1001 Pennsylvania Avenue, NW, Washington, DC 20004-2595  p202 624-2500  f202 628-5116

Gerald F. Murphy

(202) 508-8855

gmurphy@crowell.com

July 21, 2015

VIA FDMS

Ms. Cheryl Collins

Program Manager, Docket Operations

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building Ground Floor, Room W12-140

Attn: FAA Dockets

Washington, DC 20590

Re: Automobile Club of Southern California – Petition for Exemption

Dear Ms. Collins:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA)1and

14 C.F.R. Part 11, the Automobile Club of Southern California (Auto Club), on behalf of itself,

and its affiliated motor clubs, insurance companies, and travel agencies (collectively, ACSC),2

petitions for an exemption from the Federal Aviation Regulations identified herein to authorize

ACSC to operate small unmanned aircraft systems (sUAS) for aerial data collection (e.g.,

photography and videography) for roof/building inspections related to its insurance and

internal real estate/building maintenance operations, and for research and development and

marketing related to its insurance, motor club, roadside assistance service, and travel

operations.3 ACSC’s sUAS operations will be conducted under the safeguards described in this

petition and as may be further established by the Federal Aviation Administration (FAA).

FAA has now issued over 800 Section 333 exemptions to various commercial enterprises

for sUAS applications ranging from aerial photography and cinematography to precision

agriculture and flare stack, bridge and tower inspections.4 Indeed, FAA has granted hundreds

 

1

Pub. L. No. 112-95, § 333, 126 Stat. 76. 

2

The Auto Club is the ultimate controlling entity for ACSC. A list of ACSC entities seeking Section 

333 exemption authority to conduct the sUAS operations described in this petition is set forth on Appendix A 

hereto.

3

 This exemption request is based on the information provided in this petition and the DJI

Phantom Vision 2+, DJI Phantom 3 Advanced, and 3D Robotics Solo user manuals (collectively, the “Manuals”),

copies of which are already on file with FAA. See, e.g., In the Matter of the Petition of Drone Surveys and Reports,

Grant of Exemption No. 11800 (Jun. 11, 2015), Docket No. FAA-2015-1020 (DJI Phantom Vision 2+); In the Matter

of the Petition of Donan Solutions LLC, Grant of Exemption No. 11801 (Jun. 11, 2015), Docket No. FAA-2015-1019

(DJI Phantom 3, DJI Phantom Vision 2+, and DJI Phantom 2); and In the Matter of the Petition of Aerial Indigo, LLC,

Grant of Exemption No. 12009 (Jul. 10, 2015), Docket No. FAA-2015-1466 (3D Robotics Solo).

4

See FAA, Authorizations Granted Via Section 333 Exemptions (rev. Jul. 20, 2015), 

https://www.faa.gov/uas/legislative_programs/section_333/333_authorizations/. 
FAA Dockets

July 21, 2015

Page 2

of Section 333 exemptions for purposes of aerial photography and videography in

circumstances that are similar in all material respects to those proposed here.5 In issuing those

exemptions and other Section 333 grants, FAA found that “the enhanced safety achieved using

an unmanned aircraft (UA) with the specifications described by the petitioner ... gives the FAA

good cause to find that the UAS operation enabled by this exemption is in the public interest.”

6

 

The same public interest and safety justifications apply to Auto Club’s petition, and should

enable FAA to grant it on an expedited basis.

I. Petitioner

ACSC is a member service organization affiliated with the American Automobile 

Association (AAA), the national federation for all AAA motor clubs. The ACSC family of 

companies operates in the following states: Alabama; Arkansas; California; Hawaii; Illinois; 

Indiana; Kansas; Kentucky; Louisiana; Maine; Missouri; Mississippi; New Hampshire; New 

Mexico; New York; Ohio; Pennsylvania; Texas; Virginia; Vermont; and West Virginia. The 

organization serves more than 14 million AAA members, providing them with a wide range of 

products and services, including insurance, financial, travel, automotive, roadside assistance, 

and discounts. 

ACSC seeks to build on this success by leveraging sUAS in its operations. This sUAS

capability will allow ACSC to add a new dimension to the organization’s businesses by

improving the safety and efficiency of its roof/building inspections for insurance and internal

real estate maintenance operations, and enhancing its motor club, roadside assistance and

related automotive services and operations. With sUAS, ACSC can conduct these important

activities at a fraction of the cost of using a manned fixed wing aircraft or helicopter. 

