Name/Address of Petitioner:

Inman Endeavors LLC

Attn: Neil Inman 

9700 Anchusa Trl

Austin, TX 78736

Phone: 512-988-9996

Email: neilinman@icloud.com

SUMMARY

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), Inman Endeavors

LLC, dba. NuAge Aerial Solutions, hereby requests a determination by the Secretary of Transportation 

authorizing conduct of commercial operations of its UAS for the purposes of photography, videography, 

photogrammetry, inspection services, Geo-surveys, aerial mapping, precision agriculture, support

services for public service entities, monitoring services for companies, and UAS Pilot training. 

Exemption is requested from the following regulations for this purpose:

- 14 C.F.R. Part 21, Subpart H

- 14 C.F.R. § 45.23 (b)

- 14 C.F.R. § 61.113 (a), (b)

- 14 C.F.R. § 61.3 (d)(2)(iii)

- 14 C.F.R. § 91.7 (a), (b)

- 14 C.F.R. § 91.9 (b)(2)

- 14 C.F.R. § 91.103

- 14 C.F.R. § 91.109

- 14 C.F.R. § 91.119 (b), (c)

- 14 C.F.R. § 91.121

- 14 C.F.R. § 91.151 (a)(1)

- 14 C.F.R. § 91.405 (a), (b)

- 14 C.F.R. § 91.407 (a)(1)

- 14 C.F.R. § 91.409 (a)(1)-(2)

- 14 C.F.R. § 91.417 (a), (b)

Appendix A includes detailed exemption requests and demonstrates how these exemptions are in the 

public interest and will not impact level of safety. 
Commercial Operation

Inman Endeavors, LLC was founded by Neil Inman, a former fast jet and drone pilot within the Royal Air 

Force. He has over 20 years’ flight experience and 3,100 flight hours, over 1,000 of which have been on 

UAS. He has performed as a military Qualified Flying Instructor (QFI), Examiner, Operations Supervisor, 

Air Checking Officer, Duty Authorizer, Duty Aircrew Officer, Instrument Rated Pilot and LRE Instructor.

He currently holds a FAA issued Private Pilot’s License. 

During his military service, he conducted UAS operations in New Mexico, Nevada and Afghanistan, 

working alongside US Air Force forces.

The company would like to branch into UAS operations, under the assumed name NuAge Aerial 

Solutions, and seeks exemption from Section 333 to do so. Neil Inman would be the head of Flight 

Operations, training new staff and setting up Standard Operating Procedures (SOPs) to ensure the safety 

of all flight operations. His military experience in these areas will bring rigor to the UAS operations and 

ensure an equivalent level of safety is met should the requested exemptions be granted.

During his military service, Neil has taken the following courses which have provided knowledge in 

human factors awareness, crew resource management, risk management and flight instruction, all of 

which he would leverage during the setup and operation of all flight activities:

- Junior Officers Command 

- Central Flying School Instructor

- Central Flying School Examiner

- Flight Safety

- Flying Supervisors

- Forward Air Controller Instructor (JFACTSU)

In his role, Neil would ensure that for every flight, the PIC:

- Had a valid pilot’s license and met minimum flight-hour and currency requirements per internal 

SOPs or FAA guidelines, as they became available

- Had received training in safety, evasive and emergency maneuvers in order to ensure they were 

able to operate in a consistently safe manner

- Contacted the controlling air traffic organization to issue a NOTAM, where required

- Obtained a preflight briefing from a pilot briefer

- Conducted a comprehensive worksite inspection and analysis, identifying limits of customer 

property or authorized access areas

- Conducted preflight planning in accordance with Section 91.103 Preflight Action

- Only operated in areas with the consent of the landowner or designated representative

- Identified potential obstructions or other hazards to safe operation

- Cleared the area of personnel or bystanders that are non-essential to the operation

- Conducted a preflight safety briefing to Visual Observer (VO) and participating persons
- Completed a safety check list prior to each flight, ensuring that the UAS was in an airworthy 

condition 

- Yielded to manned air traffic at all times

- Maintained voice communications with VO and participating persons

- Operated under Class D visual flight rules, defined as 500 feet below and 2000 feet horizontal 

from clouds with a minimum of 3 statute miles of visibility

- Did not exceed an altitude of 400 feet AGL as determined by the installed GPS

- Kept operating documents, manuals, authorizations and exemptions in a binder collocated with 

the GCS

- Immediately terminated flight, in the safest manner possible, when safety to persons or 

property became compromised

- Terminated flight, in the safest manner possible, when unable to comply with these limitations 

or any other limitations granted as part of this exemption

- Conducted a post-flight inspection of the UAS to identify potential maintenance requirements

Furthermore, the company will ensure that maintenance and inspections are performed in accordance 

with the UAS Manufacturer’s User Manual. All inspection, maintenance and alterations will be 

documented and maintained in a record.

