June 18, 2015 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Room W12-140 

Washington, D.C. 20590 

Re: The Hartford's Petition for an Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("FMRA") and 14 

C.F.R. Part 11, The Hartford Financial Services Group, Inc. and its subsidiaries (collectively, 

"The Hartford") hereby petition for exemptions from the listed Federal Aviation Regulations 

("FARs") and any other rules necessary to allow operation of small unmanned aircraft systems 

("UAS") under the conditions set forth in this petition. The Hartford requests authorization to use 

small UAS for (1) research and development; and (2) aerial data collection in support of certain 

insurance operations. As explained below, operations under the requested exemptions will be 

conducted under operating requirements and conditions materially similar to those previously 

approved by the FAA.

1 Accordingly, The Hartford requests summary review of this petition. 

With more than 200 years of expertise, The Hartford (NYSE: HI G) is a leader in property and 

casualty insurance, group benefits and mutual funds. The Hartford's more than 17,000 

employees help its customers prepare for the unexpected, protect what's most important to 

them and prevail when the unforeseen happens. Since its founding in 1810, The Hartford has 

insured some of the nation's most historic construction projects, such as the Golden Gate 

Bridge and the Hoover Dam. The Hartford has also paid claims related to some of America's 

largest disasters, including the San Francisco earthquake of 1906, the September 11 terrorist 

attacks and, more recently, Hurricane Katrina and Storm Sandy. 

Throughout its history, The Hartford has embraced new tools and methods that improve the 

way it works. The Hartford believes UAS are a tool that can reduce risks to its employees and 

service providers, enhance the accuracy of its insurance operations, and improve the speed and 

efficiency with which it can respond to customer claims. 

1 See Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), 11 109 to Clayco, Inc. 

(see Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC (see Docket No. FAA-2014-0382), and 

11213 to Aeryon Labs, Inc. (see Docket No. FAA- 2014- 0642). 
U.S. Department of Transportation 

June 18, 2015 

Page 2 of 8 

Petitioner Information 

The contact information for The Hartford is: 

Anthony J. Salerno Jr. 

Assistant Vice President and Counsel 

The Hartford Financial Services Group, Inc. 

One Hartford Plaza 

Hartford, CT 06155 

Phone: (860) 547-3141 

E-mail: anthony.salerno@thehartford.com 

The contact information for The Hartford's outside counsel is: 

Katy Ross 

Associate 

Wiley Rein LLP 

1776 K Street NW 

Washington, DC 20006 

Phone: (202) 719-7410 

E-mail: kmross@wileyrein.com 

Proposed Operation 

The Hartford requests authorization to use small UAS for the following purposes: 

• Research and Development. The Hartford will conduct research and development at 

private facilities owned by The Hartford or a third party vendor in order to evaluate how 

best to integrate UAS into The Hartford's insurance operations, develop additional uses 

for UAS technology, and develop insurance products related to UAS operation. 

• Aerial Data Collection. The Hartford will use UAS for aerial data collection in support of 

certain of its insurance operations, including claim appraisals, risk assessments, risk 

management, loss prevention, underwriting and catastrophe response. For these 

purposes, UAS will be flown only over an insured's property or over property or inside a 

structure where, to the extent practicable, permission has been obtained from the owner. 

In each case, UAS will be operated in accordance with the manufacturer's User Manual and 

strict safety measures, including the Operating Parameters listed in Appendix 8, will be in place 

to minimize risk to the national airspace system or to persons and property on the ground. 

Unless otherwise specified, the UAS operations will comply with all applicable parts of 14 CFR 

including, but not limited to, parts 45, 47, 61 , and 91 

The FAA has granted exemptions for requests similar in all material respects to The 

Hartford's. The FAA has granted numerous exemptions for aerial data collection, including: 

Exemption Nos. 11062 to Astraeus Aerial; 11109 to Clayco, Inc.; 11112 to VDOS Global, LLC; 

and 11213 to Aeryon Labs, Inc. In addition, the FAA has granted research and development 

and aerial data collection exemptions to operators in the insurance industry, including: 
U.S. Department of Transportation 

June 18, 2015 

Page 3 of 8 

Exemption Nos. 11367 to ADM Crop Risk Services; 11293 to Erie Insurance Group; 11 188 and 

11175 to State Farm; 11273 to AIG; and 11309 and 11274 to USAA. In those grants, the FAA 

found that the enhanced safety achieved using a UAS carrying no passengers or crew, rather 

than a manned aircraft of significant greater proportions carrying crew and flammable fuel, gave 

the FAA good cause to find that the UAS operation was in the public interest. The FAA has 

good cause to make the same finding with respect to this petition. 

