August, 21 2015 Attn: U.S. Department ofTransportation Docket Operations West Building Ground Floor, Room w12-140 1200 NewJersey Ave, SE Washington, DC 20590

RE: NELSON FORENSICS, LLC dba. NELSON FORENSICS REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI INSPIRE 1UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Erik L. Nelson, Ph.D., P.E. President and CEO Nelson Forensics 2740 Dallas Parkway, Suite 220 Plano, TX 75093 Tel: (469) 429-9000 Fax: (469) 326-5200 Email: enelson@nelsonforensics.com PetitionerTABLE OF CONTENTS Page GLOSSARYOF ABBREVIATIONS

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SUMMARY

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INTRODUCTION AND INTERESTS OF PETITIONER

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BACKGROUND

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BASIS FORPETITION

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NAMEANDADDRESS OFPETITIONER

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THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH NELSON FORENSICS SEEKS EXEMPTION

..... ...... ... ... ................ ..... ...................... .. ... ......... ..... ................. .........9 THE EXTENT OF RELIEF NELSON FORENSICS SEEKS AND THE REASON NELSONFORENSICS SEEKS THERELIEF

...............................................................12 THEREASONS WHYGRANTINGNELSONFORENSICS' REQUESTWOULD BE IN THE PUBLIC INTEREST

.............................................................................................. 15 THE REASONS WHY GRANTING THE EXEMPTION TO NELSON FORENSICS WOULDNOTADVERSELYAFFECT SAFETY

............................................................ 18 SUMMARYTHAT CAN BEPUBLISHED IN THE FEDERALREGISTER.

................31 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORTNELSON FORENSICS' REQUEST

...............................................................32 CONCLUSION

..............................................................................................................................32 APPENDICES

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2AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOT AM PIC Section 333 

## so SOP UA UAS VFR VLOS VMC VTOL GLOSSARY OFABBREVIATIONS Above Ground Level Area ofInterest Air Traffic Control Air Traffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice to Airman Pilot In Command FAA Modernization and Reform Act of2012 (FMRA) Safety Observer Standard Operating Procedures Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing

3SUMMARY Nelson Forensics, LLC dba. Nelson Forensics hereafter referred to as Nelson Forensics seeksexemptionfrom therequirements of14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (DJI Inspire 1) pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Nelson Forensics to operate an Unmanned Aircraft System (UAS) for the commercialpurpose ofconducting aerial video and photography of construction sites, residential and commercial real estate, civil landscapes and events within the National Airspace System (NAS). INTRODUCTION AND INTERESTS OF THEPETITIONER Nelson Forensics has for over twenty-one years provided our clients (which include private sector businesses, insurance companies, and attorneys at law) with expertise and knowledge in forensic engineering and forensic architecture, fire investigation, chemistry and environmental science, accident reconstruction, cost estimating and appraisal, and roofing materials testing. NelsonForensics' missionis to reduce risk andprevent failure bycombining ethical standards with advancedtechnologies in an effortto discover cause offailure and to educate ourclients andpeers

on our findings. The objective ofNelson Forensics and our Unmanned Aircraft System (DJI Inspire 1) aerial operations is to provide an affordable, high-qualityproduction system for avariety ofgovernmental, commercial, public, and residential uses, specifically targeting:

• Forensic engineering

• Forensic architecture

• Natural disaster investigation

• Fire investigation

4• Roofing system assessment

• Cost estimating and appraisals

• Land surveys

5BACKGROUND Unmanned Aircraft ystems: Inspire 1UAS Nelson Forensics seeks an exemption to operate the DJI Inspire 1 UAS (Inspire 1UAS) for compensationorhire withintheNAS. The DJI Inspire 1UAS is comprised ofa verticaltakeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Inspire 1 has a maximum gross weight of approximately 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed ofapproximately 42 knots. The DJI Inspire 1is equipped with four mainrotors; driven by Lithium Polymerbattery powered electric motors. The DJI Inspire 1that willbe operatedbyNelsonForensicswill be registeredinaccordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47,AircraftRegistration, and marked in accordance with 14 C.F.R. Part 45, Identification andRegistration Marking. BASIS FORPETITION Petitioner, Nelson Forensics, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Inspire 1, UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). In consideration ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Nelson Forensics operation ofDJI Inspire 1UAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

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### Accordingly, Nelson Forensics requests relief from Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) & 

