June 18 , 20 1 5

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 S i r 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 Fi nancial Services Group, Inc. and its subs idiaries (collective ly, "The Hartford" ) hereby petit ion for exemptions from the listed Federal Aviation Regulat ions ("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 authorizat ion to use small UAS for (1) research and development; and (2) aeria l 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 th is petition
. W ith more than 200 years of expertise , The Hartford (NYSE: HI G ) is a leader i n 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 cla i ms related to some of America' s largest disasters , includ i ng 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 w ith which it can respond to customer claims.

1 See Exemption Nos
. 1 1 062 to Astraeus Aerial (see Docket No
. FAA-2014-0352) , 11 1 09 to Clayco, Inc. (see Docket No. FAA-2014-0507) , 11112 to VDOS G lobal , LLC (see Docket No
. FAA-2014-0382), and 11213 to Aeryon Labs, Inc
. (see Docket No
. FAA- 2014- 0642)
.U
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. Department of Transportation June 18 , 2015 Page 2 of 8 Petitioner Information The contact information for The Hartford is : Anthony J
. Salerno Jr
. Assistant V ice 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 followi ng 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 ae rial 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 , includ i ng the Operating Parameters li sted i n Appendix 8 , will be in place to m i nim ize risk to the national ai rspace system or to persons and property on the ground
. Un less otherwise specified , the UAS operations w i ll comply with all app licab le parts of 14 CFR i ncl ud i ng , but not li mited to , parts 45 , 47 , 61 , and 91 The FAA has granted exemptions for requests similar i n all material respects to T he Hartford 's . The FAA has granted numerous exemptions for aerial data collection , incl uding : Exemption Nos
. 11062 to Astraeus Aerial; 11109 to Clayco , Inc.; 11112 to VDOS Global , LLC ; and 112 1 3 to Aeryon Labs, Inc
. In addition , the FAA has granted research and development and aerial data collection exemptions to operators in the insurance industry, i ncluding:U
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. Department of Tr ansportation June 18, 2015 Page 3 of 8 Exempt ion Nos . 1 1367 to ADM Crop Risk Services ; 11293 to Erie Insurance Group ; 11 1 88 and 1 1 175 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 petit ion . 

### Proposed UAS The Hartford proposes to conduct its UAS operations using the DJI Inspire 1 , a small quadcopter weighing approximately 6.5 pounds , incl uding battery and camera, with a maxi mum speed of approximately 43 knots. Additional technical specifications are provided in Append ix 

### A. The Hartford will operate the Inspire 1 in accordance w ith the manufacturer's User Manua l, available at: http://www
.dji.com/producUinspire-1/download and the Operating Parameters listed in Append ix 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 i n 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 s ignal is lost for more than three seconds
. The ai rcraft also has the abi lity to pre-set flight lim its 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 capab i lity. 

### See e.g.: Exemption Nos
. 11398 to Ve ntus Wind, LLC; 1 1394 to Cirrus Exploration Company; and 1 1224 to NextEra Energy, Inc
. The requested exempt ion is merited as use of this UAS under the proposed operationa l parameters w il l not adversely affect safety and will provide a level of safety at least equivalent to the ex isti ng FARs. 

### Exemption is in the Public Interest The Hartford believes its proposed UAS operations are in the public i nterest because they will improve the safety of its employees and service providers , enhance the accuracy of its insurance operat ions, and increase the speed with which it responds to clai ms 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 dep loyed to inspect or evaluate property damage; risk engineers and safety specialists are called upon to identify and assess risks and reco m mend loss prevention measures. In the course of these duties , The Hartford 's employees and service providers regularly enter damaged or unsafe build i ngs ; cl i mb steep ly pitched roofs , ladders, and scaffolding; and encounter i nclement weather and sl i ppery condit ions. In add ition to these hazards, i ndividuals 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 exam i ne and evaluate losses. The ability to use UAS to conduct origin and cause investigations or perform roof inspections , collect data , and capture i mages and video w ill significantly reduce the need to rely on physical inspections , the reby greatly improvi ng employee and service provider safety.U.S
. Department of Transportation June 18 , 2015 Page 4 of 8 In add ition, UAS can be deployed quickly , cover large areas of property, and send data and h igh-reso l ution photographs in rea l 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 i n 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 

### § 6 1. 315(a) 14 CFR 

### § 91
. 7(a) 14 CFR 

### § 91.119(c) 1 4 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 

### § 9 1 .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), 6 1. 3 1 5(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 ReliefSought: 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 deve lopment, and (2) aerial data collect ion in support of certain insurance operat ions , includ i ng c laim appraisa ls, 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 shou ld receive summary approval. The proposed operations are not new or novel , and the UAS i n question has a l ready been approved based on its size , weight , speed and operational capab il ity. Moreover, The Hartford agrees to follow operating parameters that are materially similar to those contained i n recent FAA grants of exemption
.U
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. -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 ,



# l-4 **0~ ~**  **~** 

# .

**~** Anthony J.

**S~le9JO** Jr
. ..., Assistant

**VicEYP~sident** and Counsel The Hartford Financial Services Group , Inc
.

Appendices: Append ix 

### 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 Horizonta l : 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 Insp i re 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 i ndicated by the procedures specified in the operating manual unless a special request is made and approved by Air Traffic Control. 1 4. Flights w i ll 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 maintai ns VLOS capability
. The VO and PIC w ill be ab le to communicate verbally during fl ight 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 f light the PIC will inspect the UAS to ensure that it is in a cond ition for safe flight. If the i nspect ion reveals a cond ition that affects the safe operat ion of the UAS, the aircraft w i ll be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe fl ight. 8
. The UAS will operate in accordance with the UAS manufacturer's aircraft/component, maintenan· ce, overhaul , replacement, inspect ion and life limit requirements
. 9. The PIC will possess at least an a i rline transport, commercial, private, recreational , or sport pilot certificate. The PIC must also hold a current FAA airmen med ical certificate or a valid U
.S
. driver's license
. 1 0
. UAS operations w i ll not be conducted during night, as defined in 1 4 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 i n the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP , the center of the a i rport 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 availab le to the Administrator or any law enforcement official upon request.

1 Petitioner notes that the FAA has a po licy of issuing a Certificate of Waiver or Autho ri zation ("COA") to Section 333 exemption ho lders for fl igh ts at or below 200 feet. If this petition is granted , Petitioner will operate be low 200 feet in accorda nce with the terms of this "blanket" ex emption . 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 fl ight 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 i ncident , accid ent or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable Certificate of Wa iver or Authorization will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours
.