Proposed UAS 

The Hartford proposes to conduct its UAS operations using the DJI Inspire 1, a small 

quadcopter weighing approximately 6.5 pounds, including battery and camera, with a maximum 

speed of approximately 43 knots. Additional technical specifications are provided in Appendix A. 

The Hartford will operate the Inspire 1 in accordance with the manufacturer's User Manual, 

available at: http://www.dji.com/producUinspire-1/download and the Operating Parameters listed 

in Appendix B. 

The OJI Inspire 1 has numerous features that will help ensure safe operations. The aircraft 

has a Return to Home ("RTH") feature, which is triggered when the operator uses the RTH 

button on the remote controller or in the OJI Pilot app, when the battery is depleted to a point 

that may affect the safe return of the aircraft, and if the remote controller signal is lost for more 

than three seconds. The aircraft also has the ability to pre-set flight limits on height and 

distance. 

The FAA has already determined that the DJI Inspire 1 meets the requirements of Section 

333 of the Reform Act due to its size, weight, speed and operational capability. See e.g.: 

Exemption Nos. 11398 to Ventus Wind, LLC; 11394 to Cirrus Exploration Company; and 11224 

to NextEra Energy, Inc. The requested exemption is merited as use of this UAS under the 

proposed operational parameters will not adversely affect safety and will provide a level of 

safety at least equivalent to the existing FARs. 

Exemption is in the Public Interest 

The Hartford believes its proposed UAS operations are in the public interest because they 

will improve the safety of its employees and service providers, enhance the accuracy of its 

insurance operations, and increase the speed with which it responds to claims and other 

customer needs. 

As part of its business, The Hartford routinely sends professionals to inspect or evaluate 

physical property. Insurance professionals, including claims adjusters are deployed to inspect or 

evaluate property damage; risk engineers and safety specialists are called upon to identify and 

assess risks and recommend loss prevention measures. In the course of these duties, The 

Hartford's employees and service providers regularly enter damaged or unsafe buildings; climb 

steeply pitched roofs, ladders, and scaffolding; and encounter inclement weather and slippery 

conditions. In addition to these hazards, individuals responding to catastrophic events also 

encounter damaged and blocked roads, fallen trees, broken power lines, debris and other safety 

hazards they must navigate to visually examine and evaluate losses. The ability to use UAS to 

conduct origin and cause investigations or perform roof inspections, collect data, and capture 

images and video will significantly reduce the need to rely on physical inspections, thereby 

greatly improving employee and service provider safety. 
U.S. Department of Transportation 

June 18, 2015 

Page 4 of 8 

In addition, UAS can be deployed quickly, cover large areas of property, and send data and 

high-resolution photographs in real time to adjusters preparing estimates or to underwriters 

assessing risks. The Hartford believes this has the potential to enhance the accuracy of 

appraisals and to improve the speed and efficiency of its claims settlement process. This is 

especially critical in the context of a catastrophe, when customers need their settlement most. 

Exemptions Requested 

14 CFR § 61.23(a) & (c) 

14 CFR § 61 .101(e)(4) & (5) 

14 CFR § 61 .113(a) & (b) 

14 CFR § 61.315(a) 

14 CFR § 91 .7(a) 

14 CFR § 91.119(c) 

14 CFR § 91 .121 

14 CFR § 91.151(a)(1) & (b) 

14 CFR § 91.405(a) 

14 CFR § 91.407(a)(1) 

14 CFR § 91.409(a)(1) & (2) 

14 CFR § 91.417(a) & (b) 

Summary for the Federal Register 

The Hartford believes that publication in the Federal Register is unnecessary under the 

FAA's criteria for summary approval. To the extent that the FAA determines that publication is 

necessary, the following summary is provided: 

Petitioner: The Hartford Financial Services Group, Inc. 

Sections of14 C.F.R. Affected:§§ 61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a) & (b), 

61.315(a), 91 .7(a), 91 .119(c) 91.121 , 91.151(a)(1) & (b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (2), and 91.417(a) & (b) 

Description of Relief Sought: Petitioner seeks exemption from the requirements of 14 

C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) & (5), 61 .113(a) & (b), 61 .315(a), 91.7(a), 

91.119(c) 91.121 , 91.151(a)(1) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) to operate small unmanned aircraft systems to conduct (1) research and 

development, and (2) aerial data collection in support of certain insurance operations, 

including claim appraisals, risk assessment, risk management, loss prevention, 

underwriting and catastrophe response. In each case, Petitioner will meet or exceed 

conditions that the FAA requires for similar operations. 