All communications regarding Auto Club’s petition should be directed to:

Automobile Club of Southern California

Chris Nelson, Claims Examiner and

T. Eric Lai, Corporate Counsel

3333 Fairview Road, MS A-242 & MS A-451

Costa Mesa, CA 92626

Nelson.Chris@aaa-calif.com

Lai.Eric@aaa-calif.com

with a copy to: Gerald F. Murphy

Crowell & Moring LLP

1001 Pennsylvania Ave NW

Washington, DC 20004

gmurphy@crowell.com

 

5

 See, e.g., In the Matter of the Petition of State Farm Mutual Automobile Insurance Company, 

Grant of Exemption No. 11188 (Feb. 25, 2015), Docket No. FAA-2014-0856 (“Exemption No. 11188”); In the Matter 

of the Petition of Erie Insurance Group, Grant of Exemption No. 11293 (Apr. 8, 2015), Docket No. FAA-2014-0962 

(“Exemption No. 11293”); and In the Matter of the Petition of United Services Automobile Association, Grant of 

Exemption No. 11274 (Apr. 2, 2015), Docket No. FAA-2014-0796 (“Exemption No. 11274”).

6

See, e.g., Exemption No. 11188 at 17; Exemption No. 11293 at 2; and Exemption No 11274 at 6.
FAA Dockets

July 21, 2015

Page 3

II. Section 333

Auto Club’s petition is consistent with Congress’s goal set forth in Section 333 of the 

FMRA, which directs the Secretary of Transportation to consider whether certain UAS may 

operate safely in the national airspace system (NAS) before completion of the rulemakings

required under Section 332 of that legislation. In making this determination, the Secretary is 

required to determine which types of UAS do not create a hazard to users of the NAS or the 

public or pose a threat to national security in light of the following: (1) the UAS’s size, weight, 

speed, and operational capability; (2) operation of the UAS in close proximity to airports and 

populated areas; and (3) operation of the UAS within visual line of sight of the operator.7 To 

implement Section 333, FAA has the authority to issue exemptions from its safety regulations 

and minimum standards when the Administrator decides a requested exemption is in the public 

interest.8

ACSC’s proposed sUAS operations meet the requirements of, and qualify for expedited 

approval under, Section 333. ACSC’s DJI Phantom Vision 2+, DJI Phantom 3 Advanced, and 3D 

Robotics Solo sUAS weigh less than 55 pounds, will operate at less than 400 feet above ground 

level (AGL), within visual line of sight (VLOS), at speeds of no more than 87 knots, and will 

generally comply with the same conditions and limitations FAA established in issuing previous

Section 333 grants.

9

 Operations conducted under these safeguards will provide at least an 

equivalent level of safety compared to the current regulatory structure. Moreover, ACSC’s

operations will not “create a hazard to users of the national airspace system or the public or 

pose a threat to national security” due to the size of the sUAS and the restricted areas in which 

they will operate.10

III. Regulations from Which an Exemption is Requested

Auto Club requests an exemption from the following regulations to the extent necessary

for ACSC to conduct the operations described in this petition: 

 14 C.F.R. §§ 61.23(a) and (c)

 14 C.F.R. §§ 61.101(e)(4) and (5)

 14 C.F.R. § 61.113(a) 

 14 C.F.R. § 61.315(a) 

 14 C.F.R. § 91.7(a)

 14 C.F.R. § 91.119(c)

 14 C.F.R. § 91.121

 

7

FMRA § 333(a).

8

See 49 U.S.C. § 106(f) and 49 U.S.C. § 44701(f).

9

See supra note 4.

10 See, e.g., In the Matter of the Petition of Astraeus Aerial, Grant of Exemption No. 11062 (Sep. 25, 

2014), Docket No. FAA-2014-0352 (“Exemption No. 11062”) at 8 (citing FMRA § 333(b)).
FAA Dockets

July 21, 2015

Page 4

 14 C.F.R. § 91.151(a)(1)

 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)

The following subsections describe Auto Club’s request for an exemption from each of

these regulations and demonstrate how ACSC’s operations will provide for at least an

equivalent level of safety compared to the current regulatory structure that applies to manned

aircraft.

