RD Group

10736 Vista Heights Blvd.

Fort Worth, TX 76108

(682) 239-0778 – (voice/text)

(817) 394-1583 – (fax)

dwm0509@gmail.com

To: Jake Troutman

Jake.Troutman@faa.gov

(202) 267-9521

From: RD Group

David w Mansen

10736 Vista Heights Blvd.

Fort Worth, TX 76108

682-239-0778 (Tel)

817-394-1583 (Fax)

dwm0509@gmail.com

Date: 08 Feb 2014

Re: Response to your request for additional information

Docket No. FAA-2014-0830

Below are answers to your e-mail dated 26 Jan 2015 requesting additional information for our 

petition to Docket No. FAA-2014-0830. Your question/request are in a larger font and bold with 

our answers listed below each of your question/request.

1) Describe the aircraft make(s) and model(s) for the proposed UAS operation. 

The description(s) should include the following: size, maximum weight 

(including payload), and aircraft type (i.e. - fixed-wing, rotorcraft, lighterthan-air). 

The DJI Phantom xx

Size: 14 inches (diagonal motor-motor)

Maximum Weight (gross maximum weight including payload): 3 lbs.

Aircraft Type: Rotorcraft (multi-rotor - quad-rotor)

2) Provide description of proximity to airports. 

The Flight Operator (Pilot) or Visual Observer (VO) must monitor the Aircraft 

Emergency Frequency (Guard) on 121.5MHz during all flight operations.

sUAS flights ARE PERMITTED in all areas of the US National AirSpace System (NAS) 

with the following limitations:

1) sUAS may NOT be flown in “Class A” Airspace.

2) sUAS may NOT be flown in “Class B” Airspace.

3) sUAS may NOT be flown beneath “Class B” Airspace where the underlying “Class 

B” Airspace is less than 2,000 feet AGL.

4) sUAS may NOT be flown in “Class C” Airspace.

5) sUAS may NOT be flown in “Prohibited” Airspace.

6) sUAS may NOT be flown where the FAA has issued a Temporary Flight 

Restriction.

7) sUAS operation within 5 nautical miles of an airport (an airport WITHOUT an 

operating control tower) is permitted. The Flight crew will monitor and transmit 

position/intention reports on the local Unicom frequency when operating within this 

area.

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RD Group

10736 Vista Heights Blvd.

Fort Worth, TX 76108

(682) 239-0778 – (voice/text)

(817) 394-1583 – (fax)

dwm0509@gmail.com

3) Your petition references a pre-flight inspection and/or checklist. Describe the 

process used to determine if the UAS is airworthy and in safe condition for 

operation in the NAS. 

This is a mechanical preflight of the sUAS and related equipment.

1) All sUAS, at a minimum will require inspection of:

a) Rotor mechanical suitability for flight

b) Fully charged sUAS flight battery.

c) Sufficient charge on RF Controller and FPV downlink receiver.

d) Visual inspection of sUAS for obvious damage or items which would affect safety 

of flight.

2) Verify operation of VHF radio, including a spare set of fully charged batteries (if 

applicable).

3) It is the responsibility of the Flight Operator (Pilot) to insure that all required 

equipment has been inspected prior to flight.

4) Describe the process used to document UAS discrepancies and the corrective 

action taken in the aircraft record. Examples of processes include (1) the 

petitioner has elected to use its own process to maintain its UAS and ensure 

that only airworthy and safe UAS will be allowed to operate in the NAS and (2) 

the petitioner has elected to maintain its UAS in accordance with the 

manufacturer maintenance and inspection recommendations. 

RD Group has elected to use its own process to maintain, inspect and document its sUAS 

and to ensure that only safe and airworthy sUAS are operated in the NAS.

Each sUAS will have an Aircraft Maintenance Record. All sUAS discrepancies and any 

corrective action taken will be entered into this Aircraft Maintenance Record. All sUAS 

inspection and maintenance actions will be entered into this sUAS Aircraft Maintenance 

Record.

The Flight Operator (Pilot) will document any and all discrepancies or sUAS malfunctions 

in this Aircraft Maintenance Record.

The Chief Pilot is responsible for all maintenance of the sUAS. The Chief Pilot will make 

all final decisions as to the usability of any replacement parts.

RD Group will utilize sUAS manufacturers’ recommendations for inspection and 

maintenance procedures. 

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RD Group

10736 Vista Heights Blvd.

Fort Worth, TX 76108

(682) 239-0778 – (voice/text)

(817) 394-1583 – (fax)

dwm0509@gmail.com

5) Your petition references the material(s) listed below, however the material(s) 

were not submitted for the record. Please provide a copy of the following 

referenced materials: 

Flight, Maintenance & Operations Manual” (Proprietary) 

“Training Manual” (Proprietary) 

“Flight Dispatch” Form (Proprietary) 

Authority to Photograph” Form (Proprietary) 

Enclosed are the following documents to support our exemption request:

01_FAA Section 333 Exemption Letter Response (08 Feb 2015)

02_FAA Section 333 Exemption Cover Letter (29 Sep 2014)

03_FAA Section 333 Exemption Request Application [Rev00]

04_“Flight, Maintenance & Operations Manual [Rev01]” (Proprietary) 

05_“Training Manual [Rev00]” (Proprietary) 

06_“Flight Dispatch [Rev00]” Form (Proprietary) 

07_“Authority to Photograph [Rev00]” Form (Proprietary) 

FAA has permission to utilize any and all RD Group proprietary documents as 

necessary to facilitate approval of this requested exemption. 

We will gladly discuss any changes, modifications or amendments to our manuals, procedures or 

practices to satisfy FAA requirements for approval of this exemption.

Thank you,

David w Mansen

dwm0509@gmail.com

(682) 239-0778

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