August, 21 2015 

Attn: 

U.S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey 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 

1 UNMANNED 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 

Petitioner 
TABLE OF CONTENTS 

Page 

GLOSSARY OF ABBREVIATIONS ................................. .. .. ...................................... ................... 3 

SUMMARY ..... ... ............. .................................................... ..... ...... .......... ................ ... ............. ....... 4 

INTRODUCTION AND INTERESTS OF PETITIONER .................... ............................... ........... 4 

BACKGROUND .......... .. ..... .. ..... ............... .. ....... ........ ........... .............. ... .. .......... .............. ............... 6 

BASIS FOR PETITION ...... .... .. ........... ... ............. .... ................ .................................... .......... .. ........ 6 

NAME AND ADDRESS OF PETITIONER ................. .. ............... ...... .......... ................ ...... 8 

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 

NELSON FORENSICS SEEKS THE RELIEF ............................................................... 12 

THE REASONS WHY GRANTING NELSON FORENSICS' REQUEST WOULD BE IN 

THE PUBLIC INTEREST .............................................................................................. 15 

THE REASONS WHY GRANTING THE EXEMPTION TO NELSON FORENSICS 

WOULD NOT ADVERSELY AFFECT SAFETY ............................................................ 18 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. ................ 31 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT NELSON FORENSICS' REQUEST ............................................................... 32 

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

APPENDICES ................................................................................................ 33 

2 
AGL 

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 OF ABBREVIATIONS 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

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 of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

3 
SUMMARY 

Nelson Forensics, LLC dba. Nelson Forensics hereafter referred to as Nelson Forensics 

seeks exemption from the requirements 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 of the FAA Modernization and Reform 

Act of 2012 (FMRA). This exemption will permit Nelson Forensics to operate an Unmanned 

Aircraft System (UAS) for the commercial purpose of conducting 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 THE PETITIONER 

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. 

Nelson Forensics' mission is to reduce risk and prevent failure by combining ethical standards with 

advanced technologies in an effort to discover cause of failure and to educate our clients and peers 

on our findings. The objective of Nelson Forensics and our Unmanned Aircraft System (DJI 

Inspire 1) aerial operations is to provide an affordable, high-quality production system for a variety 

of governmental, commercial, public, and residential uses, specifically targeting: 

• Forensic engineering 

• Forensic architecture 

• Natural disaster investigation 

• Fire investigation 

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• Roofing system assessment 

• Cost estimating and appraisals 

• Land surveys 

5 
BACKGROUND 

Unmanned Aircraft ystems: Inspire 1 UAS 

Nelson Forensics seeks an exemption to operate the DJI Inspire 1 UAS (Inspire 1 UAS) 

for compensation or hire within the NAS. The DJI Inspire 1 UAS is comprised of a vertical takeoff 

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 of approximately 42 knots. The DJI Inspire 1 is equipped with four 

main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Inspire 1 that will be operated by Nelson Forensics will be registered in accordance 

with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, 

and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. 

BASIS FOR PETITION 

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 of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Nelson Forensics operation of DJI Inspire 1 UAS meets the 

conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. 

6 
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 relief is proper since an equivalent level of 

safety will be ensured. Nelson Forensics will use experienced personnel or 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 1 User Manual). Furthermore, Nelson Forensics will document and maintain all 

maintenance records for the DJI Inspire 1 UAS. 

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 a private 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 1 UAS 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 relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Inspire 1 UAS does not require 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 1 UAS is in an airworthy condition, prior to 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. 

7 
Nelson Forensics also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Inspire 1 UAS will be provided to the PIC via 

Global Positioning System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude 

information, combined with Nelson Forensics' operation of the DJI Inspire 1 UAS within visual 

line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Nelson Forensics seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Nelson Forensics submits that 

safety will not be affected by operation of the 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 approximately 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes. Battery power indicators 

are also able to show exactly how much battery power is left, as well as how much time is needed 

to return safely back to point of take off. 

In accordance with 14 C.F.R. § 11.81, Nelson Forensics provides the following information 

in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner is: 

Nelson Forensics 

2740 Dallas Parkway, Suite 220 

Plano, TX 75093 

8 
The point of contact for this Petition and specific contact information is as follows: 

Erik L. Nelson, Ph.D., P.E. 

Nelson Forensics 

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, entitled Private pilot privileges and limitations: 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 

that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if-

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property 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 person may operate a civil aircraft unless it is in an airworthy condition. 

3. Nelson Forensics Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter 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, by reference to an altimeter that is set, when operating--

9 
(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 1 00 nautical miles of the aircraft; 

(ii) Ifthere is no station within the area prescribed in paragraph (a)(l )(i) of 

this section, the current reported altimeter setting of an appropriate available 

station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before departure. 

4. Nelson Forensics Seeks Exemption From The Requirements Of Section 

91.151(b). 

Section 91.151, entitled Fuel requirements for flight 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 of intended landing and, assuming normal cruising speed, to fly after that for 

at least 20 minutes. 

