April 2, 2015 

 Exemption No. 11273 

 Regulatory Docket No. FAA–2014–0913 

Mr. Mark E. McKinnon, Esq. 

Counsel for AIG PC Global Services, Inc. 

McKenna Long & Aldridge LLP 

1676 International Drive Penthouse 

McLean, VA 22102 

Dear Mr. McKinnon: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated October 31, 2014, you petitioned the Federal Aviation Administration (FAA) 

on behalf of AIG PC Global Services, Inc. (hereinafter petitioner or operator) for an 

exemption. The exemption would allow the petitioner to operate an unmanned aircraft system 

(UAS) to conduct research and development at AIG PCGS's and corporate affiliates' own 

facilities or property and inspections for risk assessment, risk management, loss control, and 

surety performance for insured customers. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

Discussion of Public Comments: 

A summary of the petition was published in the Federal Register on February 24, 2015, 

(80 FR 9848). No comments were received. 
2 

Airworthiness Certification 

The UAS proposed by the petitioner are the Hawkeye Lancaster MK-III, IRIS+, Phantom 2 

Vision, and senseFly eBee. 

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 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 part 21, and any associated noise certification and testing requirements of part 36, is 

not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (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. 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our 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, AIG PC Global Services, Inc. is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 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 to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below. 
3 

Conditions and Limitations 

In this grant of exemption, AIG PC Global Services, Inc. is hereafter referred to as 

the operator. 

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 Hawkeye 

Lancaster MK-III, IRIS+, Phantom 2 Vision, and senseFly eBee. when weighing less 

than 55 pounds including payload. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

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

(AGL). Altitude must be reported 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 or 

U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. 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. The PIC must ensure that the VO can perform the duties 

required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 
4 

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 or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. 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 an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. 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. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal 

government. 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. 
5 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability 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 persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

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

under this exemption are permitted under the terms of this exemption. However, 

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

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. 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. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request. 

17. 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. 

18. 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. 

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 
6 

22. 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. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any 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. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or 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 in a manner ensuring the safety 

of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption. 

27. 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 for each flight to be conducted. 

28. 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. 
7 

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption. 

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption; 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N-Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM. 

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 April 30, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 
Albany 

Atlanta 

Brussels 

Denver 

McKenna Long &AldridgeLLP 

1676 International Drive • Penthouse 

Mclean, VA 22102 

Northern Virginia 

Orange County 

Rancho Santa Fe 

San Diego 

Los Angeles Tel: 703.336.8800 

mckennalong.com San Francisco 

Miami Seoul 

New York Washington, DC 

MARK E. MCKINNON 

703.336.8708 

EMAIL ADDRESS 

mmckinnon@mckennalong.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

October 31,2014 

Re: Petition of AIG PC Global Services, Inc., for an Exemption Pursuant to Section 

3 3 3 of the FAA Modernization and Reform Act of 2012 

Dear Gentlemen: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 ("Reform 

Act") and 14 C.P.R. Part 11, AIG PC Global Services, Inc. ("AIG PCGS"), hereby applies for an 

exemption from the Federal Aviation Regulations ("F ARs") identified below, to allow 

commercial operations of small unmanned aerial vehicles (i.e. "small unmanned aircraft" or 

"UAS"). 

The exemption is made based on information in this petition, as well as the 

accompanying AIG PCGS Operations and Safety Manual ("Operations Manual") and the flight 

and maintenance manuals for the UASs identified and incorporated by reference into Section 2 

of the Operations Manual. Petitioner submits these supporting materials as confidential 

documents under 14 C.P.R. § 11.35(b); as they contain confidential commercial and proprietary 

information that Petitioner has not and will not share with others. Similarly, these documents 

contain operating conditions and procedures that are not available to the public and are protected 

from release under the Freedom oflnformation Act, 5 U.S.C. § 552 et seq., and any other 

requirements established by the FAA pursuant to Section 333 of the FAA Reform Act. 