A. 14 C.F.R. §§ 61.23(a) and (c) – Medical certificates: Requirement and

duration

Sections 61.23(a) and (c) generally require pilots of manned aircraft to hold a FAA

medical certificate in order to exercise pilot privileges. As of March 24, 2015, however, FAA

determined as a matter of policy that operators holding a valid driver’s license in lieu of a third

class medical certificate may conduct commercial sUAS operations under a Section 333 grant.

11

 

Accordingly, Auto Club requests an exemption from these provisions to the extent necessary to

give ACSC the same relief from medical certificate requirements that FAA has afforded to

hundreds of other operators pursuant to Section 333.

12

B. 14 C.F.R. §§ 61.101(e)(4) and (5); 61.113(a); and 61.315(a) – Pilot Privileges

and Limitations

Section 61.113(a) limits private pilots to conducting non-commercial operations.

Similarly, Sections 61.101(e)(4) and (5) prohibit a recreational pilot from acting as pilot in

command (PIC) of an aircraft for compensation or hire or in furtherance of a business. Section

61.315(a) authorizes a sport pilot certificate holder to act as pilot in command of a light-sport

aircraft, subject to certain restrictions specified in Section 61.315(c), including a prohibition on

doing so for compensation or hire or in furtherance of a business, among other restrictions. 

FAA has already determined, however, that a private, recreational or sport pilot certificate is

sufficient to conduct commercial sUAS flights in a wide variety of operational environments.

13

 

Since ACSC will be conducting its sUAS operations for compensation in furtherance of its

businesses, Auto Club requests an exemption from these provisions to the extent necessary. 

Auto Club notes that the FAA has provided such relief to hundreds of other Section 333

operators.14

 

11

 See, e.g., supra note 4; In the Matter of the Petition of EnviroMINE, Inc., Grant of Exemption No. 

11227 (Mar. 24, 2015), Docket No. FAA-2014-0678 at 4, 8; see also FAA, FAA Summary Grants Speed UAS 

Exemptions (Apr. 9, 2015), https://www.faa.gov/news/updates/?newsId=82485. 

12 See supra note 4.

13 Id.

14 Id.
FAA Dockets

July 21, 2015

Page 5

Consistent with the operating conditions and limitations specified in similar Section 333 

grants,15 ACSC will utilize only pilots holding a FAA airline transport, commercial, private, 

recreational, or sport pilot certificate and at least a valid U.S. driver’s license. The sUAS will be 

operated within VLOS of the PIC at all times, and all operations will utilize a visual observer 

(VO), who will be able to communicate verbally with the PIC at all times during the operation. 

And because the area of operation will be controlled and restricted in accordance with the 

safeguards contained in the Manuals and the FAA-approved conditions and limitations 

described in Section VI, infra, permitting the sUAS operations as requested would provide for 

the level of safety otherwise achieved through these Part 61 provisions. Accordingly, grant of 

the requested exemption, subject to the conditions and limitations specified herein, would not 

adversely affect the safety of the NAS.

C. 14 C.F.R. § 91.7(a) – Civil aircraft airworthiness

Section 91.7(a) prohibits any person from operating a civil aircraft unless it is in an

airworthy condition. FAA has stated that no exemption is required for this provision to the

extent that the airworthiness certificate requirements of Part 2116 are waived or inapplicable. 

Such airworthiness certificate requirements are inapplicable here, insofar as ACSC’s sUAS

provide an equivalent level of safety when compared to manned aircraft, consistent with the

relevant language of the FMRA and the precedent the FAA has established under Section 333.

17

 

D. 14 C.F.R. § 91.119(c) – Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically,

Section 91.119(c) provides that except when necessary for takeoff or landing, no person may

operate an aircraft below an altitude of 500 feet above the surface except over open water or

sparsely populated areas and that in such cases, the aircraft may not be operated closer than

500 feet to any person, vessel, vehicle or structure. As detailed in previous Section 333 grants,

however, FAA has determined that adherence to certain safety measures is sufficient to

warrant an exemption from Section 91.119(c) for sUAS operations.

