State Farm 

Corporate Headquarters 

1 State Farm Plaza 

Bloomington, IL 61710-0001 

June 29, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

A State Farm® 

Re: Petition to Amend Exemption 11188; Docket No. FAA-2014-0856 

Dear Sir or Madam: 

State Farm Mutual Automobile Insurance Company ("State Farm") hereby petitions for an 

amendment to Exemption No. 11188 which the FAA issued to State Farm on February 25, 2015 

to permit unmanned aircraft system ("UAS") operations for outdoor research and development 

("R&D") related to use of UAS for insurance functions including using imagery and analytics in 

underwriting, re-underwriting, catastrophe response, roof inspection, and claim resolutions 

settings. Given the recent standardization of the FAA's grant process, State Farm respectfully 

requests that the FAA amend Exemption No. 11188 to make its operating parameters consistent 

with those imposed on entities receiving grants today. 

On October 15, 2014, State Farm submitted two petitions for exemption from several of the 

Federal Aviation Regulations pursuant to Part 11 of the FAA's rules and the FAA's authority 

under Section 333 of the FAA Modernization and Reform Act. The petition in Docket No. FAA2014-0856 sought authority to use UAS to conduct R&D both at State Farm's test sites and in 

real world catastrophe settings, and the petition in Docket No. F AA-2014-0846 requested 

permission for commercial use UAS to conduct roof inspections. The FAA granted these 

petitions on February 25, 2015, and February 13, 2015, respectively. 

State Farm prides itself on its commitment to innovation. This commitment led State Farm to be 

one of the early adopters of UAS technology. In fact, State Farm was the first insurer and only 

the thirtieth entity to receive a Section 333 exemption, a number that has grown to 605 as of midJune. As the process has evolved, however, the FAA has developed a streamlined set of 

operating conditions. This has led to an inconsistency between the conditions imposed on State 

Farm and similarly situated entities that applied later in time, including insurers proposing 

identical operations. 1 For instance, State Farm may not operate at speeds above 50 knots, within 

3 miles of a city, or over any densely populated or congested areas, whereas petitioners receiving 

grants today are subject to no such restrictions. State Farm's pilots must hold either a minimum 

of a private pilot certificate and a minimum of a third class airman medical certificate, whereas 

other operators receiving grants today can hold one of a wider range of pilot certification and no 

1 See, e. g. , Exemption Nos. 11367 to ADM Crop Risk Services, 11293 to Erie Insurance Group, 

11273 to AIG, and 11309 and 11274 to USAA. 

Providing Insurance and Financial Services Home Office, Bloomington, IL 
airman medical certification. State Farm's pilots are also subject to more extensive training 

requirements than their later-in-time counterparts. 

State Farm commends the FAA for streamlining its process and establishing conditions that 

properly balance safety with operator flexibility, and respectfully requests that these standardized 

conditions be applied to State Farm's exemptions. Specifically, State Farm requests that the 

FAA make the following revisions to Exemption 11188: 

1. Amend this exemption to permit State Farm to operate the following multirotor and fixed 

wingUAS: 

a. Aerialtronics Altura Zenith A TX8 

b. Altavian Nova F6500 

c. C-Astral Atlas UAS 

d. Delta Drone Delta Y 

e. DJI Phantom 3 

f. MicroDrone md4-200 

g. MicroDrone md4-1000 

h. PrecisionHawk Lancaster 

1. UASUSA Tempest 

J. 3DR Solo 

k. or a substantially similar multirotor or fixed-wing UAS. State 

Farm will notify the FAA in writing as additional multirotor or 

fixed-wing UAS types are incorporated into State Farm operations 

relating to this exemption. 

2. The amended exemption should note that State Farm's UAS operations will be for aerial 

data collection. State Farm's operations may include commercial UAS operations for 

insurance functions including using imagery and analytics in underwriting, reunderwriting, catastrophe response, property inspection, claim resolutions settings and 

other research and development.2 

3. Delete condition #2. 

2 Exemption 11188 specified "roof inspection" instead of the now requested "property 

inspection." 

2 
4. Replace condition #3 with the following: "The UA may not be operated at a speed 

exceeding 87 knots ( 100 miles per hour). The exemption holder may use either 

groundspeed or calibrated airspeed to determine compliance with the 87 knot speed 

restriction. In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer." 