Unmanned Aircraft Systems To Be Used

The Applicant’s commercial operations and training activities will take place in Operation Areas defined 

by the Applicant’s COA applications prior to each commercial flight or training exercise. The proposed 

UAS to be utilized all weigh less than 55 pounds, including energy sources and equipment, fly at an 

airspeed of under 87 knots, and pose little risk of injury or property damage.

The Applicant proposes to use the following multirotor UAS platforms for its operations under this 

application, which have received approval in other Section 333 Exemption requests1:

UAS Performance & Other Details can be found in online User Manuals below:

Note: These files are too big to upload electronically to your system

DJI Inspire 1 http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

DJI Phantom 2 

Vision+

http://download.dji-innovations.com/downloads/phantom-2-

vision/en/Phantom_2_Vision_User_Manual_v1.8_en.pdf

DJI Phantom 2 http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.p

df

DJI Phantom 3 http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Man

ual_v1.2_en.pdf

DJI Spreading http://download.dji-

 

1

Exemption 12029 was for DJI Phantom 1, DJI Phantom 2, DJI Inspire 1 and DJI S1000. Exemption 11969 was for 

the DJI S900, DJI Inspire 1 and Phantom 2 Vision. 
Wings S900 innovations.com/downloads/s900/en/S900_User_Manual_v1.2_en.pdf

DJI Spreading 

Wings S1000

http://download.djiinnovations.com/downloads/s1000/en/S1000_User_Manual_v1.10_en.pdf

DJI Matrice 100 http://download.djiinnovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf

EO/IR/Thermal Imagers may be used for data acquisition, depending on the service being rendered. 

These will be attached to the aircraft using either a two-axis or three-axis camera gimbal. 

Privacy

All flights will be conducted in accordance with any federal, state or local laws regarding privacy.

Public Interest

Approval of exemptions, allowing commercial operations of UAS as requested, is in the public interest 

for the following reasons:

Risk Reduction Over Traditional Operations

The use of UAS, due to their size, lack of crew & passengers, and lack of flammable fuels, makes them 

much less likely to cause damage to life and property compared to a traditional aircraft performing 

similar operations.

Public Awareness Regarding Safe and Responsible Use of UAS

Safe commercial operation of UAS by qualified individuals will help demonstrate that the FAAs UAS FARS 

provide a safe and effective means in which to govern the NAS. By putting military grade safety 

protocols into place around all operations, our company seeks to become an advocate for the practice 

of lawful UAS operations.

Economic Benefits

Using UAS as a replacement for traditional aircraft will greatly reduce the cost of aerial services, making 

them available to a larger market. This, combined with the rapid development of innovative uses of this 

technology, will undoubtedly drive up demand, resulting in an increase in jobs within this emerging 

market. 

It is expected that the inventive use of UAS will result in:

- Enhanced agricultural practices

- More efficient and frequent inspection of infrastructure, resulting in improve safety

- More efficient and frequent inspection of pipelines, resulting in a reduction in loss product

Environmental Benefits

The UAS used will be battery operated, resulting in zero emissions and significantly reduced noise when 

compared to traditional aircraft. 
Conclusion

This exemption request has outlined the services to be performed by the UAS, exemptions requested, 

PIC qualifications and experience, operational procedures to be followed to ensure safety and conduct 

in accordance with the appropriate FARs, details of the UAS to be used, and how this request is in the 

public interest.

Inman Endeavors LLC, dba. NuAge Aerial Solutions, fully intends to operate within the appropriate FAA, 

local, state and national regulations applicable to its operations and hopes to successfully showcase how 

the safe use of UAS within NAS can be beneficial to the local community and national economy. 
Appendix A – Exemptions Requested

FAR Requirement/Limitation Justification

14 C.F.R. Part 21, Subpart H Issuance of airworthiness 

certificates 

The Federal Aviation Act (49 U.S.C. § 44701 (f)) and Section 333 of the 

Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate upon consideration of the 

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

populated areas of the particular UAS. Given the small size of the UAS, 

the limited operating area, and the fact that it will carry neither 

passengers nor flammable/explosive fuels, the requested exemption 

meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the FMRA.

14 C.F.R. § 45.23 (b) Requirement to display 

registration number on aircraft

Given the small size of the aircraft, two-inch lettering, as required by 

the regulation, may not be feasible. The registration number will be 

displayed as large as practicable. 

14 C.F.R. § 61.113 (a), (b) No person who holds a private 

pilot certificate can engage in 

commercial operations

Because the UAS will not being carrying a pilot or passenger and the 

Operations Area will be controlled, with all flights planned in advance, 

the equivalent level of safety provide by the requirements will be met 

by requiring the PIC operating the aircraft to have minimum flight-hour 

and currency requirements and operate at appropriate distances from 

people, vessels, vehicles and structures. Furthermore, each PIC will 

receive training in safety, evasive and emergency maneuvers in order 

to ensure they are able to operate in a consistently safe manner, per 

SOPs to be set up by the company.

