TR

- IAG ,	LLC 3 5	East	Papago	Drive , Tempe , AZ 85281 www.tria g.us ~ 202. 517.0605 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION DOCKET MANAGEMENT SYSTEM 1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590
Regulatory Docket No. FAA

- 2015

- 1200

IN THE MATTER OF THE PETITION FOR AMMENDMENT OF GRANT OF EXEMPTION NO. 11874


## TR

- IAG, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF THE FAA REFORM ACT AND PART 11 OF THE FEDER AL AVIATION REGULATI ONS FROM TITLE 14 OF THE CODE OF FEDERAL REGULATIONS
SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a ); 91.119 (c); 91.121; 91.151(a); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).
CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted	on April 2 ,	2016

Joao	Nunes TR

- IAG,	LLC 35	East	Papago	Drive Tempe,	AZ		85281 john@triag.us (202)	517

- 0605TR

- IAG ,	LLC 3 5	East	Papago	Drive , Tempe , AZ 85281 www.tria g.us ~ 202. 517.0605 

### INTRODUCTION AND INTERESTS OF THE PETITIONER Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Petitioner, TR

- IAG, LLC , through its managing partner, Joa o Nunes, a United States Citizen is an Operator of Small Unmanned Airc raft Systems (“sUAS ”) equipped to offer on

- demand commercial s UAS operations for a host of industries and applications and to perform the purposes listed below , hereby hereby petitions t he Administrator for an Amendment to the Conditions and Limitations of Grant Of Exemption No. 11874 (Regulatory Docket No. FAA

- 2015

- 1200), which granted to TR

- IAG, LLC an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to the extent necessary to allow the petitioner to operate a DJI Inspire 1 sUAV to perform aerial data collection. Specifically, TR

- IAG, LLC s eeks an amendment to Exemption 11874 t o the extent necessary to allow the following provisions in addition to or , in the replacement of the existing provisions in Petitioner ’ s current exemption ( 11874).
1. Petitioner to operate the below listed sUAS at a safe altitude above participants at any event while maintaining a safe distance. 2. Petitioner to operate the (sUAV), unmanned aircraft system ( s UAS) to provide aerial video and live video feed to assist with search an d rescue operations under the authority and support of local authority officials , bridge Inspections, flare stack inspection, utility

- power generation system inspections and patrolling, aerial inspection, photography and videography of residential and comm ercial real estate, weddings , aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, c inematography, and v ideography , aerial video and photography for public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current andTR

- IAG ,	LLC 3 5	East	Papago	Drive , Tempe , AZ 85281 www.tria g.us ~ 202. 517.0605 futur e sUAV operations within the NAS, special events: including high schools, colleges, professional sports, open air events and fairs, disaster and catastrophe
events. 3. Petitioner to operate over or near peopl e directly participating in the operation of the sUAV. People directly participating in the operation of the sUAV include the PIC, VO, and other consenting personnel that are directly participating in the safe operation of the s UAV
4. Petitioner to operate n ear but not over people directly participating in the intended purpose of the sUAV operation. People directly participating in the intended purpose of the s UA S will be briefed on the potential risks and acknowledge and consent to those risks. Petitioner wi ll notify the local Flight Standards District Office (FSDO) with a plan of activities at least 72 hours prior to flight operations.
5. Petitioner to operate near nonparticipating persons. Except as provided in sections ( 3 ) and (4), the sUAS may only be opera ted closer than 500 feet to a person when safety provisions are in place that sufficiently protect that person from the sUAV and/or debris in the event of an accident. If a situation arises where the PIC and/or VO believes that any person’s safety is o r may be at risk, the PIC will terminate sUAV operations immediately in a manner that does not cause undue hazard to persons. 6. Petitioner ’ s a ddress change to 35 East Papago Drive, Tempe, AZ 85281

Petitioner submits that operation of the aforementioned s UA Vs under the conditions and limitations request ed in this amendment and set forth previously in Exemption No. 1 1 874 will maintain the safety standards of the National Airspace System (“NAS”), as well as the safety of persons or property on the ground. In support thereof, Petitioner states as follows:TR

- IAG ,	LLC 3 5	East	Papago	Drive , Tempe , AZ 85281 www.tria g.us ~ 202. 517.0605 

### Unmanned Aircraft Systems

TR

- IAG, LLC seeks an amendment to operate the additional s UA S listed below for compensation or hire within the NAS pursuant to Paragraph 1 of the Conditions and Limitations section of Exemption No. 11 874 . All of the proposed s UAS have been the subject of previous Grants of Exemption and are in all material respects similar to the DJI I nspire 1 sUAV . The proposed UAS were previously granted exemptions :

