Carol R. Gosain 

202 429 6461 

cgosain@steptoe.com 

1330 Connecticut Avenue, NW 

Washington, DC 20036-1795 

202 429 3000 main 

www.steptoe.com

Patrick C. Gee 

Sr. Vice President Personal Insurance Claim 

The Travelers Companies, Inc. 

One Tower Square, 4MS 

Hartford, CT 06183 

860-277-7660 TEL 

866-697-5592 FAX

July 23, 2015 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Room W12-140 

Washington, D.C. 20590 

Re: The Travelers Companies, Inc. Request to Amend 

 Exemption No. 11490, Docket No. FAA-2015-0307 

 Exemption No. 11494, Docket No. FAA-2015-0304

Dear Sir or Madam: 

On May 5, 2015, the Federal Aviation Administration (“FAA”) granted to The Travelers 

Companies, Inc. (“Travelers”) Exemption Nos. 11490 and 11494 (the “Exemptions”) in Docket 

Nos. FAA-2015-0307 and FAA-2015-0304 (the “Exemptions Dockets”), respectively. The 

Exemptions allow Travelers to operate certain small unmanned aircraft systems (“UAS”) to 

perform aerial data collection. Travelers hereby respectfully requests an amendment to each of 

the Exemptions to allow Travelers to operate additional types of small UAS under the same 

conditions and limitations set forth in the Exemptions. 

Travelers wishes to amend the Exemptions to allow Travelers to operate the DJI Phantom 

3 Professional and DJI Phantom 3 Advanced (together, “DJI Phantom 3”), as well as any other 

types of ”micro” unmanned aircraft, as that term is defined in the Small UAS Proposed Rule, i.e., 

UAS that weigh no more than 4.4 pounds.1

 The DJI Phantom 3 weighs about 2.8 pounds. Its 

 1

 Travelers is already authorized by the Exemptions to operate two types of small UAS – 

i.e., the DJI Phantom 2 and 3D Robotics IRIS+ aircraft – and it has a pending request in the 

Exemptions Dockets for authority to operate the 3D Robotics Solo aircraft, also a small UAS. 

The size, weight and performance specifications of the DJI Phantom 3 are substantially similar to 

those of the DJI Phantom 2. Each of the DJI Phantom 2, 3D Robotics IRIS+, 3D Robotics Solo 

and DJI Phantom 3 weighs less than 4.4 pounds and thus would be considered “micro” under 

FAA’s proposed micro classification in the Small UAS Proposed Rule. See Operation and 

Certification of Small Unmanned Aircraft Systems, 80 Fed. Reg. 9544 (Feb. 23, 2015). Travelers 

requests herein not only authority to operate the DJI Phantom 3, but also authority to operate any 

other types of small UAS that would be classified as micro under the proposed rule. 
diagonal size (including propellers) is about 23 inches. Its maximum speed is 38 miles per hour, 

well within the prescribed limitation of 100 miles per hour. Its maximum range is roughly 1.2 

miles, and its maximum flight time is about 23 minutes. Like the UAS that Travelers is already 

permitted to operate, the DJI Phantom 3 has geo-fencing and flight programming capabilities and 

a flight termination system. If the UAS loses communications or its GPS signal, it will return to 

a pre-determined location within the planned operating area and land or be recovered in 

accordance with the Travelers’ Unmanned Aircraft System Operating Procedures, Safety Code 

and Training Syllabus (“Manual”). 

Travelers’ Manual is already on file with FAA; it was submitted confidentially with 

Travelers’ original petitions in the Exemptions Dockets. The manufacturer’s user manuals, 

quick start manuals and safety guidelines for the DJI Phantom 3 are available at: 

http://www.dji.com/product/phantom-3/download. Travelers will operate the DJI Phantom 3 and 

all other small UAS that it is authorized to operate in accordance with its Manual (as revised 

from time to time) and the manufacturers’ manuals. 

Travelers respectfully submits that good cause exists for not publishing a summary of this 

request in the Federal Register and for granting the requested amendments expeditiously. 

Travelers asks only to amend its existing Exemptions to add other types of micro UAS, i.e., the 

DJI Phantom 3 and other “micro” unmanned aircraft, as that term is defined in the Small UAS 

Proposed Rule. Its request would not set any precedent, and any delay in acting on the request 

would harm Travelers, which intends to conduct operations using new types of micro UAS as 

soon as possible after the requested amendments are approved. 

Please do not hesitate to contact Travelers’ outside counsel, Carol Gosain, with any 

questions about this filing. 

Sincerely, 

 

Pat Gee

Carol Gosain 

Steptoe & Johnson LLP 

1330 Connecticut Avenue, N.W. 

Washington, D.C. 20036 

(202) 429-6461 

cgosain@steptoe.com 

Patrick C. Gee 

Sr. Vice President Personal Insurance Claim 

The Travelers Companies, Inc. 

One Tower Square 

Hartford, CT 06183 

(860) 277-7660 

pgee@travelers.com