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 ofthe 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 ofthe 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 operationof its UASfleet, currentlycomprisedofone 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 upto 23
- 25 minutes **Sentry Insurance** 1800 North Point Drive Stevens Point, WI 54481 **T om Werlein**  Associate Counsel tom.werlein@Sentry.com 715 346

-6017 715 346

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offlighttime.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) ofthe PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintainsVLOS capability.TheVO 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 designationforthe duration oftheflight.The PIC must ensurethattheVO 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 that3

any update or revisionwould affectthe basis uponwhichthe FAA grantedthis 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 ofaflight critical component, must undergo afunctional 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 untilthe necessary maintenance has been performed andthe UAS is foundto 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, aterritory, a possession, orthe 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 oftraining 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 § 91.119.4

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 availabletotheAdministrator 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 belowthetop ofand within 250 feet ofany 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 prohibitedfrom beginning aflight unless (consideringwind andforecastweather conditions) there is enough available power forthe 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) 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 enclosed COA. 23.All aircraft operated in accordance withthis 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.5

27.All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, andstructures 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, operatortrainees or essential persons are not considered nonparticipating persons under this exemption. 28.All operations shall be conducted over private or controlled

-access propertywith 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 WH ICH 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.6

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 oftraining 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.7

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 withintheVLOS.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 powerto 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 insurethatthe UAS is in working order priorto 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 oftheAct and the FAA has issued similar exemption grants in similar circumstances; we trust this Petition provides the Agency with the necessary information andjustification allowing Sentry to operate its UAS for the purpose of aerial insurance data collection. We appreciate your prompt review of our Petition. Sincerely,

TomWerlein8

Associate Counsel