1 Executive Offices 300 Galleria Officentre, Suite 200 Southfield, Michigan 48034

November 5, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, SE Washington, D.C. 20590

Re: Motors Insurance Corporation Petition for Exemption Pursuant to
Section 333 of the FAA Modernizatio n and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam,

Pursuant to Section 333 of the Federal Avia tion Administration (“F AA”) Modernization and Reform Act of 2012 (the “Reform Act”) and Pa rt 11 of the Federal Aviation Regulations (“FAR”), Motors Insurance Corporation (“Petitione r”) hereby petitions the FAA for authority to operate the small Unmanned Aircraft System (“ UAS”) as described here in for aerial photography and videography. Specifically, Petitioner intend s to use UAS to inspect dealer inventory
vehicles after a natural disaster has caused damage to the area wher e dealer vehicles are stored. As this petition is similar in all material re spects to other petitions the FAA has granted, Petitioner requests summary a pproval of this petition.

I. BACKGROUND OF PETITIONER

Ally Financial Inc. is a leading automotive fina ncial services company, and wholly owns Motors Insurance Corporation which is domiciled in Mi chigan. Petitioner, thr ough its insurance and noninsurance companies, offers a fu ll spectrum of financial products and services, including vehicle service contracts, inventory in surance, insurance consultative services for dealers and other ancillary products. Additional in formation about the company is available at the Ally media site at http://media.ally.com.

II. DESCRIPTION OF OPERATIONS

Petitioner requests an exemption to permit us e of UAS for aerial phot ography and videography. The UAS will be used to survey damage to insure d dealer inventories afte r casualty events. The
data collected will assist Petitioner in determini ng the scope and severity of insurance claims. Such operations may occur, subject to notice to and approval of proper fe deral, state and local officials, over areas that have suffered a natural disaster such as a hurricane, tornado, flood or wildfire. The purpose of these operations will be to develop procedures that will improve the speed of Petitioner’s response to policyholders. Petitioner will deve lop operating procedures that will integrate UAS into its response strategy to ensure safety to persons and property.2 Operation of the UAS will occur under safe and c ontrolled conditions pursuant to the terms of the FAA’s grant. Specifically,

 Operations will be conducted by a Pilot in Command (“PIC”) holding either an airline transport, commercial, private, recreational, or sport pilot certifi cate, and a current FAA
airman medical certific ate or a valid U.S. driver’s license.

 The UAS will be operated in visual line of site (“VLOS”) of the PIC at all times and operations will only occur during daytime.

 All UAS operations will utilize a visual obs erver (“VO”), who can communicate with the PIC verbally at all times.

 Prior to each flight, pilot will in spect the UAS to ensure it is in condition for safe flight.

 The airspace used for inspection will be predetermined, limited, and controlled.

 The UAS will remain clear and yield the righ t of way to all other manned operations and
activities at all times.

 All operations will be conducted over private or controlled-access property. Petitioner will limit operations to property whose owners/controllers have given permission for UAS operations

 Flights will be conducted under 400 feet a bove ground level (“AGL”) and only when 5 miles or greater from an airport, thereby avoi ding interference with users of the NAS.

In short, Petitioner will take measures to ensure that UAS operations will not create a hazard to aviation or to the public. Given the size and sp eed of the UAS, the controlled nature of the locations being used and the lack of explosive ma terials or flammable jet fuels, the operations will not pose a threat to national security.

III. PUBLIC INTEREST BENEFITS

Grant of Petitioner’s request to operate the UAS for commercial aerial photography and videography is in the public interest for several reasons. First, use of UAS in this manner will make conditions for insurance claim representati ves much safer. Today, claim representatives need to enter into the impacted area soon after the occurrence in order to obtain a preliminary scope of damage. Such activities are inhere ntly dangerous. Second, quick assessment of damage sustained to dealer inve ntory allows Petitioner to determ ine required staffing and logistic issues for inspection of vehicles and potentially movement of vehi cles that are located in areas dangerous to reach by foot. Third, use of small, light, UAS offers countless benefits over use of full-sized manned aircraft. Repl acing significantly larger manned aircraft carrying flight crews and flammable fuel with UAS that do not carry people creates a greater margin of safety for UAS operators and visual observers as well as the public on the ground. The lower acquisition, operational, and personnel costs of using UAS, in addition to reduced environmental impacts
such as reduced noise and emissions and the use of batteries for power, also benefit the public.