18

 Consistent with the relief

provided to other sUAS operators under Section 333, Auto Club requests an exemption to the

extent necessary to permit ACSC to operate below an altitude of 500 feet AGL and closer than

500 feet to any person, vessel or structure. An equivalent level of safety will be achieved given

the size, weight and speed of ACSC’s sUAS, as well as the locations where they will be operated

(i.e., nowhere near other aircraft). In addition, consistent with the flexibility that FAA has

 

15 See, e.g., Exemption Nos. 11188, 11293, and 11274.

16 FAA has concluded that no exemption from Part 21, Subpart H (Airworthiness Certificates) is 

needed if the agency makes a finding under the FMRA that the UAS selected provides an equivalent level of safety 

when compared to aircraft normally used for the same application. As these criteria are met here, no exemption is 

needed. See, e.g., Exemption No. 11062 at 13-14, 22. But to the extent FAA determines that there are some 

characteristics of ACSC’s sUAS that may not meet this standard, an exemption is requested. 

17 See, e.g., id.

18 See, e.g., supra note 4. 
FAA Dockets

July 21, 2015

Page 6

already provided to other Section 333 operators engaging in aerial photography and

videography,

19 Auto Club requests permission for ACSC to operate a minimum distance of 200

feet from any non-participating persons so long as sufficient barriers exist to protect such

persons from debris in the event of an accident.20

E. 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.” Since ACSC’s sUAS will not be

equipped with a typical barometric altimeter, Auto Club requests relief from this provision

similar to the relief that FAA has granted to other sUAS operators flying at similarly low

altitudes.21 ACSC will operate the sUAS within VLOS at or below 400 feet AGL and provide

altitude information to the PIC via a digitally encoded telemetric data feed that downlinks from

the aircraft to a ground-based on-screen display. The altitude information will be generated by

equipment installed on the sUAS, and prior to each flight a zero altitude initiation point will be

established and confirmed for accuracy by the PIC. 

 

F. 14 C.F.R. § 91.151(a) – Fuel Requirements for Flight in Visual Flight Rules

(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; or (2) At night, to fly after that for at least 45

minutes.” Provided certain operational parameters are established, however, FAA has found

that good cause exists for granting exemptions from this provision for UAS operations in a

multitude of contexts.

22

 

ACSC will be operating a less than 55-pound sUAS in tightly-controlled environments at

speeds below 87 knots and within VLOS. Combined with the fact that ACSC will not conduct

operations unless a sUAS has enough available power for the intended mission, and will not

continue unless there is at least five minutes of power remaining, relief from Section 91.151(a)

is warranted, in accordance with the conditions and limitations specified in Section VI, infra. 

 

19 Id.

20 See In the Matter of the Petition of Team 5, LLC, Grant of Exemption No. 11158 (Jan. 29, 2015), 

Docket No. FAA-2014-0783, at 16-17; In the Matter of the Petition of Picture Factory, Inc., Grant of Exemption No. 

11178 (Feb. 18, 2015), Docket No. FAA-2014-0794, at 23; In the Matter of the Petition of Shotover Camera Systems, 

L.P., Grant of Exemption No. 11159 (Jan. 30, 2015), Docket No. FAA-2014-0784, at 12; see also FAA Order 8900.1, 

Vol. 3, Ch. 8, Sec. 1 (allowing certain relief from 14 C.F.R. § 119(c) in the filming context, including the 200 ft. 

minimum distance standard requested herein).

21 See supra note 4. 

22 Id.
FAA Dockets

July 21, 2015

Page 7

G. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); and 91.417(a) and

(b): Maintenance Inspections

Section 91.405(a) generally requires that each owner or operator of an aircraft have that

aircraft inspected periodically as prescribed by 14 C.F.R. Part 91, Subpart E and have

discrepancies repaired between required inspections. Sections 91.407(a)(1), 91.409(a)(1) and

(2), and 91.417(a) and (b) generally require that other persons shall inspect or maintain the

aircraft in compliance with 14 C.F.R. Part 43. Under Section 333, however, FAA has established

safety measures for certain sUAS operations sufficient to warrant an exemption from these

provisions.23

ACSC will strictly adhere to the maintenance- and inspection-related requirements set

forth in its Manuals, which are consistent with applicable conditions and limitations described

in Section VI, infra. 

