AFS-15-085-E

Exemption No. 11188

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 20591

GRANT OF EXEMPTION

By letter dated October 15, 2014, Mr. Jack Weekes, Operations Vice President for 

State Farm Mutual Automobile Insurance Company (hereinafter Petitioner or Operator), One 

State Farm Plaza, Bloomington, IL 61710-0001, petitioned the Federal Aviation 

Administration (FAA) for an exemption part 21 Subpart H, §§ 21.191(a), 45.23(b), 45.27,

61.113(a) and (b), 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2),

and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The exemption 

would allow the petitioner to commercially operate the Aerialtronics Altura Zenith ATX8 and 

Altavian Nova F6500 unmanned aircraft systems (UAS) for outdoor research and development 

related to use of UAS for civil operations for insurance functions including using imagery and 

analytics in underwriting, re-underwriting, catastrophe response, roof inspection, and claim 

resolutions settings.

The petitioner requests an exemption from the following regulations:

Part 21 prescribes, in pertinent part, the procedural requirements for issuing and changing 

design approvals, production approvals, airworthiness certificates, and airworthiness 

In the matter of the petition of

STATE FARM MUTUAL AUTOMOBILE 

INSURANCE COMPANY

for an exemption from part 21 Subpart H;

21.191(a), §§ 45.23(b); 45.27; §§ 61.113(a)

and (b); §§ 91.119(c); 91.121; 91.151(a); 

91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 

and 91.417(a) and (b) of Title 14, Code of 

Federal Regulations

Regulatory Docket No. FAA–2014–0856
approvals. Subpart H prescribes procedural requirements for the issue of airworthiness 

certificates and § 21.191(a) addresses research and development including testing new 

aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft 

operating techniques, or new uses for aircraft.

Section 45.23(b) prescribes, in pertinent part, that when marks include only the Roman capital 

letter “N” and the registration number is displayed on limited, restricted or light-sport category

aircraft or experimental or provisionally certificated aircraft, the operator must also display on 

that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable.

Section 45.27 prescribes, in pertinent part, that each operator of a rotorcraft must display on 

that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks 

required by §45.23.

Section 61.113(a) and (b) prescribes that—

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of 

an aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

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

may operate an aircraft below the following altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.121 requires, in pertinent part, 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.”

Section 91.151(a) prescribes that no person may begin a flight in an airplane under visual 

flight rules (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.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that 

aircraft inspected as prescribed in subpart E of the same part and shall, between required 

inspections, except as provided in paragraph (c) of the same section, have discrepancies 

repaired as prescribed in part 43 of the chapter.

Section 91.407(a)(1) prescribes that no person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for

return to service by a person authorized under § 43.7 of the same chapter.

Section 91.409(a)(1) and (2) prescribes, in pertinent part, that –

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by §43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter.

Section 91.417(a) and (b) prescribes, in pertinent part, that—

(a) Each registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of 

the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for 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 service.

(2) Records containing the following information: 
(i) The total time in service of the airframe, each engine, each propeller, and each 

rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance.

(iii)The time since last overhaul of all items installed on the aircraft that are 

required to be overhauled on a specified time basis.

(iv)The current inspection status of the aircraft, including the time since the last 

inspection required 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, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD 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) for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the 

work is repeated or superseded by 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 aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 shall be 

retained until the defects are repaired and the aircraft is approved for return to 

service.

The petitioner supports its request with the following information:

The petitioner proposes to operate the Aerialtronics Altura Zenith ATX8 and Altavian Nova 

F6500 UAS to conduct commercial operations for outdoor research and development related 

to use of UAS for civil operations for insurance functions including using imagery and 

analytics in underwriting, re-underwriting, catastrophe response, roof inspection, and claim 

resolutions settings. See Appendix A for the petition submitted to the FAA describing the 

proposed operations.

The Altura Zenith ATX8 is a quad rotor aircraft built with a monocoque carbon airframe. The
Zenith’s maximum operating weight is less than 15 pounds.

The Nova F6500 Aircraft is an electric fixed wing UAS with a wingspan of 108 inches and a 

maximum operating weight of less than 20 pounds. 

The petitioner has provided the following information to support its request for an exemption, 

which includes these proprietary supporting documents:

1) Training Syllabus, 

2) Operations Manual including: 

a) Appendix A: Nova F6500 Operator Manual, 

b) Appendix B: Nova F6500 Maintenance Manual, 

c) Appendix C: Nova MP32 Field Guide, 

d) Appendix D: Nova VP23 Field Guide, 

e) Appendix E: Aerialtronics Operations Manual, 

f) Appendix E: Aerialtronics System Description Manual

Discussion of Public Comments:

A summary of the petition was published in the Federal Register on November 14, 2014, (79 

FR 68346). The FAA received three comments on the petition for exemption. The Small 

UAV Coalition (Coalition) supported the petition and the Air Line Pilots Association, 

International (ALPA) and the National Agricultural Aviation Association (NAAA) opposed it.