5. Amend condition #5 by striking the final period and adding: "or U.S. driver's license." 

6. Delete condition #7. 

7. Amend condition #9 by striking the following: "The Ground Control Station must be 

included in the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. " 

8. Amend condition #10 by replacing the second and third sentences with the following: 

"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 and property." 

9. Delete condition #13. 

10. Delete condition #15. 

11. Amend condition #16 by replacing the first sentence with the following: "Under this 

grant of 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, a territory, a possession, or the Federal government." 

12. Replace condition #17 with the following: "PIC qualification flight hours and currency 

must be logged in a manner consistent with 14 CFR § 61.51 (b ). Flights for the purposes 

of training the operator's PI Cs 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 UA with appropriate distance from nonparticipants in accordance with 

14 CFR § 91.119." 

13. Replace condition #18 with the following: "The operator may 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." 

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14. Replace condition #20 with the following : "The UA 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 

available to the Administrator or any law enforcement official upon request." 

15. Replace condition #24 with the following: "The PIC is prohibited from beginning a flight 

unless (considering wind and forecast weather conditions) there is enough available 

power for the UA to conduct the intended operation and to operate after that with the 

reserve power recommended by the manufacturer." 

16. Replace condition #25 with the following: "Air Traffic Organization (A TO) Certificate of 

Waiver or Authorization (COA). All operations shall be conducted in accordance with an 

A TO-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 any of the 

exemption holder's existing COAs." 

17. Delete condition #26. 

18. Delete condition #28. 

19. Delete condition #32. 

20. Replace condition #33 with "Flight operations must be conducted as far as practicable 

from all nonparticipating persons, vessels, vehicles and structures. The PIC, VO, 

operator trainees, other mission support personnel, or other essential persons so deemed 

by the PIC are not considered nonparticipating persons under this exemption. The 

operator will configure a geo-fence to contain the UAS to the area of operations. The 

PIC and VO will exercise good judgment in determining when a flight needs to be halted 

or aborted due to risks to nonparticipating persons, vessels, vehicles and structures in the 

area." The previous requirement in #33, mandating that flight operations must be 

conducted at least 500 feet from all nonparticipating persons, would be unduly restrictive 

in the context of conducting R&D for insurance functions. For example, a UAS 

operating over a property to inspect its roof at a low altitude would have to suspend its 

flight each time a neighbor from down the street unexpectedly walked outside. This 

restriction should be altered to permit safe, efficient use of UAS for R&D for insurance 

functions. 

21. Delete condition #34. This exemption was granted to State Farm to use UAS for aerial 

imaging for underwriting, re-underwriting, catastrophe response, property inspection, 

claim resolutions settings and other research and development (R&D). In such situations, 

this condition is not feasible. Further, operators of satellites and manned aircraft are not 

required to obtain permission from a property owner/controller or authorized 

representative prior to the beginning of each flight. Eliminating this condition would 

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benefit the public by permitting State Farm to conduct research on using UAS for 

insurance purposes in situations including catastrophe response and result in faster, more 

effective service to its customers. The public safety will not be harmed by eliminating 

this condition. 

Alternatively, State Farm requests that the FAA replace Exemption No. 11188's operating 

conditions in their entirety with the standard conditions currently being granted to operators 

engaged in aerial imaging. 

3 

As amended, State Farm's exemption will permit the same operations, under the same 

conditions, as those established by grants of exemption that the FAA has recently found to be in 

the public interest. 4 This petition for amendment alters the requested relief contained in State 

Farm's original petition only insofar as the FAA finds it is necessary to grant additional relief to 

enable the amendments. These revised parameters will allow State Farm to broaden and improve 

its UAS operations-under the same conditions imposed on all entities receiving Section 333 

exemptions under the current regime- while ensuring the safety of its operations. 

Please contact the w1dersigned with any questions. 

Sincerely, 

~\& Todd Binion, CPCU®, CLU® 

Innovation Manager 

State Farm Mutual Automobile Insurance Company 

3 

4 

See, e.g. , Exemption Nos. 11856 to Mark Ingle, 11846 to Holder Construction Group. 

See, e.g. Exemption No. 11293 to Erie Insurance Group at 2. 

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