7925 Jones Branch Drive, Suite 6200 9800 Fredericksburg Road

McLean, Virginia 22102 San Antonio, Texas 78288

Michael P. Huerta, Administrator

Office of the Administrator

Federal Aviation Administration 800 Independence Avenue SW October 2, 2014 Washington, D.C. 20591

Reference: USAA Petition for Section 333 Exemption: Re: Research & Development of Methods to Use Small Unmanned Aircraft Systems in P roperty and Casualty Insurance

Dear Administrator Huerta,

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (FMRA), United Services Automobile Association (USAA) is petitioni ng for an exemption from the Federal Aviation Regulations and other rules/statutes perta ining to unmanned aircraft systems. Section 333 of the FMRA addresses special rules for certain unmanned aircraft systems and grants the FAA authority to allow for the safe operation of ce rtain unmanned aircraft systems (UAS) within the national airspace.

Since 1922, United Services Automobile Association has served the military community and their families providing a full range of highly com petitive financial products and services to our membership. We have world class employees that are personally committed to delivering excellent service and guidance regarding insurance, banking and investments. USAA focuses its innovation on developing products and new techn ology to assist its membership from policy inception to fulfilling our service commitment duri ng a claims event. USAA has over ten million members that look to USAA to help them restore and rebuild after a wide range of natural and other disasters, and USAA is always seeking ways to improve the timing and quality of its responses to members’ needs. Property and casualty insurers play a major role in funding the restoration of businesses and communities after maj or incidents, and the integration of unmanned aircraft into USAA’s operations will have immediate, positive effects on the lives of Americans and the business community.

We have identified the unmanned aircraft system as a technology which can alleviate safety concerns associated with manned inspections in the air and on the ground, and provide enhanced service and experience to our membership i n a safe and efficient environment. At USAA’s Innovation Lab in San Antonio, Texas, since 2010, we have been thoroughly researching new small unmanned aircraft systems tec hnology to improve our existing processes, invent new ones to benefit our membershi p, and improve efficiency and safety. Over the last four years, we have conducted significant research and developed business plans for utilization of unmanned aircraft systems within our organization, including, but not limited to:

• Identifying operational areas where unmanned aircr aft systems will improve safety relative to manned operations;Federal Aviation Administration

October 2, 2014 Page 2 of 7

• Research regarding privacy best practices and exis ting laws;

• Research and development of small unmanned aircraf t systems in partnership with the manufacturers to develop excellent safety protocols and procedures; and

• Development of an internal research and developmen t team at USAA with a wide expertise in aeronautics, flight instruction, mecha nical and software engineering and business applications, along with external partners hips with public entities that further our knowledge in robotics, aerospace, and engineeri ng.

USAA shares Congress’s vision of integrating small unmanned aircraft systems for civil use into our national airspace and providing economic benefi ts and growth from this rapidly developing technology. Current law does not provide adequate a uthority to extend these research and development activities, and this application seeks interim authority from the FAA to allow USAA to continue the activities it began in 2010.

USAA has also partnered with other public entities, such as the FAA UAS Test Sites and selected universities, to further our research and development as well as seeking to obtain a Special Airworthiness Certification in the Experime ntal Category with the collaboration of the Test Sites and our UAS manufacturer. Obtaining a Se ction 333 exemption would allow USAA the authority to do further research and developmen t in a safe and efficient manner without burdening the FAA with additional requests for each of our UAS platforms and operations. Currently, the FAA does not allow civil operations (meaning operations other than public aircraft operations or model aircraft / “hobbyist” activitie s which include research and development); therefore USAA has not been able to fully develop i ts UAS flight research.

Through this petition, USAA seeks an exemption to o perate small unmanned aircraft systems to further develop its research and development of thi s emerging technology.

USAA’s small unmanned aircraft systems are aircraft weighing significantly less than 55 lbs (details are provided within). They operate at slow speeds (under 45kts) and within line of sight within the areas described in this petition. Such o perations will ensure that the small unmanned aircraft systems operated by USAA will not create a hazard to other aircraft operating in the national airspace, to the general public or pose a threat to national security as dictated by the Federal Aviation Regulations.

