State F arm Corporate Headquarte rs 1 State Farm Pl aza Bloomington, I L 61710-0001 June 29 , 2015 U. S. Department ofTransportation Docket Management System 1200 New Jersey Ave. , SE Washington, D.C
. 20590 

# A StateFarm®

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 ofUAS for insurance functions including using imagery and analytics in underwriting, re-underwriting , catastrophe response, roof inspection, and claim resolutions settings. Given the recent standardization ofthe 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 ofthe Federal Aviation Regulations pursuant to Part 11 of the FAA ' s rules and the FAA ' s authority under Section 333 ofthe FAA Modernization and Reform Act. The petition in Docket No
. FAA

2014-0856 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
. FAA

-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 itselfon its commitment to innovation. This commitment led State Farm to be one ofthe early adopters ofUAS 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 ofmidJune. 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 ofa private pilot certificate and a minimum of a third class airman medical certificate, whereas other operators receiving grants today can hold one ofa wider range ofpilot 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.

P

rov idi

ng Insur ance and Financia l Se rv ices Home Offi ce, Bloomingt on, ILairman 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 ATX8 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 ofthe now requested "property inspection. " 24
. 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 ofexemption, 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 oftraining the operator's PICs 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 ofthis 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 wi ll be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons , vessels, vehicles and structures."

314. 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 ofthe 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 (ATO) Certificate of Waiver or Authorization (COA)
. All operations shall be conducted in accordance with an ATO-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 ofthe 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 ofoperations. The PIC and VO will exercise goodjudgment 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 ofconducting 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 ofUAS 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 ofeach flight. Eliminating this condition would 4benefit the public by permitting State Farm to conduct research on using UAS for insurance purposes in situations including catastrophe response and resul t 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 ofexemption 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 reliefto 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. 5