## Name/Address of Petitioner:

Inman Endeavors LLC Attn: Neil Inman 9700 Anchusa Trl Austin, TX 78736 Phone: 702

- 767

- 0365 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

- survey s , ae rial mapping, p recision agriculture, support services for public service entities, monitoring services for companies, and UAS Pilot training.

Ex e mption 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 i ncludes detailed exemption requ ests and demonstrate s how these exemptions are in the public interest and will not impact level of safety.

Furthermore, a request is being made to fly UAS during night VFR/VMC utilizing night

- vision goggles and h igh resolution IR capabilities per justification listed in Appendix A.

## Commercial Operation

Inman Endeavors, LLC was founded by Neil Inman, a former fast jet and dron e pilot within the Royal Air Force. He has over 20 years ’ flight experi ence 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 Authori zer, Duty Aircrew Officer, Instrument Rated Pilot and LRE Instructor. He holds a F1042 medical certificate.

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 Operat ing 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 milita ry 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 activit ies:

- 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 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 maneuv ers in order to ensure they were able to operate in a consistently safe manner

- Contact ed the controll ing air traffic organization to issue a NOTAM

- Obtain ed a preflight briefing from a pilot briefer

- Conduct ed a comprehensive worksite inspection and analysis, identifying limits of customer property or authorized access areas

- Conduct ed preflight planning in accordance with Section 91.103 Preflight Action

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

- Identified potential obstructions or other hazards to safe operation

- Clear ed the area of personnel or bystanders that are non

- essential to the operation

- Conduct ed 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

- Yield ed to manned air traffic at all times

- Maintain ed voice communications with VO and participating persons

- Operate d 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 terminate d flight, in the safest manner possible, when sa fety to persons or property beca me compromised

- Terminate d 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 pote ntial maintenance requirements

Furthermore, the company will ensure that m aintenance 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 tr aining 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:

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.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf DJI Phantom 2 Vision + http://download.d ji

- innovations.com/downloads/phantom

- 2

-

vision/en/Phantom_2_Vision_User_Manual_v1.8_en.pdf DJI Phantom 2 http://download.dji

innovations.com/downlo ads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.p df DJI Phantom 3 http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_ Professional_User_Man ual_v1.2_en.pdf DJI Phantom FC40 http://download.dji

innovations.com/downloads/phantom_fc40/en/Phantom_FC40_User_Manual_v1. 06_en.pdf DJI Spreading http://download.dji

-Wings S900 innovation s.com/downloads/s900/en/S900_User_Manual_v1.2_en.pdf

DJI Spreading Wings S1000 http://download.dji

innovations.com/downloads/s1000/en/S1000_User_Manual_ v1.10_en.pdf DJI Matrice 100 http://download.dji

innovations.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 feder al, 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 th eir 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 o perations, our company s eeks 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 r apid 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 qualificat ions 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 Soluti ons, 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 area s 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 P art 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

a nd 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 consistentl y 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 r egulatory 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 li sts 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

a vailable 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 fl ight 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 sta tion 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 trai ning 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 le vel 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 th e 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 certificationFAR Requirement /Limitation Justification airworthiness c ertificates 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 § 9 1.203 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 paylo ad, 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 i nitiating 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. N/A Ability to use night

- vision goggles with High Resolution IR Camera on UAS to meet VLOS condition/limitation during night VFR/VMC conditions The use of night

- vision goggles in conjunction with a high resolution IR camera mounted on a UAS will enable the PIC to maintain visual line of sight on the aircraft and surrounding hazards at night . This would facilitate working with government security agencies (SWAT, FBI, DEA, etc.) which will require night

- time operations. The UAS 360  sonic detection for collision avoidance, along with the ability to pre program the UAS to stay within a predetermined flight area and/or path any raised risks from utilizing vision enhancing technology. Furthermore, the UAS has the ability to auto

- land should any system failure occur.