' Automobile'- Association (Docket No. FAA--;-20 14-0964), 

and 11062 to Astraeus Aerial (Docket No. FAA--'-20!4-0642) .. 

r; 

GALVESTON: 

One Moody Plaza, 18th Floor 

Galveston, Texas 77550 

409.797.3200 

348419.1 

I 

'I 

BAY AREA HOUSTON 

2525 South Shore Blvd., Suite 203 

League City, Texas 77573 

281.480.5278 

HOUSTON 

700 Milam, S~ite 1300 

Houston, Texas 77002 

713.655.15 71 

(By Appointment Only) 
< 

U.S. Department of Transportation 

January 27, 2016 Page2 

Re: American National Insurance Company's Petition for an Exemption Pursuant to 

Section 333 ofthe FAA Modernization and Reform Act of2012 

(3) improve its responsiveness and effectiveness in meeting the needs of its customers and 

policyholders. 

Petitioner Contact Information 

The contact information for ANICO is: 

BernardS. Gerwel 

SVP, Corporate Digital Officer 

Corporate Technology Services 

American National Insurance Company 

1949 E. Sunshine 

Springfield, MO 65899 

Phone: 417.887.4990 x2228 

E-mail: bernard. gerwel@americannational.com 

Proposed Operations 

• Research and Development: ANICO will conduct research and development at private 

facilities owned by ANI CO or a third party vendor to evaluate how best to integrate UAS into 

insurance operations, to evaluate and develop additional uses for UAS technology by 

ANICO, and to develop insurance products related to UAS operations. ANICO proposes to 

conduct operations, subject to the notice to and approval of proper federal, state and local 

officials, over areas that have suffered a natural disaster, or are about to suffer a natural 

disaster, such as a hurricane, tornado, flood or wildfire. The purpose of these operations 

will be to develop practices and procedures that will improve the speed of Petitioner's 

response and increase the amount and type of information Petitioner can provide 

policyholders, first responders, and appropriate industry experts in a timely manner. In 

connection with such operations, Petitioner will develop operating procedures that will 

integrate UAS into its response strategy to ensure the safety of persons and property. 

• Aerial Data Collection: ANICO will use UAS for aerial data collection in support of 

insurance operations, including surveys and inspections, claim appraisals, risk assessments, 

risk management, loss prevention, underwriting, and catastrophe response, among other 

insurance related operations. For these purposes, UAS will be flown only over property or 

inside a structure where, to the extent practicable, permission has been obtained from the 

owner. The airspace will be (i) limited, (ii) predetermined, and (iii) controlled as to access. 

Under each of these proposed areas of operation, the UAS will be operated in accordance 

with the manufacturer's User Manual, strict safety measures, the Operating Parameters listed in 

Appendix A, and any additional requirements provided by the FAA. Unless otherwise specified 

or exempted, ANICO UAS operations will comply with all applicable parts of 14 CFR including, 

348419.1 
{ 

U.S. Department of Transportation 

January 27, 2016 Page 3 

Re: American National Insurance Company's Petition for an Exemption Pursuant to 

Section 333 ofthe FAA Modernization and Reform Act of2012 

but not limited to, parts 45, 4 7, 61, and 91. All operations will be conducted with a focus on 

minimizing risk to the national airspace system, and to persons and property on the ground. 

The FAA has granted exemptions for requests similar in all material respects to 

ANI CO's. The FAA has granted numerous exemptions for aerial data collection, including: 

Exemption Nos. 11062 to Astraeus Aerial; 11109 to Clayco, Inc.; 11112 to VDOS Global, LLC; 

and 11213 to Aeryon Labs, Inc. In addition, the FAA has granted research and development and 

aerial data collection exemptions to operators in the insurance industry, including: Exemption 

Nos. 11367 to ADM Crop Risk Services; 11293 to Erie Insurance Group; 11188 and 11175 to 

State Farm; 11273 to AIG; and 11309 and 11274 to USAA. 

