1 

### U.S. Department of Transportation 1200 New Jersey Avenue, S.E.

Room W12-140 Washington, D.C. 20590

RE: HSB’s Request for Exemption Pursuant to Section 333 of the FMRA and Part 11 of the FARs to Use Small Unmanned Aircraft Systems

Dear Sir or Madam:

The Hartford Steam Boiler Inspection and Insurance Company (“HSB”) hereby petitions

for exemption from several provisions of the Fe deral Aviation Regulations to allow commercial

operations of small unmanned aircraft systems (“UAS”). HSB submits this exemption petition

pursuant to the FAA’s authority under Section 33 3 of the FAA Modernization and Reform Act

of 2012 (“FMRA”) and in accordance with Part 11 of the FAA’s rules. 1



### HSB’s petition is similar in all material respects to petitions for which the FAA has

already issued grants of ex emption under Section 333. Specifically, HSB proposes to use UAS

for aerial data collection, under conditions substantially similar to those granted in Exemptions

No. 11062 to Astraeus Aerial, 11109 to Clayc o, Inc., 11112 to VDOS Global, LLC, and 11213 to

Aeryon Labs, Inc. HSB’s operations will therefore achieve the same requisite level of safety

deemed to be met in these petitions. HSB’s ope rations are in the public interest, as they will

allow HSB to safely and efficiently conduct insurance functions fo r the benefit of its

policyholders and employees and undertake research and devel opment (“R&D”) to foster the

development of additional uses of UAS. The FAA has granted several R&D and real-world

operation exemptions to operators in the insu rance industry, including Exemption Nos. 11367 to

ADM Crop Risk Services, 11293 to Erie In surance Group, 11188 and 11175 to State Farm,

11273 to AIG, and 11309 and 11274 to USAA. HSB’ s petition thus merits grant through the

FAA’s summary grant process.

INTRODUCTION

For almost 150 years, equipment breakdown in surance, other specialty insurance and

reinsurance, loss prevention and related inspections have been HSB’s primary focus. HSB’s

1 See 14 C.F.R. §§ 11.61(b), 11.63, 11.81.2 

### engineering and inspection servic e force is one of the largest in the world, with over 800

engineers, inspectors and technicians provi ding inspection services, loss reduction and

engineering based risk management consultati on for business, home and farm. HSB also

provides fire safety, risk assessm ents and property loss control services for our company and our

client companies. Our employees are strategically located across the United States to allow for

efficient and effective performance of this technical and inspection work.

The company's goal is to provide innovative, forward thinking risk solutions and service

to its customers. HSB invests in the latest technology to meet the needs and challenges facing its

policyholders and those of its client companies. The company a pplies our experience to evaluate

a client's unique loss potential and may recommend cost effective, professional and measurable

methods to manage risks.

TYPES OF OPERATIONS

HSB seeks an exemption to use UAS to conduct R&D into new and innovative ways to

efficiently serve its policyholders and client companies, both dur ing and after natural disasters

and casualty events. In addition, HSB will use UAS to support its extensive system of risk

assessment, risk management, and loss control. These programs are an in tegral part of HSB’s

philosophy of using engineering expertise to prev ent losses before they happen. The UAS will

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

personal inspection or insp ection by manned aircraft.

HSB also seeks exemption to perform underwriting evaluations and claims investigations

for its commercial and residential policyholders, in support of our client companies and also in

support of our parent company, Munich Re. In pa rticular, inspections and evaluations of the

roofs of large commercial structures, or where the roof has an especia lly steep pitch, provide

unique challenges. UAS will allow HSB to safely obtain imagery to identify damage and wear

caused by meteorological events such as wind an d hail. The imagery also will be used to

identify the condition of equipment on roofs su ch as air conditioning units, other mechanical

equipment, ducting, etc.3 

### As set forth in the Manu facturer’s User Manual, 2 

### these flights will be conducted under a

strict set of guidelines. The UAS will be flown only over the insu red's property or over property

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

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

CONTACT INFORMATION

The contact information for Petitioner is as follows:

Jay Jablonski

Vice President Hartford Steam Boiler Inspection and Insurance Company

One State Street Hartford, CT 06103

Tel: (800) 472-1866 Fax: (800) 722-5530 Email: Jay_Jablonski@hsb.com

PROPOSED UNMANNED AIRCRAFT SYSTEMS

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Inspire 1

HSB seeks an exemption to operate DJI syst ems for compensation or hire within the

National Airspace System. The DJI Phantom 2 Vi sion+ and DJI Inspire 1 are vertical takeoff

and landing (“VTOL”) Unmanned Aircraft (“UA”) with a Gr ound Control Station (“GCS”)

utilizing electronic tablet or smart phone syst ems. The DJI Phantom 2 Vision+ has a maximum

gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of

16 inches, height of 8 inches, and a maximum sp eed of approximately 29 knots. The DJI Inspire

1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7

inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI

Phantom 2 Vision+ and DJI Inspire 1UAs are equipped with four main ro tors; driven by Lithium

Polymer battery powered electric motors.

