7925 Jones Branch Drive, Suite 6200 9800 Fredericksburg Road

McLean, Virginia 22102 San Antonio, Texas 78288

Docket Operations, M-30 U.S. Department of Transportation (DOT) 1200 New Jersey Avenue, SE

Room W12-140 West Building Ground Floor November 14, 2014 Washington, D.C. 20590-0001

Reference: USAA Petition for Section 333 Exemption: Re: Small Unmanned Aircraft Systems in Property and Casualty Insurance in Catas trophe Operations

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (FMRA), United Services Automobile Association (USAA) is petitioni ng for an exemption from the Federal Aviation Regulations and other rules/statutes perta ining to unmanned aircraft systems. Section 333 of the FMRA addresses special rules for certain unmanned aircraft systems and grants the FAA authority to allow for the safe operation of ce rtain unmanned aircraft systems (UAS) within the national airspace. Property and casualty insure rs play a major role in funding the restoration of businesses and communities after catastrophic in cidents such as wildfire, hail and wind storms, hurricanes and mudslides. The integration o f unmanned aircraft into USAA’s catastrophe response operations will have immediate , positive effects on the lives of its members and the communities in which they work and reside.

Since 1922, USAA has served the military community and their families providing a full range of highly competitive financial products and services to our membership. We have world class employees that are personally committed to deliveri ng excellent service and guidance regarding insurance, banking and investments. USAA focuses it s innovation on developing products and new technology to assist its membership from policy inception to fulfilling our service commitment during a claims event. USAA has over ten million members that look to USAA to help them restore and rebuild after a wide range of natural and other disasters, and USAA is always seeking ways to improve the timing and quali ty of its responses to members’ needs.

We have identified unmanned aircraft systems as a t echnology which can alleviate safety concerns associated with manned inspections both in the air and on the ground, and provide enhanced service and experience to our membership i n a safe and efficient environment. USAA has one of the most respected and experienced catas trophe response teams in the United States. Our response teams are trained in catastrop he operations and are ready to deploy to assist our membership and their communities at a mo ment’s notice.

USAA has developed the operational maturity needed to deploy safely and provide the benefits of the UAS technology to needed communities through our partnerships with public entities such as FAA UAS Test Sites, selected universities, and U AS studies in disaster events. Through anU.S. Department of Transportation

November 14, 2014 Page 2 of 15

13801002.4 approved FAA COA, USAA, in partnership with Robotic ists Without Borders, has been able to develop a UAS program and gain safe UAS operational experience at a catastrophe site. This year, USAA and Roboticists Without Borders traveled to Oso, WA to assist the area by providing aerial imagery and mapping of the mudslid e area so the community could rebuild roads, route rivers and assist this area that was d evastated by a massive catastrophe in March 2014. Currently, USAA along with other industry par tners is researching a UAS study for public safety and emergency response operations in collabo ration with the American Red Cross and the Federal Emergency Management Agency (FEMA). The study will demonstrate the ways UAS can be utilized to respond to emergencies, save lives and help communities recover.

Obtaining an exemption would give USAA the authorit y to request UAS catastrophe operations directly from the FAA for the direct benefit of its membership. Currently, the FAA does not allow civil UAS operations (meaning operations other than public aircraft operations or model aircraft / “hobbyist” activities which include research and de velopment); therefore USAA has not been able to operationalize and deploy its UAS for the b enefit of its membership and the communities in which they reside.

14 CFR 11.81 (a) – Name and address of the Petition er :

United Services Automobile Association 9800 Fredericksburg Road San Antonio, Texas 78288

Phone: 703-905-2808 E-mail: gcirillo@wileyrein.com

14 CFR 11.81 (b) – Exemptions Requested:

The FAA considers unmanned aircraft as “aircraft” f lown by a “pilot” regardless of the location of the pilot. All aircraft and pilots must comply with applicable sections of Title 14 of the Code of Federal Regulations (14 CFR) and other rules/regula tions to operate within the National Airspace. Unmanned aircraft are unable to comply wi th certain sections of 14 CFR as the regulations were written prior to the consideration of small UAS integration within the national airspace. Therefore USAA is requesting an exemption from certain parts of 14 CFR cited below, in addition to such further exemptions and relief a s the FAA may determine is necessary to permit the operations described herein

.

