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 Federal 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 333 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 exemption 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 Clayco, 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 operations are in the public interest, as they will 

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

policyholders and employees and undertake research and development (“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 insurance industry, including Exemption Nos. 11367 to 

ADM Crop Risk Services, 11293 to Erie Insurance 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 insurance, 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 service force is one of the largest in the world, with over 800 

engineers, inspectors and technicians providing inspection services, loss reduction and 

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

provides fire safety, risk assessments 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 applies 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 during 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 integral part of HSB’s 

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

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

personal inspection or inspection 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 particular, inspections and evaluations of the 

roofs of large commercial structures, or where the roof has an especially 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 and hail. The imagery also will be used to 

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

equipment, ducting, etc. 
3

As set forth in the Manufacturer’s User Manual,2 these flights will be conducted under a 

strict set of guidelines. The UAS 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 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 systems for compensation or hire within the 

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

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

utilizing electronic tablet or smart phone systems. 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 speed 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 rotors; 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 petition. 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 purposes of conducting R&D, aerial risk assessment, 

risk management, loss control, underwriting evaluations and claims investigations 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 evaluations 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 utilize a visual observer (“VO”). The 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 accordance 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 night, 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 request 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 aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, 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 its 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 private or controlled-access property with 

permission from the land owner/controller or authorized representative. 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 defined 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), 91.407(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 conduct 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 exemption pursuant to 14 C.F.R. § 11.61 and Section 

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

Inspire 1 UAS commercially, without an airworthiness 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 Petition, the FAA Administrator will be fulfilling the 

Congressional mandate of the FMRA, while also advancing the interests of the public, by 

allowing HSB to safely, efficiently, and economically 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, Section 333, HSB respectfully requests that the 

Administrator grant this Petition for an 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, 

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 commercially for the purpose of conducting R&D, aerial risk 

assessment, risk management, and loss control 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 achieved for each regulation from which exemption 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 industry 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 limit flight to no higher than a predetermined and set 

altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides realtime altitude and location information to the PIC via 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 - 2000/s 

1.1.1.5 Max Tilt Angel - 350

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 - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s 

1.1.3 Camera 

1.1.3.1 Operating Temperature Range - 320F - 1040F (00C - 400C) 

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 - 1100/850

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 TECHNICAL SPECIFICATIONS 

HSB only utilizes safe and reliable UAS. DJI is an industry 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 limit flight to no higher than a predetermined and set 

altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides realtime altitude and location information to the PIC via 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: 3000/s; Yaw: 1500/s

2.2.1.5 Max Tilt Angle ‐ 350 

2.2.1.6 Max Ascent 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 Model – DJI 1345

2.2.1.14 Operating Temperature Range – 140F to 1040F (‐100C to 400C)

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 Operating Current – Static: 750mA; In Motion: 900mA

2.2.2.4 Angular Vibration Range ‐ ±0.030 

2.2.2.5 Mounting – Detachable

2.2.2.6 Controllable Range – Pitch: ‐900 to +300; Pan: ±3200 

2.2.2.7 Mechanical Range – Pitch: ‐1250 to 450; Pan: ±3300 

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s

2.2.3 Camera

2.2.3.1 Name – X3

2.2.3.2 Model – 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 ‐ 940 

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 ‐ 320F ‐ 1040F (00C ‐ 400C)

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 Operating Temperature Range ‐ 140F to 1040F (‐100C to 400C)

2.2.4.6 Battery – 600mAh LiPo 2S