lIIinois Casualty Company A Mutual InsuranceCompany 225 20'" Street, Rock Island, IL61201 • (309) 793-1700 • (800) 445-3726 • Fax: (309) 793-1707 • www.ilcasco.com

October 16, 2015

U.S. DepartmentofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 NewJerseyAvenue, SE. Washington, DC 20590 RE: Petition for Exemption for Illinois Casualty Companyfrom various provisions of 14Code of Federal Regulations (CFR).

Dear Sir: Please seethe following petition for exemption, filed on behalf of Illinois Casualty Company. Included with the petition aretwo guidesfrom the manufacturerofthe Small Unmanned Aircraft System, which are:
• Phantom 2 Vision Plus User Manual v1.B • Phantom 2 Vision Plus Pilot Training Guidev1.1 Thankyou in advancefortaking the timeto considerour request. Sincerely,

Norm Schmeichel Vice President/Chief Information Officer NormS@ilcasco.com Illinois CasualtyCompany 225 20th Street Rock Island, IL61201 Phone: B00.445.3726extension 106 Fax 309.793.1707

Providing Insurance Protection Exclusivelyforthe FoodandBeverage IndustrySince 1950Illinois Casualty Company A Mutual InsuranceCompany 225 20" Street. Rock Island. Il61201 • (309) 793-1700 • (800) 445-3726 • Fax: (309) 793-1707 • www-ilcasco.com 

## Summary IllinoisCasualtyCompany (ICC) requests exemptionfrom multiple regulatory provisionsto allow the use of small unmanned aerial systems (sUAS) on land controlled by ICC's representatives to assist in the safe inspection of property and claims investigations. ICC requests an exemption from several provisions of Title 14 of the Code of Federal Regulations (CFR) to permitthe use of sUAS to assist in the evaluation of infrastructurefor our clients. This request is motivated primarily by the desire to maximize safety and efficiency in inspection of property and claims investigations. While an exemption would not eliminate the current need for in-person visual inspection required, it would allow ICC to broadly evaluate assets and operations with sUAS, resulting in a safer and more efficient manner. Accordingly, the grantofan exemption is consistentwith Congress' intent, reflected in Section 333ofthe FAA Modernization and Reform Act of 2012 (Modernization Act), that safe systems be permitted in the national airspace prior to the issuance of final regulations governing general use of these systems. 

## Introduction ofthe Petitioner ICC is an insurancecompany located in Rock Island, Illinois. ICCwasfounded in Illinois in 1950 to provide insurance products and aggressive claims defense exclusively for the food and beverage industry. Today, we are an admitted carrier in six states: Illinois, Iowa, Indiana, Minnesota, Missouri, and Wisconsin. We recognizethat establishmentsserving alcohol require unique insurance protection. Ourgoal is to meet the full range of business insurance needs for our clients in the food and beverage industry. Our coverage options include liquor liability, property, umbrella, and workers' compensation. 

## Basisfor Exemption Request Pursuant to company policy, our field representatives routinely physically inspect our policyholders' infrastructures, such as property, building and roof conditions, when we write the policies and when a claim has been submitted. At present, this work is done primarily by company personnel on foot. This is often a labor-intensive and sometimes arduousjob. While our representatives do all they can to make these inspections as safe as possible, there is an element of risk involved whenever employees are required to go out on structures. Employees may need to climb overoronto structures, which can be slippery, rough, and/orexposedto the elements. Some buildings are high above the ground. Due to the nature of our clients' businesses, may are located in high traffic, congested areas and/or share common walls with other structures making access more dangerous and difficult. Equipment and traffic moving

Page 1of 10through inspectionzonescan increase riskespeciallyin high-trafficareas.Whilethe useofsUAS for supplemental infrastructure and general asset evaluation would not eliminate these risks entirely (as it is an additive safety measure), it would reduce the risks to employees by allowing for remote aerial review. By using sUAS for supplemental asset evaluation, ICC would be able to substantially improve its ability to safely detect and address potential issues before they become a problem for safe operations and to accurately and safely assess damages to our insureds' property. Thus, the use of sUAS has the potential to improve efficiency, resulting in faster and safer inspections of properties. 

## Specific Exemptions Requested • Duetothe size ofthe sUAS, ICC seeks exemption from the following regarding the sizing ofthe letters on the sUAS. 14CFR 45.23(b) Displayof marks; general.
o (a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letterUN" (denoting United States registration) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter.
o (b) When marks include onlythe Roman capital letter UN" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionallycertificated aircraft, the operatormustalso displayon that aircraft neareach entranceto the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. • ICC seeks exemption from this section since the sUAS is remote controlled and has more than one failsafe in place in case of low batteryor loss of connection to remote control unit. 14CFR 91.109 Flight instruction; Simulated instrumentflight and certain flighttests.
o (a) No person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unlessthat aircraft hasfullyfunctioning dual controls. However, instrument flight instruction may be given in an airplane that is equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, wheno (1) The instructor has determinedthat the flight can be conducted safely; and
o (2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.
o (b) An airplane equipped with a single, functioning throwover control wheel that controls the elevatorand ailerons, in place offixed, dual controls may be usedforflight instruction to conduct a flight review required by §61 .56 of this chapter, or to obtain recent flight experience oran instrument proficiencycheck required by §61.57 whenPage 2 of 10o (1) The airplane is equipped with operable rudder pedals at both pilot stations;
o (2) The pilot manipulatingthecontrols is qualifiedto serveand servesas pilot in command duringthe entireflight;
o (3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of §61.195(b), and has logged at least 25 hours of pilot-incommand flight time in the make and model of airplane; and
o (4) The pilot in command andthe instructor have determinedthe flight can be conducted safely.
o (c) No person mayoperate a civil aircraft in simulated instrumentflight unlesso (1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriateto the aircraft being flown.
o (2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplementsthe vision of the safety pilot; and
o (3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single-engine airplane, equipped with a single, functioning, throwover control wheel, in place offixed, dual controls ofthe elevatorand ailerons, wheno (i) The safety pilot has determined that the flight can be conducted safely; and
o (ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.
o (d) No person may operate a civil aircraftthat is being used for aflight test for an airline transport pilot certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully qualifiedto act as pilot in command ofthe aircraft. • ICC seeks exemption from the rule below as the sUAS will stay below the proposed 400ft AGL level. 14CFR 91.119 Minimum safe altitudes: General.
o Except when necessary for takeoff or landing, no person may operate an aircraft belowthe following altitudes:
o (a) Anywhere. An altitude allowing, ifa power unitfails, an emergency landingwithout undue hazard to persons or property on the surface.
o (b) Overcongestedareas. Overany congested area of a city, town, orsettlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of2,000 feet of the aircraft.
o (c) Overotherthan congestedareas.An altitude of500feet abovethe surface, except overopen water orsparsely populated areas. In those cases, the aircraft may not be operated closerthan 500feetto any person, vessel, vehicle, orstructure.

Page 3 of 10o (d) Helicopters, poweredparachutes, andweight-shift-controlaircraft. Ifthe operation is conducted without hazardto persons orproperty on the surfaceo (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicoptercomplieswith any routes oraltitudes specifically prescribed for helicopters bythe FAA; and
o (2) A powered parachute orweight-shift-control aircraft may be operated at less than the minimums prescribed in paragraph (c) ofthis section. • ICC's sUAS does not carry passengers and is too small to display anything within it. The appropriate certificatewill be kept within the storage caseforthe sUAS. 14CFR 91.203 (a) & (b) Civil aircraft: Certifications required.
o (a) Exceptas provided in §91.715, no person mayoperate acivil aircraft unless it has within it the following:
o (1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications issued under §21.197(c) of this chapter, appropriate sections of the aircarrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under §21.197(c), oran authorization under§91.611) musthaveon itthe registration number assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days afterthat numberisfirst affixed tothe aircraft. A revised airworthinesscertificate having on it an assigned special identification number, that has been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards district office.
o (2) An effective U.S. registration certificate issued to its owneror, foroperation within the United States, the second copyoftheAircraft registration Application as provided for in §47.31(c), or a registration certification issued under the laws of a foreign country.
o (b) No person mayoperate acivil aircraft unlessthe airworthinesscertificate required by paragraph (a) ofthis section ora special flight authorization issued under§91.715 is displayed atthe cabin orcockpitentrancesothat it is legibleto passengersorcrew.

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## SafetyOperations and Procedures Overview Mechanical/Physical: 1. ICC's trained Pilot in Command (PIC) will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS to the PIC orspotter, thus eliminating the concern of signal severance (flying behind objects/walls). 2. The sUAS will weigh lessthan 55 Ibs. and travel at lessthan 50 knots

. 3. Batteries should far exceed the capacity required for actual flight time. 4. Flights will be operated at an altitude of no more than 400 feetAGL. 5. UA operated underthis exemption will be marked in accordance with 14 CFR part 45 or as otherwise authorized bythe FAA.


### Personnel: 1. Spotters ensure safe operation and act as a redundant set of eyesfor operators, and will be used ifthe PIC is unableto keep the sUAS in VLOS at all times. 2. The operator will obtain the consent of any and all people involved in the sUAS operations, or on the site of the flight, and ensure that only consenting persons will be present. 3. Observerand pilotwill at all times be ableto communicate byvoice. 4. Written and/ororal permission from the relevant property holders will be obtained. 5. Pilot and observerwill have been trained in operation of UAS generally and received upto-date information on the particular UAS to be operated.

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### Operations: 1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), including energy source(s) and equipment. Operations authorized bythis petition of exemption are limited to the following aircraft described: 

### Drone Drone Model Phantom 2 Vision+ Model PV331 PVT581 

### Number Serial PT645203287 V2.0 

### Number FCC 10 SS3-201309581 SS3-PV3311402 This Device complieswith part 15 of the FCC Rules. Operation is subjectto the following two conditions: (1) This device may not cause harmful interference, and (2) This device must accept any interference received, including interferencethat maycause undesired tion.