### (a)(2), and 91.417(a) & 

### (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Nelson Forensics submits that the requested reliefis proper since an equivalent level of safety will be ensured. Nelson Forensics will use experienced personnel ortechnicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log and DJI Inspire 1 User Manual). Furthermore, Nelson Forensics will document and maintain all maintenance records for the DJI Inspire 1UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, 

### is requested by Nelson Forensics to the extent necessary to allow a Pilot in Command (PIC) holding aprivate pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1UAS in a

manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Nelson Forensics seeks relieffrom Section 91.7(a), entitled Civil aircraft airworthiness, 

### because the DJI Inspire 1UAS does notrequire an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Nelson Forensics submits that they will ensure that the DJI Inspire 1UAS is in an airworthy condition, priorto every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log and DJI Inspire 1 User Manual), and that the aircraft are in a condition for safe flight.

7Nelson Forensics also seeks an exemption from the requirements of Section 91.121, entitledAltimeter Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter onboard. However, altitude information ofthe DJI Inspire 1UAS will be provided to the PIC via Global Positioning System (GPS) equipment andradio communicationstelemetry datalink, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Nelson Forensics' operation ofthe DJI Inspire 1UAS within visual line ofsight, at orbelow400 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. Additionally, Nelson Forensics seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirementsforflight in VFR conditions. Nelson Forensics submits that safety will not be affected by operation ofthe DJI Inspire 1UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration ofapproximately 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly afterthat for at least4.5 minutes. Batterypowerindicators

are also able to show exactly how much batterypower is left, as well as howmuch time is needed to return safely backto point oftake off. In accordancewith 14 C.F.R. § 11.81,NelsonForensicsprovidesthefollowing information in support ofits petition for exemption: 

### A. Name And Address OfThe Petitioner. The name and address ofthe Petitioner is: NelsonForensics 2740 Dallas Parkway, Suite 220 Plano, TX 75093

8The point ofcontact for this Petition and specific contact information is as follows: Erik L. Nelson, Ph.D., P.E. NelsonForensics 2740 Dallas Parkway, Suite 220 Plano, TX 75093 Tel: (469) 429-9000 Fax: (469) 326-5200 Email: enelson@nelsonforensics.com 

### B. The Specific Sections Of 14 C.F.R. From Which Nelson Forensics Seeks Exemption.**~** 

### 1. Nelson Forensics Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitledPrivatepilotprivileges andlimitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may thatperson, for compensation orhire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, act as PIC ofan aircraft in connection with any business or employment if- (1) The flight is only incidental to that business oremployment; and (2) The aircraft does not carrypassengers orproperty for compensation or hire. 

### 2. Nelson Forensics Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No personmay operate a civil aircraft unless it is in an airworthy condition. 

### 3. NelsonForensics Seeks ExemptionFromTheRequirementsOfSection91.121. Section 91.121, entitledAltimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, byreference to an altimeter that is set, when operating--

9(1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting ofa station along the route and within 1 00 nautical miles ofthe aircraft; (ii) Ifthere is no station withinthe areaprescribed in paragraph (a)(l)(i) of this section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 

### 4. Nelson Forensics Seeks Exemption From The Requirements OfSection 91.151(b). Section 91.151, entitled Fuel requirementsforflight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed, to fly afterthat for at least 20 minutes. 

### 5. Nelson Forensics Seeks Exemption From The Requirement OfSection 91.405(a). Section 91.405, entitledMaintenance required, subsection (a), states the following: Each owner or operator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.] 

### 6. Nelson Forensics Seeks Exemption From The Requirements OfSection 91.407(a)(l) Section 91.407, entitled Operation aftermaintenance,preventivemaintenance, rebuilding,

or alteration, subsection (a)(l), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-- (1) It has been approved for return to service by a person authorized under§ 43.7 ofthis chapter[.] 107. Nelson Forensics Seeks Exemption From The Requirements Of Sections 91.409(a)(l) And 91.409(a)(2). Section 91.409, entitledInspections, subsection (a), states the following: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 ofthis chapter and has been approved for return to service by a person authorized by§ 43.7 ofthis chapter; or (2) Aninspectionfor the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. 8. Nelson Forensics Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitledMaintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with§§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section: (1) Records ofthemaintenance, preventive maintenance, and alteration andrecords of the 1 00-hour, annual, progressive, and other required or approved inspections, as appropriate, for eachaircraft (includingthe airframe) and eachengine, propeller, rotor, and appliance ofan aircraft. The records must include-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) Thetotal time in service ofthe airframe, eachengine, eachpropeller, and each rotor. (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed onthe aircraft which are required to be overhauled on a specified time basis.

