State Farm 

Corporate Headquarters 

1 State Farm Plaza 

Bloomington, IL 61710-0001 

December 23, 2014 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor 

Room W12-140 

Washington, D.C. 20590 

&State Farm~ 

Re: Docket No. FAA-2014-0846; Summary Notice No. PE-2014-125 

State Farm Mutual Automobile Insurance Company; Petition for Exemption 

Dear Sir or Madam: 

State Farm Mutual Automobile Insurance Company ("State Farm") submits this letter for the 

FAA's consideration in connection with State Farm's petition under Section 333 of the FAA 

Modernization and Reform Act of 20121 for an exemption to allow operation of Unmanned 

Aircraft Systems ("UAS") to conduct roof inspections.2 Two commenters, the Air Line Pilots 

Association ("ALPA") and the National Agricultural Aviation Association ("NAM"), filed in 

opposition to State Farm's petition citing various concerns. This filing explains how State 

Farm's proposed operations, as detailed in the company's petition for exemption, will be 

conducted to ensure safety to those on the ground and other aircraft. 

Area of Operation. ALPA states that State Farm's petition does not define how the area of 

operation will be limited or predetermined and does not offer a means to control the airspace or 

areas of operation. 3 To the contrary, State Farm's petition describes the parameters of the area 

of operation-use will occur solely over customers' property and under 200 feet above ground 

level ("AGL").4 State Farm will use gee-fencing as the means to control the area of operations. 5 

Indeed, a typical UAS flight for roof inspection would occur predominantly near and around the 

structures of the property. 

Mitigation of Hazard to Other Aircraft. ALPA suggests that State Farm's petition does not 

ensure that the hazard of other aircraft intruding on the operation is mitigated.6 Both ALPA and 

NAM raise concerns about how the UAS will "sense and avoid" other aircraft. 7 State Farm's 

2 

FAA Modernization and Reform Act of 2012, Pub Law No. 112-95. 

See Docket No. FAA-2014-0846; Summary Notice No. PE-2014-125. 

3 Comments of ALPA, Docket No. FAA-2014-0846 at 1 (filed Dec. 3, 2014) ("ALPA Comments"). 

4 State Farm Petition for Exemption, Docket No. FAA-2014-0846 at 2, 3 (filed Oct. 15, 2014) 

("State Farm Petition"). 

5 State Farm Petition at 3. 

s ALPA Comments at 1. 

7 ALPA Comments at 2; Comments of NAAA, FAA Docket No. FAA-2014-0846 at 1-2 (filed Dec. 3, 

2014) ("NAAA Comments"). 

Providing Insurance and Financial Services Home Office, Bloomington, IL 
petition explains that hazards to other aircraft will be mitigated through a variety of safety 

measures. 

• State Farm's UAS will only operate during daytime.8 

• UAS operations will always occur within the line of sight of the UAS operator. 9 

• The operator will request a Notice to Airmen ("NOT AM") not more than 72 hours in 

advance but not less than 48 hours prior to UAS operations. 10 

• State Farm will ensure safety to first responder aircraft and helicopter traffic. Upon 

notification from aircraft controllers or through visual identification of aircraft, State Farm 

will immediately suspend the UAS flight until the airspace is cleared. 11 State Farm notes 

that a typical UAS roof inspection would be conducted near and around property 

structures, areas unlikely be proximate to first responder aircraft and helicopters. 

These requirements, which the FAA approved in its grant of the motion picture and television 

operator petitions, 12 will ensure that State Farm's use of UAS for roof inspections does not 

create a hazard to other users of the national airspace. 

Pilot and Observer Requirements. ALPA requests that both pilot and observer be able to 

maintain a visual observation of both the aircraft and the area of operation. 13 NAAA adds that 

the operator should be attending/monitoring the UAS at all times and that the observer must be 

present and able to communicate with the operator from the most minimal distance possible. 14 

State Farm's petition states that the UAS must be operated in the visual line of sight of the pilot 

at all times, and the Operations Manual notes that the observer is responsible for keeping the 

vehicle in sight at all times. 15 The Petition also states that that the pilot and observer must be 

able to communicate verbally at all times. 16 

Lost Signal Mitigations. ALP A's filing queries how the UAS will safely land in the event of a 

loss of GPS. 17 State Farm's Operations Manual details how the UAS will respond in such a 

situation. The UAS has safety features which attempt to reacquire the lost signal and will help 

a State Farm Petition at 4. 

9 State Farm Petition at 2, 3, 6. NAAA's comments also specifically request that UAS operators be 

subject to the requirement to maintain line-of-sight operations. NAAA Comments at 2. 

10 State Farm Petition at 7. NAAA's comments also specifically request that UAS operators be 

subject to this NOT AM requirement. NAAA Comments at 2. 

