Brittany Ne\vton 

Docket 1 1904 

Dear Ms. Newton: 

Please accept this letter as The Hartford Steam Boiler Inspection and 

Insurance Company's ("HSB") response to your correspondence dated 

August 14, 2015 seeking additional information as to the reasons why 

granting the request would be in the public interest, and benefit the public 

as a whole, in accordance with Section 1 1.81. 

Granting the present Petition will further the public interest allowing 

efficiently, and economically perform aerial risk 

""""'"' risk management, and loss control activities and undertake 

development into new and innovative to respond to 

natural and casualty events. HSB' s proposed operations will 

a number benefits to the public at communities affected by 

HSB's and . ( 

Control 
p

ys

ca

 potential for collateral damage to life 

and property on the ground, and in the air, compared to the manned 

aircraft that typically conduct similar operations. 

In addition, the public has an interest in reducing the hazards associated 

with traditional methods of conducting similar inspection operations. 

Currently, inspections are conducted with inspection personnel physically 

climbing onto structures using ladders. By using UAS, an inspector will 

be able to reduce his or her exposure to physical hazards by conducting 

the inspection while remaining safely on the ground. These benefits are 

particularly pronounced in the context of catastrophe response, where 

affected structures may be severely damaged. 

2. Faster Claims Investigation and Service After Catastrophic 

Events Will Lead to Faster Recovery by Policyholders and the 

Economy and Improve the National Response to Natural 

Disasters 

HSB seeks authorization to operate UAS to improve claim resolution 

following natural disasters and other casualty events, which will have 

identifiable benefits for its policyholders and the communities it serves. 

HSB will be better able to inspect, survey, and document the condition of 

its policyholders' property after a casualty event safely, thoroughly, and 

efficiently. This should expedite HSB's evaluation and processing of 

claims after an event and ensure that its policyholders can receive the 

money necessary to rebuild, facilitating quicker economic recovery in 

affected regions. Expedited claims processing and community recovery 

will also improve the national response to catastrophic events by enabling 

faster and more efficient implementation of other programs. 
p

well as to commercial entities employing UAS in 

other circumstances. The public has a strong interest in commercial 

operators realizing the full potential ofUAS through safe R&D programs 

on controlled-access property. 

4. The Public \Viii Benefit from Decreased Pollution and 

Airspace Congestion 

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are battery-powered 

and serve as a safe, efficient, and economical alternative to the manned 

aircraft traditionally utilized to obtain aerial imagery. By reducing the 

amount of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use ofUAS would reduce airspace congestion, 

alleviate burdens on air traffic control, and reduce noise and air pollution. 

Allowing UAS operations reduces both the congestion of manned aircraft 

in the national airspace and the congestion around airports caused by 

arriving and departing aircraft, as UAS do not require an airport to takeoff 

or land. Likewise, a reduction of manned aircraft conducting aerial 

missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases 

of flight operations. 

Moreover, conducting aerial acquisitions with the proposed UAS, instead 

of manned aircraft, will greatly benefit the public by drastically reducing 

the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power and 

electric motors, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS 

produce no air pollution. UAS are the most viable environmentallyto the cabin cylinder internal combustion 

are propelled 

internal combustion engine. 
Inspire 1 UAS will allow United States

based companies, like HSB, to 

remain competitive and contribute to gro~1h of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency ("EPA") regulatory actions phasing out leaded aviation 

fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery-powered 

DJI Phantom 2 Vision+ and DJI Inspire 1 UAS is one such technology 

that not only allows companies greater operational flexibility than manned 

aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating such UAS, companies such as HSB can remain competitive 

and profitable, and therefore provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. 

economy. Improved financial performance of U.S. companies, through 

commercial use ofUAS, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and 

allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad. 

Vice President