5. Nelson Forensics Seeks Exemption From The Requirement Of Section 

91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft-

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. Nelson Forensics Seeks Exemption From The Requirements Of Section 

91.407(a)(l) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 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[.] 

10 
7. Nelson Forensics Seeks Exemption From The Requirements Of Sections 

91.409(a)(l) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this 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 of this chapter and has been 

approved for return to service by a person authorized by§ 43.7 of this chapter; or 

(2) An inspection for the issuance of an 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, entitled Maintenance 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 ofthe maintenance, preventive maintenance, and alteration and records 

of the 1 00-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and 

appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

11 
(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft and its 

appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety directive 

number and revision date. If the 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 or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(l) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under§ 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service. 

C. The Extent Of Relief Nelson Forensics Seeks And The Reason Nelson Forensics Seeks 

The Relief. 

1. Extent Of Relief Nelson Forensics Seeks And The Reason Nelson Forensics 

Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 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 relief is 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 

12 
business or employment if: (1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

As set forth more fully below, Nelson Forensics submits that an equivalent level of safety 

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 in this exemption, including evasive and emergency maneuvers, as well 

as maintaining appropriate distances from people, vessels, vehicles and structures. 

Further, Nelson Forensics submits that all flights of the DJI Inspire 1 UAS, conducted by 

the PIC pursuant to the grant of this Petition: (1) will be incidental to Nelson Forensics' business; 

and (2) will not carry passengers or property for compensation or hire. 

2. Extent Of Relief Nelson Forensics Seeks And The Reason Nelson Forensics 

Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, 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 1 User Manual). 

Nelson Forensics seeks the requested relief because 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 

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI 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. 

13 
3. Extent Of Relief Nelson Forensics Seeks And The Reason Nelson Forensics 

Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations ofthe DJI Inspire 1 UAS, 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 relief because the DJI Inspire 1 UA'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 of the proposed operations, relief from 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 of safety 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 of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Nelson Forensics Seeks And The Reason Nelson Forensics 

Seeks ReliefFrom Section 91.15l(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered DJI Inspire 1 UAS 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 of intended landing and, assuming normal cruising 

speed, to fly after that for at least 4.5 minutes. Nelson Forensics seeks the requested relief because 

without an exemption from Section 91.151 (b), the flight time duration of the battery powered DJI 

14 
Inspire 1 UAS will severely constrain the practicality of any aerial video or still photo flight 

operations that Nelson Forensics proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the 

DJI Inspire 1 operating 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 of intended 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 Relief From 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 

Sections because the DJI Inspire 1 UAS do not require 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, or preventative maintenance on the UAS of the DJI Inspire 1 

performed by 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 

User Manual). Furthermore, only the Original Equipment Manufacturer (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 maintenance records for the 

DJI Inspire 1 UAS. 

15 
D. The Reasons Why Granting Nelson Forensics Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public 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 of engineering and/or architectural forensic practices, land surveys, and 

natural disaster research. Additionally, use of the 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 Of The NAS. 

The DJI Inspire 1 UAS 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 of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use 

of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and 

air pollution, as well as increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned 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 takeoff or land. Likewise, a reduction of manned 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 of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI 

Inspire 1 UAS. 

Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial video and still photography flight operations. By using battery power and 

16 
electric 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 1 UAS, while reducing the carbon 

footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by 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 

with no fuel on board), has less physical potential for collateral damage to life and property on the 

ground, and in the air, compared to the manned aircraft that typically conduct similar operations 

(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 

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 of the 

DJI Inspire 1 UAS will allow United States based companies, like Nelson Forensics, to remain 

competitive and contribute to growth of the 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 

17 
one 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 of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, provides a 

stable workforce that increases consumer spending; improves local, state, and federal tax revenues; 

and allows companies to invest in research and development in order to remain competitive both 

in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

Nelson Forensics' proposed operation of the 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 owner involvement 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 The Rule From Which Nelson Forensics Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 UAS Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, Nelson Forensics' operation of the DJI Inspire 1 UAS meet 

18 
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 of the 

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 

states the following, in part: 

(a) In General. --Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 

of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum-

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national 

security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for 

the operation of unmanned aircraft systems identified under paragraph (1). 

(c) Requirements for Safe Operation. --If the Secretary determines under this section 

that certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system. 

In seeking this exemption, Nelson Forensics submits that the DJI Inspire 1 UAS 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. 

19 
a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe 

Characteristics. 

The DJI Inspire 1 UAS does not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability. 

i. Technical Specifications Of The DJI Inspire 1 UAS. 

The technical specifications of the 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 pursuant to 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 

Operational Area. 

The DJI Inspire 1 UAS may be operated in both semi and fully autonomous flight modes. 

A complete description of the flight and navigational modes of the DJI Inspire 1 UAS 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 Or Navigation. 

A complete description of the 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 of the operation and specifications of the DJI Inspire 1 GCS and 

flight control software is provided in the DJI Inspire 1 User Manual. DJI Inspire 1 User Manual 

20 
is 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 Of DJI Inspire 1 UAS Is Limited To The Line Of 

Sight Of A Certificated Pilot in Command With 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) of the DJI Inspire 1 UAS. 