14 CFR Part 21 Subpart H – Airworthiness certificat ion 14 CFR Part 45.23 (b) – Display of marks; general 14 CFR Part 61.113 (a) and (b) – Private pilot priv ileges and limitations: Pilot in command

14 CFR Part 91.7 – Civil Aircraft Airworthiness 14 CFR Part 91.9 (b) – Civil aircraft flight manual , marking and placard requirements 14 CFR Part 91.109 – Flight Instruction

14 CFR Part 91.119 – Minimum safe altitudes 14 CFR Part 91.121 – Altimeter settingsU.S. Department of Transportation

November 14, 2014 Page 3 of 15

13801002.4 14 CFR Part 91.151 – Fuel requirements for flight i n VFR conditions 14 CFR Part 91.203 (a) and (b) – Civil Aircraft; Ce rtifications Required 14 CFR Part 91.405 – Maintenance required 14 CFR Part 91.407 – Operation after maintenance, p reventive maintenance, rebuilding or

alteration 14 CFR Part 91.409 – Inspections

14 CFR Part 91.417 – Maintenance Records U.S. DOT-FAA-Air Traffic Organization Policy Notice N JO 7210.873 (6.d)

14 CFR Part 11.81 (c) – The extent of relief USAA s eeks, and the reason USAA seeks the

relief:

USAA seeks relief pursuant to this exemption from a pplicable parts of the Federal Aviation Regulations and other rules/regulations to the exte nt necessary to permit civil flight operations within the national airspace. USAA seeks authorizat ion to conduct small UAS flight operations within the perimeters of this exemption request.

14 CFR Part 21 Subpart H (Airworthiness Certificate s)

USAA seeks to utilize the PrecisionHawk Lancaster U AS platform under this exemption request. This UAS platform has gained substantial operationa l maturity via several FAA approved Certificates of Authorization. It has a proven safe ty record and has demonstrated that its operations would not adversely affect safety compar ed to similar aircraft that have been issued an airworthiness certificated under 14 CFR Part 21, Subpart H. Should the FAA approve this exemption request and determine that an airworthine ss certificate is not required, noise certification and testing under 14 CFR Part 36 will also not be required for the UAS for the term of the exemption.

14 CFR Part 45.23 (b) (Display of Marks: General) USAA, as the petitioner seeks relief from Part 45.2 3 (b) requiring markings on certain sections of the aircraft and markings of a certain size. USA A will register their UAS in compliance with 14 CFR Part 47 and obtain N# registrations and will pl ace that N# registration on the UAS as large as practicable due to the UAS small size.

14 CFR Part 61.113 (a) and (b) (Private Pilot Privi leges and Limitations: Pilot in Command) Part 61.113 (a) states that no person who holds a p rivate pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as p ilot in command or an aircraft. Part 61.113 (b) states that a private pilot may, for compensati on or hire, act as pilot in command of an aircraft in connection with any business or employm ent if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does n ot carry passengers or property for compensation or hire. Within the Grant of Exemption Regulatory Docket No. FAA-2014-0352,

the FAA stated that it had to determine the level o f pilot certificate appropriate for that proposed operation. The FAA said within the Grant that it co nsiders the overriding safety factor to be the airmanship skills acquired through UAS-specific fli ght cycles, flight time, and specific make and model experience and UAS testing. USAA agrees with this determination; however we do notU.S. Department of Transportation

November 14, 2014 Page 4 of 15

13801002.4 feel that that it is necessary for our exemption re quest that the PIC possess a FAA Private Pilot Certificate. USAA contends that in determining the appropriate level for pilot certification, that consideration should be given for airspace operatio ns (separation from manned aircraft), aeronautical knowledge requirements, and UAS airman ship skills. USAA finds that the appropriate level of training and certification to support safe UAS operations within the parameters proposed by this petition is to require that the PIC and VO have taken and passed FAA Private Pilot Ground School and passed that FAA written knowledge exam. This provides the knowledge base for airspace operations and aero nautical knowledge. USAA also agrees with the FAA’s determination of UAS airmanship skil ls and requirements for the PIC as stated in

the Grant. USAA has also secured a FAA Commercial P ilot/FAA Certified Flight Instructor with UAS experience as its Safety Officer and that perso n will maintain oversight of the training and flight operations and have the final authority and responsibility for the operation and safety of all UAS flights.