IV. AIRCRAFT SPECIFICATIONS

Petitioner requests authority to use the DJI Ph antom 3 Professional model. This UAS is a quadcopter weighing 1280 g includi ng battery and propellers and having a diagonal size of 5903 mm including propellers. The FAA has previously granted Section 333 exemptions to operators using this UAS, noting that in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, th e Secretary of Transportation has determined that
this aircraft meets the conditions of Section 333. 1 Petitioner also requests authority to use a model of aircraft comparable in size, weight , and safety capabilities to the DJI Phantom 3 Professional and any updated model of the same DJI aircraft.

V. STATUTORY AUTHORITY FOR REQUESTED EXEMPTION

This petition for exemption is submitted in acco rdance with Section 333 of the Reform Act and
Section 44701 of the Federal Aviation Act. The Federal Aviation Act grants the Administrator of the FAA general authority to grant exempti ons from the agency's safety regulations and minimum standards when the Administrator decides such a requested exemption is in the public
interest. 2 In addition, the Reform Act directs the Secretary of Tran sportation to determine which UAS “as a result of their size, weight, speed, ope rational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace syst em or the public or pose a threat to national security.” 3 The FAA’s regulations require that a party requesting an exemption incl ude (i) the reasons why granting the request would be in the public interest, and ( ii) the reasons why granting the exemption would not adversely affect safety or how it would provide a level of safety at least equal to the existing
rules. 4

VI. APPLICATION INFORMATION

The name and address of the applicant are:

Hasan Ozel 1000 Abernathy Road, 400 NorthPark, Suite 275 Atlanta, GA 30328 Phone: (770) 677-5349 hasan.ozel@ally.com

Regulations from which the exemption is requested:

14 C.F.R. § 61.23(a) and (c) - Medical Cert ificates: Requirement and duration. 14 C.F.R. § 61.101(e)(4) and (5) - Recreati onal pilot privileges and limitations. 14 C.F.R. § 61.113(a) - Private pilot privil eges and limitations: Pilot in command. 14 C.F.R. § 61.315(a) - What are the privileges and limits of my sport pilot certificate 14 C.F.R. § 91.7(a) - Civil aircraft airworthiness. 14 C.F.R. § 91.119(c) - Minimum safe altitudes: General.

1 See Grant of Exemption No. 11801, Regulatory Docket No. FAA–2015–1019 (Donan Solutions LLC); Grant of Exemption No. 11944, Regulatory Docket No. FAA–2015–1034 (Adam Szaruga); Grant of Exemption No. 11824, Regulatory Docket No. FAA–2015–1078 (Axis Surveying, LLC).

2 See 49 U.S.C. § 44701(f).

3 Pub. L. No. 112-95, 126 Stat. 75-76 (codified as a Note to 49 U.S.C. § 40101).

4 14 C.F.R. § 11.81.4 14 C.F.R. § 91.121- Altimeter settings. 14 C.F.R. § 91.151(a)(1) - Fuel requirements for flight in VFR conditions. 14 C.F.R. § 91.405(a) - Maintenance required. 14 C.F.R. § 91.407(a)(1) - Operation after maintena nce, preventive maintenance, rebuilding, or
alteration. 14 C.F.R. § 91.409(a)(1) and (2) - Inspections 14 C.F.R. § 91.417(a) and (b) - Maintenance records

VII. REQUEST FOR SUMMARY GRANT

The FAA can issue a summary grant when it find s it has already granted a previous exemption similar to the new request. As described in deta il herein, Petitioner reque st authority to use a small UAS for aerial photography an d videography. Given that this exemption is similar to those that have already been granted, 5 Petitioner requests that, if possibl e, this request for exemption be considered on an expedited basis.

VIII. JUSTIFICATIONS FOR EACH EXEMPTION REQUEST

A. 14 C.F.R. §§ 61.23(a) and (c) Medical Ce rtificates: Requirement and duration; 61.101(e)(4) and (5) Recreational pilot privileges and limitations; 61.113(a) Private pilot privileges a nd limitations: Pilot in command; 61.315(a) What are the privileges and limits of my sport pilot certificate.

Petitioner notes that FAA has required previous Section 333 grantees to use a PIC holding either an airline transport, commercial, private, recreational or sport certi ficate pilot license and either 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 terr itory, a possession, or the Federal government.
Petitioner will ensure that its PI Cs will satisfy each of these requirements. Since Petitioner’s PICs will be operating UAS under the same conditions as those previously granted by the FAA, an equivalent level of safety will be met by granting these exemptions.

B. 14 C.F.R. § 91.7(a) Civil aircraft worthiness.

Section 91.7(a) prohibits operation of a civil aircra ft unless it is in airworthy condition for safe flight. The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable. Petitio ner requests an exemption from this regulation because the UAS would not operate with an airworthin ess certificat e under the proposal set forth in this filing. Given the size of the aircraft a nd the operational parameters, an equivalent level of safety will be provided. Petitioner notes that th e Administrator has granted relief from this section in previous exemptions.