11(iv) The current inspection status ofthe aircraft, includingthe time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner oroperator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(l) ofthis section shall be retained until the work is repeated or superseded by other work orfor 1year after the work is performed. (2) The records specified inparagraph (a)(2) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner oroperator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. 

### C. TheExtentOfReliefNelson Forensics Seeks AndTheReason Nelson Forensics Seeks TheRelief. 1. Extent Of Relief Nelson Forensics Seeks And The Reason Nelson Forensics Seeks ReliefFrom Section 61.113(a) And (b). Relieffrom Section 61.113(a) and (b) entitledPrivatepilot privilegesandlimitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This reliefis requested since the limitations set forth in Section 61.113(a) and (b) state that

a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

12business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers orproperty for compensation or hire. As set forth more fully below, Nelson Forensics submits that an equivalent level ofsafety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a manner consistent with the operations specifications as described inthis exemption, including evasive andemergencymaneuvers, as well

as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Nelson Forensics submits that all flights ofthe DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant ofthis Petition: (1) will be incidental to Nelson Forensics' business; and (2) will not carry passengers orproperty for compensation orhire. 

### 2. Extent Of Relief Nelson Forensics Seeks And The Reason Nelson Forensics Seeks ReliefFrom Section 91.7(a). Relieffrom Section 91.7(a) entitled Civil aircraftairworthiness, is requested to the extent required to allow Nelson Forensics to determine that the DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log and DJI Inspire 1User Manual). Nelson Forensics seeks the requested reliefbecause the DJI Inspire 1 UAS do not require

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Nelson Forensics will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon its compliancewiththe operatingdocuments (i.e., MonthlyMaintenanceLog, andDJI Inspire 1) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

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### 3. Extent Of Relief Nelson Forensics Seeks And The Reason Nelson Forensics Seeks ReliefFrom Section 91.121. Relief from Section 91.121, entitled 

### Altimeter settings, may be required to allow flight operations ofthe DJI Inspire 1UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Nelson Forensics seeks the requested reliefbecause the DJI Inspire 1UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the DJI Inspire 1 UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information ofthe UA on the heads-up display ofthe GCS. 

### 4. Extent Of Relief Nelson Forensics Seeks And The Reason Nelson Forensics Seeks ReliefFrom Section 91.15l(b). Relieffrom Section 91.151(b) entitled 

### Fuel requirementsforflight in VFR conditions, is requested to the extent required to allow flights ofthe battery powered DJI Inspire 1UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly afterthat for at least4.5 minutes. Nelson Forensics seeks the requested reliefbecause without an exemption from Section 91.151(b), the flight time duration ofthe batterypowered DJI

14Inspire 1 UAS will severely constrain the practicality of any aerial video or still photo flight operations that Nelson Forensics proposes to conductpursuantto this Petition. Significantly, as set forth below, the technical specifications ofthe DJI Inspire 1UAS, the DJI Inspire 1operating documents, and Nelson Forensics' proposed operating limitations, ensure that Nelson Forensics will safely operate the battery powered DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

### 5. Extent Of Relief Nelson Forensics Seeks And The Reason Nelson Forensics Seeks ReliefFrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) & 

### (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Nelson Forensics requests relief from these Sectionsbecausethe DJI Inspire 1UAS do notrequire airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. All maintenance, alterations, orpreventative maintenance on the UAS ofthe DJI Inspire 1 performedby Nelson Forensics will be in accordance with the methods, techniques, and practices prescribed in the UAS operating documents (i.e., Monthly Maintenance Log and DJI Inspire 1 UserManual). Furthermore, only the Original EquipmentManufacturer (OEM) or qualified OEM maintainers will perform higher level inspections and maintenance per the operating documents and OEM standards. Nelson Forensics will document and maintain all maintenancerecords for the DJI Inspire 1UAS.

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### D. The Reasons Why Granting Nelson Forensics Request Would Be In The Public Interest; ThatIs, How It

### Would BenefitThePublic As A Whole. Granting the present Petition will further the public interest by allowing Nelson Forensics to safely, efficiently, and economically perform aerial video and photography within the NAS, commercially, in support ofengineering and/or architectural forensic practices, land surveys, and natural disaster research. Additionally, use ofthe DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Nelson Forensics' proposed operation of the DJI Inspire 1 UAS will be realized without implicating any privacy issues. 