14 CFR Part 91.7 (Civil Aircraft Airworthiness) This regulation states that (a) No person may opera te a civil aircraft unless it is in airworthy condition and (b) The pilot in command of a civil a ircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural c onditions occur. This exemption would not be necessary should the FAA approve the exemption for 14 CFR Part 21 Subpart H. If USAA’s UAS is not required to obtain an airworthiness cert ificate, then this would not apply; however

USAA would maintain the UAS and the PIC would deem the UAS safe for flight operations and discontinue any flight if any mechanical, electrica l, or structural problem arose.

14 CFR Part 91.9 (b) (Civil Aircraft Flight Manual, marking and placard requirements) and 14 CFR Part 91.203 (a) and (b) (Civil Aircraft; Certif ications Required) This regulation states that no person may operate a U.S. registered civil aircraft-(1) For which an Airplane or Rotorcraft Flight Manual is required by Part 21.5 of 14 CFR unless there is available in the aircraft a current, approved Airpl ane or Rotorcraft Flight Manual or the manual provided for in 14 CFR Part 121.141 (b); and (2) Fo r which an Airplane or Rotorcraft Flight Manual is not required by 14 CFR Part 21.5, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, appr oved manual material, markings and placards or any combination thereof. Based on the F AA’s Memorandum titled, “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station”, dated August 8. 2014, USAA feels that req uesting relief from these regulations may not be necessary. USAA will have in its possession, on site, the UAS manufacturer’s flight/operations manual and registration paperwork

.

14 CFR Part 91.109 (Flight Instruction) This regulation relates to civil aircraft with dual controls or throw over controls for flight trainin g. USAA seeks relief from this regulation in that our UAS does not have dual or throw over controls for flight instruction. USAA has provided all train ing and operational documents for our UAS platform, the PrecisionHawk Lancaster. USAA evaluat es the qualification of our pilots based on their experience with the UAS to be operated and ve rifies this through manufacturer and USAAsupplemented training (from USAA’s own FAA Certifie d Flight Instructor and UAS pilot).U.S. Department of Transportation

November 14, 2014 Page 5 of 15

13801002.4 14 CFR Part 91.119 (b) and (c) (Minimum Safe Altitu des: General) Per the regulation, except when necessary for takeo ff or landing, no person may operate an aircraft below the following altitudes: (a) Anywher e. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons o r property on the surface. (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 abov e the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over othe r than congested areas. An altitude of 500 feet above the surface, except over open water or sparse ly populated areas. In those areas, the aircraft may not be operated closer than 500 feet t o any person, vessel, vehicle, or structure. USAA does not request relief from (a) as we feel th at our UAS can make an emergency landing without undue hazard to persons or property on the ground if its power unit fails due to its size and operating parameters. USAA is seeking relief fr om (b) and (c) because in catastrophe events/locations, we would need to operate at a low er altitude (no less than 200 feet) to obtain the most optimal flight conditions, but we would no t operate at an altitude that would create any undue hazard to persons or property on the surface.

14 CFR Part 91.121 (Altimeter Settings) This regulation states that:(a) Each person operati ng an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the c ase may be, by reference to an altimeter that is se t, when operating—(1) Below 18,000 feet MSL, to—(i) Th e current reported altimeter setting of a station along the route and within 100 nautical mil es of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) o f this section, the current reported altimeter setting of an appropriate available station; or (ii i) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, to 2 9.92 ′′ Hg.(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following

table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210U.S. Department of Transportation

November 14, 2014 Page 6 of 15

13801002.4 (c) To convert minimum altitude prescribed under §§ 91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equiva lent of the minimum altitude in feet and add the appropriate number of feet specified below, accordi ng to the current reported altimeter setting:

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

Although USAA will not have a typical aircraft baro metric altimeter onboard the UAS, our intention is to operate within VLOS and at or below 400 feet AGL. This, in combination with our UAS’s capacity will provide altitude information to both the PIC and mission specialist/planner

via a telemetric data feed which downlinks from the UAS to a ground based display. Prior to each flight the UAS PIC and mission specialist/plan ner will confirm altitude accuracy prior to

launch.