In the above detailed grants, the FAA found that the enhanced safety achieved using a 

UAS carrying no passengers or crew, rather than a manned aircraft of significantly greater 

proportions carrying crew and flammable fuel, gave the FAA good cause to find that UAS 

operations were in the public interest. The FAA has· good cause to make the same finding with 

respect to this petition. 

Unmanned Aircraft System 

ANICO proposes to conduct its UAS operations using the DJI Phantom 2 and 3 and the DJI 

Inspire 1 models detailed in this section. As stated previously, all UAS will be operated in 

accordance with the manufacturer's User Manual, strict safety measures, and the Operating 

Parameters listed in Appendix A. 

A. DJI Phantom 2 I 3 (Models) 

The DJI Phantom 2 and 3 are lightweight multi-rotor helicopters that will be operated at a 

maximum speed of less than 50 mph and a flight time of no more than 25 minutes. The diagonal 

size of the UAS is 590mm. It weighs less than 5 pounds. It has a high level of pre-programmed 

controls and various built-in technical capabilities (i.e., programming of a geo-fence and height 

limitations) that prevent the operator from doing a mission outside of the operating limits. If its 

communications with the PIC is lost, the safety system will allow it to either hover in place and 

slowly descend or to return to a predetermined point. The FAA has previously granted an 

exemption to 14 CFR part 21, certification procedures for products and parts, Subpart HAirworthiness Certificates, and any associated noise certification and testing requirements of part 

36, for the DJI Phantom 3 (and its predecessor DJI Phantom 2) UAS.2 

2 See, e.g., Altek Media Group (DJI Phantom 3-Exemption 12820), Montico, Inc (DJI Phantom 2- Exemption 

11230), Erie Insurance (DJI Phantom 3- Exemption 11293A), NextEra Energy, Inc. (DJI Phantom 3- Exemption 

11224A), and Travelers Companies, Inc. (DJI Phantom 3- Exemption 11494A). 

348419.1 
I 

U.S. Department of Transportation 

January 27,2016 Page4 

Re: American National Insurance Company's Petition for an Exemption Pursuant to 

Section 333 ofthe FAA Modernization and Reform Act of2012 

B. DJI Inspire 1 (Models) 

The DJI Inspire 1 weighs less than 7 pounds, has four motors, and has the ability to hover 

and move along a vertical and horizontal plane simultaneously. Its dimensions are 438mm x 

451mm x 301mm. It has a high level of pre-programmed controls and various built-in technical 

capabilities (i.e., programming of a geo-fence and height limitations) that prevent the operator 

from doing a mission outside of the operating limits. The maximum speed is no more than 50 

mph with a cruising speed of 25 mph. If its communications with the PIC is lost, the safety 

system will allow it either to hover in place and slowly descend or to return to a predetermined 

point. The FAA has previously granted an exemption to 14 CFR part 21, certification procedures 

for products and parts, Subpart H-Airworthiness Certificates, and any associated noise 

certification and testing requirements of part 36, for the DJI Inspire 1 Series UAS. 3 

Public Interest 

There are a number of reasons why granting the Petitioner's request to operate the UAS 

for commercial aerial data collection and research and development related to insurance is in the 

public interest. The proposed UAS operations will improve the safety of its employees and 

contractors; enhance the efficiency and accuracy of its property insurance operations; increase 

the speed with which ANICO can respond to customer needs; and expand its ability to respond to 

larger catastrophic events and disasters. Further, it will better allow ANICO to evaluate the 

various liabilities created by the use of UAS and develop insurance products to meet this 

emerging need. 

As an example of enhanced safety consider the risks incurred by claims adjusters 

evaluating roof damage. Currently claims adjusters must physically climb onto roofs for data 

collection. This is inherently dangerous and each year claim handlers are injured in falls. Claim 

handlers will be able to reduce their exposure to such hazards by using a UAS. Adjustors will 

also be able to more quickly obtain the data necessary to make accurate assessments. 

The use of UAS will enhance safety in other respects as well. UAS are now capable of 

safe interior flight; this allows adjusters and other claims representatives to access damaged 

structures that are otherwise unsafe or unstable-protecting employees while responding and 

providing information to customers more quickly. Further, the use ofUAS to conduct aerial data 

collection over areas that have been impacted by a natural or other catastrophic disaster will 

allow access to these areas that are otherwise dangerous to reach by foot or other means. 

3 See, e.g., The Hartford Financial Services Group (DJI Inspire !-Exemption 13251), Build Imagery, LLC (DJI 

Inspire !-Exemption 11204), and CineDrones, LLC (DJI Inspire !-Exemption 11279). 

348419.1 
U.S. Department of Transportation 

January 27,2016 Page 5 

Re: American National Insurance Company's Petition for an Exemption Pursuant to 

Section 333 of the FAA Modernization and Reform Act of2012 

Drug and Alcohol Program 

ANICO has policies in place to ensure that no person may act as a PIC, observer, or 

sensor operator if they are under the influence of alcohol or drugs. 

Privacy 

All flights will be conducted in accordance with any federal, state, or local laws regarding 

pnvacy. 

Exemptions Requested 

14 CFR § 21, Subpart H (Airworthiness Certificates) 

14 CFR § 45.23(b) (Display of Marks: General) (To provide for markings as large as practicable.) 

14 CFR § 61.23(a) & (c) (Medical certificates: Requirement and Duration) 

14 CFR § 61.101(e)(4) & (5) (Recreational Pilot Privileges and Limitations) 

14 CFR § 61.113(a) & (b) (Private Pilot Privileges and Limitations: Pilot in Command) 

14 CFR § 61.315(a) (Sport Pilot Certificate Privileges and Limitations) 

14 CFR § 91.7(a) (Civil Aircraft Airworthiness) 

14 CFR § 91.119 (Minimum Safe Altitudes: General) 

14 CFR § 91.121 (Altimeter Settings) 

14 CFR § 91.151(a) (Fuel Requirements for Flight in VFR Conditions) 

14 CFR § 91.405(a) (Maintenance Required) 

14 CFR § 91.407(a)(l) (Operation after maintenance, preventive maintenance, rebuilding or alteration) 

14 CFR § 91.409(a)(l) & (2) (Inspections) 

14 CFR § 91.417(a) & (b) (Maintenance Records) 

Summary for the Federal Register 

ANI CO believes that publication in the Federal Register is unnecessary under the FAA's 

criteria for summary approval. To the extent that the FAA determines that publication is 

necessary, the following summary is provided: 

348419.1 

Petitioner: American National Insurance Company 

Sections of 14 C.F.R. Affected: §§ 21, Subpart H, 61.23(a) & (c), 

45.23(b),61.101(e)(4) & (5), 61.113(a) & (b),61.315(a), 91.7(a), 91.119(c) 

91.121, 91.151(a)(l) & (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (2), and 

91.417(a) & (b). 
' ' 

U.S. Department of Transportation 

January 27, 2016 Page 6 

Re: American National Insurance Company's Petition for an Exemption Pursuant to 

Section 333 ofthe FAA Modernization and Reform Act of2012 

Description of Relief Sought: Petitioner seeks exemption from the 

requirements of 14 C.F.R. §§ 21, Subpart H, 61.23(a) & (c), 61.101(e)(4) & 

(5), 61.113(a) & (b), 61.315(a), 91.7(a), 91.119(c) 91.121, 91.151(a)(l) & (b), 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) to operate 

small unmanned aircraft systems to conduct (1) research and development, 

and (2) aerial data collection in support of certain insurance operations, 

including claim appraisals, risk assessment, risk management, loss prevention, 

underwriting and catastrophe response. In each case, Petitioner will meet or 

exceed conditions that the FAA requires for similar operations. 

Based on the information provided, ANICO submits that this request should receive 

summary approval. The proposed operations are not new or novel and the UAS models proposed 

for use have already been approved based on their size, weight, speed and operational capability. 

Moreover, ANICO agrees to follow operating parameters that are materially similar to those 

contained in recent FAA grants of exemption. 

Conclusion 

ANICO's Petition for Exemption satisfies the criteria articulated in Section 333 of the 

Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports and 

populated areas, operations within the line of sight, and national security issues. We respectfully 

request your consideration and approval of this Petition for Exemption. 

Please do not hesitate to contact Petitioner's outside counsel with any questions or 

requests for additional information regarding this filing. 

Enclosure 

Appendix A 

348419.1 

Very respectfully, 

Counsel for Petitioner 
' ' 

APPENDIX A 

ANICO OPERATING PARAMETERS 

1. The UAS will be limited to ANICO's Petition for Exemption or any subsequent amendments. 

Specifically, the DJI Phantom 2/3 and the DJI Inspire 1. The UAS will weigh less than 55 pounds 

including payload. 

2. The UAS will be limited to an indicated airspeed not to exceed 87 knots (100 mph). The UAS will 

not be operated at airspeeds greater than the maximum UA operating speed recommended by the 

UAS manufacturer. 

3. Flights will be operated at an altitude of no more than 400 feet above ground level ("AGL"), and 

as indicated by the procedures specified in the operating manual, unless a special request is made 

and approved by Air Traffic Control.1 

4. Flights will be operated within visual line of sight ("VLOS") of the pilot-in-command ("PIC") at all 

times. PIC will maintain VLOS with human vision unaided by any device other than corrective lens, 

as specified on the PIC's FAA-issued Airmen Medical Certificate or U.S. driver's license. 

5. Flight operations will utilize a visual observer ("VO"). The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC will be able to 

communicate verbally during flight operations. Texting or electronic messaging is not permitted 

during flight operations. The PIC will be designated 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. 

6. The manufacturer's manual and these Operating Parameters will be accessible during UAS 

operations and made available to the Federal Aviation Administrator or his delegate (the 

"Administrator") upon request. 

7. Prior to each flight the PIC will 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 will be 

prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. 

8. The UAS will operate in accordance with the UAS manufacturer's aircraft/component, 

maintenance, overhaul, replacement, inspection and life limit requirements. Each UAS operated will 

adhere to all manufacturers' safety bulletins. 

9. The PIC must possess at least an airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC must also hold a current FAA Airmen Medical Certificate or a valid U.S. driver's 

license. The PIC will meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in 

which the PIC is rated on his or her pilot certificate. 

1 Petitioner notes that the FAA has a policy of issuing a Certificate of Waiver or Authorization ("COA'') to Section 

333 exemption holders for flights at or below 200 feet. If this petition is granted, Petitioner will operate below 200 

feet in accordance with the terms of this "blanket" exemption. Petitioner may later file for a separate COA to 

operate over 200 feet. 

349413.1 

As of27 January 2016 
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10. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will 

be conducted under visual meteorological conditions ("VMC"). Special Visual Flight Rule (SVFR) 

flights will not be made. If flight at night is required, a special request will first be made at the FAA 

office closest to the proposed area of operations. 

11. The UAS will 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 symbol as denoted on the current FAA-published aeronautical chart, unless a 

letter of agreement with that airport's management is obtained or otherwise permitted by a GOA 

issued to the exemption holder. The letter of agreement with the airport management will be made 

available to the Administrator or any law enforcement official upon request. 25. The UA will remain 

clear and give way to all manned aviation operations and activities at all times. 

12. The UAS will 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. 

13. If the UAS loses communications or loses its GPS signal, it will have the capability to return to a 

pre-determined location. 

14. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

15. The PIC is prohibited from beginning a flight unless there is enough available power for the UAS 

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. The PIC will take into account wind 

and weather conditions in his or her estimate. 

16. All operations will be conducted over private or controlled-access property. To the extent 

practicable, permission from the land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

17. Any incident, accident or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable Certificate of Waiver or Authorization will be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will also be 

reported to the National Transportation Safety Board (NTSB) per instructions detailed on the NTSB 

Web site: www.ntsb.gov. 

18. The UAS will not be operated by the PIC from any moving device or vehicle. 

19. The PIC will demonstrate to the operator their 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 person, vessels, vehicles, and 

structures. PIC flight hours and currency will be logged in a manner consistent with 14 CFR § 

61.51(b). 

20. 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 

under the terms of the attached COA. 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 will 

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. 

349413.1 

As of27 January 2016