### 1. The Public Will Benefit From Decreased Congestion OfTheNAS. The DJI Inspire 1UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Inspire 1UAS would reduce the amount ofmanned aircraft in the NAS, reduce noise and airpollution, as well as increase the safety oflife and property in the air and on the ground. Furthermore, byreducing the number ofmanned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UAS do not require an airport to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations. 

### 2. The Public Will BenefitFrom The Safety And Efficiency OfTheDJI Inspire 1 UAS. Conducting aerial acquisitions withthe DJI Inspire 1UAS, instead ofmanned aircraft, will greatly benefit the public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and 16electric motors, the DJI Inspire 1 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour ofleaded aviation fuel. The DJI Inspire 1UAS, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAS are propelledby battery powered electric motors, rather than an internal combustion engine. By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UAS (weighing approximately 6 pounds 7.5 ounces at its maximum gross weight with length of 17.7 inches, and withno fuel onboard), has less physical potential for collateral damage to life and property onthe ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons). 3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Inspire 1 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation ofthe DJI Inspire 1 UAS will allow United States based companies, like Nelson Forensics, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Inspire 1 UAS is

17one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Inspire 1 UAS, companies such as Nelson Forensics, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance ofU.S. companies, through commercial use ofthe DJI Inspire 1 UAS, provides a stable workforcethatincreases consumer spending; improves local, state, andfederal tax revenues; and allows companies to invest in research and development in order to remain competitive both inthe United States and abroad. 

### 4. ThereAre No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Nelson Forensics' proposed operation ofthe DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., Monthly Maintenance Log and DJI Inspire 1 User Manual) which requires property ownerinvolvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 

### E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By TheRule From Which Nelson Forensics Seeks Exemption. 1. 

### Reasons Why The DJI Inspire 1 UAS Meet The Conditions Of The FAA Modernization and Reform Act of2012 (FMRA) Section 333. In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Nelson Forensics' operation ofthe DJI Inspire 1 UAS meet

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### the conditions of FMRA Section 333, and will not require an airworthiness certificate m accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose athreat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.--Notwithstanding any other requirement of this subtitle, andnot later than 180 days after the date of enactment of this Act, the Secretary ofTransportation shalldetermine 

### if certain unmannedaircraftsystemsmayoperatesafely in the national airspace system before completion of theplan andrulemaking requiredbysection 332 of thisActor the guidance requiredbysection 334 of thisAct. (b) Assessment ofUnmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary shall determine, ata minimum- (1) which types of unmannedaircraft systems, 

### if any, as a result of their size, weight, speed, operational capability, proximity to airports andpopulated areas, andoperation within visual line of sightdo not create a hazardto users ofthe national airspace system or the public or pose a threat to national security; and (2) whethera certificate of waiver, certificate of authorization, orairworthiness certification undersection 44704 of title 49, UnitedStates Code, is required for the operation of unmannedaircraftsystems identified underparagraph (1). (c) Requirementsfor Safe Operation.--Ifthe Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirementsfor the safe operation ofsuch aircraftsystems in the national airspace system. 

### In seekingthis exemption,NelsonForensics submitsthatthe DJI Inspire 1UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

19a. The Specifications OfThe DJI Inspire 1UAS Demonstrate Its Safe Characteristics. The DJI Inspire 1 UAS does not create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. i. Technical Specifications OfThe DJI Inspire 

### 1 UAS. The technical specifications ofthe DJI Inspire 1 UAS are set forth by the DJI Inspire 1 User Manual, attached hereto as Appendix A. Appendix A contains proprietary information and is to be held in a separate file pursuantto 14 C.F.R. § 11.35(b) 1• ii. The DJI Inspire 

### 1 UAS Autonomous Flight and Navigation Modes Enable The UAS To Remain Within A Defined OperationalArea. The DJI Inspire 1 UAS may be operated in both semi and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe DJI Inspire 1UAS is provided in the DJI Inspire 1 User Manual attached hereto as Appendix A. Appendix A contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b) 1• iii. The DJI Inspire 

### 1 UAS Is Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link OrNavigation. A complete description ofthe Failsafe Functions ofthe DJI Inspire 1 UAS are set forth in the DJI Inspire 1 User Manual, attached hereto as Appendix A. Appendix A contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b) 1• iv. The DJI Inspire 1 GCS And Its Operation. A complete description ofthe operation and specifications ofthe DJI Inspire 1 GCS and flight control software is provided inthe DJI Inspire 1 User Manual. DJI Inspire 1 User Manual



### 20is attached hereto as Appendix A. Exhibit A contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b)1• 

### b. Flight Operations OfDJI Inspire 1 UAS Is Limited To The Line Of Sight OfA Certificated Pilot in CommandWith A Safety Observer. Nelson Forensics will only utilize certificated pilots who possess a current and valid FAA issued airman medical certificate to act as a pilot in command (PIC) ofthe DJI Inspire 1 UAS. Additionally, a safety observer will assist him at all times during flight time.