14 CFR Part 91.151 – Fuel Requirements for Flight i n VFR Conditions According to this regulation, (a) No person may beg in a flight in an airplane under VFR conditions unless (considering wind and forecast we ather conditions) there is enough fuel to fly to the first point of intended landing and, assumin g normal cruising speed— (1) During the day, to fly after that for at least 30 minutes; or (2) A t night, to fly after that for at least 45 minutes. (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel t o fly to the first point of intended landing and, assuming normal cruising speed, to fly after that f or at least 20 minutes. USAA seeks relief from Part 91.151 (a.1) and (b), a s its UAS does not carry fuel onboard and is powered via battery. USAA’s UAS is 5.5 lbs, operate s at slow speeds and within VLOS in VMC conditions. USAA intends to terminate flights after 90 minutes or with 20% remaining battery power (whichever occurs first). USAA does not seek an exemption from Part 91.151 (a)(2) as UAS operations will be conducted during the daytime VMC (visual meteorological conditions).

14 CFR Part 91.203 (a) and (b) – Civil Aircraft; Ce rtifications Required This regulations states that (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness

certificate. Each U.S. airworthiness certificate us ed to comply with this subparagraph (except a special flight permit, a copy of the applicable ope rations specifications issued under §21.197(c) of this chapter, appropriate sections of the air ca rrier manual required by parts 121 and 135 ofU.S. Department of Transportation

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13801002.4 this chapter containing that portion of the operati ons specifications issued under §21.197(c), or an authorization under §91.611) must have on it the registration number assigned to the aircraft under part 47 of this chapter. However, the airwort hiness certificate need not have on it an assigned special identification number before 10 da ys after that number is first affixed to the

aircraft. A revised airworthiness certificate havin g on it an assigned special identification number, that has been affixed to an aircraft, may o nly be obtained upon application to an FAA Flight Standards district office. (2) An effective U.S. registration certificate issued to its owner o r, for operation within the United States, the second copy of the Aircraft registration Application as provided for in §47.31(c), or a registration certif ication issued under the laws of a foreign country. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special fligh t authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Should the FAA allow for the exemption of 14 CFR Pa rt 21, USAA would not need an exemption from this regulation, as an airworthiness certifica te would not be required; however since that exemption has not been received to date, USAA seeks relief from this regulation. USAA’s UAS will be registered with the FAA and will have the a ppropriate documentation available upon
request.

14 CFR Part 91.405 – Maintenance required According to this regulation, each owner or operato r of an aircraft—(a) Shall have that aircraft inspected as prescribed in subpart E of this part a nd shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter; (b) Shall ensure that maintenan ce personnel make appropriate entries in the aircraft maintenance records indicating the aircraf t has been approved for return to service; (c) Shall have any inoperative instrument or item of eq uipment, permitted to be inoperative by §91.213(d)(2) of this part, repaired, replaced, rem oved, or inspected at the next required inspection; and (d) When listed discrepancies inclu de inoperative instruments or equipment, shall ensure that a placard has been installed as r equired by §43.11 of this chapter. USAA seeks relief from this regulation because alternate UAS inspection requirements are needed. USAA will follow UAS manufacturer requirements rega rding maintenance via the attached

manufacturer maintenance schedule. USAA will docume nt all maintenance, overhaul, replacement, and inspection requirements, as well a s any preflight inspection procedures that account for discrepancies not already covered in th e manufacturer’s manual; documentation of maintenance records and will partner with the UAS m anufacturer to develop UAS technician qualification criteria.

14 CFR Part 91.407 – Operation after maintenance, p reventive maintenance, rebuilding or

alteration Per this regulation, (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration u nless— (1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and (2) The maintenance record entry required by §43.9 or §43.11, as applicable, o f this chapter has been made. (b) No person may carry any person (other than crewmembers) in an aircraft that has been maintained, rebuilt, or altered in a manner that may have appreciably ch anged its flight characteristics orU.S. Department of Transportation

November 14, 2014 Page 8 of 15

13801002.4 substantially affected its operation in flight unti l an appropriately rated pilot with at least a priv ate pilot certificate flies the aircraft, makes an oper ational check of the maintenance performed or alteration made, and logs the flight in the aircraf t records. (c) The aircraft does not have to be flown as required by paragraph (b) of this section if, prior to flight, ground tests, inspection, or both show conclusively that the maintenance, preven tive maintenance, rebuilding, or alteration has not appreciably changed the flight characterist ics or substantially affected the flight operation of the aircraft

.

USAA seeks relief from this regulation, and request s that the FAA adopt an alternative version that is applicable to UAS operations. A USAA-approv ed UAS technician or the UAS manufacturer will approve the UAS to return to serv ice/operation after it has undergone maintenance, rebuilding or alteration. The UAS PIC may approve the UAS for return to service after performing any preventive maintenance. USAA w ill keep UAS maintenance records that contain the following information: name of the pers on performing the maintenance, description of work performed, and date of work completion/retu rned to service.

14 CFR Part 91.409 – Inspections According to this regulation, (a) Except as provide d in paragraph (c) of this section, no person may operate an aircraft unless, within the precedin g 12 calendar months, it has had—(1) An annual inspection in accordance with part 43 of thi s chapter and has been approved for return to service by a person authorized by §43.7 of this cha pter; or 2) An inspection for the issuance of an airworthiness certificate in accordance with par t 21 of this chapter. No inspection performed under paragraph (b) of this section may be substitu ted for any inspection required by this paragraph unless it is performed by a person author ized to perform annual inspections and is entered as an “annual” inspection in the required m aintenance records. (b) Except as provided in paragraph (c) of this section, no person may ope rate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the prece ding 100 hours of time in service the aircraft has received an annual or 100-hour inspection and b een approved for return to service in accordance with part 43 of this chapter or has rece ived an inspection for the issuance of an airworthiness certificate in accordance with part 2 1 of this chapter. The 100-hour limitation may be exceeded by not more than 10 hours while en rout e to reach a place where the inspection can be done. The excess time used to reach a place where the inspection can be done must be included in computing the next 100 hours of time in service. (c) Paragraphs (a) and (b) of this section do not apply to— (1) An aircraft that carri es a special flight permit, a current experimental certificate, or a light-sport or provi sional airworthiness certificate; (2) An aircraft inspected in accordance with an approved aircraft i nspection program under part 125 or 135 of this chapter and so identified by the registration number in the operations specifications of the certificate holder having the approved inspection p rogram; (3) An aircraft subject to the requirements of paragraph (d) or (e) of this sectio n; or (4) Turbine-powered rotorcraft when the operator elects to inspect that rotorcraft in accor dance with paragraph (e) of this section.

USAA seeks relief from this regulation, in that USA A will follow the guidance included in the

UAS manufacturer’s maintenance schedule as attached

.U.S. Department of Transportation

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13801002.4 14 CFR Part 91.417 – Maintenance Records According to this regulation, (a) Except for work p erformed in accordance with §§91.411 and 91.413, each registered owner or operator shall kee p the following records for the periods specified in paragraph (b) of this section: (1) Rec ords of the maintenance, preventive maintenance, and alteration and records of the 100- hour, annual, progressive, and other required or approved inspections, as appropriate, f or each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and ( iii) The signature, and certificate number of the person approving the aircraft for return to ser vice. (2) Records containing the following information: i) The total time in service of the ai rframe, each engine, each propeller, and each rotor. (ii) The current status of life-limited part s of each airframe, engine, propeller, rotor, and appliance.(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) Th e current inspection status of the aircraft, including the time since the last inspection requir ed by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, fo r each, the method of compliance, the AD or safety directive number and revision date. If the A D or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner o r operator shall retain the following records for the periods prescribed: (1) The records specifi ed in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 year after the work is performed. (2) The records specified in paragraph ( a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircr aft is sold. (3) A list of defects furnished to a registered owner or operator under §43.11 of this c hapter shall be retained until the defects are repaired and the aircraft is approved for return to service. (c) The owner or operator shall make all maintenance records required to be kept by this section available for inspection by the Administrator or any authorized representative of t he National Transportation Safety Board (NTSB). In addition, the owner or operator shall pr esent Form 337 described in paragraph (d) of this section for inspection upon request of any law enforcement officer. (d) When a fuel tank is installed within the passenger compartment or a bag gage compartment pursuant to part 43 of this chapter, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner
or operator.

USAA seeks relief from this regulation and requests an exemption. All maintenance and alterations will be properly documented in the UAS aircraft records. USAA will follow the UAS manufacturer’s aircraft/component, maintenance, ove rhaul, replacement, inspection and life limit requirements. All maintenance, preventive maintenan ce, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS will be recorded and documented. USAA will comply with all manufactu rer safety bulletins.

