February 25, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Av. SE

Washington, DC 20590

Re: Sentry Insurance’s Petition for Exemption Pursuant

to Section 333 of the FAA Modernization and Reform Act

To Whom it May Concern:

Sentry Insurance a Mutual Company (Sentry) applies for an exemption, pursuant to Section 333 

of the Federal Aviation Administration Modernization and Reform Act of 2012 (the Act) and 14 

C.F.R. Part 11, from the Federal Aviation Regulations (FAR) identified in this Petition, in order to 

operate small unmanned aircraft vehicle systems (UAS) more fully described in this Petition. 

Sentry intends to use the exemption to operate several UAS in furtherance of its insurance 

activities, including underwriting and claim inspections, marketing purposes (including 

photographing and other marketing functions on the Sentry campus), and related undertakings.

In conducting UAS activities, Sentry will safely operate its exempted UAS in furtherance of the 

public interest by eliminating reliance on aircraft using flammable fuels, exposing aircraft 

personnel to dangerous situations, and reducing the risk to claims and underwriting personnel 

in inspecting dangerous areas, such as rooftops, commercial enterprises, and areas suffering 

from the results of natural disasters. Such use will also reduce the time required to complete 

underwriting activities and evaluate and pay claims. 

The FAA has recently found that Sentry’s request for exemption is similar to relief it has 

previously granted in Exemptions No. 11112, 11213, 12030, 12645 and 14110.

APPLICANT INFORMATION & PROPOSED OPERATIONS

In business since 1903 Sentry is a major provider of property, casualty, workers compensation 

and related insurance to individuals, families, and businesses across the United States. 

As indicated above, Sentry’s proposed UAS operations are not unique as the FAA has reviewed 

and approved a number of other property casualty underwriter petitions. Sentry is committed 

to safe operation of its UAS fleet, currently comprised of one Phantom 3 Standard UAS and one 

Phantom 3 Professional (Phantom 3).

Both the Phantom 3 Standard and Phantom 3 Professional are “easy-to-fly quadcopters” which 

include a camera, custom remote and Intelligent Flight Battery providing up to 23 - 25 minutes 

Sentry Insurance

1800 North Point Drive

Stevens Point, WI 54481

Tom Werlein

Associate Counsel

tom.werlein@Sentry.com

715 346-6017

715 346-7028 Fax

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62-52H
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of flight time. Weighing approximately 2.7 pounds, the Phantom 3 has a maximum airspeed of 

35.8 miles per hour, an ascent speed of 11.1 miles per hour and descent speed of 6.7 miles per 

hour. The FAA has previously determined that the Phantom 3 meet all the criteria set forth in 

Section 333 and Sentry requests similar exemption for operation of its Phantom 3s.

CONDITIONS & LIMITATIONS

In seeking this exemption, Sentry will comply with all of the conditions and limitations listed 

here:

1. Operations requested in application for exemption are limited to the DJI Phantom 3s (UAS) 

when weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition.

2. Operations for the purpose of closed-set motion picture and television filming will not be 

permitted.

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

may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot 

speed restriction. In no case will the UAS be operated at airspeeds greater than the maximum 

UAS operating airspeed recommended by the aircraft manufacturer.

4. The UAS 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 UAS must be operated within visual line of sight (VLOS) of the pilot in charge (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 UAS 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. All documents needed to operate the UAS and conduct its operations in accordance with the 

conditions and limitations states 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 limitations in this exemption and the procedures outlined in the operating 

documents, the conditions and limitations herein take precedence and must be followed. 

Otherwise, Sentry must follow the procedures as outlined in its operating documents. Sentry 

may update or revise its operating documents. It is Sentry’s responsibility to track such 

revisions and present updated and revised documents to the Administrator or any law 

enforcement official upon request. Sentry must also present updated and revised documents if 

it petitions for extension or amendment to this grant of exemption. If Sentry determines that 
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any update or revision would affect the basis upon which the FAA granted this exemption, then 

Sentry 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 or property.

9. Sentry 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 inspections 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. Sentry 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 requested 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 Columbia, 

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. 

14. Sentry will 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 UAS with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119.
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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 UAS 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 FAA-published 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 UAS 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. For tethered UAS operations, the tether line must have colored pennants or streamers 

attached at not more than 50 foot intervals beginning at 150 feet above the surface of the 

earth and visible from at least one mile. This requirement for pennants or streamers is not 

applicable when operating exclusively below the top of and within 250 feet of any structure, so 

long as the UAS operation does not obscure the lighting of the structure.

19. If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location with the private or controlled-access property.

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

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

conditions) there is enough available power for the UAS to conduct the intended operation and 

to operate after that for at least 5 minutes or with the reserve power recommended by the 

manufacturer if greater.

22. All operations shall be conducted in accordance with an (Air Traffic Organization) ATOissued 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 enclosed COA.

23. 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 (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

24. Documents used by Sentry 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.

25. The UAS must remain clear and give way to all manned aviation operation and activities at 

all times.

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

28. 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. 

29. 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 Wes 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.