For your convenience, the petition is organized as follows: 

I. Description of Petitioner 

II. Types of Operations 

A. Request to Use UASs for R&D at Test Sites Owned or Controlled by AIG 

PCGS 
U.S. Department ofTransportation 

October 31,2014 

Page 2 

B. Request to Use UASs for Survey and Inspection of Damage After Casualty 

Events 

C. Request to Use UASs for Risk Assessment, Risk Management, Loss Control, 

and Surety Performance 

III. Relevant Statutory Authority 

IV. AIG PCGS's Proposed UAS Operations Meet the Requirements of Section 333 of 

the Reform Act 

V. Regulations From Which Exemption is Requested 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 

C.F.R. § 91.203 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category 

Rotorcraft 

C. 14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and 

Identification Requirements 

D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and 

Registration 

E. 14 C.F.R. § 91. 7(a): Civil Aircraft Airworthiness 

F. 14 C.F.R. § 91.103: Preflight Action 

G. 14 C.F.R. § 91.109(a): Flight Instruction 

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

I. 14 C.F.R. § 91.121: Altimeter Settings 

J. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR 

Conditions 

K. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

L. 14 C.F.R. § 61.113 

VI. Drug and Alcohol Program 

VII. Public Interest 

VIII. Privacy 

IX. Federal Register Summary 

X. Conclusion 

I. DESCRIPTION OF PETITIONER 

AIG PCGS is an indirect, wholly-owned subsidiary of American International Group, 

Inc. (AIG). AIG PCGS provides services to, or on behalf of, other subsidiaries and affiliates of 

AIG. Founded in 1919, AIG is the world's largest insurance organization. AIG has more than 

88 million customers, serving commercial, institutional and individual customers. AIG is a 

leader in property casualty insurance, life insurance, retirement services and mortgage insurance. 
U.S. Department of Transportation 

October 31, 2014 

Page 3 

AIG is a network of over 64,000 people in more than 130 countries and jurisdictions. 

The company's goal is to come together to provide the best service to its customers. In this 

regard, AIG invests in the latest technology to meet the needs and challenges facing its 

policyholders. 

It is in this spirit that AIG PCGS seeks an exemption to use UASs to conduct Research 

and Development ("R&D") into new and innovative ways to efficiently serve its corporate 

affiliates' policyholders, both during and after natural disasters and casualty events. In addition, 

AIG PCGS will use UASs to support its corporate affiliates extensive system of risk assessment, 

risk management, loss control, and surety performance. These programs are an important part of 

the AIG member companies' philosophy of preventing accidents before they happen. UASs will 

provide a unique tool to assess and enhance safety in places that are inaccessible either for 

personal inspection or inspection by manned aircraft. 

AIG PCGS has assembled a UAS team covering all of the skill sets necessary to offer 

safe and effective UAS services, including an array of experienced aviation system professionals. 

In addition, AIG member companies already have substantial experience underwriting special 

coverage for UAS owners and operators. As a result, AIG PCGS has developed a keen 

knowledge of the issues affecting the safe use of UAS and the importance of thorough planning 

for both normal operations and for contingencies that might affect the safety of flight. 

The contact information for Petitioner is as follows: 

Conrad J. Naas 

Associate General Counsel 

Global Claims, Operations & Systems 

AIG Property Casualty 

80 Pine Street- 30th Floor 

New York, NY 10005 

Tel +1 212 458 9153 

Fax+ 1 201 748 5240 

Email conrad.naas@aig.com 

II. TYPES OF OPERATIONS 

A. Request to Use UASs for R&D at Test Sites Owned or Controlled by AIG 

PCGS 

AIG PCGS is requesting exemptions pursuant to Section 333 to conduct research and 

development at AIG PCGS's and corporate affiliates' own facilities or property. The testing 
U.S. Department of Transportation 

October 31,2014 

Page4 

facilities are not open to the public and access will be restricted to AIG PCGS and corporate 

affiliates' employees or consultants engaged in R&D or R&D-related work. UAS testing will 

occur outside navigable airspace at altitudes of 400 feet AGL or less. The test sites will enable 

AIG PCGS to evaluate how the UASs will operate and capture images over various types of 

buildings and in various conditions. 