2 HSB will operate the DJI Phantom 2 Vision+ and the DJI Inspire 1 in accordance with the corresponding Manufacturer’s User Manual. HSB has not altered these user manuals in any way, and understands that the FAA

has access to these materials. As such , HSB has not included them in the pe tition. HSB can provide these manuals at the FAA’s request.4 

### The DJI Phantom 2 Vision+ and DJI Inspire 1 UAS that will be operated by HSB will be

registered in accordance with 49 U.S.C. § 44103, Registration of Aircraft , as well as 14 C.F.R

Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification

and Registration Marking

.

OPERATING PARAMETERS

In seeking this exemption, HSB proposes to commercially operate the DJI Phantom 2

Vision+ and DJI Inspire 1 for the special purpos es of conducting R&D, aerial risk assessment,

risk management, loss control, underwriting evalua tions and claims inves tigations over certain

areas of United States, pursuant to the following specific operating limitations:

1. The UAS will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Phantom 2 Vision+ and DJI Inspire 1 Unmanned Aircraft Systems.

2. The UAS will be used for the purposes of R&D, aerial risk assessment, risk management, loss control, underwriting ev aluations and claims investigations.

3. The UAS will be limited to an indicated airspeed not to exceed 87 knots.

4. Flights will be operated at an altitude of no more than 500 feet above ground level (“AGL”), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC.

5. Flights will be operated within visual line of sight (“VLOS ”) of the pilot-in-command (“PIC”) at all times.

6. Flight operations will utili ze a visual observer (“VO”). Th e VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC will be in constant voice contact during flight operations.

7. The operating documents and the grant of exemption will be accessible during UAS operations and made available to the Administrator upon request.

8. Prior to each flight the PIC will inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. All

maintenance and alterations will be documented in the aircraft records.5 

### 9. The UAS will operate in accordan ce with the UAS manufacturer’s aircraft/component, maintenance, overhaul , replacement, inspection, and life limit requirements.

10. The PIC will possess at least an airline transport, commercial, private, recreational, or sport pilot certificate.

11. UAS operations will not be conducted during ni ght, as defined in 14 C.F.R. § 1.1. All operations will be conducted under visual meteorological conditions (“VMC”). If flight at night is required, a special reque st will first be made at the FAA office closest to the proposed area of operations.

12. The UAS will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautic al chart unless a letter of agreement with that airport’s management is obt ained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management will be made available to the Administrator

upon request.

13. The UAS will 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.

14. If the UAS loses communications or loses it s GPS signal, it will have the capability to safely abort flight or return to a pre-determined location.

15. The PIC will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

16. All operations will be conducted over privat e or controlled-access property with permission from the land owner/controller or authorized represen tative. Permission from the land owner/controller or authorized representative will be obtained for each flight to be conducted.

17. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as define d by the applicable COA will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours.

SUMMARY FOR FEDERAL REGISTER

Petitioner : The Hartford Steam Boiler Inspection and Insurance Company

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

Description of Relief Sought : Petitioner seeks exemption from the requirements of 14 C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a) & (b), 61.315(a), 91.7(a), 91.119(c) 91.121,6 

### 91.151(a)(1) & (b), 91.405(a), 91.40 7(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b) to operate small unmanned aircraft systems to perform underwriting evaluations, claims investigations, and risk assessment, and conduc t R&D relating to insurance functions, under

conditions that meet or exceed those that the FAA requires for similar operations.

CONCLUSION

As set forth herein, HSB seeks an exempti on pursuant to 14 C.F.R. § 11.61 and Section

333 of the FMRA, which will permit safe opera tion of the DJI Phantom 2 Vision+ and DJI

Inspire 1 UAS commercially, without an airwor thiness certificate, for the limited purpose of

conducting aerial risk assessment, risk management , loss control, and R&D over certain areas of

the United States. By granting this Petiti on, the FAA Administrator will be fulfilling the

Congressional mandate of the FMRA, while al so advancing the inte rests of the public, by

allowing HSB to safely, efficiently, and economi cally operate the DJI Phantom 2 Vision+ and

DJI Inspire 1 UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Sec tion 333, HSB respectfully requests that the

Administrator grant this Petition for an ex emption from the requirements of 14 C.F.R §§

61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a) & (b), 61.315(a), 91.7(a), 91.119(c) 91.121,

91.151(a)(1) & (b), 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) and any

other regulations as the FAA deems appropriate, 3 

### and permit HSB to operate the DJI Phantom 2

Vision+ and DJI Inspire 1 UAS co mmercially for the purpose of conducting R&D, aerial risk

assessment, risk management, and loss contro l over certain areas of the United States.

3 In keeping with the summary grant process, HSB has not included a separate, detailed analysis of how an equivalent level of safety will be ac hieved for each regulation from which ex emption is requested. Because HSB’s petition is similar in all material respects to past Section 333 petitions the FAA has granted, HSB’s operations will achieve the same requisite level of safety found in those cases. HSB can provide a more detailed analysis should the FAA determine it is necessary to evaluate this petition.7 

### Please do not hesitate to contact Petitioner or Petitioner’s outside counsel—Laura A.

Foggan at 202-719-3382 or lfoggan@wileyrein.com and Sara M. Luxenberg at 202-719-3755 or

sluxenberg@wileyrein.com—with any questions about this filing.