### c. Flights OfDJI Inspire 1UAS Will Be Conducted PursuantTo Specific OperatingLimitations. In seeking this exemption, Nelson Forensics proposes to commercially operate DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography within the NAS, pursuant to the following specific operating limitations: 1. Operations authorized bythis grant ofexemptionwill be limitedto the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a newpetition or a petitionto amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial video and photography. 3. The UAS may not be flown at an indicated airspeed exceeding 20 knots

. 4. The UA must be operated at an altitude ofno more than 400 feet above ground level (AGL), as indicatedbytheprocedures specifiedinthe operatingdocumentsunless a special request is made and approved by ATC. All altitudes reportedto ATC mustbe in feet AGL. 5. The UAS must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified onthe PIC's FAA-issued airman medical certificate. 6. The use offirst person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permittedduring flight operations. The PIC mustbe designatedbeforethe flight and cannot

21

### transfer his or her designation for the duration ofthe flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding otherairtraffic and other groundbased obstacles/obstructions and is notpermitted to operate the camera or other instruments. 9. The operating documents and the grant ofexemption must be accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. 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 ifit petitions for extension or amendment to the grant of exemption. Ifthe operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe 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. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service. 

### 2215. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorizedpersonmust make anentry in the aircraftrecord ofthe corrective action taken against discrepancies discovered between inspections. 17. ThePIC mustpossess at least aprivatepilotcertificate and at least a currentthird- class medical certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with howthe UAS will be operated underthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes oftraining the operator's PICs are permitted under the terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. During 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 C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Ifflight at night is required, a special request will be made at the FAA office closestto proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized. 20. TheUAmaynotoperatewithin 5 nautical miles ofan airportreferencepointas denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator's COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 21. The UA may 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. 22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% batterypower remaining.

2325. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 29. The UA mustremain clear and yield the right ofway to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipatingpersons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipatingpersons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessmentofthe risk ofoperating closerto those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 32. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Permission from 

### 24land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.
2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Nelson Forensics submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Nelson Forensics' proposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those ofcommercialpilotrequirements (See ExemptionNo. 11062); andthe airmanship skills necessary to safely operate the DJI Inspire 1 UAS, Nelson Forensics submits that the additional manned airmanship experience ofa commercially certificated pilot would not correlate to the airmanship skills necessary for Nelson Forensics' specific proposed flight operations. The FAA has previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,11063,11064,11065,11066,11067,11080,11109,11110,11112,11136,11138,11150, 11153,11156,11158,11159,11160,11161,11170,11171, 11172).

25Nelson Forensics will not allow any PIC to operate the DJI Inspire 1UAS unless that PIC has demonstrated,by meetingminimumflight-hour requirements orthe DJI Inspire 1UAS training and currencyrequirements, that the PIC is able to safely operatethe DJI Inspire 1UAS in amanner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.P.R. § 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours of those hours as a UAS pilot operating the same make and model ofUAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that

was obtained in compliance with applicable regulations will ensure an equivalent level ofsafety during Nelson Forensics' proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose ofmotion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours oftotaltime as a UAS rotorcraft pilot including at least I0 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of5hours as a UAS pilot operating the same make and model ofUAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours ofmulti-rotor time and the 10 hours may be included inthe total25 hours ofUAS rotorcraft time. In additionto the hourrequirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriateto practice and build proficiency inthe skills necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior documented flight experiencethat was obtainedin compliancewith applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be

26conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. ExemptionNo. 11138 atpage 15. Accordingly, Nelson Forensics will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1UAS unlessthatPIC has demonstrated, by meeting minimum flight-hour and currencyrequirements, thatthe PIC is able to safely operate the DJI Inspire 1UAS in amanner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, Nelson Forensics will ensure that the DJI Inspire 1 UAS is in an airworthy condition based upon the UAS's compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relieffrom Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,11063,11064,11065,11066,11067,11080,11109,11110,11112,11136,11138,11150, 11153,11156,11157,11158,11159,11160,11161,11170,11171, 11172). 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level ofsafety established by Section 91.121 will be maintained because the altitude information ofthe DJI Inspire 1UAS will be providedto the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path and altitude. This altitude information, combined withNelson Forensics' operationofthe DJI Inspire 1UAS withinvisual1ine ofsight, at orbelow500 feet AGL, 

### 27will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,11063,11064,11065,11066,11067,11080,11109,11112,11136,11138,11150,11153, 11156,11157,11158,11159,11160,11161,11170,11171, 11172). 

