lIIinois 

Casualty 

Company 

A Mutual Insurance Company 

225 20'" Street, Rock Island, IL 61201 • (309) 793-1700 • (800) 445-3726 • Fax: (309) 793-1707 • www.ilcasco.com 

October 16, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

RE: Petition for Exemption for Illinois Casualty Company from various provisions of 14 Code of Federal 

Regulations (CFR). 

Dear Sir: 

Please see the following petition for exemption, filed on behalf of Illinois Casualty Company. 

Included with the petition are two guides from the manufacturer of the Small Unmanned Aircraft 

System, which are: 

• Phantom 2 Vision Plus User Manual v1.B 

• Phantom 2 Vision Plus Pilot Training Guide v1.1 

Thank you in advance for taking the time to consider our request. 

Sincerely, 

Norm Schmeichel 

Vice President/Chief Information Officer 

NormS@ ilcasco.com 

Illinois Casualty Company 

225 20th Street 

Rock Island, IL 61201 

Phone: B00.445.3726 extension 106 

Fax 309.793.1707 

Providing Insurance Protection Exclusively for the Food and Beverage Industry Since 1950 
Illinois 

Casualty 

Company 

A Mutual Insurance Company 

225 20" Street. Rock Island. Il61201 • (309) 793-1700 • (800) 445-3726 • Fax: (309) 793-1707 • www-ilcasco.com 

Summary 

Illinois Casualty Company (ICC) requests exemption from multiple regulatory provisions to 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 permit the use of sUAS to assist in the evaluation of infrastructure for 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 grant of an exemption is consistent with Congress' intent, reflected in Section 333 of the 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 of the Petitioner 

ICC is an insurance company located in Rock Island, Illinois. ICC was founded 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 recognize that establishments serving alcohol require unique insurance protection. Our goal 

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. 

Basis for 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 arduous job. 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 over or onto structures, which can be slippery, rough, and/or exposed to 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 1 of 10 
through inspection zones can increase risk especially in high-traffic areas. While the use of sUAS 

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 

• Due to the size of the sUAS, ICC seeks exemption from the following regarding the sizing 

of the letters on the sUAS. 

14 CFR 45.23(b) Display of marks; general. 

o (a) Each operator of an aircraft must display on that aircraft marks consisting of the 

Roman capital letter UN" (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 only the Roman capital letter UN" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to 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 battery or loss of connection to remote control unit. 

14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight tests. 

o (a) 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. 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 determined that 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 elevator and ailerons, in place of fixed, dual controls may be used for flight instruction 

to conduct a flight review required by §61 .56 of this chapter, or to obtain recent flight 

experience or an instrument proficiency check required by §61.57 whenPage 2 of 10 
o (1) The airplane is equipped with operable rudder pedals at both pilot stations; 

o (2) The pilot manipulating the controls is qualified to serve and serves as pilot in command 

during the entire flight; 

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 and the instructor have determined the flight can be conducted 

safely. 

o (c) No person may operate a civil aircraft in simulated instrument flight 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 appropriate to 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 supplements the 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 of fixed, dual controls of the elevator and 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 aircraft that is being used for a flight 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 qualified to act as pilot in command of the aircraft. 

• ICC seeks exemption from the rule below as the sUAS will stay below the proposed 400ft 

AGL level. 

14 CFR 91.119 Minimum safe altitudes: General. 

o Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: 

o (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface. 

o (b) Over congested areas. Over any congested area of a city, town, or settlement, or 

over any open air assembly of persons, an altitude of 1,000 feet above the highest 

obstacle within a horizontal radius of 2,000 feet of the aircraft. 

o (c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. 

Page 3 of 10 
o (d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation 

is conducted without hazard to persons or property 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 helicopter complies with 

any routes or altitudes specifically prescribed for helicopters by the FAA; and 

o (2) A powered parachute or weight-shift-control aircraft may be operated at less than 

the minimums prescribed in paragraph (c) of this section. 

• ICC's sUAS does not carry passengers and is too small to display anything within it. The 

appropriate certificate will be kept within the storage case for the sUAS. 