Dated: May 13, 2015

Respectfully submitted,

Jay J. Jablonski

_________________________ Hartford Steam Boiler IIC

One State Street Hartford, CT 06103 Tel: (800) 472-1866

Appendices:

A – DJI Phantom 2 Vision+ Specifications Data Sheet B – DJI Inspire 1 Specifications Data Sheet C – Monthly Maintenance Log

### APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

HSB only utilizes safe and reliable UAS. DJI is an i ndustry leader in small UAS production. DJI UAS are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to lim it flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and setdistance. In addition, DJI software provides realtime altitude and location information to the PIC vi a the linked monitor (smart phone/tablet devices).

1.1 DJI Phantom 2 Vision+

1.1.1 Aircraft 1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity - 200 0 /s 1.1.1.5 Max Tilt Angel - 35 0 1.1.1.6 Max Ascent Speed – 6m/s 1.1.1.7 Max Descent Speed – 2m/s 1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal 1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy - ±0.03 0 1.1.2.3 Controllable Range – Pitch: -90 0 - 0 0 1.1.2.4 Maximum Angular Speed – Pitch: 90 0 /s

1.1.3 Camera 1.1.3.1 Operating Temperature Range - 32 0 F - 104 0 F (0 0 C - 40 0 C)

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288 4.1.3.5 HD Video Recording – 1080p30 & 720p 4.1.3.6 Recording Field of View - 110 0 /85 0

1.1.4 Transmitter 1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz 1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm 1.1.4.4 Transmitter Power – FCC Compliance: 100mW 1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender 1.1.5.1 Operating Frequency – 2412-2462MHz 1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm 1.1.5.4 Power Consumption – 2W

### APPENDIX – B

DJI INSPIRE 1 TECHNI CAL SPECIFICATIONS

HSB only utilizes safe and reliable UAS. DJI is an i ndustry leader in small UAS production. DJI UAS are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to lim it flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and setdistance. In addition, DJI software provides realtime altitude and location information to the PIC vi a the linked monitor (smart phone/tablet devices).

2.2 DJI Inspire 1

2.2.1 Aircraft

2.2.1.1 Model

– T600

2.2.1.2 Weight (Battery Included)

– 6lbs 7.5291oz (2935g)

2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m

2.2.1.4 Max Angular Velocity

– Pitch: 300 0 /s; Yaw: 150 0 /s

2.2.1.5 Max Tilt Angle ‐ 35 0

2.2.1.6 Max Asc e nt Speed

– 5m/s

2.2.1.7 Max Descent Speed

– 4m/s

2.2.1.8 Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED)

2.2.1.9 Max Flight Altitude

– 4500m

2.2.1.10 Max Wind Resistance

– 10m/s

2.2.1.11 Max Flight Time

– Approximately 18 minutes

2.2.1.12 Motor Model

– DJI 3510

2.2.1.13 Propeller Mo del

– DJI 1345

2.2.1.14 Operating Temperature Range

– 14 0 F to 104 0 F (

‐ 10 0 C to 40 0 C)

2.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”

2.2.2 Gimbal

2.2.2.1 Model

– ZENMUSE X3

2.2.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W

2.2.2.3 Opera t ing Current

– Static: 750mA; In Motion: 900mA

2.2.2.4 Angular Vibration Range ‐ ±0.03 0

2.2.2.5 Mounting

– Detachable

2.2.2.6 Controllable Range

– Pitch: ‐ 90 0 to +30 0 ; Pan: ±320 0

2.2.2.7 Mechanical Range

– Pitch: ‐ 125 0 to 45 0 ; Pan: ±330 0

2.2.2.8 Max Controllable Speed

– Pitch: 120 0 /s; Pan: 180 0 /s

2.2.3 Camera

2.2.3.1 Na me

– X3

2.2.3.2 Mo del

– FC350

2.2.3.3 Total Pixels

– 12.76M

2.2.3.4 Effective Pixels

– 12.4M

2.2.3.5 Image Max Size

– 4000x3000

2.2.3.6 ISO Range

– 100

‐ 3200

2.2.3.7 Field of View ‐ 94 0

2.2.3.8 CMOS

– Sony EXMOR 1/2.3”2.2.3.9 HD Video Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60

2.2.3.10 Operating Temperature Range ‐ 32 0 F ‐ 104 0 F (0 0 C ‐ 40 0 C)

2.2.4 Transmitter

2.2.4.1 Name

– C1

2.2.4.2 Operating Frequency

– 5.728

‐ 5.850GHz; 2.400

‐ 2.483GHz

2.2.4.3 Communicating Distance (unobstructed)

– 2000m

2.2.4.4 Output Power

– 9W

2.2.4.5 Opera t ing Temperature Range ‐ 14 0 F to 104 0 F (

‐ 10 0 C to 40 0 C)

2.2.4.6 Battery

– 600mAh LiPo 2S