'VT A Vl\.. T£" Insurance W .rt..J.. l. ~ Group 

Wayne • Washington • Marion 

July 28, 2015 

U.S. Department ofTransportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

3873 Cleveland Road, Wooster, Ohio 44691 

330-345-8100 X 322 . F: 888-345-8775 

David_ Tschantz@wayneinsgroup.com 

Re: Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the 

Federal Aviation Regulations to Use Small Unmanned Aircraft System in the 

Property and Casualty Insurance Industry. 

Dear Sir or Madam: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 

CFR Part 11, Wayne Mutual Insurance Company hereby petitions for an exemption from the listed 

Federal Aviation Regulations ("FARs") and any other rules necessary to allow operation of small 

Unmanned Aircraft Systems ("sUAS") under the conditions set forth in this petition. FMRA Section 333 

grants the FAA authority to allow operation of certain UAS within the national airspace. Wayne Mutual 

Insurance Company requests authorization to conduct sUAS operations related to its insurance business, 

including roof inspections, underwriting risk assessment, less inspection and evaluation, and risk 

control. As detailed below, the operations under the requested exemptions will be conducted with strict 

requirements and conditions to ensure safety for all involved. 

1. Description of Petitioner 

Founded in 1910, Wayne Mutual Insurance Company has provided premier property and 

casualty insurance to Ohio residents for more then a century. Wayne Mutual Insurance Company 

has earned a reputation for supplying superior coverage to home, farm, automobile and business 

owners in Ohio's communities. Wayne Mutual is headquartered in Wooster, Ohio, and has a 

network of more than 130 independent agency partners throughout the state. In 2009 it affiliated 

with Washington Mutual Insurance Association. This affiliation formed the Wayne Insurance 

Group. In 2012, Marion Mutual Insurance Association also joined this alliance. Wayne Mutual 

Insurance Company has continuously persevered with developing technologies in the insurance 

marketplace in order to keep pace with the ever-changing needs of our customers. The use of 

sUAS will allow Wayne Mutual Insurance Company to continue to provide excellent service to 
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our customers, while eliminating risk of injury to our claim professionals and incurring liability 

to others, all without posing a safety or privacy threat to the general public. 

This petition is being filed on behalf of Wayne Mutual Insurance Company and all of its 

subsidiaries, affiliates, successors and assigns. 

The contact information for Wayne Mutual Insurance Company is: 

David Tschantz, Esq. 

Vice President of Claims 

3873 Cleveland Rd. 

Wooster, OH 44691 

2. Types of Operation 

A. Request to Use sUAS for Survey and Inspection of Damage and Loss after Casualty 

Events. 

Wayne Mutual Insurance Company hereby requests an exemption for the use ofsUAS to 

inspect, photograph, and assess the nature and extent of damage to our policyholders' private 

property after a casualty event. Wayne Mutual Insurance Company will only conduct these 

inspections after obtaining consent from the property owner. Currently, Wayne Mutual 

Insurance Company's adjusters use conventional methods to conduct surveys and inspections 

of damage and loss after a casualty event. These methods require individuals to conduct 

physical inspections and evaluations of claims. By their very nature, these methods are time 

consuming and expensive and carry substantial safety risks. In addition to improving Wayne 

Mutual Insurance Company's customer experience and claim effectiveness, granting this 

petition would improve safety of our claim professionals by eliminating most of their ladder 

inspections. The risks associated with physical roof inspections include potential harm to the 

claims professional by falling or causing a ladder to fall, the potential harm to persons on the 

ground impacted by a falling person or ladder, and the potential property damage caused by a 

falling person or ladder. 

B. Request to Use UASs for Risk Assessment, Risk Management, Loss Prevention and 

Underwriting 

Wayne Mutual Insurance Company also requests an exemption for the use of sUAS to 

perform risk assessment, risk management, loss prevention and underwriting evaluations for 

its residential and commercial lines of businesses. In particular, inspections and evaluations 

of larger residential structures, commercial structures, and instances where the roof system 

itself is of a steep pitch, provide unique challenges. Currently, most ofthese aforementioned 

structures require physical inspections that involve sending a person onto the roof system by 

way of a ladder. These inspections are time consuming and carry the aforementioned risks, 

which can all be eliminated through the use of a sUAS. Wayne Mutual Insurance Company 
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also insures a large book of farm business which includes farms with multistory barns. With 

barns of that size and magnitude, it is impossible to physically inspect the roof structure and 

the use of a sUAS will insure that the appropriate property coverage is provided to the 

policyholder and any need for repairs identified. 