REGULATIONS FROM WHICH EXEMPTION IS SOUGHT

Sentry requests an exemption from the following regulations, found at 14 C.F.R. Parts 45, 61, 

and 91, as well as any other regulations that the FAA deems unnecessary in the operations of 

Sentry’s UAS:

Federal Aviation Regulations Description

91.9(c); 45.23(b); and 45.27(a) Aircraft Marking and Identification 

Requirements

All UAS flown by Sentry will display an N-number marking that is as large as practicable. In 

prior grants the FAA had determined that an exemption from marking and identification 

requirements was appropriate because the UAS have no cabin, cockpit, or pilot station and 

often are of such a size as to make two-inch lettering prohibitive.
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61.23(a) and (c); 61.11361.101(e)(4) and 

(5); 61.315

Pilot Medical Certificate, Privileges and 

Limitations

Sentry seeks exemption from these sections which restrict operation to commercially-licensed 

pilots. As the Agency knows, these UAS are remotely operated and carry no passengers nor 

property. Allowing a sport or a recreational pilot to operate a UAS would in no way impact 

safety levels. Moreover, the Agency has recently allowed similar exemptions, specifically in 

Exemptions 11277, 11278, 11138, and 11410.

91.7(a) Civil Airworthiness

Sentry understands that the FAA does not issue Airworthiness Certificates for UAS like the 

Phantom 3. Instead, the Agency has determined in earlier Exemptions that compliance with the 

operating documents, the operational Conditions and Limitations, and the PIC determine the 

specific airworthiness of the UAS at the time of the flight were sufficient.

91.9(b)(2); 91.203(a) and (b) Aircraft Flight Manual, Certification and 

Registration

These regulations require that the aircraft flight manual, certification and registration paperwork 

be included and stored within the aircraft. Of course, the Phantom 3 and similar UAS are far 

too small to hold such documentation. The Agency has determined in prior Exemptions that a 

Pilot’s access to these documents from the ground control location where the UAS is being 

operated would be sufficient to achieve an equivalent level of safety. 

91.103 Preflight Activity

Sentry seeks an exemption from this section, which requires a PIC to become familiar with 

specific information before each flight, including information in an Agency approved Flight 

Manual. However, adherence to the UAS operating documents will provide assurance that the 

UAS is airworthy and Sentry seeks an exemption to the requirement of an Agency approved 

Flight Manual.

91.109(a) Flight Instruction

Sentry seeks an exemption from this section, which requires dual controls in civil aircraft. Given 

the size, speed and nature of UAS, a safe level of training and operation can be achieved with 

the use of dual controls because no pilot or passenger is on board, and all persons are a safe 

distance away from operation during flight instruction.

91.119(c) Minimum Safe Altitude Over Other than 

Congested Areas

Sentry seeks an exemption from this section, which requires the operation of civil aircraft at a 

minimum safe altitude above 500 feet. However, given the size, weight, speed and proposed 

operating conditions, a minimum level of safety is achieved with the UAS operating under the 

required minimum altitude.
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91.121 Altimeter Settings

Sentry requires an exemption from this section because the Phantom 3 which requires PIC 

operating the UAS to maintain flight level by reference to an altimeter that is set to the 

elevation of the departure airport or an appropriate altimeter setting before departure. 

However, the Phantom 3 automatically calibrates its position without user input. The Agency 

has indicated that an equivalent level of safety is achieved when the UAS is operated at or 

below 400 feet and within the VLOS. Additionally, the UAS uses GPS based altitude information 

relayed in real time to the PIC and, prior to each flight a zero altitude initiation point is 

established for the PIC to confirm onboard GPS accuracy. Sentry will operate its UAS pursuant 

to these requirements. 

91.151(a) Fuel Requirements for Flight in VFR 

Conditions

Sentry seeks an exemption to this section because UAS technology limitations mean that no 

meaningful flight operation can be conducted while still maintaining a 30 minute battery 

reserve. Both Phantom 3s are equipped with a rechargeable NiCad battery with a capacity of 

4480 mAh and a voltage of 15.2 V providing up to 25 minutes of flight time. They are also 

equipped with a Low Battery Return to Home feature which alerts the PIC of any situation 

where the UAS current distance from home and altitude make the battery level problematic for 

a safe return. Sentry will require the PIC not to begin a flight unless there is enough power to 

fly and return home given the wind and weather conditions; Sentry will require the UAS to 

return home and safely land when the battery when the battery reaches 30% capacity.

91.405(a), 91.407(a)(1), 91.409(a)(1), and 

(2), and 91.417(a) and (b)

Maintenance Inspections

Sentry seeks an exemption to these sections regarding required inspections because an equivalent 

level of safety will be achieved when Sentry complies with the Operating Documents maintenance 

and inspection requirements. PIC will insure that the UAS is in working order prior to initiating any 

flight, perform any required maintenance, and keep a log of any performed maintenance.

CONCLUSION

Sentry’s Petition for Exemption satisfies the requirements set out in Section 333 of the Act and the 

FAA has issued similar exemption grants in similar circumstances; we trust this Petition provides the 

Agency with the necessary information and justification allowing Sentry to operate its UAS for the 

purpose of aerial insurance data collection.

We appreciate your prompt review of our Petition. 

Sincerely,

Tom Werlein
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Associate Counsel