In support of the petition, the Coalition stated the petitioner has proposed to abide by stronger 

safety measures than hobby and modeler groups operating similar aircraft. The Coalition 

stated that it does not believe that heightened safety measures should be required for the 

petitioner simply because of the commercial nature of its operations. The Coalition urged the 

FAA to adopt an evaluation framework for UAS operations under section 333 of Pub. L. 112–

95 that weighs the relative safety issues and risks of UAS by class and operational 

circumstances, rather than adopting artificial distinctions among unmanned aerial vehicles 

based on commercial and noncommercial operations. The Coalition suggested FAA safety 

regulations be proportionate to the risks posed by the particular proposed UAS operations by 

distinguishing between UAS. The petitioner’s UAS pose considerably less safety risk than 

larger UAS. The Coalition asserted that because UAS operations like the petitioner’s pose 

minimal risk to safety, they should be subject to minimal and appropriate regulations.

The Coalition noted the FAA is to consider the seven factors1 in section 333 as a minimum. 

The Coalition stated the petition shows the FAA should consider factors other than those 

 1

 Section 333(b) of P.L. 112-95 states, in part: “In making the determination under subsection (a), the Secretary 

shall determine, at a minimum-- (1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line 

of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national 

security; ...”
specified in section 333, such as the location and altitude of its small UAV operations. The 

Coalition maintained that the petitioner’s proposed operations satisfy the seven factors in 

section 333 and include several additional mitigating factors to ensure the safety and security 

of the proposed UAS operations. The Coalition emphasized the FAA must evaluate each 

factor within the context of the petitioner’s proposed UAS operations. 

The Coalition also commented that the FAA should grant relief from the requirement to hold 

an airman’s certificate, but stated that at a minimum the FAA should provide an exemption 

from part 61 and approve training, experience, and testing regiments that pertain to UAS 

commercial operations pertinent to the aircraft and operation proposed. The Coalition also 

asserted that Congress intended the section 333 national security criterion to focus on the 

operation rather than on the pilot and that shifting that focus imposes an unnecessary burden.

In response, as discussed in the grant of exemption to Trimble Navigation Ltd. (No. 11110), 

neither section 333 nor the FAA’s authority to exempt from its regulations found in 

49 USC § 44701(f), authorizes the FAA to provide exemption to the statutory requirement to 

hold an airman certificate as prescribed in 49 USC § 44711. The FAA notes that under this 

exemption the petitioner proposed to use pilots holding private certificates and it will be able 

to use the training program it proposed. Finally, the FAA does not agree that relying on the 

pilot certificate for a national security finding poses an unnecessary burden because pilots 

under this exemption, and the exemptions granted previously to section 333 requests, are 

already required to hold a pilot certificate to satisfy 49 USC § 44711.

The Coalition commented that a visual observer (VO) should not be required for all small 

UAS operation. The Coalition further asserted that the presence of one or more VOs may 

allow the UAS to be operated beyond visual line of sight (VLOS) of the pilot in command 

(PIC) and that the petitioner’s proposal to operate the unmanned aircraft (UA) within VLOS 

of the PIC and/or VO should be permitted. The FAA notes that one of the determinations for 

operations under section 333 is operation within visual line of sight. As the PIC is determined 

to be in command of the UA, he or she must maintain VLOS while operating the UA. The 

FAA also notes that a visual observer complements the PICs capability to see and avoid other 

aircraft, including when the PIC may be momentarily attending to other flying tasks. The VO 

provides an additional level of operational safety.

The Coalition stated that submitting a plan of activities “in all cases” should not be required of 

sUAS operators and notifying the FAA should be necessary only when there is a potential 

conflict with manned aircraft operations because of the altitude of the UAV operaton or its 

proximity to airports. Although the petitioner has volunteered to submit a written Plan of 

Activities to the local FSDO, this is not required by this grant of exemption.

The Coalition also commented that in the case of State Farm’s proposed operation over State 

Farm property at least 5 miles from any airport that it is not necessary to obtain a letter of 

agreement when in proximity of non-towered airports, rather, that State Farm be mindful of 
any nearby airfields and knowledgeable about arrival and departure paths. These comments 

are addressed in the FAA’s analysis and conditions and limitations below. 

ALPA expressed concern regarding several aspects of the petition. ALPA noted the 

petitioner’s reference to operations conducted within “limited or predetermined” sterile areas 

is not defined, nor does the petitioner detail procedures for controlling the airspace or area of 

operation. Specifically, ALPA stated “there must be means both to ensure that the sUAS 

remains within the defined airspace and to ensure that the hazard of other aircraft intruding on 

the operation is mitigated.” The FAA believes the limitations under which the petitioner will 

operate (i.e. VLOS and at or below 400 feet above ground level (AGL) with a VO) are 

sufficient mitigations to this risk so that the operations will not adversely affect safety. 

Additionally, State Farm will utilize geo-fencing at test sites to ensure the UAS remain within 

defined boundaries.

Regarding the petitioner’s statement that the PIC and observer will be able to communicate by 

voice or text, ALPA stated that the pilot and observer should be able to maintain a visual 

observation of the aircraft and area of operation when using voice communication. NAAA 

states UAS observers must be present and able to communicate with the operator from the 

most minimal distance possible. The FAA has inserted a condition regarding PIC and VO 

communications.