3. Relevant Statutory Authority 

This petition for exemption is submitted pursuant to Section 333(a) through (c) of the FAA 

Modernization and Reform Act of2012. Congress has directed the FAA "to safely accelerate the 

integration of civil unmanned aircraft systems into the national airspace system." Pursuant to this 

section, the FAA Administrator is permitted to allow unmanned aircraft system to operate in the 

National Air Space ("NAS") where it is safe to do so based on the following criteria: 

Operations of the s U AS within the visual line of sight of the operator; 

The sUAS's size, weight, speed and operational capability; and 

Operation of the sUAS in close proximity to airports and populated areas. 

Additionally, the FAA Administrator has general authority to grant exemptions from the 

agency's safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 USC § 1 06( f) (defining the authority of the 

Administrator); 49 USC§44701(f) (permitting exemptions from §§44701(a), (b) and §§44702-

44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: 

(1) would be benefit to the public, and (2) would not adversely affect safety (or how it would 

provide a level of safety at least equal to the existing rules.) See 14 CFR§ 11.81 (petitions for 

exemption). 

4. Wayne Mutual Insurance Company's proposed UAS operations meet the requirements of 

Section 333 of the Reform Act. 

Wayne Mutual Insurance Company's operations proposed in this petition qualify for exemption 

and expedited approval per Section 333 ofthe Reform Act as each of the criteria and relevant 

factors are fulfilled as follows: 

1. Operations will utilize the DJI Phantom 2 Vision and the Phantom 3, which are less 

then 10lbs, including payload. These sUAS has a proven track record of utilization in 

such inspections and are being used by other companies which have already received 

FAA exemptions. 

2. The sUAS DJI Phantom 2 Vision and Phantom 3 will have a maximum speed of 15 

knots. 

3. The sUAS will not fly higher then 200 AGL. 
Page4 

4. Operations will only fly on private property and only after receiving prior permission 

from the property owner. The sUAS will not be flown over public roadways. 

5. Wayne Mutual's sUAS will not carry pilots, passengers, explosive materials or 

flammable liquids. 

6. All operations will be conducted during daylight hours under visual meteorological 

conditions (VMC). No operations will be conducted at night. 

7. The UASs will always be operated within the visual line of sight (VLOS) of the Pilot 

in command (PIC). The PIC will be unaided by any other device except corrective 

lenses. 

8. All operation will use a Visual Observer (VO). The sUAS will be operated at all 

times within the VLOS of PIC and VO. The VO and PIC will be able to communicate 

verbally at all times of operation. The PIC will have control of the sUAS at all times 

throughout the duration ofthe flight, and will not transfer control of the sUAS to any 

other person. 

9. All documents pertaining to the above discussed operation and exemption will be 

available and accessible during sUAS operations and will be available to the 

Administrator upon request. 

10. Prior to each flight, the PIC will be required to conduct a preflight examination of the 

UAS. The sUAS will be examined based on manufacturing guidelines and by the 

Applicant's Operations Manual. If the preflight inspection reveals an issue that will 

affect the safe operation of the sUAS, the aircraft will not be flown. 

11. A preflight surveillance of the property will be conducted to identify any hazards 

such as power lines, power poles, vehicles, etc. A take off and landing zone will be 

designated at the same time. If at any time the inspection identifies an undue hazard, 

the operation will be terminated. 

12. The sUAS will not be flown near any other aircraft. 

13. All flight operations will be conducted at least 500 feet away from all nonparticipating persons, vessels, vehicles, and structures, unless: 

(a) Barriers or structures are present that sufficiently protect the non-participating 

persons from the sUAS and/or debris in the even of an accident. The PIC will 

ensure that all non-participating persons remain under such protection. If a 

situation arises where non-participating persons leave this protection and come 

within 500 feet of the sUAS, all flight operations will be terminated immediately; 

(b) The owner/controller of such vessels, vehicles or structures has granted 

permission for the operation closer to those objects and the PIC has made a safety 
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assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard. 

14. A geo-fence will be enabled on the sUAS that will limit the aircraft from leaving the 

airspace above the property to be inspected. If at any time the sUAS loses 

communications or its GPS signal, the Return to Home feature ofthe sUAS will 

immediately be activated. 

15. All sUAS that have undergone repairs or alterations of any kind will be required to 

undergo a functional test flight prior to use in any further operations. The function 

test will be conducted by the PIC away from any person or property to eliminate any 

undue hazard. 

16. The Applicant will follow the sUAS manufacturer's aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. Applicant will ensure 

its sUAS are in a condition of safe operation at all times. 

17. The Applicant will comply with all manufacturer Safety Bulletins. 

18. The maintenance, inspection, and alteration of each sUAS will be recorded in its 

respective logbook and made available upon request. All flight hours and each 

operation will be recorded in the logbook as well. 

19. All PIC will obtain a private, recreational or equivalent certification. Applicant will 

also implement a training program designed by a licensed FAA pilot as well as a 

trainer who will have completed an FAA-compliant UA V ground school and who 

will have obtained a UAV pilot certification through Unmanned Vehicle University, 

or a similar training institute. All PIC will also possess a valid US driver's license. 

As part of the training, and prior to any operations, the PIC will be required to have at 

least 10 hours of total time piloting a sUAS. Of this time, at least 5 hours will be the 

piloting of the make and model ofthe sUAS to be used in actual operations. 

20. If operation needs to occur within 5 miles of an airport, that operattion will only occur 

if permission is obtained from that airport's management prior to inspection. 

21. The radio frequency spectrum used for operation and control of the sUAS will 

comply with the FCC or other appropriate government oversight agency 

requirements. 

22. All flights will be terminated after 15 minutes, or when the battery has dropped to 

25% power capacity, whichever occurs first. 

23. The sUAS will not be operated from any moving device or vehicle. 
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24. All sUAS will have the Applicant's name and contact information, along with the 

exemption information, permanently attached to it with markings as large as 

practicable. 

25. Any incident, accident, or flight operation that transgresses the boundaries of the 

operating area as defined by the applicable COA will be reported to the FAA's sUAS 

Integration Office within 24 hours. Accidents will be reported to the National 

Transportation Safety Board in accordance with federal regulations. 

5. Wayne Mutual Insurance Company requests exemption from the following sections: 

14 CFR Part 21, Subpart H- Airworthiness Certificates 

14 CFR §45.23(b),- §45.27- Markings 

14 CFR §§61.113 (a) and (b);- Private pilot privileges and limitations 

14 CFR §91.7(a);- Civil Aircraft Worthiness 

14 CFR §91.9 (b) (2);- Civil Aircraft Flight Manual 

14 CFR §91.1 03 (b) (2); - Preflight action 

14 CFR §91.109;- Flight Instruction 

14 CFR §91.119(b) and (c);- Minimum safe altitudes 

14 CFR §91.121; - Altimeter settings 

14 CFR §91.151(a);- Fuel requirements for flight 

14 CFR §91.405(a);- Maintenance required 

14 CFR §91.407(a) 1;- Operations after Maintenance, preventative maintenance, rebuilding or 

alteration. 

14 CFR §§91.409(a) (1) and (2);- Inspections 

14 CFR §§91.417(a) and (b);- Maintenance Records 

And any other relief as the FAA deems appropriate to enable the requested operations. 

6. Specific Response for Exemption 

A. 14 CFR Part 21 Subpart H 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates. Give the size and limited operating area associated with 

the aircraft to be utilized, an exemption from Part 21, Subpart H, meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal 

Aviation Act and Section 3 3 3 of the FMRA both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate upon consideration of the size, weight, speed, 

operational capability, and the proximity to airports and populated areas of the particular UASs. 

In all cases, an analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate, such as in the proposed environments and under the conditions set forth 

in this exemption request, will be at least as safe, or safer, than conventional aircraft (fixed wing 
Page 7 

or rotorcraft) operating with an airw~rthiness certificate without the restrictions and conditions 

proposed. 

B. 14 CFR §45.23(b)- Display of marks; general; 14 CFR §45.27- Location of marks 

This regulation requires markings, in letters no less then 2 inches or more then 6 inches high, 

words such as "limited," "restricted", and "experimental," as applicable. Section 45.27 requires 

that each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of 

the cabin, fuselage, boom, or tail the marks required by section 45.23. 

Due to the size of the sUAS, the 2 inch letter required will not be feasible. Furthermore, the 

sUAS does not have a cabin, cockpit, or pilot station on which to mark any words or phrase. An 

equivalent level of safety will be achieved by having all required words displayed on the aircraft, 

as applicable, in letters of legible size, so that anyone may read the markings. 