One of USAA’s business partners and UAS platforms i s PrecisionHawk, and its Lancaster HawkEye. PrecisionHawk is a leader in the small UAS community and through their impressive research and development have successfully obtained several FAA Certificates of Authorization for their platform through various FAA UAS test sit es and public entities. This demonstrates the confidence in operation and safety that the FAA alr eady has for this UAS manufacturer and its platform. PrecisionHawk continues its advancement i n safety and UAS integration into the national airspace by researching and developing sen se and avoid technology to benefit the UAS community, the FAA and other users of the national airspace.Federal Aviation Administration

October 2, 2014 Page 3 of 7

14 CFR 11.81 (a) – Name and address of the Petition er :

United Services Automobile Association 9800 Fredericksburg Road San Antonio, Texas 78288

Phone: 703.905.2808 E-mail: gcirillo@wileyrein.com

14 CFR 11.81 (b) – Exemptions Requested:

The FAA considers unmanned aircraft as “aircraft” f lown by a “pilot” regardless of the location of the pilot. All aircraft and pilots must comply with applicable sections of Title 14 of the Code of Federal Regulations (14 CFR) to operate within the National Airspace. Unmanned aircraft are unable to comply with certain sections of 14 CFR as the regulations were written prior to the consideration of small UAS operating within the nat ional airspace. Therefore USAA is requesting an exemption from certain parts of 14 CF R cited below in addition to such further exemptions and relief as the FAA may determine is n ecessary to permit the operations

described herein

.

14 CFR Part 21.191 (a) – Experimental Certificates 14 CFR Part 45.23 (b) – Display of marks; general 14 CFR Part 61.113 (a) and (b) – Private pilot priv ileges and limitations: Pilot in command

14 CFR Part 91.7 – Civil Aircraft Airworthiness 14 CFR Part 91.9 (b) – Civil aircraft flight manual , marking and placard requirements 14 CFR Part 91.109 – Flight Instruction

14 CFR Part 91.119 – Minimum safe altitudes 14 CFR Part 91.121 – Altimeter settings 14 CFR Part 91.151 – Fuel requirements for flight i n VFR conditions 14 CFR Part 91.203 (a) and (b) – Civil Aircraft; Ce rtifications Required 14 CFR Part 91.405 – Maintenance required 14 CFR Part 91.407 – Operation after maintenance, p reventive maintenance, rebuilding or

alteration 14 CFR Part 91.409 – Inspections

14 CFR Part 91.417 – Maintenance Records

14 CFR Part 11.81 (c) – The extent of relief USAA s eeks, and the reason USAA seeks the

relief:

USAA seeks relief pursuant to this exemption from a pplicable parts of the Federal Aviation Regulations to the extent necessary to permit civil flight operations within the national airspace

and USAA seeks authorization to conduct small UAS f light operations within the perimeters of this exemption request.Federal Aviation Administration

October 2, 2014 Page 4 of 7

14 CFR Part 11.81 (d) – The reasons why granting US AA’s request would be in the public interest; that is, how it would benefit the public as a whole:

Granting the exemption for USAA would allow the org anization to safely and efficiently conduct small UAS flight operations to gain valuable inform ation and experience with USAA’s research and development in this technology. Gaining this in formation and experience would enable USAA, in the future, to utilize UAS technology to c onduct safe and efficient operations both

before and after claim events to assist its members hip in preparing for natural disasters and post-disaster recovery and relief operations, and r educe the time it takes communities to rebuild after natural disasters. Without this exemption, US AA would be unable to conduct the proper research and development to build a successful smal l UAS operation which would assist its

over ten million members and their communities. US AA believes such UAS research can lead to safer, quicker, and more economical and effectiv e claims service for its policy holders and

their communities.

14 CFR Part 11.81 (e) – The reasons why granting th e exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which USAA seeks the exem ption:

USAA requests that the exemption be granted with th e following limitations and operational conditions. These limitations and conditions will p rovide an enhanced level of safety and will be the guiding principles when USAA is conducting R&D operations under this exemption:

A. The small unmanned aircraft systems maximum take -off weight will be less than 55 lbs. Detailed specifications are included in the attachm ents. USAA is willing to have its

authorization restricted below the 55 lb. threshold to the operating weight of the

unmanned aircraft identified. One of the fixed win ged UAS platforms that USAA is seeking to utilize through this exemption is curren tly operating safely within the national airspace pursuant to several Certificates of Author ization (COA) granted by the FAA to Texas A&M College Station and other public entities . One of the COAs was for the PrecisionHawk Lancaster HawkEye to provide aerial i magery and mapping for authorities at the recent Washington state mudslide s in Oso, WA. Other COAs have been approved for this particular platform through other public entities demonstrating the

confidence that the FAA has for this manufacturer’s operational and safety protocol. USAA has attached and will be operating in accordan ce with PrecisionHawk Lancaster’s Flight Manual, Maintenance Schedule, and training d ocuments for review within this exemption application. Although this platform is on e that USAA is utilizing within its current research and development, USAA asks that th e exemption be granted with respect to this aircraft and other aircraft of like size, weight and capabilities; however, we want to demonstrate our commitment to safety and th e continuance of strong UAS partnerships.