IV. Unmanned Aircraft System

ACSC proposes to fly DJI Phantom Vision 2+, DJI Phantom 3 Advanced, and 3D Robotics

Solo sUAS. These sUAS are battery-powered multi-rotors weighing less than 55 pounds that will

be flown in accordance with strict operating safeguards as more fully described in Section VI,

infra, as well as those described in the Manuals. The sUAS will operate at a speed of no more

than 87 knots and have the capability to hover, and move in the vertical and horizontal plane

simultaneously. Moreover, Auto Club also notes that several of the Section 333 grants

encompass operations with the same makes and models of sUAS that ACSC seeks to operate

through this petition.24

The system safety features of ACSC’s sUAS include geo-fencing, a full suite of

contingency management functions, user and flight plan management and approval

functionality, and many more. These and other features will ensure the safety of persons and

property within and surrounding the limited operating area. In the event the sUAS loses

communications or its GPS signal, it will have the capability to return to a pre-determined

location and land. The sUAS will also have the capability to abort a flight in the event of

unpredicted obstacles or emergencies. A comprehensive description of ACSC’s sUAS and their

specifications and capabilities is contained in the Manuals. 

As FAA has recognized, the limited weight of less than 55-pound sUAS significantly

reduces the potential for harm to participating and nonparticipating individuals or property in

the event of an accident or incident, and the risk to an onboard pilot and crew is eliminated

with the use of sUAS for aerial photography and videography operations.

25

 

23

 Id.

24 See supra note 3.

25 See supra note 4. 
FAA Dockets

July 21, 2015

Page 8

In addition, prior to each flight, the PIC will conduct a pre-flight inspection of the sUAS,

and maintenance will be performed to address any condition potentially affecting safe

operations. All maintenance and alterations will be documented in the aircraft records. The

safety guidelines specified in the sUAS Manuals address the following key areas: (1) individual

parts (e.g., remote controller, camera, gimbal, compass, parameter settings, battery, storage

and transportation, maintenance and upkeep, etc.); (2) flight environment requirements; (3)

flight warnings (e.g., failsafe and return to home, low battery, vision positioning system,

transformation function, etc.); (4) pre-flight checklist; and (5) maintenance checks concerning

the battery, transformation system, aircraft, motors, propellers, gimbal and camera, and vision

positioning system.

V. Unmanned Aircraft PIC

As described above, the PIC will be a FAA licensed airman with either an airline

transport, commercial, private, recreational, or sport pilot certificate that holds a current FAA

airman medical certificate or a valid U.S. driver’s license. The PIC will also meet the flight

review requirements specified in Section 61.56 in an aircraft in which the PIC is rated on his or

her pilot certificate. And, prior to conducting commercial operations under this exemption, the

PIC will have accumulated and logged sufficient UAS-specific flight experience, including at least

12 hours on the DJI Phantom Vision 2+, DJI Phantom 3 Advanced, and 3D Robotics Solo sUAS

before being designated to operate them commercially. 

In addition, the PIC and the VO will have successfully completed a qualification process

and a sUAS flight demonstration administered by an ACSC-approved and -qualified pilot.

VI. Operation of the Unmanned Aircraft

ACSC will conduct all flights under the requested exemption subject to the following 

conditions and limitations, and as further detailed in the Manuals:

26

A. The sUAS will weigh less than 55 pounds (25 kilograms), including payload.

B. The sUAS will not be flown at a ground speed exceeding 87 knots (i.e. 100 miles per 

hour).

C. Flights will be operated at an altitude of no more than 400 feet AGL. All altitudes

reported to ATC will be in feet AGL.

D. The sUAS will be operated within VLOS of the PIC and/or VO at all times. 

 

26 The conditions and limitations detailed in this section are consistent with those set forth in the 

previous FAA Section 333 grants for operations similar to those ACSC seeks to conduct through this petition. See, 

e.g., Exemption No. 11458.
FAA Dockets

July 21, 2015

Page 9

E. All operations will utilize a VO, who 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 at all times.

F. The grant of exemption and Manuals will be accessible during ACSC’s sUAS operations

and made available to FAA upon request. If a discrepancy exists between the conditions 

and limitations in the grant of exemption and the procedures outlined in the Manuals, 

the conditions and limitations in the exemption take precedence and will be followed. 