U.S. DOT-FAA-Air Traffic Organization Policy Notice N JO 7210.873 (6.d)U.S. Department of Transportation

November 14, 2014 Page 10 of 15

13801002.4 6(d) Certificates of Waiver or Authorization (COA)- Emergency and Urgent Applications: The FAA must ensure procedures are available to accommo date real-time applications that will directly support emergency and law enforcement-type operations. UA Operations that reduce safety must not be approved in any case. (1) An eme rgency UAS COA may be considered when all of the following conditions apply: (a) The re is a situation of such distress or urgency that the possibility of loss of life is great. (b) Manned flight is not possible or practicable due to a hazard or the operation cannot be conducted safely with manned flight, or manned assets are not available. (c) The proposed proponent and UAS a re operating under a current approved

COA. Note- Requests for UAS COAs that fall outside of these pe rimeters must be processed through the normal online COA application process. (2) Emergency UAS COAs will not be considered for: (a) Demonstration flights. (b) Flig hts to test capabilities. (c) Training. (d) Flights in Class B airspace. (e) Flights over populated are as.

USAA seeks an exemption from the normal FAA UAS Civ il COA Request mandated by a Section 333 Exemption filing and the current Emerge ncy COA process. During a catastrophe event, the exact timeframe and location is not know n ahead of time; therefore, USAA could not abide by the current COA process and would need an exemption from the normal COA process as well as the current Emergency COA process. USAA would notify the local FSDO of the affected area immediately, apply for an amended Eme rgency COA (as granted by this exemption) and would notify any Incident Command or first responders for approval and

coordination and would not interfere with first res ponders’ activities. Through this request, USAA is seeking relief from U.S. DOT-FAA-Air Traffic Org anization Policy Notice N JO 7210.873 (6.d)- 1(a), 1(c), 2(d) with ATO approval, and 2(e) of the COA process stated above.

14 CFR Part 11.81 (d) – The reasons why granting US AA’s request would be in the public interest; that is, how it would benefit the public as a whole:

Granting the exemption for USAA would allow the org anization to safely and efficiently conduct small UAS flight operations to assist its membershi p and their communities after catastrophic

events and will reduce the time it takes communitie s to rebuild after natural disasters. UAS operations will provide more efficient claims servi ce to its membership and could positively impact post-disaster recovery and relief operations via shared resources with first responders. Without this exemption, USAA would be restricted to ground only operations which would not have the benefits of UAS efficiency in terms of bot h service and safety. Property inspections at these areas are difficult and at times dangerous fo r employees to navigate, especially when debris and dwelling integrity is an issue. USAA bel ieves a UAS operation can lead to safer, quicker, and more economical and effective claims s ervice for its more than ten million

members and their communities.

14 CFR Part 11.81 (e) – The reasons why granting th e exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which USAA seeks the exem ption:U.S. Department of Transportation

November 14, 2014 Page 11 of 15

13801002.4 USAA requests that the exemption be granted with th e following limitations and operational conditions. These limitations and conditions will p rovide an enhanced level of safety and will be the guiding principles when USAA is conducting oper ations under this exemption:

A. The small unmanned aircraft systems maximum take -off weight will be less than 55 lbs. Detailed specifications are included in the attachm ents. USAA is willing to have its

authorization restricted below the 55 lb. threshold to the operating weight of the unmanned aircraft identified. The fixed winged UAS platform that USAA is seeking to utilize through this exemption is currently operati ng safely within the national airspace pursuant to several COAs granted by the FAA to Texa s A&M College Station and other public entities. One these COAs was for the use of the PrecisionHawk Lancaster HawkEye – the type of UAS that USAA seeks to utiliz e -to provide aerial imagery and mapping for authorities at the recent Washington st ate mudslides in Oso, WA. Other COAs have been approved for this particular platfor m through other public entities,

which demonstrates the confidence that the FAA has for this manufacturer’s operational and safety protocol. USAA has attached the Precisio nHawk Lancaster’s Flight Manual, Maintenance Schedule, and training documents for re view within this exemption application. USAA would operate in accordance with all of these documents.