C. 14 CFR §§61.113(a) & (b)- Private Pilot Privileges and Limitations: 

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the sUAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the PIC operating the aircraft to have a private pilot's 

license, rather then a commercial pilot's license, to operate the proposed sUAS. 

Unlike a conventional aircraft that carries a pilot and passengers, the sUAS is remotely 

controlled with no living thing on board. The area of operation is controlled and restricted, and 

all flights will be planned and coordinated in advance. The risks associated with the operations of 

the sUAS are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 that allowing operations of the sUAS as requested with a private pilot, 

or equivalent, exceeds the present level of safety achieved by 14 CFR §§61.113(a) and (b). 

D. 14 CFR §91.7(a)- Civil Aircraft Worthiness: 

This regulation requires that a civil aircraft be in airworthy condition to be operated. The FAA 

has stated that no exemption is required to the extent that the requirement of Part 21 are waived 

or found inapplicable. Accordingly, Applicant request that the requirements for Section 91.7 be 

treated accordingly. 

E. 14 CFR §91.9(b) (2)- Civil Aircraft Flight Manual: 

This regulation requires that no U.S.-registered civil aircraft operate unless there is available in 

the aircraft a current and approved airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placard, or any combination thereof. 

The sUAS, given its size and configuration, has no ability or place aboard to carry such a flight 

manual, not only because there is no pilot on board, but because there is no room or capacity to 
Page 8 

carry such an item. The equivalent level of safety will be maintained by keeping the flight 

manual at the location of the PIC to provide for immediate access to it. 

F. 14 CFR §91.103- Preflight Action: 

This regulation requires a pilot to become familiar with specific information before each flight, 

including information contained in the FAA-approved Flight Manual on board the aircraft. 

While the PIC will be familiar with all information necessary to safely conduct the flight, an 

exemption is requested to the extent that an FAA-approved Flight Manual is required. The PIC 

will take all actions including reviewing weather, battery status, landing and takeoff distances 

and aircraft performance data before initiation of flight. 

G. 14 CFR §91.109- Flight Instruction: 

This regulation provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. 

sUAS and remotely piloted aircraft, by their design, do not have fully functioning dual controls. 

Flight control is accomplished through the use of a control box or radio transmitter. An 

equivalent level of safe training can still be performed without dual controls because no pilot or 

passengers are aboard the sUAS, and all persons will be a safe distance away in an event that the 

sUAS experiences difficulties during flight instruction. 

H. 14 CFR §91.119(b) and (c)- Minimum safe altitudes: 

This regulation requires safe altitudes of civil aircraft over areas other than congested areas. 

An equivalent level of safety will be achieved given the size, weight, and speed ofthe sUAS, as 

well as the location where it is operated. In order to avoid any risk, flight operations will be 

restricted to 200 AGL or less. The sUAS will be operated in a restricted area, away from persons 

or structures not involved in the operation and will only occur with pre-obtained consent. 

I. 14 CFR §91.121- Altimeter settings: 

This regulation requires a person operating an aircraft to maintain cruising altitude or flight level 

is reference to an altimeter that is set to the elevation of the departure airport or barometric 

pressure. 

An exemption is required to the extent that sUASs do not have a barometric altimeter, but rather 

a GPS altitude read out. An equivalent level of safety will be achieved by the PIC, who will be 

operating under 200 AGL, within the VLOS, in addition to the GPS-based altitude information 

relayed in real time to the PIC. 
Page 9 

J. 14 CFR §91.151(a)- Fuel requirements for flight in VFR conditions: 

This regulation prohibits an individual from beginning a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing, and assuming normal cruising speed. 

The battery powering the sUAS provides approximately 25 minutes of powered flight. Applicant 

believes that an equivalent level of safety is achieved by limiting flights to 15 minutes or less, or 

25% of battery power, whichever happens first. This restriction would be more than adequate to 

return the sUAS to its planned landing zone from anywhere within the limited operating area. 

K. 14 CFR §91.405(a) Maintenance required; 14 CFR §91.407(a)1 Operations after 

Maintenance, preventative maintenance, rebuilding or alteration; 14 CFR 

§§91.409(a)(1) and (2) Inspections; 14 CFR §§91.417(a) and (b) Maintenance Records: 

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall, between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter ... " and others shall inspect or maintain the aircraft in compliance with part 43. Given 

that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the petitioner. 

