TR-IAG,	LLC			35	East	Papago	Drive,	Tempe,	AZ 85281

www.triag.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 FEDERAL AVIATION REGULATIONS 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)	517-0605
TR-IAG,	LLC			35	East	Papago	Drive,	Tempe,	AZ 85281

www.triag.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, Joao Nunes, a United States Citizen is an Operator of Small Unmanned Aircraft 

Systems (“sUAS”) equipped to offer on-demand commercial sUAS operations for a 

host of industries and applications and to perform the purposes listed below, hereby 

hereby petitions the 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 seeks an amendment to Exemption 11874 to 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 (sUAS) to provide

aerial video and live video feed to assist with search and 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 commercial 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, cinematography, 

and videography, 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 and 
TR-IAG,	LLC			35	East	Papago	Drive,	Tempe,	AZ 85281

www.triag.us	~ 202.517.0605

future 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 people 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 sUAV

4. Petitioner to operate near but not over people directly participating in the 

intended purpose of the sUAV operation. People directly participating in the 

intended purpose of the sUAS will be briefed on the potential risks and 

acknowledge and consent to those risks. Petitioner will 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 operated 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 or 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 address change to 35 East Papago Drive, Tempe, AZ 85281

Petitioner submits that operation of the aforementioned sUAVs under the conditions 

and limitations requested in this amendment and set forth previously in Exemption No. 

11874 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			35	East	Papago	Drive,	Tempe,	AZ 85281

www.triag.us	~ 202.517.0605

Unmanned Aircraft Systems

TR-IAG, LLC seeks an amendment to operate the additional sUAS listed below 

for compensation or hire within the NAS pursuant to Paragraph 1 of the Conditions and

Limitations section of Exemption No. 11874. All of the proposed sUAS have been the 

subject of previous Grants of Exemption and are in all material respects similar to the 

DJI Inspire 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

• Phoenix 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

• SenseFly eXom
TR-IAG,	LLC			35	East	Papago	Drive,	Tempe,	AZ 85281

www.triag.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 Petitioner is:

TR-IAG, LLC

35 East Papago Drive

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. 11874. As the Administrator held on page 2 of 

Exemption No. 11874, the FAA found that the enhanced safety achieved using an 

unmanned 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 that 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 proposed 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			35	East	Papago	Drive,	Tempe,	AZ 85281

www.triag.us	~ 202.517.0605

Publishing in The Federal Register.

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. 11874 would not set a precedent, and any delay in acting on this 

petition would be detrimental to the petitioner.

Additional Information, views, or arguments available to Support Petitioner’s

Request

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 actively 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 

rotorcraft 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 

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set 

forth above. Additionally, Petitioner respectfullyrequeststhatthe Administrator 

grant this Petition for an amendment to Exemption No. 11874 to the extent 

necessary to allow Petitioner 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, Phoenix Aerial Systems AL3 S1000+, Phoenix Aerial Systems ALTA, Phoenix 

Aerial Systems Scout S900, Phoenix Aerial Systems TerraHawk T-16, Phoenix Aerial Systems 
TR-IAG,	LLC			35	East	Papago	Drive,	Tempe,	AZ 85281

www.triag.us	~ 202.517.0605

TerraHawk T-32, Phoenix Aerial Systems Vapor 55, SenseFly eBee, SenseFly eBee Ag,

SenseFly eBee RTK, SenseFly 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 listed 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, 2016

Respectfully submitted,

TR-IAG, LLC

/s/ Joao Nunes

 Joao Nunes

35 East Papago Drive

Tempe, Arizona 85281

Tel: (202) 517-0605