C. 14 C.F.R. § 91.119(c) Minimum safe altit udes over congested and other areas.

Section 91.119(c) establishes safe altitudes for op eration of civil aircraft over areas other than congested areas. The Petitioner requests relief from this section with respect to those

5 See Grant of Exemption No. 11676, Regulatory Docket No. FAA-2015-0568 (DPR Construction); Grant of Exemption No. 12116, Regulatory Docket No. FAA-2015-1059 (Unmanned Ad-Hoc Industries, Inc.).5 participating persons, vehicles, and structures directly involved with operations. The UAS will never operate at higher than 400 AGL. Relief from this section is warranted as operations will be conducted with adequate safety provisions as outlined in this document. As a result, an equivalent level of safety will be met by granting this exemption. Petitioner notes that the Administrator has granted relief from this section in previous exemptions.

D. 14 C.F.R. § 91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by
reference to an altimeter that is set to the elev ation of the departure ai rport or an appropriate altimeter setting available before departure. An exemption from this section may be needed if the UAS does not have a barometric altimeter, but instead has a GPS altitude read out. An equivalent level of safety will be achieved by the operator confirming the altitude of the launch
site shown on the GPS altitude indicator before fli ght. As a result, an equivalent level of safety will be met by granting this exemption. Petitioner notes that the Administra tor has granted relief from this section in previous exemptions.

E. 14 C.F.R. § 91.151(a)(l) Fuel requiremen ts for flight in VFR conditions.

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast w eather conditions) there is enough fuel to fly to the first point of intended landing, and, a ssuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes.” Co mplying with the 30 minute reserve would severely limit the length of the Petitioner’s UAS flights and hamper operations. Given the limitations on the UAS’s proposed flight area, a longer time frame for flight in daylight conditions is reasonable. Operating the UAS in a tightly contro lled area does not raise the type of risks that
this section was intended to addres s, particularly given the size and speed of the UAS. Petitioner notes that the Administrator has granted relief from this section in previous exemptions.

F. 14 C.F.R. §§ 91.405(a) Maintenance re quired; 91.407(a)(l) Operation after maintenance, preventive maintenance, rebuilding or altera tion; 91.409(a)(l) and (2) Inspections; 91.417(a) and (b) Maintenan ce records.

These regulations require that an aircraft operator or owner “shall ha ve that aircraft inspected as prescribed in subpart E of this part and shall between required inspections , except as provided in paragraph (c) of this section, have discrepancie s repaired as prescribed in part 43 of this chapter...,” and others shall in spect or maintain the aircraft in compliance with Part 43.
Given that these sections and Part 43 apply only to aircraft with an airworthine ss certificate, these sections will not apply to the Petitioner. The UAS will be maintained by the petitioner. An equivalent level of safety will be achieved because the UAS are very limited in size and will carry a small payload and operate only in restricted areas fo r limited periods of time and only during daylight hours. If mechanical issues aris e, the UAS will be operating from no higher than 400 feet AGL and can immediately land. The operat or will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. As a6 result, an equivalent level of safety will be me t by granting this exemption. Petitioner notes that the Administrator has granted relief from this section in previous exemptions.

G. Additional Relief.

In addition to the exemptions listed above, the Petitioner requests exem ption from such other rules and regulations as the FAA deems appropria te to enable the opera tions described. If, during the effective date of any Grant of Exemp tion issued pursuant to this Petition, the FAA issues interim or final rules applicable to the operation of any UAS included herein, any conditions and limitations required in such Grant that are more burdensome than the new regulation be appropriately modified or removed.

IX. SUMMARY TO BE PUBLISHED IN FEDERAL REGISTER

If the FAA determines that summary grant is not appropriate in this case, below is a summary of the petition for publication in the Federal Register.

Petitioner : Motors Insurance Corporation

Sections of 14 C.F.R. Affected : 14 C.F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(1); 14 C. F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b).

Description of Relief Sought : Petitioner seeks relief from the requirements of 14 C.F.R. Part 21 Subpart H; 14 C.F.R. § 21.191(a); 14 C.F. R. § 45.23(b); 14 C.F.R. § 45.27; 14 C.F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) a nd (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(1); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate an unmanned aerial system for aerial photography and videography.

X. CONCLUSION

This petition satisfies the criteria provided in Section 333 of the Refo rm Act regarding size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security, and provides more than adequate justification for the grant. Please do not hesitate to contact Pe titioner’s outside counsel Katy Ross at 202-719-7410

or kmross@wileyrein.com with any questions about this filing.

Sincerely,

/s/
Deborah L. Rhodes General Counsel, Motors Insurance Corporation