AIG PCGS will use these tests to, among other things, develop new potential uses for 

UASs that support AIG PCGS corporate affiliates' core business, refine operational procedures 

and protocols, and test different payloads and sensors. The test areas will also be used for 

maintenance evaluation and pilot training purposes. AIG PCGS's R&D efforts are focused on 

meeting the needs of its corporate affiliates' policyholders and enhancing the AIG member 

companies' business processes. Specifically, AIG PCGS will evaluate how to utilize the 

employed UASs to assess and evaluate risks associated with or damage to customers' property. 

B. Request to Use UASs for Survey and Inspection of Damage After Casualty 

Events 

AIG PCGS also seeks exemption pursuant to Section 333 to conduct inspections of its 

corporate affiliates' policyholders' property that has suffered damage. Certain types of property 

damage are difficult and dangerous for a human to physically inspect, particularly where the 

structural integrity has been compromised. The alternative of using conventional aircraft or 

helicopters carries with it a large expense, operational difficulties, and added risks. 

As one of the world's largest providers of property casualty insurance, AIG member 

companies face unique demands during and immediately following catastrophic events or natural 

disasters. By using UASs, AIG PCGS will be able to provide more expeditious responses and 

post-disaster claims adjusting, allowing its corporate affiliates' policyholders access to the 

resources necessary to begin the process of recovery and rebuilding. 

As part of this effort, AIG PCGS is committed to partnering with appropriate federal, 

state and local governments and first responders to ensure full cooperation and coordination with 

their needs. This will include information sharing that can further assist first responders. 

C. Request to Use UASs for Risk Assessment, Risk Management, Loss Control, 

and Surety Performance 

AIG member companies are leaders in providing services to their customers aimed at 

ensuring that accidents never occur. It is AIG member companies' philosophy to manage risks 

proactively. As a world-leading insurance organization, AIG has a keen understanding of why 

losses happen. AIG member companies apply their experience to evaluate a client's unique loss 

potential and may recommend cost effective, professional and measurable methods to manage 

risks. 
U.S. Department of Transportation 

October 31, 2014 

Page 5 

A range of loss control services can be customized to address liability management, 

employee safety, business continuity and crisis management business-wide. As part of that 

program, AIG PCGS believes that UASs will be an invaluable tool that will permit risks to be 

assessed and mitigated in places where it is impossible or unsafe for a human to conduct an 

assessment. In addition, UASs provide an opportunity for ongoing documentation and 

monitoring of risks and will permit new mitigation strategies to be applied as necessary. 

As set forth in the attached Operations manual, these flights will be flown under a strict 

set of guidelines. They will be flown only over the insured's property or over property where 

permission has been obtained from the owner, and strict safety measures will be in place to 

ensure that there is no exposure to members of the public who are not involved in the operations. 

III. RELEVANT STATUTORY AUTHORITY 

This petition for exemption is submitted in accordance with Section 333(a) through (c) of 

the FAA Modernization and Reform Act of 2012. Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system." 

Pursuant to Section 333 ofthe Reform Act, the FAA Administrator is to permit unmanned 

aircraft systems to operate in the National Airspace ("NAS") where it is safe to do so based on 

the following considerations: 

• The UAS's size, weight, speed and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the U AS within the visual line of sight of the operator. 1 

Additionally, the FAA Administrator has general authority to grant exemptions from the 

agency's safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the 

Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 4470l(a), (b) and§§ 44702-

44 716, et seq.). A party requesting an exemption must explain the reasons why the exemption: ( 1) 

would benefit the public as a whole, and (2) would not adversely affect safety (or how it would 

provide a level of safety at least equal to the existing rules). See 14 C.F .R. § 11.81 (petitions for 

exemption). 

· 1 Id. at 333(b)(l). 
U.S. Department of Transportation 

October 31,2014 

Page 6 

IV. AIG PCGS'S PROPOSED OPERATIONS MEET THE REQUIREMENTS OF 

SECTION 333 OF THE REFORM ACT 

The proposed operations in this Petition for Exemption qualify for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. 

