1 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 Pu rsuant to FMRA Section 333 and Part 11 of the FARs to Use Small Unmanned Aircraft Systems in Support of Catastrophe Response

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modern ization and Reform Ac t 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 Regul ations (“FARs”) and any other rules necessary to allow operation of small unmanned aircraft sy stems (“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 au thorization to conduct small UAS operations in support of its catastrophe response strategy. As explained below, operations under the requested exemptions will be conducted under strict ope rating 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 indepe ndent agents. The company generated revenues of $26 billion in 2013. Founded in 1853, as one of the oldest in surance companies in the United States, Travelers has continuously kept up with developi ng technologies in the insurance marketplace. Travelers is committed to keeping pace with the ever-changing needs of

1 

### Travelers is filing this petit ion on behalf of itself and a ll of its respective parents, subsidiaries, affiliates, predecessors, successors and assigns.- 

### 2 - our customers, for instance by offering the first-ev er 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: Request to Use UAS for Survey and Inspection of Damage to Private Property following Catastrophic Events



### Travelers seeks an exemption to allow use of UAS during and after natural disasters. Travelers would like to integrate UAS technology into its catastrophe response strategy. There may be many opportunities for UAS technology to be deployed to improve the overall speed and efficiency of our catastrophe response mode l and, accordingly, provide assistance to our customers during times of great nee d. Further, there are likely to be public safety benefits to deployment of UAS during catastrophes where acce ss is otherwise unavailable by foot, but UAS can provide data remotely. This information c ould be utilized for res ponse planning and shared with first responders, local auth orities and appropriate industry experts to the benefit of the community at large. By comparison, a test s ite could never provide the real-world operating
conditions of a natural disaster site. Traveler s, therefore, requests the FAA to grant an authorization for UAS oper ations during and following a natural disaster.

Travelers will limit any risk to the public by strictly following its Manual 2 

### and complying with all conditions, limitations, and operating parameters contai ned in the FAA’s order granting an exemption. Travelers will also follow all inst ructions from the FAA and the official-in-charge at the scene of an emergency response following a natural disaster. Tr avelers will coordinate with all relevant par ties, including first responders and the FAA, to ensure that its UAS operations are conducted safely a nd without hindering public safety efforts. Travelers’ UAS operations will cease immediately at the direction of relevant o fficials. Further, its UAS operations will be conducted with notice to manned aircraft and will at all times yield the right of way to such aircraft.

Travelers proposes the following process fo r obtaining access to a disaster. When a catastrophe is expected to occur or has rece ntly occurred, Traveler s will contact the UAS Integration Office, the pertinent Flight Standa rds District Office, local Air Traffic Control Facilities, and the official-in-ch arge of on-scene emergency response activities, or whomever the FAA designates in the grant. Travelers will give the applicable authoritie s a copy of its grant and information about the operating area, UAS, and flight activities to be conducted. The UAS

2 

### Travelers is submitting its Unmanned Aircra ft System Operating Procedures, Safety Code and Training Syllabus (“Ma nual”) to FAA confidentially with a request for confidential treatment pursuant to 14 CFR Section 11.35(b). Th e Manual contains conf idential, proprietary and commercially sensitive information that has no t been made available to the public and that is protected under the Fr eedom of Information Act, 5 U.S.C. § 552, et seq.- 

### 3 - Integration Office will give Travelers permission to conduct flight operations subject to the conditions and limitations in the grant. Travel ers will coordinate with both the FAA and the officials in charge of on-scene emergency re sponse activities prior to conducting its UAS operations during or immediately following a catastrophe. Travelers will take direction from the FAA and the officials in charge of on-scene emergency response activities as to the location, duration and real-time coordination of its operations.

With these controls and limitations, Traveler s believes such operations can be safely conducted to avoid any risk to first responders, other aircraft and pers ons and property on the ground.

II. Pilot Requirements

Travelers would like to partne r with the FAA to design a pilot certification program that focuses on the skills, knowledge and expertise required to operate sm all 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 im plement 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 commer cial certification requirements, Travelers believes that its pilots and the public w ould be better served by a training regimen that is specifically designed to certi fy the safe operation of small UAS . Further, Travelers believes that there is a significant difference between sm all UAS of the type it plans to operate, i.e., under5.5 pounds, and heavier unmanned aircraft stil l considered “small” by the FAA, i.e., up to 55 pounds. The program Travelers intends to de sign 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 neighbor ing persons or property.