ALPA asserted the UAS’s lithium polymer batteries have numerous associated fire and 

explosion hazards as outlined in DOT/FAA/AR-09/55, “Flammability Assessment of 

Lithium-Ion and Lithium-Ion Polymer Battery Cell Designed for Aircraft Power Usage 

(January 2010),” and that the safe carriage of the batteries and the mitigations in place for 

known risks should be addressed. The FAA notes, that the referenced study was primarily 

conducted to determine how certain battery cells react in a fire situation aboard manned 

airplanes. Given the size of the battery and the operating conditions of the UAS, the FAA 

concludes that the use of a lithium polymer battery will not pose an undue safety risk for the 

proposed operations. 

ALPA commented that command and control (C2) link failures are one of the most common 

failures on a UAS, and that lost link mitigations should require safe modes to prevent flyaways or other scenarios. The FAA agrees and carefully examined the proposed operation to 

ensure that the vehicle design and the petitioner’s operating documents addressed potential 

hazards related to C2 failure. The FAA finds that the UAS to be operated by the petitioner has 

sufficient design features to address these hazards. The FAA also finds that the operating 

documents have incorporated safety procedures to be followed by all operational participants 

should a C2 failure occur. Further detail is contained in the analysis of the UAS below. 

Although the petitioner did not request an exemption from § 91.203, ALPA states the UAS 

should be certified to the same level of safety under § 91.203 as other commercially operated 

aircraft in the National Airspace System (NAS). The FAA has addressed this comment in the 

conditions and limitations below.
ALPA also notes that the petitioner’s proposed operations are for “compensation or hire,” and 

argues the pilot must hold at least a current FAA commercial pilot certificate with an 

appropriate category and class rating for the type of aircraft being flown, as well as specific 

and adequate training on the UAS make and model intended to be used. Similarly, ALPA 

asserts a current second-class airman medical certificate should be required. The National 

Agricultural Aviation Association (NAAA) also commented on pilot qualification, stating—

Just as manned aircraft pilots are required to undergo a rigorous training 

curriculum and show that they are fit to operate a commercial aircraft, so too 

must UAS operators. Holding a commercial certificate holds UAS operators 

to similar high standards as commercial aircraft operators and ensures they 

are aware of their responsibilities as commercial operators within the NAS. 

Medical requirements ensure they have the necessary visual and mental 

acuity to operate a commercial aircraft repeatedly over a sustained period of 

time.

The FAA has reviewed the knowledge and training required by holders of both private and 

commercial certificates. Additional details are available in the ensuing analysis of this issue 

with regards to 14 CFR § 61.113.

ALPA also commented on14 CFR § 91.109 Flight Instruction, stating the petitioner intends to 

conduct flight instruction. ALPA stated, “[w]hile the petitioner’s rationale for this may have 

some merit, the broader issue is that the petitioner makes no reference to any attempts to 

comply with (or request a waiver to) 14 CFR 61.195 which defines the requirements for flight 

instructors. Thus there is no indication at all regarding what the qualifications of persons, who 

may be providing instruction, will be.” 

Regarding ALPA’s comments on 14 CFR § 61.195, Flight instructor limitations and 

qualifications, which defines the requirements for flight instructors, a certificated flight 

instructor is authorized to provide the instruction required for the certificates or ratings or 

currency listed in 14 CFR § 61.193. A person instructing on how to operate the UAS under 

the petitioner’s training program would not need to be a certificated flight instructor because 

the instruction is not being provided for a certificate or rating listed in § 61.193. We note that 

none of the UAS operations proposed by the petitioner require such flight instruction because 

§ 61.31(l) allows for operation of the UAS by an airman who is current per 14 CFR § 61.56 

without a category and class rating. Instruction provided toward obtaining the pilot certificate 

required by this exemption would need to be provided by a certificated flight instructor.

ALPA notes the petitioner must specify a means to meet see and avoid requirements in 

§ 91.113 given the absence of an onboard pilot. This comment is addressed in detail in the 

FAA analysis below. 
ALPA expressed concern regarding the petitioner’s waiver request for 14 CFR § 91.119(c).

ALPA believes all aircraft in the National Airspace System (NAS) must operate to the same 

high level of safety, this include maintaining a safe altitude for both airplanes and helicopters. 

These comments are addressed in the FAA’s analysis and conditions and limitations below.

ALPA mentioned the aircraft may not have a barometric altimeter as required by 14 CFR 

§ 91.121, stating the ability to accurately maintain altitude must be addressed, and processes 

or mitigations, such as redundant control capability, fail-safe systems, backups and specific, 

validated procedures for system and equipment failures must be in place. The FAA addresses 

this concern in its analysis of the exemption from 14 CFR § 91.121, finding that the 

alternative means of compliance proposed by the petitioner does not adversely affect safety.

Regarding the fuel requirements of § 91.151, ALPA argued that using batteries as the only 

source of an aircraft’s power is a substantial shift from traditional methods of propulsion, and 

requires further research to determine best safety practices. This comment is addressed in 

detail below.