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the sUAS Manufacturer's Manual, and will be required in 

Applicant's Operations Manual. The sUAS are very limited in size and will carry a very small 

payload and will operate only in a restricted area for a limited time. If mechanical issues arise, 

the sUAS can land immediately as they will be operated from no higher then 200 AGL. As 

provided in the Operations Manual, the PIC will ensure that the sUAS is in working order prior 

to initiating flight, will perform required maintenance, and will keep a log of any maintenance 

performed. 

L. Such other relief as the FAA deems appropriate to enable the requested operations 

Petitioner also requests exemption from such other F ARs as the FAA deems appropriate to 

enable the requested operations. 

7. Privacy 

The petition raises no privacy issues as all flights will occur over private or controlled access 

property with the property owner's prior knowledge and consent. 
Page 10 

8. Public Interest 

The public interest will be served by granting Wayne Mutual Insurance Company's Petition for 

Exemption. Congress has established a national policy that favors early integration of sUAS into 

the NAS in controlled, safe working environments such as those outlined in this petition. In 

addition, the public also has an interest in reducing the hazards associated with alternate methods 

of conducting similar inspections. Currently inspections are conducted using inspection teams 

physically climbing onto structures using ladders. By using sUAS, an inspector will be able to 

reduce his or her exposure to physical hazards by conducting the inspection while remaining 

safely on the ground. This will also allow the inspector to rapidly obtain an accurate assessment 

of roof damage which will result in a faster claims service, as well as facilitating a quicker 

payment to the policyholder who can then promptly begin necessary repairs. 

Additionally, Wayne Mutual Insurance Company's intended uses for the sUAS have identifiable 

benefits for its policyholders and the communities it serves. The sUAS work will also aid Wayne 

Mutual Insurance Company's risk assessment, risk management, loss prevention and 

underwriting programs. These programs prevent accidents and injuries, and identify needed 

repairs, and there is a strong public interest in making these programs more effective through the 

use ofsUAS. 

9. National Security 

No national security issue is presented by granting this exemption. Given that the sUAS are 

exceedingly small and lightweight, have lost-link and geo-fencing capability, will operate at very 

low speeds, have extremely low payload capacity and will carry no flammable, explosive, or 

otherwise dangerous materials, their operation poses no threat to national security. 

10. Summary to be published in the Federal Register 

Petitioner: Wayne Mutual Insurance Company 

Sections of 14 CFR that Wayne Mutual Insurance seek an exemption: 

14 CFR Part 21, Subpart H- Airworthiness Certificates 

14 CFR §45.23(b);- § 45.27- Markings 

14 CFR §§61.113(a) and (b);- Private pilot privileges and limitations 

14 CFR §91.7(a);- Civil Aircraft Worthiness 

14 CFR §91.9(b);- Civil aircraft light manual, marking and placard requirements 

14 CFR §91.103(b) (2);- Preflight action 

14 CFR §91.109;- Flight Instruction 

14 CFR §91.119(b) and (c);- Minimum safe altitudes 

14 CFR §91.121;- Altimeter settings 

14 CFR §91.151(a);- Fuel requirements for flight 

14 CFR §91.405(a);- Maintenance required 
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14 CFR §91.407(a) 1;- Operations after Maintenance, preventative maintenance, rebuilding or 

alteration. 

14 CFR §§91.409(a) (1) and (2);- Inspections 

14 CFR §§91.417(a) and (b);- Maintenance Records 

Description of Relief sought: 

Applicant seeks relief from the requirements of the above-listed sections so it may conduct small 

unmanned aircraft systems (sUAS) roof inspections subject to the operating procedures that meet or 

exceed those that the FAA requires for similar operations. 

11. Attachments 

-Phantom 3 User Manual. 

- Phantom 2 Vision+ Manual 

- Phantom Pilot Training Guide 

12. Conclusion 

Wayne Mutual Insurance Company's Petition for Exemption satisfies the criteria set forth in 

Section 333 ofthe Reform Act of2012 including the weight, speed, operating capabilities, 

proximity to airports and populated areas, operation within visual line of sight and national 

security. Additionally, the Petition provides more than adequate justification for the grant of the 

requested exemption to permit Wayne Mutual Insurance Company to operate the selected sUAS 

for the operations specified herein. 

Granting the exemption will benefit the public interest as a whole in several ways, including (1) 

significantly improving safety and reducing the risk by alleviating human exposure to danger, 

and (2) improving the quality of services as well as decreasing operating costs. 

Respectfully, 

Wayne Mutual Insurance Company