G. Prior to each operation, the PIC will inspect the sUAS to ensure it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the 

sUAS, it will not be operated until the necessary maintenance has been performed and 

the sUAS is found to be in a condition for safe flight. The ground control station will also 

be included in the preflight inspection. All maintenance and alterations will be 

documented in the sUAS records.

H. Any sUAS that has undergone maintenance or alterations that affect its operation or

flight characteristics (e.g., replacement of a flight critical component) will undergo a

functional test flight prior to resumption of operations. The PIC who conducts the

functional test flight will make an entry in the sUAS aircraft records of the flight. 

I. ACSC will follow the manufacturer’s sUAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

J. The PIC will possess either an airline transport, commercial, private, recreational, or 

sport pilot certificate, and a current FAA airman medical certificate or a valid U.S. 

driver’s license. The PIC will undergo at least 12 hours of training to ensure that he or 

she can follow these procedures. The PIC will also meet the flight review requirements 

specified in Section 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate.

K. Prior to conducting commercial operations under this exemption:

1. The PIC will have accumulated and logged, in a manner consistent with Section 

61.51(b), a minimum of: 12 hours of flying the DJI Phantom Vision 2+, DJI 

Phantom 3 Advanced, and 3D Robotics Solo sUAS or 24 flights accrued before 

being designated to operate it for commercial aerial photography and 

videography. During training, proficiency, and experience-building flights, the 

PIC will operate the sUAS with appropriate distance from nonparticipants in 

accordance with Section 91.119.

2. A flight demonstration, administered by an ACSC-approved and -qualified pilot,

will be successfully completed and documented. This documentation will be

available for review upon request by FAA. 
FAA Dockets

July 21, 2015

Page 10

L. The sUAS will be operated at least 500 feet from all nonparticipating persons, vessels, 

vehicles, or structures unless both of the following conditions are met:

1. Barriers or structures are present that sufficiently protect nonparticipating 

persons in the event of an accident; and 

2. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that 

it does not present an undue hazard.

M. If the sUAS loses communications or loses its GPS signal, it will return to a 

predetermined location within the security perimeter and land or be recovered in 

accordance with the Manuals.

N. The sUAS will abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the Manuals.

O. The sUAS will not be operated unless it has enough available power to conduct the 

intended operation and to operate after that for at least five minutes, or with the 

reserve power recommended by the manufacturer, whichever is greater. 

P. ACSC will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations above 200 feet AGL under the

exemption.27 

Q. All sUAS operated in accordance with this exemption will be identified by serial number, 

registered in accordance with 14 C.F.R. Part 47, and have identification (N-Number) 

markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings will be as large as 

practicable.

R. ACSC will follow the procedures established in the Manuals for documenting and 

maintaining records of the sUAS maintenance, preventative maintenance, alterations, 

 

27 Pursuant to its “blanket” COA, FAA will automatically grant a COA for flights at or below 200 feet 

to any UAS operator with a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during 

daytime VFR conditions, operate within VLOS, and stay certain prescribed distances away from airports or 

heliports. See FAA, FAA Streamlines UAS COAs for Section 333 (rev. Mar. 24, 2015), 

https://www.faa.gov/news/updates/?newsId=82245. This blanket COA allows flights anywhere in the country 

except restricted airspace and certain other prohibited areas, and FAA automatically issues it at the time the 

exemption is approved. Id. Since ACSC intends to conduct the vast majority of its operations at or below 200 ft. 

AGL, it will not require a separate COA for such operations; however, to the extent ACSC will be operating above 

200 ft. AGL at any of its operation sites, Auto Club will apply for a COA authorizing ACSC to do so. 
FAA Dockets

July 21, 2015

Page 11

status of replacement/overhaul component parts, and the total time in service of the 

sUAS. 

S. Each sUAS operated under this exemption will comply with all manufacturer Safety

Bulletins.

T. The preflight inspection section described in the Manuals will account for all 

discrepancies (i.e., inoperable components, items, or equipment).

U. ACSC’s use of radio frequency spectrum for operation and control of the sUAS will

comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

V. The documents required under Sections 91.9 and 91.203 will be available to the PIC at

the GCS of the sUAS any time the aircraft are operating. These documents will be made 

available to FAA or any law enforcement official upon request.

W. The sUAS will remain clear and yield the right of way to all other manned operations and

activities at all times (including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, hang gliders, etc.).

