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 Administ ration (“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 Docket s”), 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 (toget her, “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 Exem ptions 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 a nd 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 woul d be classified as micro under th e proposed rule.diagonal size (including propeller s) is about 23 inches. Its maximum speed is 38 miles per hour, well within the prescribed limitation of 100 mile s per hour. Its maximum range is roughly 1.2 miles, and its maximum flight time is about 23 mi nutes. Like the UAS that Travelers is already permitted to operate, the DJI Phantom 3 has geo-fe ncing and flight programming capabilities and a flight termination system. If the UAS loses co mmunications or its GPS si gnal, 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 ope rate 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 gran ting the requested amendments expeditiously. Travelers asks only to amend its existing Exempti ons 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 pr ecedent, 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 cont act Travelers’ outside counsel, Carol Gosain, with any questions about this filing.

Sincerely,



## Pat Ge e

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