B. All pilot in command (PIC) and ground observers (also known as the air crew) will receive FAA certified private pilot ground school a nd have taken and passed the FAA

Private Pilot Written Exam. This ensures that all a ir crew members (PIC and groundFederal Aviation Administration

October 2, 2014 Page 5 of 7

observers) have the knowledge regarding the Federal Aviation Regulations, Airspace, and other pertinent knowledge to conduct safe opera tions of small unmanned aircraft systems. A USAA employee with a FAA commercial pilo t certificate and flight instructor certificate that has been trained on UAS operations will oversee all training and ensure all air crew receive proper training and abide by a ll pertinent regulations. All pilot in command and ground observers will be trained in det ail to each of the unmanned aircraft system platform’s operations, systems and emergency procedures. Every air crew

member will obtain an FAA Class 2 medical certifica te.

C. All flight operations will be operated at an alt itude of no more than 400 ft above the ground (AGL) and within Class G (uncontrolled airsp ace) and some Class E (with prior approval). No flight operations will be operated wi thin Class A, B, C, or D airspace or special use airspace. All flight operations are to be conducted during daylight hours, under 30 mph winds and within line of sight. Areas of operation will be on USAA’s secured campus in San Antonio, Texas and other desi gnated remote, unpopulated areas around the San Antonio, Texas area within Cla ss G airspace. These areas are located a sufficient distance from any airport, hel iport, military base/airspace or other location with aviation activity. All flights will b e communicated to FAA Flight Service with posted NOTAMS prior to the flight(s).

D. All flight operations will be conducted within l ine of sight of the pilot in command and ground observer(s). Maximum total flight time for e ach flight will be 90 minutes or less in duration. All flight operations will be terminated when the aircraft has less than 20% battery life remaining.

E. Flight operations and safety briefings will be c onducted prior to all planned small unmanned aircraft system flights and will be mandat ory for all air crew. Briefings will include weather reviews, take off, landing and airc raft performance data for those real time conditions, and full pre- and post-flight insp ections/checklists and briefings for each specific unmanned aircraft system being operated.

F. In the event of a communication lost link, the U AS will return to a specific predetermined location and once the UAS is safely recovered, all flight operations will cease until any communication/data link issues are properly resolve d.

G. Regarding privacy concerns, USAA will have land use agreements in place for all areas of operations. The land utilized is USAA-owned or p rivately owned remote/unpopulated land with owner agreements in place for UAS operati ons.Federal Aviation Administration

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14 CFR Part 11.81 (f) A summary the FAA can publish in the Federal Register, stating:

(1) The rule from which you seek the exemption

Petitioner: United Services Automobile Association Sections of 14 CFR that USAA seeks an exemption:

14 CFR Part 21.191 (a) 14 CFR Part 45.23 (b) 14 CFR Part 61.113 (a) and (b)

14 CFR Part 91.7 14 CFR Part 91.9 (b)

14 CFR Part 91.109

14 CFR Part 91.119

14 CFR Part 91.121

14 CFR Part 91.151 14 CFR Part 91.203 (a) and (b)

14 CFR Part 91.405

14 CFR Part 91.407

14 CFR Part 91.409

14 CFR Part 91.417

(2) A brief description of the nature of the exemption you seek:

USAA seeks relief from the applicable parts of 14 C FR 21, 45, 61 and 91 as requested within this petition to allow USAA to safely and efficient ly conduct commercial UAS flight operations on its secure campus and other remote private land wit hin Class G and Class E (with prior approval) airspaces for R&D purposes.

14 CFR Part 11.81 (g) – Any additional information, views or arguments available to support USAA’s request:

Allowing USAA this exemption would give USAA the ab ility to continue our UAS research and development beyond the limits imposed today. Additi onal testing would benefit not only USAA and its membership, but would serve as a partnershi p with the FAA and others within the UAS community to advance this new and emerging technolo gy in a safe and controlled environment.

Recently, USAA employees in partnership with Texas A&M Roboticists Without Borders were invited to the Oso, Washington mudslide area to ass ist Snohomomish County and other public entities with aerial surveys and mapping. Under the approval of an FAA COA (Certificate of Authorization), USAA and Roboticists Without Border s were able to fly their platforms successfully and provided valuable data to governme nt entities. This demonstrates the value of our request to continue our UAS research and develo pment to help communities rebuild after disasters and maintain the safety of our employees, business partners and the general public.Federal Aviation Administration

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14 CFR Part 11.81 (h) – Request to exercise the pri vileges of the exemption outside the United States, the reason why the petitioner needs to do so:

USAA does not seek to exercise the privileges of th is exemption, should it be granted, outside the United States. Our request is strictly to be gr anted authority for civil UAS R&D operations at specified locations within the national airspace sy stem.

Sincerely,

Greg Cirillo Wiley Rein LLP

Counsel for USAA 

# Michael Burns

Michael Burns

Assistant Vice President

USAA

Attachments: PrecisionHawk Flight Manual, Maintenan ce Schedule and training documents.