X. sUAS operations will not be conducted during night, as defined in Section 1.1. All

operations will be conducted under visual meteorological conditions (VMC). Flights

under special visual flight rules (SVFR) are not authorized.

Y. The sUAS will not be operated by the PIC from any moving device or vehicle.

Z. The sUAS 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 three statute miles from the PIC.

AA.The sUAS will not operate within five 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 FAApublished aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to ACSC. The letter of 

agreement with the airport management will be made available to FAA and any law 

enforcement official upon request.

BB. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA will be reported to

FAA’s UAS Integration Office (AFS-80) within 24 hours and the National Transportation 

Safety Board (NTSB), as applicable.
FAA Dockets

July 21, 2015

Page 12

VII. Public Interest

Authorizing ACSC to conduct aerial photography and videography using sUAS under the

conditions specified herein will bring immediate and significant safety improvement to its

members and business operations. In particular, ACSC’s sUAS operations will:

 Improve the safety of its claims and real estate personnel and vendors that conduct a 

ladder-assisted roof/building inspection for insurance claims and for internal real estate 

maintenance operations; 

 Improve the efficiency of its claims review and underwriting processes;

 Reduce the risk of property damage related to ladder-assisted roof/building inspections; 

 Improve and enhance motor club, roadside assistance, and related automotive services 

and operations; and

 Enhance its marketing and educational materials for its insurance, automotive, and 

travel services.

ACSC’s sUAS will be used to conduct aerial photography and videography in a manner

that provides at least an equivalent level of safety compared to the current regulatory structure

that applies to manned aircraft.

28 Conventional aerial photography and videography requires a

human being to pilot an aircraft that weighs thousands of pounds. By replacing these manned

aircraft flights with sUAS flights, ACSC can conduct high quality photography and videography

and at a fraction of the cost of conventional manned aircraft operations.

VIII. Conclusion

Given the small size of ACSC’s sUAS and the restricted, controlled environment within

which they will operate, ACSC’s proposed sUAS aerial photography and videography operations 

fall squarely within the type of operations that Congress intended be authorized pursuant to 

Section 333. They are also similar in all material respects to those that FAA has already 

authorized under Section 333, including several covering nearly identical types of operations –

and should be approved on an expedited basis. Based on the clear direction from Congress, the 

authority contained in the Federal Aviation Act, as amended; the well-established equivalent 

level of safety present in ACSC’s proposed operations; the significant public benefits associated

with using sUAS to conduct aerial photography and videography; and the precedent that FAA

has established through more than 800 Section 333 grants, grant of Auto Club’s petition is in 

the public interest. Accordingly, Auto Club respectfully requests that FAA grant it an exemption 

without delay.

 

28 See Exemption No. 11062 at 22. 
FAA Dockets

July 21, 2015

Page 13

Crowell & Moring LLP  www.crowell.com  Washington, DC  New York  San Francisco  Los Angeles  Orange County  Anchorage  London  Brussels

Respectfully submitted,

Gerald F. Murphy

Counsel for 

Automobile Club of Southern California

cc: Chris Nelson

Eric Lai
Appendix A

The ACSC entities seeking Section 333 exemption authority to conduct the sUAS operations 

described in this petition consist of the following companies:

 Automobile Club of Southern California (ultimate controlling entity of ACSC)

 AAA Arkansas Insurance Agency, Inc.

 AAA East Central

 AAA East Central Insurance Agency, Inc.

 AAA Hawaii, LLC

 AAA New Mexico, LLC

 AAA Northern New England

 AAA Northern New England Insurance

 AAA Texas, LLC

 ACSC Management Services, Inc.

 Alabama Motorists Association, Inc.

 Auto Club Casualty Company

 Auto Club County Mutual Insurance Company

 Auto Club Enterprises

 Auto Club Family Insurance Company

 Auto Club Indemnity Company

 Auto Club Services, LLC

 Automobile Club Inter-Insurance Exchange

 Automobile Club of Missouri

 Automobile Club of Southern California Life Insurance Company

 Club Exchange Corporation

 Club Insurance Agency, Inc.

 Hawaii World, LLC

 Interinsurance Exchange of the Automobile Club

 Pleasant Holidays, LLC

 Pleasant Travel Holding Company, LLC

 Tidewater Automobile Association of Virginia, Inc.