11 State Farm Petition at 8. 

12 See, e.g. FAA, Grant of Exemption, Astraeus Aerial, FAA Docket No. FAA-2014-0352, Exemption 

No. 11062 (Sept. 25, 2014) ("Astraeus Grant"). 

13 ALPA Comments at 1. 

14 NAAA Comments at 2-3. 

15 State Farm Petition at 6; State Farm UAS Operations Manual, FAA Docket No. FAA-2014-0846, 

at 3-3(filed Oct. 15, 2014) ("Operations Manual"). 

1s State Farm Petition at 5. 

11 ALPA Comments at 2. 

Providing Insurance and Financial Services Home Office, Bloomington, IL 
the UAS safely descend if GPS is lost. 18 ALP A's filing also states that mitigations for spectrum 

interference, terrain, and obstacles should be developed. 19 State Farm's Operations Manual 

further describes safety features that will help maintain safe operations in the event of 

emergencies such as power loss, loss of communications, loss of video link, airspace incursion 

from other aircraft, and software crashes. 2

° For example: 

• Loss of power to the propulsion systems will result in a controlled landing at an 

emergency decision site and the UAS will continue to operate with the communications 

link and flight controls; 

• If a loss of communications occurs, a communications strength indicator on the ground 

station will alert the operator, then the UAS will navigate to the home way point which is 

uploaded before takeoff. The UAS will continue to re-acquire link while it navigates 

through the landing procedure and loiter along a tangential path to the touchdown spot; 

• If a loss of video link occurs, the manual has a checklist of systems to check and verify 

settings; 

• In the event of airspace incursion from another aircraft, the pilot and observer should 

direct the UAS to safe altitudes and locations to maintain safe separation and continue 

to monitor incurring aircraft for direction, speed, and altitude. If a collision appears 

eminent, the operator is instructed to manually down the vehicle; 

• In the event of a software crash, the UAS operator will immediately turn off the comm 

box to ensure that the UAS loses command and control and will begin to perform its loss 

of communication procedure. 21 

Hazard to Low-Level Pilots. NAAA notes its concern that State Farm's UAS will present a 

hazard to low-level pilots. 22 State Farm's proposed roof inspection operation will occur at a 

maximum ceiling of 200 feet AGL and solely over policyholders' property. 23 The FAA and other 

aircraft will have advance notice of the flight area due to the NOT AM. Further, as noted above, 

UAS roof inspection operations will occur predominantly near and around structures. It is 

therefore highly unlikely that State Farm's use of UAS for roof inspection will be proximate to 

low-level aircraft conducting aerial application of pesticides. 

NAAA also suggests that if an agricultural or other type of low-flying aircraft is within two miles, 

the UAS operator procedure should be to immediately ground the UAS as soon as practicable. 24 

State Farm's petition requires the UAS to yield right of way to all manned aircraft, and to ensure 

safety to first responder aircraft and helicopter traffic.25 Further, upon notification from manned 

16 Operations Manual at 9-1 - 9-2. 

19 ALPA Comments at 2. 

20 Operations Manual at 9-1 - 9-5. 

21 /d. 

22 NAAA Comments at 1. 

23 State Farm Petition at 2, 3. 

24 NAAA Comments at 2. 

25 State Farm Petition at 8. 

Providing Insurance and Financial Services Home Office, Bloomington, IL 
aircraft controllers or through visual identification of manned aircraft, State Farm will 

immediately suspend the UAS flight until the airspace is cleared. 26 

Finally, NAAA states that UAS conducting low-level aerial application work must comply with 14 

C.F.R. Part 137.27 This proposal is not applicable to State Farm's UAS, which will not be 

conducting low-level aerial application work. 

Airworthiness Certificate. ALPA opposes what it views as State Farm's attempt to avoid 

certifying the airworthiness of its UAS.28 NAAA likewise proposes that the UAS be required to 

have an airworthiness certificate. 29 State Farm notes that the requirement to have an 

airworthiness certificate was waived in the FAA's previous Section 333 grants to the motion 

picture and television operators. 30 The State Farm petition merits the same exemption due to 

the UAS safety features and its size, weight, speed, and operating area. 

Pilots License and Medical Certificate. ALPA and NAAA's comments both state that the UAS 

pilot should hold at least a current FAA commercial pilot certificate and a current 2nd class FAA 

medical certificate. 31 The FAA addressed this issue in its previous Section 333 grants. The 

FAA analyzed the UAS's separation from manned aircraft operations, the current aeronautical 

knowledge requirements for a private pilot compared to a commercial pilot, and the specific 

airmanship skills required for operation of a UAS. 32Given these considerations, the FAA found 

that its safety objectives would be met by only requiring a pilot to possess a private pilot 

certificate and at least a third-class medical certificate. 33 Accordingly, the State Farm petition 

provides that pilots undertaking roof inspections will hold at least a private pilot certificate and a 

third class medical certificate. 34 

Minimum Safe Altitudes. ALPA's position is that all aircraft in the national airspace system 

("NAS") must maintain minimum safe altitudes as required in 14 C.F.R. § 91.113. 35 As noted 

above, State Farm's UAS will operate at no more than 200 feet above ground level and will be 

operated in a defined area. 36 The FAA previously granted an exemption to Section 91.119( c) on 

minimum safe altitudes in the motion picture and television operator grants.37 State Farm's UAS 

operations will occur at safe altitudes with respect to manned aircraft. 

