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 Pursuant 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 Modernization and Reform Act 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 Regulations (“FARs”) and any other rules necessary 

to allow operation of small unmanned aircraft systems (“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 authorization 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 operating 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 independent agents. The company generated 

revenues of $26 billion in 2013. Founded in 1853, as one of the oldest insurance companies in 

the United States, Travelers has continuously kept up with developing technologies in the 

insurance marketplace. Travelers is committed to keeping pace with the ever-changing needs of 

 1

Travelers is filing this petition on behalf of itself and all of its respective parents, 

subsidiaries, affiliates, predecessors, successors and assigns. 
- 2 -

our customers, for instance by offering the first-ever 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 model and, accordingly, provide assistance to our 

customers during times of great need. Further, there are likely to be public safety benefits to 

deployment of UAS during catastrophes where access is otherwise unavailable by foot, but UAS 

can provide data remotely. This information could be utilized for response planning and shared 

with first responders, local authorities and appropriate industry experts to the benefit of the 

community at large. By comparison, a test site could never provide the real-world operating 

conditions of a natural disaster site. Travelers, therefore, requests the FAA to grant an 

authorization for UAS operations during and following a natural disaster. 

 Travelers will limit any risk to the public by strictly following its Manual2

 and complying 

with all conditions, limitations, and operating parameters contained in the FAA’s order granting 

an exemption. Travelers will also follow all instructions from the FAA and the official-in-charge 

at the scene of an emergency response following a natural disaster. Travelers will coordinate 

with all relevant parties, including first responders and the FAA, to ensure that its UAS 

operations are conducted safely and without hindering public safety efforts. Travelers’ UAS 

operations will cease immediately at the direction of relevant officials. 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 for obtaining access to a disaster. When a 

catastrophe is expected to occur or has recently occurred, Travelers will contact the UAS 

Integration Office, the pertinent Flight Standards District Office, local Air Traffic Control 

Facilities, and the official-in-charge of on-scene emergency response activities, or whomever the 

FAA designates in the grant. Travelers will give the applicable authorities 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 Aircraft System Operating Procedures, Safety 

Code and Training Syllabus (“Manual”) to FAA confidentially with a request for confidential 

treatment pursuant to 14 CFR Section 11.35(b). The Manual contains confidential, proprietary 

and commercially sensitive information that has not been made available to the public and that is 

protected under the Freedom 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. Travelers will coordinate with both the FAA and the 

officials in charge of on-scene emergency response 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, Travelers believes such operations can be safely 

conducted to avoid any risk to first responders, other aircraft and persons and property on the 

ground. 

II. Pilot Requirements 

 Travelers would like to partner with the FAA to design a pilot certification program that 

focuses on the skills, knowledge and expertise required to operate small 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 implement 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 commercial certification requirements, 

Travelers believes that its pilots and the public would be better served by a training regimen that 

is specifically designed to certify the safe operation of small UAS. Further, Travelers believes 

that there is a significant difference between small UAS of the type it plans to operate, i.e., 

under5.5 pounds, and heavier unmanned aircraft still considered “small” by the FAA, i.e., up to 

55 pounds. The program Travelers intends to design 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 neighboring persons or property. 

Travelers will be submitting a training program designed by an on-staff commercially 

certificated pilot that has an extensive security 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 fully 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 pilot to: (a) successfully complete 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 available 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 and model of UAS to be utilized for operations 

under this exemption; (d) certify that he or she has no medical defect that 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 take place under the direct supervision and control 

of a person holding an FAA commercial or private pilot certificate.5 

III. Public Interest Benefits

UAS technology would be particularly helpful following a natural disaster, when it may 

be more dangerous and time consuming to reach 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 industry 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, flight 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 authorities, 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 following limitations and conditions when 

conducting UAS operations during and after a catastrophe. The proposed operating limitations 

 4

 FAR 61.23 permits piloting of gliders and balloons without a medical certificate. 

Travelers operations would pose less threat to national airspace or neighboring persons or 

property than gliders and balloons, which are heavier and operated at higher altitudes. 

5

 Travelers recognizes that the FAA has concluded that it does not have 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 Travelers, would develop a pilot 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 FAA reconsider its decision in this 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 any 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 safely 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 Integration Office, the pertinent Flight Standards 

District Office, local Air Traffic Control Facilities, and the official-in-charge of 

on-scene emergency response activities (or whomever FAA designates in the 

order granting exemption) to request “activation” of its authority to conduct 

operations at the specified 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 holder or representative; 

7. Description of flight activities, including maps/diagrams of operating areas 

and altitudes. Operations will be limited to the authorized areas. 

2. Before and during operations, Travelers will coordinate with FAA and the on-scene 

commander. 

3. Operations will cease immediately at the request of on-scene officials. Travelers will 

vacate the area if so requested. 