• 3DR Solo

• DJI F450

• DJI F550

• DJI Inspire 1

• DJI Inspire 1 Pro

• DJI Matrice 100

• DJI S1000

• DJI S1000+

• Draganfly Tango

• Draganflyer Commander

• Draganflyer Guardian

• Draganflyer X4

- ES

• Draganflyer X4

- P

• Draganflyer X6

• Draganflyer X8

• Freefly ALTA 6

• Freefly ALTA 8

• GeoScan 101

• GeoScan 201

• GeoScan 401

• Ph oenix Aerial Systems AL3 S1000+

• Phoenix Aerial Systems ALTA

• Phoenix Aerial Systems Scout S900

• Phoenix Aerial Systems TerraHawk T

- 16

• Phoenix Aerial Systems TerraHawk T

- 32

• Phoenix Aerial Systems Vapor 55

• SenseFly eBee

• SenseFly eBee Ag

• SenseFly eBee RTK

• Sense Fly eXomTR

- IAG ,	LLC 3 5	East	Papago	Drive , Tempe , AZ 85281 www.tria g.us ~ 202. 517.0605 • Trimble UX5

• Trimble UX5 HP

• Trimble ZX5

• Yuneec Tornado H920

• Yuneec Typhoon G

• Yuneec Typhoon H

• Yuneec Typhoon H920

• Yuneec Typhoon Q500

• Yuneec Typhoon Q500+

• Yuneec Typhoon Q500+ Pro

Name and address of Petitioner. The name and address of P etitioner is:
TR

- IAG, LLC 35 East Papago D rive Tempe, AZ 85281

Reasons why granting an amendment will not adversely affect safety. Granting the present petition for amendment will further the public interest as set forth by the Administrator in Exemption No. 11 874 . As the Administrator held on page 2 of Exemption No. 11 874 , the FAA found that the enhanced safety achieved using an

unma nned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find tha t the UAS operation enabled by this exemption is in the public interest. Further, there has been no change in the conditions and reasons relative to the public interest and safety that were the basis for granting the original exemption. TR

- IAG ’ s propose d amendment not only furthers the public’s interest as set forth by the Administrator in Exemption No. 11874 , it also is another step forward in fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, by allowing TR

- IAG to safely, efficiently, and economically operate the proposed UAS commercially within the NAS.TR

- IAG ,	LLC 3 5	East	Papago	Drive , Tempe , AZ 85281 www.tria g.us ~ 202. 517.0605 Publish ing in The Federal Registe r . TR

- IAG, LLC submits that good cause exists for not publishing a summary of this petition for amendment in the Federal Register because the requested amendment to Exemption No. 11 874 would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Additional Information, v iews, o r a rguments a vailable t o Support Petitioner ’ s Reque st Petitioner has logged nearly 100 hours of sUAV commercial flight operation since obtaining Exemption 11874. In all sUAV operations, Petitioner obtains permits as required and always coordinates with local public safety agencies and files appropriate NOTAMs . Petitioner has been acti vely involved in General Aviation , and with sUAS (fixed wing & rotorcraft) since 1979 logging over 1000 hours as a private pilot in complex & multi

- engine aircraft and in excess of 500 hours as PIC in sUAS; both
rotorcra ft and fixed wing. Petitioner takes every opportunity to be a goodwill ambassador to promote safe operation of sUAS within the NAS.

Conclusion This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Petitioner ’ s request for amendment may be
gran ted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above

. Additionally, Petitioner respectfully requests that the Administrator grant this Petition for an amendment to Exemption No. 11 874 to the extent necessary to allow Petitione r to operate the following sUAS: 3DR Solo , DJI F450 , DJI F550 , DJI Inspire 1 Pro , DJI Matrice 100 , DJI S1000 , DJI S1000+ , Draganfly Tango , Draganflyer Commander , Draganflyer Guardian , Draganflyer X4

- ES , Draganflyer X4

- P , Draganflyer X6 , Draganflyer X8 , Freefly ALTA 6 , Freefly ALTA 8 , GeoScan 101 , GeoScan 201 , GeoScan 401 , Ph oenix Aerial Systems AL3 S1000+ , Phoenix Aerial Systems ALTA , Phoenix Aerial Systems Scout S900 , Phoenix Aerial Systems TerraHawk T

- 16 , Phoenix Aerial SystemsTR

- IAG ,	LLC 3 5	East	Papago	Drive , Tempe , AZ 85281 www.tria g.us ~ 202. 517.0605 TerraHawk T

- 32 , Phoenix Aerial Systems Vapor 55 , SenseFly eBee , SenseFly eBee Ag , SenseFly eBee RTK , Sense Fly eXom , Trimble UX5 , Trimble UX5 HP , Trimble ZX5 , Yuneec Tornado H920 , Yuneec Typhoon G , Yuneec Typhoon H , Yuneec Typhoon H920 , Yuneec Typhoon Q500 , Yuneec Typhoon Q500+ , Yuneec Typhoon Q500+ Pro , in addition to the DJI Inspire 1 UAS under the Conditions and Limitations originally set forth in Exemption No. 11874

. Please note that each of the above l isted sUAS are part of the List of Approved Unmanned Aerial Systems (UAS) under Section 333 at regulatory docket FAA

- 2007

- 3330 at www.regulations.gov

Dated: April 2 , 201 6 Respectfully submitted,

TR

- IAG, LLC

/s/ Joao Nunes Joao Nunes 35 East Papago Drive Tempe, Arizona 85281 Tel: ( 202 ) 517

- 0605