### 5. Reasons Why An Exemption From The Requirements Of Section 

### 91.15l(b) Would Not Adversely Affect Safety. A grant ofthis exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of(I) the technical specifications ofthe DJI Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, Nelson Forensics will ensure that it will safely operate the battery powered DJI Inspire 1UAS during daylight hours in visual metrological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications ofthe DJI Inspire 1 UAS; the limitations on the proposed flight operations; and the location ofthe proposed operations, will

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage. At the critically low battery level, the DJI Inspire 1UAS will descend and land automatically.

28Significantly, previous exemptions granted by the FAA concernmg Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relieffrom Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136,11138,11150,11153,11156,11157,11158,11159,11160,11161 , 11170,11171, 11172). 

### 6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) & 

### (b) Would Not Adversely Affect Safety. In seekingthis exemption,NelsonForensics submitsthatthe equivalentlevel ofsafety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Nelson Forensics will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log and DJI Inspire 1User Manual). Furthermore, Nelson Forensics will document and maintain all maintenance records for the DJI Inspire 1UAS. Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents, Nelson Forensics will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy ofthe DJI Inspire 1 User Manual is attached hereto as Appendix A. Likewise, the exemption sought will not adversely affect safety because Nelson Forensics will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. 29Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected whenthe technical characteristics and operating limitations ofthe UAS are considered. In consideration ofNelson Forensics' proposed operating limitations, the operating documents, and the technical aspects ofthe DJI Inspire 1 UAS, Nelson Forensics submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAAhaspreviously granted reliefspecificto UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,11063,11064,11065,11066,11067,11080,11109,11110,11112,11136,11138,11150, 11153,11156,11157,11158,11159,11160,11161,11170,11171, 11172). 

### 7. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled 

### Special Conditions, Nelson Forensics requests that the FAA prescribe special conditions for the intended operation ofthe DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas ofthe United States for compensation

30or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create

a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

### § 21.16, for operation ofthe DJI Inspire 1 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel orunusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level ofsafety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. 

### § 21.16, the FAA may prescribe special conditions for Nelson Forensics' intended operation ofthe DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). F. A Summary ThatCanBe Published In TheFederalRegister, stating: TheRules From Which Nelson Forensics Seeks Exemption: Nelson Forensics seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91

.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and91.417(a) & (b).

31

### A BriefDescription OfThe Nature OfTheExemption Nelson Forensics Seeks: This exemption will permit Nelson Forensics to commercially operate an Unmanned AircraftSystem (UAS)for thepurpose of conducting aerial video andphotography within the NationalAirspace System (NAS). 

### G. Any Additional Information, Views, Or Arguments Available To Support Nelson Forensics' Request. This Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely inthe NAS. As such, Nelson Forensics' request for exemption maybe granted pursuant to the authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create

a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Nelson Forensics will operate the DJI Inspire 1 UAS safely intheNAS, without creating a hazardto users oftheNAS, orthe public, orotherwisepose a threat to national security. 

### CONCLUSION As set forth herein, Nelson Forensics seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe DJI Inspire 1UAS commercially, without an airworthiness certificate, for the limitedpurpose ofconducting aerial video andphotography overcertainareas oftheUnited States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAAModernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing Nelson Forensics to safely, efficiently, and economically operate the DJI Inspire 1 UAS commercially within the NAS.

32WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, Nelson Forensics respectfully requests that the Administrator grant this Petition for an exemptionfrom the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Nelson Forensics to operate the DJI Inspire 1 UAS commercially for the purpose ofconducting aerial video and photography withinthe NAS.

33Dated: August 21, 2015 Respectfully submitted,

Erik L. Nelson, Ph.D., P.E. President and CEO NelsonForensics 2740 Dallas Parkway, Suite 220 Plano, TX 75093 Tel: (469) 429-9000 Fax: (469) 326-5200 Email: enelson@nelsonforensics.com

Appendices: A- Link to DJI Inspire 1 Manual: http://download.dji-innovations.com/downloads/inspire _1/en/Inspire_1_ User _Manual_ vl.O

_en.pdf

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