Travelers will be submitting a training pr ogram designed by an on-staff commercially certificated pilot that has an extensive secur ity background as well as considerable experience with UAS, rotary winged and fixed winged aircraft. 3 

### Travelers would like to partner with the FAA to improve and refine the training to fu lly 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 pilo t to: (a) successfully co mplete 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;

3 

### 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 avai lable to the public and that is protected under the Freedom of Information Act, 5 U.S.C. § 552, et seq.- 

### 4 - (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 a nd model of UAS to be utilized for operations under this exemption; (d) certify that he or she has no medical defect th at would make him or her unable to pilot a small UAS in a safe manner; 4 

### and (e) clear a criminal background check and drug test. All pilot certification training will ta ke place under the direct supervision and control of a person holding an FAA commerc ial or private pilot certificate. 5

III. Public Interest Benefits



### UAS technology would be particularly helpfu l following a natural disaster, when it may be more dangerous and time consuming to r each our policyholders via ground operations. Allowing Travelers to conduct real-world testing is the next step toward realizing the consumer benefits of using UAS in the insurance industr y during the aftermath of a catastrophe. These flights will take place amid conditions that would be impossible to create at any test site. UAS operations at an actual disaster site will provide a wide range of aftermath conditions to test realtime coordination techniques, fli ght planning, and flight operations for Travelers’ UAS and its operators. In addition to providing faster, more effective service to its customers, Travelers’ UAS operations in actual disaster conditions may also speed overall post-disaster relief
assessments if this data is shared with first responders, local authoriti es, and others, thereby allowing manned ground and aviation assets to do more vital tasks.

IV. Operating Parameters, Operations, Inspection and Maintenance Manual

A. Operating Parameters

Travelers agrees to be bound by the fo llowing limitations and conditions when conducting UAS operations during and after a ca tastrophe. The proposed operating limitations

4 

### FAR 61.23 permits piloting of gliders and ba lloons without a medi cal certificate. Travelers operations would pose less threat to national airspace or neighboring persons or property than gliders and balloons, which are heav ier and operated at higher altitudes.

5 

### Travelers recognizes that the FAA has conclu ded that it does not ha ve 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 Traveler s, would develop a pilo t 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 F AA reconsider its decision in th is 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 a ny 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.- 

### 5 - describe how Travelers UAS operations will be safe ly conducted to minimize risk to the national airspace or to persons and property on the ground:

1. Procedure for Gaining Access to Catastrophe Area

a. Travelers will contact the UAS Integrati on Office, the pertinent Flight Standards District Office, local Air Traffic Control Facilities, and the offi cial-in-charge of on-scene emergency response activities (or whomever FAA designates in the order granting exemption) to request “act ivation” of its authority to conduct operations at the specifi ed disaster location.

b. Travelers will provide the applicable authorities:

1. A copy of the FAA order granting the exemption;

2. Dates and times for all flights;

3. Make, model, and serial or N-number of UAS;

4. Name and phone number of the operator for the UAS and the person responsible for on-site operations;

5. Name of pilot(s);

6. Signature of exemption hol der or representative;

7. Description of flight activities, includ ing maps/diagrams of operating areas and altitudes. Operations will be limited to the authorized areas.

2. Before and during operations, Travelers wi ll coordinate with FAA and the on-scene commander.

3. Operations will cease immediat ely at the request of on-scen e officials. Travelers will vacate the area if so requested.

4. To the extent there are people on the gr ound, operations will be conducted as far as practicable from non-participating persons.

5. The UAS must remain clear and yield the right of way to all manned operations and activities at all times.

6. Travelers will request a NOTAM as early as practicable prior to operations to alert other users of the airspace about the UAS operations.- 

### 6 - 7. The operations will be cond ucted using a 3DR IRIS+ aircraft , which is a small UAS weighing approximately 4.4 pounds with payload, or a DJI Phantom 2 aircraft, which is a small UAS weighing approximately 5.4 pounds with payload. 6

8. Flights will be operated at all times within vi sual line of sight of a pilot unaided by any device
other than corrective lenses.

9. The UAS will not carry persons, explosive materials or flammable liquid fuels.

10. The UAS will not be flown at ground speeds exceeding 15 knots.

11. Flights will be terminated at 25% battery power reserve.

12. Flights will be operated at an altitude of no more than 300 feet AGL.

13. 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 a ffects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenan ce 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 prope rly documented in the aircraft records.

14. Any UAS that has undergone maintenance or a lterations 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. The pilot who conduc ts the functional test flight must make an entry in the UAS aircraft records of the flight.

15. The preflight inspection section in the Manual includes the requirement that the preflight inspection must account for all discrepancies, i.e., i noperable components, items or equipment, etc.

16. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection and life limit requirements.

17. The operator must carry out its maintenan ce, 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.

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

19. 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.

6 

### FAA is familiar with the DJI Phantom 2 airc raft and has previously granted exemptions approving use of the DJI Phantom 2 airc raft for commercial operations. See Exemption Nos. 11138, 11153 and 11157.- 

### 7 - 20. Each flight will be operated by a pilot that h as: (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 desi gned 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 u tilized 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.

21. Each pilot will successfully complete a sm all 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 Tr avelers intends to operate, i.e., under 5.5 lbs. Prior to any opera tions 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.

22. A geo-fencing perimeter will be estab lished at a maximum ceiling of 300 feet AGL.

23. The pilot will designate a landing zone from which the UAS will take off and land.

24. The pilot will abort the flight in the event of any unpredicted obstacles or emergencies as detailed
in the Manual.

25. If the communications link or GPS signal is lost, the UAS will return to a pre-programmed location, within the restricted area of operations, a nd land or be recovered in accordance with the Manual.

26. Before conducting operatio ns, a qualified UAS pilot will demonstrate and log in a manner consistent with 14 CFR 61.51(b) the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and em ergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures

27. All operations must be conducted under visual meteorologi cal conditions (VMC) and during daylight hours.

28. Before operations begin under the exemption, the radio frequency spectrum used for operation and control of the UAS will comply with Federa l Communications Commission requirements.

29. 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.

30. The flight operations will occur in Class G ai rspace 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

7 

### FAR 61.23 permits piloting of gliders and ba lloons without a medi cal certificate. Travelers operations would pose less threat to national airspace or neighboring persons or property than gliders and balloons, which are heav ier and operated at higher altitudes.- 

### 8 - geographic center of an airport as denoted on a current FAA-published aeronautical chart unless an agreement with that airport’s management is obtaine d, and the operation is conducted in accordance with a NOTAM. The letter of agreement with the airpor t management will be made available to FAA upon request.

31. All aircraft operated in accordance with th e exemption will be identified by serial number, registered in accordance with 14 CFR Part 47, and have identification (N-Number) markings in accordance with 14 CFR Part 45, Subpart C. Ma rkings will be made as large as practicable.

32. The documents required under 14 CFR 91.9 a nd 91.203 will be available to the pilot at the ground control station of the UAS during flight opera tions. These documents must be made available to the Administrator or any law enforcement official upon request.

33. The UAS must remain clear and yield the right of way to all manned operations and activities.

34. Travelers will ensure safety to first responde r aircraft and helicopter traffic. Upon notification from manned aircraft controllers or through visual identification of manned aircraft, Travelers will immediately suspend the UAS flight until the airspace is cleared.

35. The UAS may not be operated by the pilot from any moving device or vehicle.



### 36. In the event a Certificate of Authorizati on (COA) is required, any incident, accident, or flight operation that transgre sses the boundaries of the opera ting area as defined by the applicable COA must be reported to the F AA’s UAS Integration Office within 24 hours. Accidents must be reported to the National Tr ansportation Safety Board (NTSB) in accordance with federal regulations.

37. The operator will comply with the operat ing, 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 w ill be maintained and will be made available to FAA upon request. Travelers also anticipates partnering with the F AA 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 suppor t of this petition. The Manual will be maintained and will be made available to FAA upon request.- 

### 9 - 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. It s maximum flight time is 25 minutes.

Specifications include:

SPECS 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 300 feet AGL and within the boundaries of the designed operating areas, flight programming capabilities, and a flight termination system. If the UAS loses co mmunications or its GPS signal, it will return to a pre-determined location within the planned operatin g 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 prom ote Congress’ goal in enacting Section 333 of the FMRA. Section 333 directs the Secretary of Transpor tation 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 ki nds of UAS operations that do not create a hazard to users of the national airspace or the public or pose a th reat to national security in light of the UAS’ size, weight, speed, operational capability and areas of opera tion 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 opera tions under conditions that ensure safety, like those proposed in this petition.

In addition, the Federal Aviation Act expressly gran ts the FAA the authority to issue exemptions. This statutory authority by its terms includes exemp ting civil aircraft (as that term is defined under § 40101 of the Act, which includes UAS) from the requirem ent that all such aircraft must have a current

8 

### FAA Modernization and Reform Ac t of 2012, Pub. L. No. 112-95, 126 Stat. 75- 76 (codified as a Note to 49 U.S.C § 40101).- 

### 10 - airworthiness certificate and granting exemptions from the pilot certification requirements. The Administrator may grant an exemption from a requireme nt of a 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 requireme nts 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. § 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 aircra ft systems (UAS) in order to conduct small UAS

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).- 

### 11 - operations related to its insurance business, including ( but not limited to) roof inspections, underwriting, risk assessment, risk control, accident reconstructi on, 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 li cense to be pilot in command of an aircraft for compensation or hire. FAA has already determined th at 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 ch aracteristics 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 ex ceedingly 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 fl yers. 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 automati cally 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 pi lot, passengers or any flammable or explosive materials. The operating area is controlled and restri cted, and all flights are pl anned and coordinated in advance as set forth in the Manual. Travelers resp ectfully submits that the proposed operations can achieve an equivalent level of safety by requiring th e pilot of these small, lightweight, low-altitude, lowspeed, limited range of operations UAS to be traine d 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 requirements included in the Manual exceeds that provi ded 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).- 

### 12 - B. 14 C.F.R. § 91.7(a): Civil aircraft airworthiness

Section 91.7(a) requires that no person may opera te a civil aircraft unless it is in airworthy condition. Given the characteristics of the UAS (incl uding their extremely small size, weight and payload capacity, very low operating altitude , and exceedingly short flight tim e capability) and the stringent operating restrictions and conditions proposed in this petition, an e quivalent 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: “ex cept when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: ... (b) Over congested area s. 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 th e surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operate d 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 300 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 airc raft. 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 Manua l. The FAA issued an exemption from Section 91.119(c) in Exemption Nos. 11136 and 11138.

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 elevati on of the departure airport or an appropriate altimeter setting available before departure.” An exemp tion 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, c onfirming 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.- 

### 13 - E. 14 C.F.R. § 91.151(a): Fuel requi rements 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 weathe r 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 justifie d. An equivalent level of safety can be achieved by terminating flights at 25% battery power reserve, whic h 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 sha ll between required inspections, except as provided in paragraph (c) of this section, have discrepancies repair ed as prescribed in part 43 of this chapter...” and (ii) shall inspect or maintain the aircraft in complia nce with Part 43. Because these sections and Part 43 apply only to aircraft with an airworthiness certifi cate, these sections will not apply to the petitioner. Maintenance will be accomplished by the operator purs uant to the manufacturer’s manual and Travelers’ 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 land immediately and w ill be operating from no higher than 300 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 k eep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircra ft and best suited to maintain the aircraft in an airworthy condition to provide an e quivalent 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, duri ng 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 requi rements of any conditions and limitations of the exemption and allowed to comply with any less burdensome ap plicable regulations that may have become effective.- 

### 14 - IX. Privacy

The petition raises no privacy issues because, to the extent possible, Travelers will obtain the prior consent of affected property owners. Additionally, Travelers strict privacy policies would apply to all UAS operations.

X. National Security

No national security issue is presented by gr ant 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 payloa d capacity and carry no flammable, explosive or otherwise dangerous materials, the operati ons pose no threat to national security.

XI. Conclusion

For the reasons stated above, Travelers’ pr oposed 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. Peti tioner’s proposed safety measures and operating parameters provide more than adequa te 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 th e same grant. Please do not hesitate to contact petitioner’s outside counsel, Carol Gosain, with any que stions 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

Attachments: Manual and a dditional supporting materials.