14 C.F.R. § 61.3 (d)(2)(iii) Requirement for pilot certificate The PIC performing training activities under this exemption may not 

hold a FAA-issued flight instructor certificate. An equivalent level of 

safety will be achieved by the Applicant’s adherence to the procedures 

set forth in the SOP and Manufacturer Instructions.

14 C.F.R. § 91.7 (a), (b) Airworthiness requirement As there will be no airworthiness certificate issued for the aircraft, no 

FAA regulatory standard will exist for determining airworthiness. An 

equivalent level of safety will be provided by the small size of the 

aircraft and the requirements contained in the SOP and Manufacturer 

Instructions for maintenance and use of safety check lists prior to each 

flight. The Applicant will ensure that the UAS is in an airworthy 

condition prior to each flight based on compliance with the 

specifications in the SOP and Manufacturer Instructions.
FAR Requirement/Limitation Justification

14 C.F.R. § 91.9 (b)(2) Requirement for manual to be 

available in the cockpit

Given its size, the aircraft is not capable of carrying a flight manual. 

However, by keeping all operating documents, manuals, authorizations 

and exemptions in a binder co-located with the ground control point 

where the pilot flying the UAS will have immediate access to it, an 

equivalent level of safety will be maintained.

14 C.F.R. § 91.103 Requirement for crew members 

to be onboard

As FAA approved flight manuals will not be on board the aircraft, and 

the aircraft is not capable of carrying a pilot or crewmembers, 

exemption is required. An equivalent level of safety will be provided 

through the PIC following the procedures set forth in the SOP and 

Manufacturer Instructions.

14 C.F.R. § 91.109 Requirement for dual controls 

during flight instruction

The majority of UAS by design are developed with single operational 

control through the use of pre-determined GPS enabled waypoints 

programmed before or during flight in addition to the use of a single 

hand held transmitter or control station controlled by the PIC. If the 

design does not allow for dual controls during flight training, the 

exemption is requested to train operators and maintain proficiency. 

Where dual controls are available, they will be utilized during training 

activities. An equivalent level of safety will be achieved by conducting 

all training in a controlled, dedicated environment under close 

supervision of an experienced PIC.

14 C.F.R. § 91.119 (b), (c) Minimum altitudes for safe flight Commercial UAS operations will be conducted at or below 400 ft. AGL. 

Given the size, speed, weight and lack of fuel, as well as the locations 

where they are operated, the operation will be conducted with a 

greater level of safety than exists with current manned aviation 

operations.

14 C.F.R. § 91.121 Altimeter settings The UAS platform may not have a barometric altimeter, but rather a 

GPS which will provide altitude and geo-location data to the operator. 

GPS are precise within a few feet and combined with fail-safes and a 

visual observer the operation will meet an equivalent level of safety.

14 C.F.R. § 91.151 (a)(1) Fuel Requirements for flight in 

VFR conditions

The majority of UAS have flight times of an hour or less. Given the 

limitations of the UAS platform, a longer time frame for VFR conditions 

is reasonable. Operating the UAS platforms in controlled Operations 

Areas does not engender the type of risks that Section 91.151(a) was 

intended to alleviate given the size and speed of the UAS platforms. 

14 C.F.R. § 91.203 (a),(b) Requirement for registration and The FAA has previously determined that no airworthiness certification 
FAR Requirement/Limitation Justification

airworthiness certificates to be 

onboard

is necessary for UAS platforms. The Applicant therefore believes that 

no exemption is necessary from § 91.203. However, to the extent that 

the FAA find that § 91.203 is applicable to the Applicant’s operations, 

the Applicant requests an exemption from them. 

14 C.F.R. § 91.405 (a), (b), 

14 C.F.R. § 91.407 (a)(1),

14 C.F.R. § 91.409 (a)(1)-(2)

14 C.F.R. § 91.417 (a), (b)

Maintenance Inspections Given that these sections and Part 43 apply only to aircraft with an 

airworthiness certificate, these sections will not apply to the applicant. 

An equivalent level of safety will be achieved because the UAS is very 

limited in size, will carry a small payload, and will operate in restricted 

areas for a limited period of time. If mechanical issues arise, the UAS

can land immediately and will be operating from no higher than 400 

feet AGL. Per SOP, the PIC will ensure that the UAS is in working order 

prior to initiating flight. Maintenance and inspections will be performed 

in accordance with the UAS Manufacturer’s User Manual. All 

inspection, maintenance and alterations will be documented and 

maintained in a record.