Based on the information provided, The Hartford respectfully submits that its request should 

receive summary approval. The proposed operations are not new or novel, and the UAS in 

question has already been approved based on its size, weight, speed and operational capability. 

Moreover, The Hartford agrees to follow operating parameters that are materially similar to 

those contained in recent FAA grants of exemption. 
U.S. -Department of Transportation 

June 18, 2015 

Page 5 of 8 

Should you have any questions, or need any additional information regarding this petition, 

please do not hesitate to contact The Hartford, or The Hartford's outside counsel, using the 

information provided above. 

Sincerely, 

Anthony 

~ l-4 . J. S~le9JO ~ 0~Jr. ~ ..., 

Assistant VicEYP~sident and Counsel 

The Hartford Financial Services Group, Inc. 

Appendices: 

Appendix A: OJ! Inspire 1 Specifications Data Sheet 

Appendix 8: Operating Parameters 
APPENDIX A 

DJIINSPIRE 1 SPECIFICATIONS DATA SHEET 

Model T600 

Weight (Battery Included) 2935 g 

Hovering Accuracy (GPS Mode) Vertical: 0.5 m 

Horizontal: 2.5 m 

Max Angular Velocity Pitch: 300°/s 

Yaw: 150°/s 

Max Tilt Angle 35° 

Max Ascent Speed 5 m/s 

Max Descent Speed 4 m/s 

Max Speed 22 m/s (A TTl mode, no wind) 

Max Flight Altitude 4500 m 

Max Wind Speed Resistance 10 m/s 

Max Flight Time Approximately 18 minutes 

Motor Model DJI 3510 

Propeller Model DJI 1345 

Indoor Hovering Enabled by default 

Operating Temperature Range -10° to 40° C 

Diagonal Distance 559 to 581 mm 

Dimensions 438 x 451 x 301 mm 
APPENDIX 8 

OPERATING PARAMETERS 

1. The UAS will be limited to the DJI Inspire 1 Unmanned Aircraft System. 

2. The UAS will be limited to an indicated airspeed not to exceed 87 knots. 

3. Flights will be operated at an altitude of no more than 400 feet above ground level ("AGL"), as 

indicated by the procedures specified in the operating manual unless a special request is made 

and approved by Air Traffic Control. 1 

4. Flights will be operated within visual line of sight ("VLOS") of the pilot-in-command ("PIC") at all 

times. 

5. Flight operations will 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 will be able 

to communicate verbally during flight operations. 

6. The manufacturer's manual and these Operating Parameters will be accessible during UAS 

operations and made available to the Federal Aviation Administrator or his delegate (the 

"Administrator") upon request. 

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

the inspection reveals a condition that affects the safe operation of the UAS, the aircraft will be 

prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. 

8. The UAS will operate in accordance with the UAS manufacturer's aircraft/component, 

maintenan·ce, overhaul, replacement, inspection and life limit requirements. 

9. The PIC will possess at least an airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC must also hold a current FAA airmen medical certificate or a valid U.S. 

driver's license. 

10. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations 

will be conducted under visual meteorological conditions ("VMC"). If flight at night is required, a 

special request will first be made at the FAA office closest to the proposed area of operations. 

11 . The UAS will not operate within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless 

a letter of agreement with that airport's management is obtained or otherwise permitted by a 

GOA issued to the exemption holder. The letter of agreement with the airport management will 

be made available to the Administrator or any law enforcement official upon request. 

1 Petitioner notes that the FAA has a policy of issuing a Certificate of Waiver or Authorization ("COA") to 

Section 333 exemption holders for flights at or below 200 feet. If this petition is granted, Petitioner will 

operate below 200 feet in accordance with the terms of this "blanket" exemption. Petitioner may later file 

for a separate COA to operate over 200 feet. 
12. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from 

a cloud or when visibility is less than 3 statute miles from the PIC. 

13. If the UAS loses communications or loses its GPS signal, it will have the capability to return to a 

pre-determined location. 

14. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

15. The PIC is prohibited from beginning a flight unless there is enough available power for the UAS 

to conduct the intended operation and to operate after that for at least five minutes or with the 

reserve power recommended by the manufacturer, if greater. 

16. All operations will be conducted over private or controlled-access property. To the extent 

practicable, permission from the land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

17. Any incident, accident or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable Certificate of Waiver or Authorization will be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours.