8,15 Brittany Ne\vton Docket

11904 DearMs.Newton: Please acceptthisletterasTheHartfordSteamBoiler Inspectionand Insurance Company's ("HSB") response
to yourcorrespondence dated August 14,2015 seekingadditional information

astothereasonswhy grantingthe requestwouldbeinthe public interest,andbenefitthe public asawhole,inaccordancewithSection

11.81. Grantingthe presentPetitionwillfurtherthe publicinterest allowing efficiently,and economically performaerialrisk """"'"'risk management,andlosscontrolactivitiesandundertake developmentintonewandinnovative

to respond
to natural
and casualtyevents.HSB'

sproposed operationswill anumberbenefits
tothe publicatcommunities affected by HSB's
and

.( Controlacquisitions,
the risk to life and property
in the air and on the ground which
is associated with traditional manned aircraft flight operations will be substantially reduced or completely eliminated. Aside from the lack of t1ight crew members located onboard the aircraft, the DJI Phantom

2 and DJI Inspire

1 UAs-weighing approximately

2 pounds
11 ounces and 6 pounds 7.5 ounces, respectively,

at their maximum gross weights with lengths of 16 inches and
1 inches, respectively, and with no fuel on board-have less physical 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.3. HSB's R&D Could Create New UAS Applications
for Multiple Industries HSB's proposed R&D operations will enable HSB to develop newand innovative usesfor UAS. Although HSB's program

is geared
atinsurer response
tonatural disasters and other casualty events, the resulting UAS applications could be beneficial

toentities performing other catastrophe responsefunctions
aswell asto 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 oncontrolled-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 serveasa safe, efficient, and economical alternative

tothe manned aircraft traditionally utilized
toobtain aerial imagery. By reducing the amount of manned aircraft needed
to perform aerial acquisitions,

an exemption allowing the useofUAS would reduce airspace congestion, alleviate burdens onair 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,
asUAS do not require an airport to takeoff orland. Likewise,

areduction of manned aircraft conducting aerial missions would result in fewer aircraft that mustbe 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 powerand electric motors, the DJI Phantom

2 Vision+ and DJI Inspire

1 UAS produce noair pollution. UAS arethe most viable environmentallytothe cabin cylinder internal combustion are propelled internal combustion engine.5. Performing Aerial Operations To Support Risk Assessment, Risk Management, and Loss Control Will Benefit The Economy. In addition
to being safe and efficient, the proposed use ofUAS

is also an economical alternative

to using manned aircraft to conduct similar aerial operations.
As such, operation of the DJI Phantom

2 Vision+ and DJI 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