B. All pilot in command (PIC) and visual observers (VO) will complete FAA certified private pilot ground school and will have taken and passed the FAA Private Pilot Written Exam. This ensures that all PIC and VO have the knowledge regarding the Federal Aviation Regulations, Airspace, and other pertinent knowledg e to conduct safe operations of small unmanned aircraft systems. A USAA employee wi th a FAA commercial pilot certificate and flight instructor certificate (USAA Safety Officer) that has been trained on UAS operations will oversee all training/operations and ensure all PIC and VO receive proper training and abide by all pertinent regulati ons. This employee/FAA commercial pilot will meet all the flight review requirements specified in 14 CFR Part 61.56 in an aircraft in which the PIC is rated on her/his fligh t certificate. All PIC and VO will be

trained in detail to each of the unmanned aircraft system platform’s operations, systems and emergency procedures and passed every level of training on the platform and pass the manufacturer’s test administered by the USAA em ployee/CFI (Trained by the UAS manufacturer on the platform). Training records wil l be kept at USAA for every PIC and VO and will be available for review. Every PIC and VO will obtain an FAA Class 3 medical certificate. Every USAA PIC and VO will rec eive FEMA training and will fully participate with Incident Command and follow their guidance.

C. Prior to conducting operations in a disaster/cat astrophe event, the PIC will have accumulated and logged, in a manner consistent with 14 CFR Part 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS fixed wing pilot and at least 10 hours logged as a UAS pilot with a similar UAS type . The PIC will have accumulated and logged a minimum of 5 hours as a UAS pilot operatin g the make and model of the UAS to be utilized for operations and 3 take off and la ndings in the preceding 90 days. USAA has utilized its partnerships with FAA UAS Test Sit es and Roboticists Without Borders toU.S. Department of Transportation

November 14, 2014 Page 12 of 15

13801002.4 gain this maturity along with other experience buil ding authorized flights. USAA, through its first exemption request (Docket FAA-2014-0796-0 001), seeks to make this process more efficient and streamlined for building UAS exp erience in the future.

All flight operations will be coordinated and appro ved by the FAA in advance of USAA’s arrival at the catastrophe site via an amended emer gency COA (see emergency COA exemption request). USAA would comply with all dire ction from onsite Incident Command and any other public safety or emergency re sponse official. USAA would not impede or disrupt any first responder activities an d UAS operations would only be

conducted when it is deemed safe to do so and in co ordination with the appropriate officials at the location. The UAS will not be oper ated directly over any person, except authorized and consenting personnel at the site or unless the UAS is at sufficient altitude not to create a hazard to other people or property on the ground.

D. All flight operations will be operated at an alt itude of no more than 400 ft above the ground (AGL) within daylight VFR conditions and wit hin visual line of sight (VLOS). The UAS will be operated within VLOS of the PIC at all times. The UAS will remain clear and yield the right of way to all other manned operatio ns and activities at all times. All operations will utilize at least one visual observe r (VO) and the PIC and VO will be able to communicate verbally at all times. As it is not possible to determine where or when a natural disaster will occur, USAA seeks authorizati on to conduct UAS operations within Class G, E, C, D and B and special use airspaces (T FR), with appropriate written authorization from the FAA (via an amended emergenc y COA), ATO, and any applicable incident command. No flight operations will be oper ated within Class A airspace. The UAS will not operate within 5 nm of any airport unl ess a letter of agreement with that airport’s management is obtained and the operation is conducted in accordance with a NOTAM, as required by a COA. All flights will be co mmunicated to FAA Flight Service with posted NOTAMS prior to the flight(s).

E. All flight operations will be conducted within l ine of sight of the pilot in command and visual observer(s). Maximum total flight time for e ach flight will be 90 minutes or less in duration. All flight operations will be terminated when the aircraft has less than 20% battery life remaining.

F. Flight operations and safety briefings will be c onducted prior to all planned small unmanned aircraft system flights and will be mandat ory for PIC and VO. Briefings will include weather reviews, take off, landing and airc raft performance data for those real time conditions, and full pre- and post-flight insp ections/checklists and briefings for each specific unmanned aircraft system, including the gr ound control station being operated and account for any discrepancies (i.e. inoperable components, items or equipment that are not covered in the relevant preflight inspectio n sections of the operations manual.) Before conducting any flight, the radio frequency s pectrum used for the operation and control of the UAS will comply with the FCC or othe r appropriate government oversight agency requirements.U.S. Department of Transportation

November 14, 2014 Page 13 of 15

13801002.4 G. USAA will obtain an Air Traffic Organization (AT O) issued Emergency COA (amended by this exemption) prior to conducting any operatio ns. This Emergency COA will require USAA to request a Notice to Airmen (NOTAM) upon imm ediate approval of the COA. Since no one can predict with certainty the locatio n and timing of natural disasters, USAA would not be able to give the local FSDO three days notice of planned activities; however, upon notice of the event, USAA will submit a written plan to the local FSDO of

the affected area:

• Dates and approximate times of flights

• Name and phone number of the USAA PIC and VO

• Name and phone number of the person responsible fo r on-site operation of the

UAS

• Make, model, and serial or N-Number of the UAS to be used

• Name and certificate number of the USAA Safety Off icer at the site

• A statement that USAA has obtained permission from local officials/incident command to conduct operations at the site; the list of those who gave the permission will be made available to the FAA upon r equest

• A description of the flight activity, including ma ps of any area, city, town, county and/or state which flights will be conducted and th e altitudes essential to accomplish the flights.

H. Any UAS that has undergone maintenance or altera tions that affects the UAS operation or flight characteristics must undergo a functional test flight in accordance with the

manufacturer’s recommendations. The PIC who conduct s the test flight will make an entry in the UAS aircraft records of the flight. Al l maintenance and alterations will be properly documented in the aircraft records. USAA w ill follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacem ent, inspection and life limit requirements. All maintenance, preventive maintenan ce, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS will be recorded and documented. USAA will comply with all manufacturer safety bulletins.

I. In the event of a communication lost link, the U AS will return to a specific predetermined location and once the UAS is safely recovered, all flight operations will cease until any communication/data link issues are properly resolve d. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in ac cordance with the operator’s

manual.

J. Regarding privacy concerns, USAA will coordinate all activities with incident command and any other public officials.

K. Any incident, accident or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by th e applicable COA will be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hrs. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the

NTSB Web site: www.ntsb.com . USAA will suspend all flight operations until theU.S. Department of Transportation

November 14, 2014 Page 14 of 15

13801002.4 incident, accident, or transgression is reviewed by AFS-80 and authorization to resume operations is provided.

14 CFR Part 11.81 (f) A summary the FAA can publish in the Federal Register, stating:

(1) The rule from which you seek the exemption

Petitioner: United Services Automobile Association

Sections of 14 CFR and FAA regulations that USAA se eks an exemption:

14 CFR Part 21 Subpart H 14 CFR Part 45.23 (b) 14 CFR Part 61.113 (a) and (b)

14 CFR Part 91.7 14 CFR Part 91.9 (b)

14 CFR Part 91.109

14 CFR Part 91.119

14 CFR Part 91.121

14 CFR Part 91.151 14 CFR Part 91.203 (a) and (b)

14 CFR Part 91.405

14 CFR Part 91.407

14 CFR Part 91.409

14 CFR Part 91.417 U.S. DOT-FAA-Air Traffic Organization Policy Notice N JO 7210.873 (6.d)

(2) A brief description of the nature of the exemption you seek:

USAA seeks relief from the applicable parts of 14 C FR 21, 45, 61, 91 and U.S. DOT-FAA-Air Traffic Organization Policy Notice N JO 7210.873 (6 .d) as requested within this petition to allow USAA to safely and efficiently conduct civil UAS fl ight operations during disaster and catastrophe events to assist its membership and the ir communities.

14 CFR Part 11.81 (g) – Any additional information, views or arguments available to support USAA’s request:

This exemption would give USAA the ability to assis t its members and their communities with UAS development and operations beyond the limits im posed today. Additional development and operation would benefit not only USAA and its membe rship, but would allow USAA to serve as a partner with the FAA and others within the UAS comm unity to advance this new and emerging technology in a safe and controlled environment. Wi th our partnerships, USAA has demonstrated the value of our request to utilize ou r UAS technology within disaster recoveryU.S. Department of Transportation

November 14, 2014 Page 15 of 15

13801002.4 areas to help communities rebuild after these event s and maintain the safety of our employees, business partners and the general public.

14 CFR Part 11.81 (h) – Request to exercise the pri vileges of the exemption outside the United States, the reason why the petitioner needs to do so:

USAA does not seek to exercise the privileges of th is exemption, should it be granted, outside of the United States. Our request is strictly to be granted authority for civil UAS operations at locations within the national airspace system.

Sincerely,

Greg Cirillo Wiley Rein LLP

Counsel for USAA 

# Michael Burns

Michael Burns

Assistant Vice President

USAA

Attachments: PrecisionHawk Flight Manual, Maintenan ce Schedule and training documents.