Regarding §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b), ALPA opposed the 

petitioner’s “attempt to avoid compliance with established aircraft maintenance and record

keeping” requirements. ALPA stated the UAS should comply with the same level of safety as 

other aircraft operated commercially in the NAS. This comment is addressed in detail below.

ALPA also expressed concern that the petitioner’s waiver request is not for a single specific 

operation or location, but for all operations of the same general type. ALPA stated this results 

in a considerable increase in the FAA’s oversight tasks. The FAA notes ALPA’s concern and 

in order to minimize potential impact to the NAS, the FAA requires each operator secure a 

COA which covers specific details of the petitioners operation. The FAA recognizes that UAS 

integration will generate new NAS access demand and will review and adjust accordingly.

NAAA stated it represents the interests of small business owners and pilots licensed as 

commercial applicators. NAAA explained that its members operate in low-level airspace, and 

a clear flight path in low-level airspace is vital to the safety of these operators. The FAA 

believes an equivalent level of safety can be maintained through strict adherence to the 

petitioner’s operating documents, the additional conditions and limitations identified below, 

as well as requirements incorporated in the Air Traffic Organization (ATO) issued COA.

NAAA stated that seeing and avoiding other aircraft and hazardous obstructions is the 

backbone for agricultural safety, and agricultural pilots depend on pilots of other aircraft to 

perform their see-and-avoid functions needed to prevent collisions. NAAA believes UA 

operations at low altitudes will increase the potential of collision hazards with agricultural 

aircraft. NAAA argued that until adequate see-and-avoid technology is developed, the FAA 

should require UAS operators to post a Notice to Airmen (NOTAM) 48 to 72 hours before 

operations. NAAA proposes UAS aircraft be painted a highly visible color, be equipped with 

strobe lights, and use Automatic Dependent Surveillance–Broadcast (ADS–B) or other similar 

location reporting technology. To address these concerns the FAA has incorporated 
associated conditions and limitations into this exemption, including: a) NOTAMs issued for 

all operations, b) operations conducted within VLOS of the PIC and the VO, and c) the UAS 

PIC must always yield right-of-way to manned aircraft.

NAAA also proposed a number of operating limitations and requirements for UAS operators. 

NAAA stated UAS operators should have procedures to immediately ground the UAS if 

another low-flying aircraft is within 2 miles; be attending/monitoring UAS at all time and 

attentive to surroundings (no headphones, etc., or other distractions); comply with all 

applicable regulations, policies, and procedures; be equipped with aviation radios set to a 

locally defined frequency; have a separate VO with a second-class medical certificate and 

perform duties for only one UAS at a time; maintain line-of-sight operations; and be wellversed in the UAS operator document. NAAA further stated the UAS should be properly 

maintained; have a registered N-Number on an indestructible and unmovable plate; and be 

required to have an airworthiness certificate and liability insurance. These comments are 

addressed in the FAA’s analysis and conditions and limitations.

The petitioner filed a response to ALPA’s and NAAA’s comments. The petitioner noted that 

its use of UAS for research and development addresses the safety concerns voiced

by ALPA and NAAA.

Concerns raised in this comment section are addressed in the FAA’s analysis below and where 

necessary appropriate risk mitigations are implemented through the conditions and limitations 

on the operations.

The FAA’s analysis is as follows:

The FAA has organized its analysis into four sections: (1) Unmanned Aircraft System (UAS), 

(2) the UAS pilot in command (PIC), (3) the UAS operating parameters, and (4) the public 

interest.

Unmanned Aircraft System (UAS)

The petitioner requested relief from 14 CFR part 21, Subpart H Airworthiness Certificates. In 

accordance with the statutory criteria provided in Section 333 of P.L. 112-95 in reference to 

49 USC § 44704, and in consideration of the size, weight, speed, and limited operating area 

associated with the aircraft and its operation, the Secretary of Transportation has determined 

that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the 

requested relief from 14 CFR parts 21, and any associated noise certification and testing 

requirements of part 36, is not necessary. 

Manned helicopters conducting aerial surveying can weigh 6,000 lbs. or more and are 

operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The 

petitioner’s UA will weigh less than 20 lbs. with no onboard pilot or crew. The pilot and crew 

will be remotely located from the aircraft. The limited weight significantly reduces the 
potential for harm to participating and nonparticipating individuals or property in the event of 

an incident or accident. The risk to an onboard pilot and crew during an incident or accident is 

eliminated with the use of a UA for the aerial filming operation. 

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The 

petitioner’s UA carries no fuel, and therefore the risk of fire following an incident or accident 

due to fuel spillage is eliminated. 

This exemption does not require an electronic means to monitor and communicate with other 

aircraft, such as transponders or sense and avoid technology. Rather the FAA is mitigating the 

risk of these operations by placing limits on altitude, requiring stand-off distance from clouds, 

permitting daytime operations only, and requiring that the UA be operated within VLOS, 

utilize a visual observer for all flights, and yield right of way to all other manned operations. 

Additionally, the exemption provides that the operator will request a NOTAM prior to 

operations to alert other users of the NAS. These mitigations address concerns raised by 

NAAA and ALPA regarding awareness of UAS operations occurring in the airspace.