4. To the extent there are people on the ground, 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 conducted 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 visual 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 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. The ground control station must be included in the preflight inspection. 

All maintenance and alterations must be properly documented in the aircraft records. 

14. 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 in 

accordance with Travelers’ Manual. The pilot who conducts 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., inoperable 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 maintenance, 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 aircraft and has previously granted exemptions 

approving use of the DJI Phantom 2 aircraft for commercial operations. See Exemption Nos. 

11138, 11153 and 11157. 
- 7 -

20. Each flight will be operated by a pilot that has: (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 designed 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 utilized 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 small 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 Travelers intends to operate, i.e., 

under 5.5 lbs. Prior to any operations 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 established 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, and land or be recovered in accordance with the Manual. 

26. Before conducting operations, a qualified UAS pilot will demonstrate and log in a manner 

consistent with 14 CFR 61.51(b) the ability to safely operate the UAS in a manner consistent with how 

the UAS will be operated under the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures 

27. All operations must be conducted under visual meteorological 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 Federal 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 airspace 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 balloons without a medical certificate. 

Travelers operations would pose less threat to national airspace or neighboring persons or 

property than gliders and balloons, which are heavier 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 obtained, and the operation is conducted in accordance with 

a NOTAM. The letter of agreement with the airport management will be made available to FAA upon 

request. 

31. All aircraft operated in accordance with the 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. Markings will be made as large as practicable. 

32. The documents required under 14 CFR 91.9 and 91.203 will be available to the pilot at the 

ground control station of the UAS during flight operations. 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 responder 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 Authorization (COA) is required, any incident, accident, or 

flight operation that transgresses the boundaries of the operating area as defined by the 

applicable COA must be reported to the FAA’s UAS Integration Office within 24 hours. 

Accidents must be reported to the National Transportation Safety Board (NTSB) in accordance 

with federal regulations. 

37. The operator will comply with the operating, 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 will be maintained and will be made available to FAA upon request. 

Travelers also anticipates partnering with the FAA 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 support 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. Its 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 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 

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 promote Congress’ goal in enacting Section 333 of the 

FMRA. Section 333 directs the Secretary of Transportation 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 kinds of UAS operations that do not create a hazard to 

users of the national airspace or the public or pose a threat to national security in light of the UAS’ size, 

weight, speed, operational capability and areas of operation 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 operations under conditions that ensure safety, like those proposed in this 

petition. 

 In addition, the Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft (as that term is defined under § 

40101 of the Act, which includes UAS) from the requirement that all such aircraft must have a current 

 8

 FAA Modernization and Reform Act 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 requirement 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 requirements 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 aircraft 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 reconstruction, 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 license to be pilot in command of an aircraft for 

compensation or hire. FAA has already determined that 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 characteristics 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 exceedingly 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 flyers. 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 automatically 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 pilot, passengers or any flammable or explosive 

materials. The operating area is controlled and restricted, and all flights are planned and coordinated in 

advance as set forth in the Manual. Travelers respectfully submits that the proposed operations can 

achieve an equivalent level of safety by requiring the pilot of these small, lightweight, low-altitude, lowspeed, limited range of operations UAS to be trained 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 provided 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 operate a civil aircraft unless it is in airworthy 

condition. Given the characteristics of the UAS (including their extremely small size, weight and payload 

capacity, very low operating altitude, and exceedingly short flight time capability) and the stringent 

operating restrictions and conditions proposed in this petition, an equivalent 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: “except when necessary for takeoff or landing, no person 

may operate an aircraft below the following altitudes: ... (b) Over congested areas. 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 the surface, except over open water or sparsely populated 

areas. In those cases, the aircraft may not be operated 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 aircraft. 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 Manual. 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 elevation of the departure airport or an appropriate altimeter 

setting available before departure.” An exemption 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, confirming 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 requirements 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 weather 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 justified. An equivalent level of safety can be achieved by 

terminating flights at 25% battery power reserve, which 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 shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...” and 

(ii) shall inspect or maintain the aircraft in compliance with Part 43. Because these sections and Part 43 

apply only to aircraft with an airworthiness certificate, these sections will not apply to the petitioner. 

Maintenance will be accomplished by the operator pursuant 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 will 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 keep a log of any maintenance performed. Moreover, 

the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide an equivalent 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, during 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 requirements of any conditions and limitations of the exemption and 

allowed to comply with any less burdensome applicable 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 grant 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 payload capacity and carry no flammable, explosive or 

otherwise dangerous materials, the operations pose no threat to national security. 

XI. Conclusion 

 For the reasons stated above, Travelers’ proposed 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. Petitioner’s proposed safety measures 

and operating parameters provide more than adequate 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 the same grant. Please do not hesitate to contact 

petitioner’s 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 

 

 

Attachments: Manual and additional supporting materials.