14 CFR 91.203 (a) & (b) Civil aircraft: Certifications required. 

o (a) Except as provided in §91.715, no person may operate a civil 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 air carrier manual required by parts 121 and 135 

of this chapter containing that portion of the operations specifications issued under 

§21.197(c), or an authorization under §91.611) must have on it the 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 after that number is first affixed to the aircraft. A revised airworthiness certificate 

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 owner or, for operation within 

the United States, the second copy of the Aircraft 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 may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) of this section or a special flight authorization issued under §91. 715 

is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

Page 4 of 10 
Safety Operations 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 or spotter, thus eliminating the concern of signal 

severance (flying behind objects/walls). 

2. The sUAS will weigh less than 55 Ibs. and travel at less than 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 feet AGL. 

5. UA operated under this exemption will be marked in accordance with 14 CFR part 45 or 

as otherwise authorized by the FAA. 

Personnel: 

1. Spotters ensure safe operation and act as a redundant set of eyes for operators, and will 

be used if the PIC is unable to 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. Observer and pilot will at all times be able to communicate by voice. 

4. Written and/or oral permission from the relevant property holders will be obtained. 

5. Pilot and observer will have been trained in operation of UAS generally and received upto-date information on the particular UAS to be operated. 

Page 5 of 10 
Operations: 

1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), including energy 

source(s) and equipment. Operations authorized by this 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 complies with part 15 of the 

FCC Rules. Operation is subject to the 

following two conditions: 

(1) This device may not cause harmful 

interference, and 

(2) This device must accept any 

interference received, including 

interference that may cause undesired 

tion. 

Check List 

Before Every 

Flight 

Keep the flight away from objects, such as obstacles, human beings, highvo e lines etc. 

Check that the ellers and the motors are in 

Always check the battery status, and start the flight with a fully charged 

LiPo fIi t batte 

Please always switch on the transmitter first, and then power on the quadrotor before takeoff! Power off the quad-rotor first, and then switch off the 

transmitter after 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 by the procedures specified in the operator's manual. 

Page 6 of 10 
4. The UA must be operated within visual line of sight (VLOS) of the PIC, or spotter, at all 

times. This requires the PIC to be able to 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), and this petition of exemption 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 must follow the procedures as outlined in its operator's manual. 

The operator may update or revise its operator's manual. It is the operator's responsibility 

to track such revisions and present updated and revised documents to 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 for which the FAA grants this petition for exemption, then 

the operator must petition for amendment to their exemption. The FAA's UAS Integration 

Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the 

operator's manual. 

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft is prohibited from operating until the necessary maintenance 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 UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight in accordance with the operator's manual. The PIC who conducts the 

functional test flight must make an entry in the UAS aircraft records of the flight. The 

requirements and procedures for a functional test flight 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 current third-class 

medical certificate or valid state driver's license. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his 

or her pilot 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 

Page7of10 
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. 

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 flight time and 90 day currency. During training, proficiency, experience-building, 

and take-off and landing currency 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. 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 by the operator, the test must be developed 

and implemented by a qualified person designated at the sole discretion of the operator. 

A record of completion of this qualification process must be documented and made 

available to the Administrator upon request. 

14. The UA may not be operated directly over any person, except authorized and consenting 

personnel, below an altitude that is hazardous to persons or property on the surface in 

the event of a UAS failure or emergency. 

15. Regarding the distance from participating persons, the operator's manual has safety 

mitigations for authorized and consenting personnel. At all times, those persons must be 

essential to the operations. 

16.lf the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance 

with the operator's manual. 

17. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator's manual. 

18. Each UAS operation must be completed with 25% battery power remaining. 

19. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

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 10 
21. 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 amended to include the 

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 of the 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 

other appropriate government oversight agency requirements. 

26. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to 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 

activities at all times (including, but not limited to, ultralight vehicles, 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 

under special visual flight rules (SVFR) are not authorized. 

29. The UAS may not be operated by the PIC from any moving device or vehicle. 

Page9of10 
Glossary of Abbreviations 

AGL Above Ground Level 

ATO Air Traffic Organization 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

GCS Ground Control Station 

GPS Global Positioning System 

ICC Illinois Casualty Company 

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 

Page 10 of 10