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/d. 

NAAA Comments at 3. 

ALPA Comments at 2. 

NAAA Comments at 2. 

See, e.g. Astraeus Grant at 14. 

ALPA Comments at 2; NAAA Comments at 2. 

See, e.g. Astraeus Grant at 17-18. 

/d. at 25. 

State Farm Petition at 5. 

ALPA Comments at 2. 

State Farm Petition at 6. 

See, e.g. Astraeus Grant at 20. 

Providing Insurance and Financial Services Home Office, Bloomington, IL 
Altimeter Settings. ALPA raises the concern that, due to the lack of a barometric altimeter on 

the UAS, processes or mitigations for system and equipment failures must be in place. 38 The 

FAA's grants to the motion picture and television operators permitted use of a GPS altitude 

readout instead of a barometric altimeter, finding that this alternative means of compliance with 

the FAA's rules would not adversely affect safety. 39 State Farm's petition notes that the UAS 

may have a GPS altitude readout and the Operations Manual details the failsafe systems and 

safety features of the UAS.40 

Maintenance. ALPA states that FAA certified professionals should perform all inspections and 

owner/operators should keep records verifying certain maintenance is in compliance. 41 NAAA 

also suggests requiring that the UAS be properly maintained. 42 State Farm's petition notes that 

the company will institute a rigorous maintenance program and the operator will develop 

procedures to document and maintain a record of UAS maintenance. 43 State Farm requires that 

all maintenance and alterations be properly documented in the aircraft records. 44 Further, 

operators will develop UAS technician qualification criteria, which will be added to the 

Operations Manual. 45 State Farm's commitments promote safe, regular maintenance of the 

UAS. 

UAS Markings. NAAA believes that UAS should be painted in colors to make them readily 

distinguishable from the background and that the UAS and ground vehicle should have strobe 

lighting. 46 State Farm's UAS operations will only occur during daytime, eliminating the need for 

special color painting or strobe lighting. 47 NAAA further suggests that the UAS should have a 

registered N-number on an indestructible and unmovable plate attached to the UAS.48 State 

Farm's petition already includes the commitment that the UAS will have markings identifying the 

serial number and N-number as large as practicable. 49 

FAA Oversight. As a final matter, ALPA notes its concern that the use of waiver requests 

could tax the FAA's resources and that the request is not for a single specific operation or 

location, increasing the FAA's oversight task. 5° First, the Section 333 exemption process is the 

interim policy that the FAA has chosen to establish until the small UAS rule is adopted. The 

FAA has noted that it is anticipated that this activity will result in significant economic benefits, 

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ALPA Comments at 2. 

See, e.g. Astraeus Grant at 21. 

State Farm Petition at 8; see e.g. Operations Manual at 9-1 -9-5. 

ALPA Comments at 3. 

NAAA Comments at 3. 

State Farm Petition at 9. 

State Farm Petition at 10. 

/d. 

NAAA Comments at 2. 

State Farm Petition at 4. 

NAAA Comments at 3. 

State Farm Petition at 4. 

ALPA Comments at 3. 

Providing Insurance and Financial Services Home Office, Bloomington, IL 
and the FAA Administrator has identified this activity as a high priority project. 51 The FAA is 

moving forward carefully with granting these requests and there is no reason to doubt the 

agency's ability to oversee the operations it permits. Second, State Farm's proposed operations 

will occur over customer property in defined and pre-determined areas, which should simplify 

the FAA's oversight. 

In conclusion, State Farm's petition to use UAS for roof inspections addresses the safety 

concerns voiced by ALPA and NAAA. The petition is supported by the Small UAV Coalition. 52 

State Farm respectfully requests that the FAA move expeditiously to grant the State Farm 

petition. 

Sincerely, 

Todd 

~7l~ Binion, CPCU®, CLU® 

Innovation Manager 

State Farm Mutual Automobile Insurance Company 

309-735-8633 

todd.binion.hkoO@statefarm.com 

51 FAA, Section 333, available at https://www.faa.gov/uas/legislative programs/section 333/. 

52 Comments of Small UAV Coalition, Docket No. FAA-2014-0846 (filed Dec. 3, 2014). 

Providing Insurance and Financial Services Home Office, Bloomington, IL