Check List 

### Before Every Flight Keepthe flight awayfrom objects, such as obstacles, human beings, highvo e lines etc. Checkthatthe ellers andthe motors are in Always checkthe batterystatus, and starttheflight with afully charged LiPo 

### fIi t batte Please always switch on thetransmitterfirst, and then poweron the quadrotor beforetakeoff! Poweroffthe quad-rotorfirst, and then switch offthe transmitterafter landin 

### !

2. The UA may not be flown at a ground speed exceeding 50 knots. 3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated bythe procedures specified in the operator's manual.

Page 6 of 104. The UA must be operated within visual line of sight (VLOS) of the PIC, orspotter, at all times. This requires the PIC to be ableto use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued medical certificate. 5. All operations may utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 6. The operator's manual (attached), andthis petition ofexemption must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operator's manual, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator mustfollowthe procedures as outlined in its operator's manual. The operatormay updateorrevise its operator's manual. It istheoperator's responsibility to track such revisions and present updated and revised documentsto the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment. If the operator determines that any update or revision would affect the basis forwhich the FAA grantsthis petition for exemption, then the operatormust petition foramendmentto theirexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestionsarise regarding updatesorrevisionstothe operator's manual. 7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affectsthe safe operation of the UAS, the aircraft is prohibitedfrom operating untilthe necessarymaintenance has been performed and the UAS is found to be in a condition for safe flight. All maintenance and alterations must be properly documented in the aircraft records. 8. Any UASthat has undergone maintenance oralterationsthat affectthe UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional testflight in accordancewith the operator's manual. The PIC who conductsthe functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and proceduresfor afunctional testflight and aircraft record entry must be added to the operator's manual. 9. The operator must follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator's manual. 10.The PIC must possess at least a private pilot certificate and at least a currentthird-class medical certificate orvalid statedriver's license. The PIC mustalso meettheflight review requirements specified in 14 CFR 

### § 61.56 in an aircraft in which the PIC is rated on his or herpilot certificate. 11.Training, proficiency, and experience-building flights can also be conducted under this petition of exemption to accomplish the required flight cycles and flight time. During

Page7of10training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distancefrom nonparticipants in accordance with 14 CFR 

### § 91.119. 12.Prior to operations conducted for the purpose of infrastructure inspection, the PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take-offs and three landings in the preceding 90 days. Training, proficiency, experience building, and take-off and landing currency flights can be conducted under this petition of exemption to accomplish the required flighttime and 90daycurrency. Duringtraining, proficiency, experience-building, and take-offand landing currencyflights all persons not essentialforflight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91.119. 13.Prior to any flight operations authorized by this petition of exemption, the PIC and VO must have successfully completed a qualification process, as outlined in the operator's manual. As this is a requirement stipulated bythe operator, the test must be developed and implemented by a qualified person designated atthe sole discretion of the operator. A record of completion of this qualification process must be documented and made availableto the Administrator upon request. 14.The UA may not be operated directlyoverany person, except authorized and consenting personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UASfailure oremergency. 15.Regarding the distance from participating persons, the operator's manual has safety mitigationsfor authorized and consenting personnel. At all times, those persons must be essential to the operations. 16.lfthe UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the securityperimeterand land orbe recovered in accordance with the operator's manual. 17.The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordancewith the operator's manual. 18.Each UAS operation must be completed with 25% battery power remaining. 19.The operator must obtain an AirTraffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) prior to conducting any operations under this petition of exemption. 20.All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

Page 8 of 1021.The operator must develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures must be added to the operator's manual. 22. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 23.The operator must develop UAS technician qualification criteria. These criteria must be added to the operator's manual. 24.The preflight inspection section in the operator's manual must be amendedto includethe following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections ofthe operator's manual. 25. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or otherappropriate government oversight agency requirements. 26.The documents required under 14 CFR 

### §§91.9 and 91.203 must be availableto the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 27.The UA must remain clear and yield the right of way to all other manned operations and activitiesat all times (including, but not limited to, ultralightvehicles, parachute activities, parasailing activities, hang gliders, etc.). 28.UAS operations may not be conducted during night, as defined in 14 CFR 

### § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights underspecial visual flight rules (SVFR) are not authorized. 29.The UAS may not be operated bythe PIC from any moving device orvehicle.

Page9of10GlossaryofAbbreviations

AGL Above Ground Level ATO AirTraffic Organization CFR Code of Federal Regulations COA Certificate ofAuthorization FAA Federal Aviation Administration GCS Ground Control Station GPS Global Positioning System ICC Illinois CasualtyCompany PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) sUAS Unmanned Aircraft System SVFR Special Visual Flight Rules

UA Unmanned Aircraft VLOS Visual Line of Site VMC Visual Meteorological Conditions

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