A. Approval is Warranted Based on the UASs Size, Weight and Operational 

Capability 

AIG PCGS will employ the UASs identified in Section 2 of the accompanying Operations 

Manual. These UAS will be used for all of the operations as set forth in the Operations Manual. 

Each of these UASs have characteristics in common that warrant approval. All of the UASs will be 

limited to a maximum flight speed of 30 m.p.h., and vertical ascent speed will be limited to 15 

m.p.h., and none of the devices have a weight in excess of25 pounds. Each of the UASs have an 

integrated GPS system to calculate the UASs' position and height and to relay that information via 

secure connection to the operator. In addition, each contains a failsafe mode if its connection to the 

remote control is lost. The system permits the vehicle to return to a predetermined location and land 

to prevent injury or damage. 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manual 

AIG PCGS's Operations Manual and the manufacturers' maintenance and flight manuals 

contain all of the procedures and limitations necessary to successfully perform R&D and inspections 

of AI G PCGS corporate affiliates' customers' property before, during and after catastrophes or other 

loss events. To assist the FAA in its safety assessment of AIG PCGS's operations, below is a 

summary of operational limitations and conditions which will ensure a level of safety equal to or 

exceeding the level of safety for operations conducted under current regulatory guidelines: 

1. The UASs employed by AIG PCGS will weigh 25 pounds or less. 

2. Flights will be operated within line of sight of a pilot and observer. 

3. Maximum total flight time for each operational flight will be limited to the amount of 

time the U ASs can be flown and still maintain a reserve battery power of no less than 

25%. 

4. Flights will be operated at an altitude of no more than 400 feet A G L and will not be 

conducted within navigable airspace. 

5. Flights will be operated at a lateral distance of at least 100 feet from any persons 

or property not associated with the operation who have not given prior 

permiSSIOn. 
U.S. Department of Transportation 

October 31,2014 

Page 7 

6. Flights will be limited to a speed of 30 m.p.h., and vertical ascent will be limited to 

15 m.p.h. 

7. Minimum crew for each operation will consist of the UAS Pilot, one or more Visual 

Observers as necessary to safely conduct the mission, and a Sensor Operator, if the 

sensor requires human direction or control. 

8. The pilot will have a private pilot's license and will have sufficient experience and 

recurrent training to safely conduct the flight in accordance with the standards set 

forth in the Operations Manual. 

9. The observer designated for any operation will be in constant voice contact with the 

pilot. 

10. The UASs will operate in accordance with the safety and operational requirements of 

their respective Manuals. 

11. Prior to the operation, a Mission Plan will be created setting forth the limitations for 

the flight as well as contact and hazard information. 

12. A NOT AM will be issued not more than 72 hours in advance of flight, but not less 

than 48 hours before flight. 

13. A Certificate of Authorization will be obtained prior to flight. 

14. All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire or other appropriate 

governmental agencies. 

15. The operator will coordinate all flights with the appropriate Flight Standards District 

Office. 

16. If the UASs lose communications or loses its GPS, they will have the capability 

to return to a pre-determined location within the operational area and land. 

17. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer. 

18. The UASs will have the capability to abort a flight in case ofunpredicted obstacles or 

emergencies. 
U.S. Department of Transportation 

October 31,2014 

Page 8 

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined 

under§ 40101 of the Act, including UASs, from its safety regulations and minimum standards 

when the Administrator decides a requested exemption is in the public interest. 2 

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 

45, 61 and 91 for purposes of conducting the requested operations using a UAS. Listed below 

are (1) the specific sections of 14 C.F .R. for which exemption is sought, and (2) the operating 

procedures and safeguards that Petitioner has established which will ensure a level of safety 

better than or equal to the rules from which exemption is sought.3 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 

91.203(a)(1) 

The FAA has stated that no exemption is needed from this section if a finding is made 

under the Reform Act that the UAS selected provides an equivalent level of safety when 

compared to aircraft normally used for the same application. These criteria are met, and 

therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA2014-0352 at 13-14,22. If, however, the FAA determines that there are some characteristics of 

the chosen UAS that fail to meet the requirements of the Reform Act, an exemption is requested. 

Equivalent Level of Safety 

The UASs identified in Section 2 ofthe Operations Manual are safe when taking into 

account their size, weight, speed, and operational capability. As set forth in Section II, Supra, 

all of the UASs weigh less than 25 pounds and will be flown at less than 30 miles per hour and 

completely outside controlled airspace. Additionally, the UASs carry neither pilots nor 

passengers, carry no explosive materials and or flammable liquid fuels, and operate exclusively 

within the parameters stated in the Operations Manual. 

2 See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations 

prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716). 

3 See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include: 

The reasons why granting the 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 you seek exemption. 
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October 31,2014 

Page 9 

Operations under this exemption will be closely controlled and monitored by the operator 

and will be conducted in compliance with local public safety requirements, to provide security 

for the area of operation. AIG PCGS will also provide the FAA with advance notice of all 

operations via NOTAMS and coordination with the local FSDO. In all cases, the UASs operated 

under the proposed conditions, will be at least as safe as, or safer than conventional rotorcraft 

operating with an airworthiness certificate without the restrictions and conditions of the proposed 

UAS operations. 

The aircraft themselves do not need a means to communicate with other aircraft or A TC, 

because those capabilities will be possessed by the pilot and observer, who are not onboard. See 

Grant ofExemption, Docket FAA-2014-0352 at 13. In addition, no sense and avoid technology 

is necessary on the U AS because it will be operated at all times by visual line-of-sight. !d. 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category 

Rotorcraft 

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent the Petitioner's UASs would otherwise require 

certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards 

for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H, 

supra. 

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and 

Identification Requirements 

Petitioner seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, 

provides that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with Part 45 ofthis chapter. 

• 14 C.F.R. § 45.23(b), Markings ofthe Aircraft, states: 

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. 
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October 31,2014 

Page 10 

• 14 C.F.R. § 45.27(a), Rotorcraft, states: 

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. 

In a previous Grant of Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft "have identification (N-Number) markings 

in accordance with 14 CFR part 45, Subpart C if the markings are as large as practicable." FAA 

Docket No. FAA-2014-0352. 

Equivalent Level of Safety 

AIG PCGS will mark all aircraft with their N-Number in a prominent spot on the 

fuselage with markings that are as large as practicable. 

D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and 

Registration 

Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a U.S.-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is required by§ 21.5 of 

this chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof. 

Pursuant to 14 C.F.R. § 91.203(a) and (b): 

(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 ... 

(b) No person may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) ofthis section or a special flight authorization issued under 

§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew. 
U.S. Department of Transportation 

October 31,2014 

Page 11 

AIG PCGS does not request an exemption from this section but instead notifies the FAA 

that, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the UAS 

flight manual, registration certificate and other documentation will be kept at the control station 

with the PIC during flight. The Chief Counsel's Office has held that for all UAS operations, this 

alternate method constitutes full compliance with the regulations. 

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is 

required to the extent that the requirements of Part 21 are waived or found inapplicable. 

Accordingly, Petitioner requests that the requirements for Section 91.7 be treated in accordance 

with Section V(A), supra. 

F. 14 C.F.R. § 91.103: Preflight Action 

Petitioner seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in the 

FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all 

information necessary to safely conduct the flight, an exemption is requested to the extent that an 

FAA-approved Flight manual is required. 

Equivalent Level of Safety 

An equivalent level of safety will be provided by following the Aircraft Operations 

Manual and flight manual provided by the manufacturer. The PIC will take all required preflight 

actions- including performing all required checklists and reviewing weather, flight requirements, 

battery charge, landing and takeoff distance, aircraft performance data, and contingency landing 

areas - before initiation of flight. The Operations Manual and manufacturer's flight manual will 

be kept at the ground station with the operator at all times. 

G. 14 C.F.R. § 91.109(a): Flight Instruction 

Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o 

person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted 

aircraft, by their design, do not have functional dual controls. Instead, flight control is 

accomplished through the use of a device that communicates with the aircraft via radio 

communications. 
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October 31,2014 

Page 12 

Equivalent Level of Safety 

Given the size and speed of the UASs employed by AIG PCGS, an equivalent level of 

safe training can still be performed without dual controls because no pilot or passengers are 

aboard the UASs, and all persons will be a safe distance away in the event that the UASs 

experiences any difficulties during flight instruction. In addition, Petitioner will conduct flight 

training at its Research and Development test sites, which are located on its own property. These 

training flights will be conducted in a sterile area and will otherwise comply with the provisions 

in the Operations Manual for flights at the R&D facility. Accordingly, AIG PCGS's proposed 

method of operation provides superior levels of safety. 

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

Petitioner requests an exemption from the minimum safe altitude requirements of 14 

C.F .R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may 

not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or 

structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA." 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the maximum 

weights proposed herein, and given the lack of flammable fuel, any risk associated with these 

operations is far less than those that presently exist with conventional aircraft. An equivalent 

level of safety will be achieved given the size, weight, and speed ofthe UASs, as well as the 

location where it is operated. In order to avoid any risk to aircraft, flight operations will be 

restricted to 400' AGL or below. As set forth in the Manuals, the UASs will be operated in a 

restricted area, away from persons or structures not involved in the operation. 

I. 14 C.F.R. § 91.121: Altimeter Settings 

This petition seeks an exemption from 14 C.F .R. § 91.12 I, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that 

is set to the elevation of the departure airport or barometric pressure. An exemption is required 

to the extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read 

out. 

Equivalent Level of Safety 

The FAA has stated that an equivalent level of safety can be achieved ifthe UASs will be 

operated at 400' AGL or below and within visual line-of-sight in addition to GPS based altitude 
U.S. Department of Transportation 

October 31,2014 

Page 13 

information relayed in real time to the operator. See Grant of Exemption to Astraeus Aerial, 

Docket No. F AA-2014-0352. As the attached Operations Manual indicates, the chosen UASs 

meets these requirements, and a zero altitude initiation point will be obtained prior to flight. 

J. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR 

Conditions 

Petitioner requests an exemption from 14 C.P.R.§ 91.151(a)'s fuel requirements for flight 

in VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under 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. 

Here, the technological limitations on UAS battery power means that no meaningful 

flight operations can be conducted while still maintaining a 30 minute reserve. AIG PCGS 

proposes that all flights comply with this requirement by mandating that the aircraft be safely 

landed with no less than 25% of battery life remaining. 

Equivalent Level of Safety 

The FAA has stated that an equivalent level of safety is provided ifthe UAS flight is 

terminated with at least 25% reserve battery power still available. See Grant of Exemption to 

Astraeus Aerial, Docket No. FAA-2014-0352. The Operations Manual conforms to this limit, 

providing an equivalent level of safety. 

K. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

Petitioner seeks an exemption from the maintenance inspection requirements contained in 

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.F.R. § 

91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ... have discrepancies 

repaired as prescribed in part 43 of this chapter"). An exemption from these regulations is 

needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, 

which the U AS will not have. 
U.S. Department of Transportation 

October 31, 2014 

Page 14 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because maintenance and inspections will 

be performed in accordance with the UAS Manufacturer's Manual, as referenced in the 

Operations Manual. As provided in the Operations Manual, flights will not be conducted unless 

a flight operations checklist is performed that includes all of the aircraft's components. The 

Operations Manual also sets requirements for maintenance log books and record keeping as well 

as routine and post-flight maintenance. The Manual sets requirements for both annual 

maintenance and preventative maintenance based on hours of flight. 

L. 14 C.F.R. § 61.113: Private Pilot Privileges And Limitations 

Petitioner seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate 

holders from flying aircraft for compensation or hire, and would also require a second class 

medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if the 

private pilot is carrying passengers or cargo for hire. In this case, while the UASs will be 

operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant 

of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined that the unique 

characteristics ofUAS operation outside of controlled airspace did not warrant the addition cost 

and restrictions attendant with requiring a the PIC to have a commercial pilot certificate and 

class II medical certificate. 

The restrictions AIG PCGS has placed on its UAS operations meet or exceed the 

restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352. AIG 

PCGS will operate in a sterile area way from persons and property not involved in the operation. 

It will be flown based on VLOS at 400' AGL or below. A NOT AM will be issued between 48 

and 72 hours before the flight is to occur, and the flight will be coordinated with the applicable 

FSDO. 

Equivalent Level of Safety 

In addition to these flight restrictions, AIG PCGS will further ensure safe operation by 

requiring that any PIC be thoroughly versed not only in airspace and communication issues 

pertaining to all aircraft operators but also in the unique aspects ofUAS flight. Pilots will also 

be required to conduct training flights at AIG PCGS's Research and Development facilities to 

obtain flight experience with UAS generally and with the specific models used for commercial 

operations in particular. Petitioner believes that this system will provide a higher level of 

competency and proficiency for its pilots. 
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October 31, 2014 

Page 15 

VI. DRUG AND ALCOHOL PROGRAM 

AIG PCGS has policies in place to ensure that no person may act as a PIC, observer, or 

sensor operator if they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST 

Granting AIG PCGS's exemption request furthers the public interest. National policy set 

by Congress favors early integration ofUAS into the NAS in controlled, safe working 

environments such as those proposed in this petition. In addition, the public also has an interest 

in reducing the hazards and emissions associated with alternate use of helicopters to conduct 

similar inspection operations. The UASs in question are very light and do not carry any 

flammable fuel, further reducing the risk from any potential accident. 

Additionally, AIG PCGS's intended uses for the UASs have real-world benefits for AIG 

member companies' policyholders and the public at large. AIG PCGS will be able to inspect and 

survey its corporate affiliates' policyholder's property after a casualty event safely, thoroughly, 

and efficiently. This will allow AIG to adjust claims more quickly after a loss and ensure that its 

policyholders can receive the funds necessary for them to start the process of recovery and 

rebuilding. The UAS work will also aid in AIG member companies' risk assessment, risk 

management, loss control, and surety performance programs. These programs prevent accidents 

and injuries, and there is a strong public interest in making these programs more effective 

through the use ofUASs. 

Finally, by coordinating and teaming with federal, state and local governments after a 

disaster, AIG PCGS can provide valuable information to first responders and government that 

can help coordinate the response. 

VIII. PRIVACY 

All flights will be conducted in accordance with any federal, state or local laws regarding 

pnvacy. 

IX. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

AIG PCGS seeks an exemption from the following rules: 

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 CFR § 61.113; 14 

CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 
U.S. Department of Transportation 

October 31,2014 

Page 16 

91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 

14 CFR 91.409(a)(2); 14 CFR 91.417 (a) & (b). 

The exemption will enhance safety by reducing risk to the general public and property 

owners from the substantial hazards associated with performing equivalent work with 

conventional aircraft and rotorcraft. 

X. CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012-size, 

weight, speed, operating capabilities, proximity to airports and populated areas, operation within 

visual line of sight, and national security-provides more than adequate justification for the grant 

of the requested exemptions to permit AIG PCGS to operate the selected UASs and provide 

R&D and inspections during and after casualty events. 

Granting the requested exemption will benefit the public interest as a whole in ,many 

ways, including (1) significantly improving safety and reducing risk by alleviating human 

exposure to danger, and (2) improving the quality of services and decreasing operating costs 

compared with conventional flight operations. 

If you have any questions or require any additional information, please do not hesitate to 

call. 

A LONG & ALDRIDGE LLP 

·k E. McKinnon, Esq. 

Mark A. Dombroff, Esq. 

Attachments: AIG PCGS Operations Manual (submitted as a Confidential Document under 14 

C.P.R. § 11.35(b) and exempt from disclosure under the Freedom oflnformation Act, 5 U.S.C. 

§ 552 et seq., and any other requirements established by the FAA pursuant to Section 333 ofthe 

Reform Act); Aircraft Flight and Maintenance Manuals as incorporated into the AIG PCGS 

Operations Manual (submitted as a Confidential Document under 14 C.P.R. § 11.35(b) and 

exempt from disclosure under the Freedom oflnformation Act, 5 U.S.C. § 552 et seq., and any 

other requirements established by the FAA pursuant to Section 333 ofthe Reform Act).