Additionally, a safety observer will assist him at all times during flight time. 

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations. 

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 by this grant of exemption will be limited to 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 

of any other aircraft will require a new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial 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 of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents unless a special 

request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the 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 on the PIC's FAA-issued airman medical certificate. 

6. The use of first 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 

permitted during flight operations. The PIC must be designated before the flight and cannot 

21 
transfer his or her designation for the duration of the 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 other air traffic and other ground based obstacles/obstructions and is not permitted 

to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a 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 of exemption 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 if it petitions for extension 

or amendment to the grant of exemption. If the 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. If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. 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 of a 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 of work accomplished, and the 

signature of the authorized person returning the UAS to service. 

22 
15. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third- 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 how the UAS will be operated under the 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 of training the operator's 

PICs are permitted under the terms of the 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). If flight at 

night is required, a special request will be made at the FAA office closest to proposed area 

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

20. The UA may not operate within 5 nautical miles of an airport reference point as 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 of unpredicted 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% battery power remaining. 

23 
25. 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 

(NOT AM) 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 of airspace, 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 of the 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 must remain clear and yield the right of way 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 nonparticipating persons 

(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 of an accident. The operator must 

ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 feet 

of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission and 

the PIC has made a safety assessment of the risk of operating closer to 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 

24 
land 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 of the 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 of operations, and the operating limitations 

set forth-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those 

of commercial pilot requirements (See Exemption No. 11 062); and the airmanship skills necessary 

to safely operate the DJI Inspire 1 UAS, Nelson Forensics submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the airmanship 

skills necessary for Nelson Forensics' specific proposed flight operations. 

The FAA has previously granted relief from 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). 

25 
Nelson Forensics will not allow any PIC to operate the DJI Inspire 1 UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour requirements or the DJI Inspire 1 UAS training 

and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner 

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 of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of 

those hours as a UAS pilot operating the same make and model of UAS 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 of safety 

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 of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours oftotal time as a UAS 

rotorcraft pilot including at least I 0 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 of 5 hours 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 of multi-rotor time and the 10 hours may be 

included in the total25 hours ofUAS rotorcraft time. In addition to the hour requirements, 

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 appropriate to practice and build proficiency in the skills necessary to safely 

conduct the petitioner's proposed operations. The FAA also finds that prior documented 

flight experience that was obtained in compliance with applicable regulations would satisfy 

this requirement. Training, proficiency, and experience-building flights can also be 

26 
conducted 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. 

Exemption No. 11138 at page 15. 

Accordingly, Nelson Forensics will ensure safe operations by not allowing any PIC 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. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety 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 relief from 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 of safety established by Section 91.121 will be maintained because 

the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipment 

and a radio communications telemetry data link, which downlinks from the UA to the GCS for 

active monitoring of the flight path and altitude. This altitude information, combined with Nelson 

Forensics' operation of the DJI Inspire 1 UAS within visual1ine of sight, at or below 500 feet AGL, 

27 
will 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 of this 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 of the proposed flight 

operations. Accordingly, Nelson Forensics will ensure that it will safely operate the battery 

powered DJI Inspire 1 UAS 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 of intended 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 of the DJI Inspire 1 UAS; 

the limitations on the proposed flight operations; and the location of the 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 1 UAS 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 1 UAS will descend and land automatically. 

28 
Significantly, previous exemptions granted by the FAA concernmg Section 91.151 

establish that safety is not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered. Relief has 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 relief from 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 seeking this exemption, Nelson Forensics submits that the equivalent level of safety 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 1 User Manual). Furthermore, Nelson 

Forensics will document and maintain all maintenance records for the DJI Inspire 1 UAS. 

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 of the 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. 

29 
Furthermore, 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 when the technical characteristics and operating limitations of the UAS are considered. 

In consideration of Nelson Forensics' proposed operating limitations, the operating documents, 

and the technical aspects of the 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 FAA has previously granted relief 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). 

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 of the 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 §§ 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 of the United States for compensation 

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

a hazard to users of the 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 of the UAS in 

the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§ 21.16, for operation of the 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 or unusual design 

features of the 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 of a novel or unusual design feature of the 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 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety 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 of the 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 That Can Be Published In The Federal Register, stating: The Rules 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), 

and 91.417(a) & (b). 

31 
A Brief Description Of The Nature Of The Exemption Nelson Forensics Seeks: 

This exemption will permit Nelson Forensics to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and photography within 

the National Airspace 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 of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, Nelson Forensics' request for exemption may be 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 of the 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 

in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose 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 of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial video and photography over certain areas of the United States. 

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of 

the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, 

by allowing Nelson Forensics to safely, efficiently, and economically operate the DJI Inspire 1 

UAS commercially within the NAS. 

32 
WHEREFORE, 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 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), and 

91.417(a) & (b), and permit Nelson Forensics to operate the DJI Inspire 1 UAS commercially for 

the purpose of conducting aerial video and photography within the NAS. 

33 
Dated: August 21, 2015 

Respectfully submitted, 

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 

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 

34