The petitioner’s two UAS have the capability to operate safely after experiencing certain inflight contingencies or failures and uses an auto-pilot system to maintain UAS stability and 

control. The UAS are also able to respond to a loss of global positioning system (GPS) or a 

lost-link event with a pre-coordinated, predictable, automated flight maneuver. These safety 

features provide an equivalent level of safety compared to a manned aircraft performing a 

similar operation and address ALPA’s comment on mitigating risk of command and control 

link failures. 

Regarding the petitioner’s requested relief from 14 CFR §§ 45.23(b), Display of marks, and 

21.191 Experimental certificates, the petitioner requests this relief under the assumption that 

marking with the word “experimental” will be required as a condition of a grant of exemption. 

However, this marking is reserved for aircraft that are issued experimental certificates under 

§ 21.191. The petitioner’s UAS will not be certificated under § 21.191, and therefore the 

“experimental” marking is not required. Since the petitioner’s UAS will not be certificated

under § 21.191, a grant of exemption for §§ 45.23(b) and 21.191 is not necessary.

The petitioner has also requested relief from 14 CFR § 45.27(a), Location of marks. Given 

that an exemption from § 45.23(b) is not necessary, an exemption from § 45.27(a) is also not 

necessary. Markings must be as large as practicable per § 45.29(f).

Regarding the petitioner’s requested relief from 14 CFR §§ 91.405 (a) Maintenance required, 

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

91.409(a)(1) and (a)(2) Inspections, and 91.417(a) and (b) Maintenance records, the FAA has 

carefully evaluated the petitioner’s request and determined that cause for granting the 

exemption is warranted. The FAA notes that the petitioner’s UAS operating documents 

contain detailed preflight checks, as well as routine maintenance, preventative maintenance, 

replacement/overhaul of component parts and alterations for the UAS. The FAA finds that 
adherence to the petitioner’s operating documents, and the conditions and limitations below 

are sufficient to ensure that safety is not adversely affected. In accordance with the petitioner’s 

UAS maintenance, inspection, and recordkeeping requirements, the FAA finds that exemption 

from 14 CFR §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) is 

warranted subject to the conditions and limitations below.

UAS Pilot in Command (PIC)

Regarding the petitioner’s requested relief from 14 CFR § 61.113(a) and (b) Private pilot 

privileges and limitations, the petitioner proposes to operate its UAS with a pilot holding, at a 

minimum, a private pilot certificate and at least a current third-class medical certificate for its 

Phase I R&D operations. However, for Phase II R&D operations, the petitioner requests use of 

“PICs holding third-class medical certificates” with certificated pilots acting in a supervisory 

capacity. Although Section 333 provides limited statutory flexibility relative 

to 49 USC § 44704 for the purposes of airworthiness certification, it does not provide 

flexibility relative to other sections of 49 USC. Therefore, the FAA does not possess the 

authority to exempt from the statutory requirement to hold an airman certificate, as prescribed 

in 49 USC § 44711. For further information see Exemption No. 11110, Trimble Navigation, 

Ltd. 

The FAA is also requiring a pilot certificate for UAS operations because pilots holding an 

FAA issued private or commercial pilot certificate are subject to the security screening by the 

Department of Homeland Security that certificated airmen undergo. As previously determined 

by the Secretary, the requirement to have an airman certificate ameliorates security concerns 

over civil UAS operations conducted in accordance with Section 333.

Given these grounds, the FAA must determine the appropriate level of pilot certification for 

the petitioner’s proposed operation. 

Under current regulations, civil operations for compensation or hire require a PIC holding a 

commercial pilot certificate per 14 CFR part 61. Based on the private pilot limitations in 

accordance with pertinent parts of 14 CFR § 61.113(a) and (b), a pilot holding a private pilot 

certificate cannot act as a PIC of an aircraft for compensation or hire unless the flight is only 

incidental to a business or employment. However, in Grant of Exemption No. 11062 to 

Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate 

operating the Astraeus UAS would not adversely affect operations in the NAS or present a 

hazard to persons or property on the ground. 

The FAA has analyzed the petitioner’s proposed operation and has determined that it does not 

differ significantly from the situation described in Grant of Exemption No. 11062 (Astraeus 

Aerial). The petitioner plans to operate over private property with controlled access in the 

NAS. Given: 1) the similar nature of the petitioner’s proposed operating environment to that 

of Astraeus, 2) the parallel nature of private pilot aeronautical knowledge requirements to 

those of commercial requirements [ref: Exemption No. 11062], and 3) the airmanship skills 
necessary to operate the UAS, the FAA finds that the additional manned airmanship 

experience of a commercially certificated pilot would not correlate to the airmanship skills 

necessary for the petitioner’s specific proposed operations. Therefore, the FAA finds that a 

PIC holding a private pilot certificate and a third-class airman medical certificate is 

appropriate for the proposed operations. 

With regard to the airmanship skills necessary to operate the UAS (item #3 stated above), the 

petitioner has proposed that “prior to operations, the pilot must have accumulated and logged 

a minimum of 200 flight cycles, or more as required by the FAA, and 25 hours of total time as 

a UAS rotorcraft pilot.” “The pilot must also have accumulated and logged prior to operations 

at least ten hours as a UAS pilot with a similar UAS type (single blade or multi-rotor).” The 

conditions and limitations below stipulate that the petitioner may not permit any PIC to 

operate unless that PIC has demonstrated through the petitioner’s training and currency 

requirements that the PIC is able to safely operate the UAS in a manner consistent with how 

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

and maintaining appropriate distances from people, vessels, vehicles and structures. 

In conclusion, the FAA finds that a PIC holding a private pilot certificate and a third-class 

airman medical certificate, and who has completed the petitioner’s UAS training and currency 

requirements, can conduct the proposed UAS operations without adversely affecting the safety 

of the NAS and persons or property on the ground. Upon consideration of the overall safety 

case presented by the petitioner and the concerns of the commenters, the FAA finds that 

granting the requested relief from 14 CFR § 61.113(a) and (b), is warranted.

The FAA considers the PIC to be designated for the duration of the flight. Therefore, per the 

conditions and limitations below, the PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight.

The petitioner has also indicated it will supplement his proposed operation(s) with a VO. The 

conditions and limitations below stipulate that the PIC must ensure that the VO can perform 

the functions prescribed in the operating documents. Additionally, as discussed in Exemption 

No. 11109 to Clayco, Inc., there are no regulatory requirements for visual observer medical 

certificates. Although a medical certificate is not required for a VO, the UA must never be 

operated beyond the actual visual capabilities of the VO, and the VO and PIC must have the 

ability to maintain VLOS with the UA at all times. It is the responsibility of the PIC to be

aware of the VO’s visual limitations and limit operations of the UA to distances within the 

visual capabilities of both the PIC and VO. Moreover, the VO will not be operating the 

aircraft. Therefore, as in Grant of Exemption No. 11062 to Astraeus, the FAA does not 

consider a medical certificate necessary for the VO.

UAS Operating Parameters

Although the petitioner did not seek relief from 14 CFR § 91.7(a) Civil aircraft airworthiness, 

the FAA finds that relief from § 91.7 is necessary. While the UAS will not require an 
airworthiness certificate in accordance with 14 CFR part 21, Subpart H, the FAA considers 

the petitioner’s compliance with its operating documents to be sufficient means for 

determining an airworthy condition in accordance with § 91.7(a). Therefore, relief from 

§ 91.7(a) is granted. The petitioner is still required to ensure that its aircraft is in an airworthy 

condition – based on compliance with manuals and checklists identified above – prior to every 

flight. 

Additionally, in accordance 14 CFR § 91.7(b), the PIC is responsible for determining whether 

the aircraft is in a condition for safe flight. The FAA finds that the PIC can comply with this 

requirement.

Regarding the petitioner’s requested relief from 14 CFR § 91.119(c) Minimum safe altitudes:

Over other than congested areas, relief is sought because the petitioner states that operations 

will only be conducted within “a restricted area where buildings and people will not be 

exposed to operations without their pre-obtained consent.” The petitioner proposes to operate 

the UA no more than 400 feet AGL.

The FAA is requiring that prior to conducting UAS specific operations, all persons not 

essential to flight operations (nonparticipating persons) must remain at appropriate distances. 

In open areas this requires the UA to remain 500 feet from all persons other than essential 

flight personnel (i.e. the PIC and VO). The FAA has also considered that each UA will weigh 

20 pounds or less. If barriers or structures are present that can sufficiently protect 

nonparticipating persons from debris in the event of an accident, then the UA may operate 

closer than 500 feet to persons afforded such protection. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately. The primary concern, when considering how to 

immediately cease operations, is the safety of those nonparticipating persons. In addition, the 

FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and 

structures when the land owner/controller grants such permission and the PIC makes a safety 

assessment of the risk of operating closer to those objects. Provided adherence to the

procedures in the operating documents and the additional conditions and limitations outlined

below, the FAA finds that relief from § 91.119(c) is warranted.

Regarding the petitioner’s requested relief from 14 CFR § 91.121 Altimeter settings, the FAA 

believes that an altitude reading is a critical safety component of the petitioner’s proposed 

operation. Although the petitioner will not have a typical barometric altimeter onboard the 

aircraft, the FAA finds the petitioner’s intention to operate the UA within VLOS and at or 

below 400 feet AGL, combined with the petitioner’s intention to provide altitude information 

to the UAS pilot via a radio communications telemetry data link, which downlinks from the 

aircraft to the PIC for active monitoring of the flight path, to be a sufficient method for 

ensuring the UAS operations do not adversely affect safety. The altitude information will be 

generated by GPS equipment installed onboard the aircraft, and/or a static pressure sensor 

(barometer) which aids in estimating the altitude. Prior to each flight, a zero altitude initiation 
point will be established and confirmed for accuracy by the UAS PIC. The FAA has 

determined that good cause exists for granting the requested relief to 14 CFR § 91.121 and 

this approach satisfies ALPA’s concern about the ability of the UAS to accurately maintain 

altitude. 

Regarding the petitioner’s requested relief from § 91.151 (a) Fuel requirements for flight in 

VFR conditions, prior relief has been granted for manned aircraft to operate at less than 

prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar 

UAS-specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, 

VFR conditions. The petitioner states in the event that the UAS should run out of power, it 

would simply land within the access controlled operating area. Given its weight and 

construction material, the risks are less than contemplated by the current regulation.

Regarding the ATX8, as stated in the UA specifications in the operating documents, the UA 

batteries provide 35 minutes of powered flight on average. The operating documents indicate 

that at 30% reserve, the UA will enter a return and land sequence and at 20% reserve, the UA 

will land immediately. Therefore, the FAA has determined that the PIC will be prohibited 

from beginning a flight unless (considering wind and forecast weather conditions) there is 

enough power to fly at a normal cruising speed to the intended landing point and land the UA 

with not less than 30% battery power remaining.

Regarding the F6500, as stated in the UA specifications in the operating documents, the UAS 

indicates current remaining battery power measured in volts. The indication is located above

the HUD. There are two UA failsafes contingent upon battery voltage:

• Low battery failsafe 1: Battery voltage is 20.4V or less. The UA will fly to rally if the 

battery remains at 20.4V or lower for 5 seconds.

• Low battery failsafe 2: Battery voltage is critically low battery at 19.4V or less. The

UA will land regardless of location.

Therefore, the FAA has determined that the PIC will be prohibited from beginning a flight 

unless (considering wind and forecast weather conditions) there is enough power to fly at a 

normal cruising speed to the intended landing point and land the UA with not less than 20.4 

volts battery power remaining.

Therefore, the FAA grants the relief from 14 CFR § 91.151(a) to the extent necessary to 

comply with the conditions and limitations below.

Additionally, in evaluating the petitioner’s proposed operating parameters with regard to 

VLOS and a safe operating perimeter, the FAA considered operations from a moving device 

or vehicle. Since the petitioner did not discuss provisions for these circumstances, the 

conditions and limitations below preclude operations from moving devices or vehicles. 
Regarding an ATO issued COA, the majority of current UAS operations occurring in the NAS 

are being coordinated through Air Traffic Control (ATC) by the issuance of a COA. This is an 

existing process that not only makes local ATC facilities aware of UAS operations, but also 

provides ATC the ability to consider airspace issues that are unique to UAS operations. The 

COA will require the operator to request a NOTAM, which is the mechanism for alerting 

other users of the NAS to the UAS activities being conducted. Therefore, the FAA believes 

that adherence to this process is the safest and most expeditious way to permit the petitioner to 

conduct their proposed UAS operations. The conditions and limitations below prescribe the 

requirement for the petitioner to obtain an ATO-issued COA.

Public Interest

The FAA finds that a grant of exemption is in the public interest. The enhanced safety and 

reduced environmental impact achieved using a UA with the specifications described by the 

petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly 

greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to 

find that the UAS operation enabled by this exemption is in the public interest. The FAA also 

finds that UAS provide an additional tool for aerial imagery in support of the insurance 

industry, adding a greater degree of flexibility and enhanced safety, which supplements the 

current capabilities offered by manned aircraft. 
The following table summarizes the FAA’s determinations regarding the relief sought by the 

petitioner:

Relief considered (14 CFR) FAA determination (14 CFR)

21 Subpart H Relief not necessary

21.191(a) Relief not necessary

45.23(b) Relief not necessary

45.27 Relief not necessary 

61.113(a) and (b) Relief granted with conditions and 

limitations

91.7(a) Relief granted with conditions and 

limitations 

91.119(c) Granted with conditions and limitations

91.121 Granted with conditions and limitations

91.151(a) Relied granted for 91.151(a)(1), day, 

with conditions and limitations

91.405(a) Relief granted with conditions and 

limitations

91.407(a)(1) Relief granted with conditions and 

limitations

91.409(a)(1) and (2) Relief granted with conditions and 

limitations

91.417(a) and (b) Relief granted with conditions and 

limitations

The FAA’s Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, State Farm Mutual Automobile Insurance Company is 

granted an exemption from 14 CFR §§ 61.113(a) and (b), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to the 

extent necessary to allow the petitioner to operate a UAS for the purpose of outdoor research 

and development related to the use of UAS for civil operations for insurance functions 

including: using imagery and analytics in underwriting, re-underwriting, catastrophe response,

roof inspection, and claim resolutions settings. This exemption is subject to the conditions and 

limitations listed below.
Conditions and Limitations

Relative to this grant of exemption, State Farm Mutual Automobile Insurance Company is 

hereafter referred to as the operator.

The petition and the following supporting documentation are hereinafter referred to as the 

operating documents: 

1) Training Syllabus, 

2) Operations Manual including: 

g) Appendix A: Nova F6500 Operator Manual, 

h) Appendix B: Nova F6500 Maintenance Manual, 

i) Appendix C: Nova MP32 Field Guide, 

j) Appendix D: Nova VP23 Field Guide, 

k) Appendix E: Aerialtronics Operations Manual, 

l) Appendix E: Aerialtronics System Description Manual

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the following aircraft 

described in the operating documents which are the Aerialtronics Altura Zenith ATX8 

Unmanned Aircraft System, a quad rotor aircraft weighing less than 18 pounds 

maximum takeoff weight, and the Altavian Nova F6500, an all electric fixed wing 

UAS with a wingspan of 108 inches and a maximum operating weight of less than 20 

pounds. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this grant.

2. UAS operations under this exemption are limited to outdoor research and development 

related to the use of a UAS for insurance functions including: using imagery and 

analytics in underwriting, re-underwriting, catastrophe response, roof inspection, and 

claim resolutions settings.

3. The UAs may not be flown at an indicated airspeed exceeding 50 knots.

4. The UA’s must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operator’s manual. All altitudes 

reported to ATC must be in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

6. All operations must utilize a visual observer (VO). The VO may be used to satisfy the 

VLOS requirement as long as the PIC always maintains VLOS capability. The VO and 
PIC must be able to communicate verbally at all times. Electronic messaging or texting 

is not permitted during flight operations. The PIC must be designated before the flight 

and cannot transfer his or her designation for the duration of the flight.

7. The VO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments.

8. The operating documents and this grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in this exemption and the procedures 

outlined in the operating documents, the conditions and limitations herein take 

precedence and must be followed. Otherwise, the operator must follow the procedures 

as outlined in its operating documents. The operator may update or revise its operating 

documents. It is the operator’s responsibility to track such revisions and present 

updated and revised documents to the Administrator upon request. The operator must 

also present updated and revised documents if it petitions for extension or amendment. 

If the operator determines that any update or revision would affect the basis upon 

which the FAA granted this exemption, then the operator must petition for amendment 

to their exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

9. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe 

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

the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

10. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight in accordance with the operating documents. The PIC who 

conducts the functional test flight must make an entry in the UAS aircraft records of 

the flight. The requirements and procedures for a functional test flight and aircraft 

record entry must be added to the operating documents.

11. The preflight inspection must account for all discrepancies, i.e. inoperable 

components, items, or equipment, not covered in the relevant preflight inspection 

sections of the operating documents.

12. The operator must follow the manufacturer’s UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements, with particular attention 

to flight critical components that may not be addressed in the manufacturer’s manuals.
13. The operator must carry out their maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

and alterations must be noted in the aircraft logbook, including total flight hours, 

description of work accomplished, and the signature of the authorized UAS technician 

returning the UAS to service. 

14. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins.

15. The authorized person must make a record entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections.

16. The PIC must possess at least a private pilot certificate and a current third-class airman 

medical certificate. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

17. Prior to operations, the PIC must have completed the operator’s training and currency 

requirements as prescribed in the operating documents. During that training, the PIC 

must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), 

the minimum hours prescribe in the operating documents as UAS pilot operating the 

make and model of the UAS to be utilized for operations under the exemption. 

Training, proficiency, and experience-building flights can be conducted under this 

grant of exemption to qualify the operator’s PIC(s), VO(s) and other essential 

personnel as defined in the operating documents. However, said training operations 

may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights the PIC is required to operate the UA with 

appropriate distances in accordance with 14 CFR § 91.119.

18. The operator may not permit any PIC to operate unless that PIC has demonstrated 

through the operator’s training and currency requirements that the PIC is able to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

19. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

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

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

20. The UA may not operate within 5 nautical miles of the airport reference point of an 

airport as denoted on a current FAA-published aeronautical chart. The UA may not 

operate within 3 nautical miles from any city or densely populated area.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
22. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property and land or be 

recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents.

24. The PIC is prohibited from beginning a UAS flight unless (considering wind and 

forecast weather conditions and assuming normal cruising speed) there is enough 

power to fly to the intended landing point and land the UA:

a. When operating the ATX-8: with 30% battery power remaining.

b. When operating the F6500: with battery voltage not less than 20.4 volts.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation, but may provide for a shorter time period in emergency response situations.

All operations shall be conducted in accordance with airspace requirements in the 

ATO issued COA including class of airspace, altitude level and potential transponder 

requirements. 

26. All operations shall be coordinated with state or local government agencies having 

jusidictional authority over the emergency response.

27. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

28. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements.

29. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request.

30. The UA must remain clear and yield the right of way to all other manned aviation 

operations and activities at all times.
31. The UAS may not be operated by the PIC from any moving device or vehicle.

32. The UA may not be operated over congested or densely populated areas. 

33. Flight operations must be conducted at least 500 feet from all nonparticipating persons 

(persons other than the PIC or VO), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately and/or;

b. the aircraft is operated near vessels, vehicles or structures where the land 

owner/controller has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and;

c. operations near the PIC or VO do not present an undue hazard to the PIC or 

VO, per § 91.119(a).

34. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained prior to the beginning of every flight.

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

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

to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 

45, 47, 61, and 91.

This exemption terminates on February 28, 2017, unless sooner superseded or rescinded.

Issued in Washington, DC, on February 25, 2015.

/s/

John Barbagallo

Acting Deputy Director, Flight Standards Service