This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 1 of 35 

# RD Group

10736 Vista Heights Blvd

Fort Worth, TX 76108

682

- 239

- 0778 (Tel)

817

- 394

- 1583 (Fax)

dwm0315 @gmail.com



# Section 333
Exemption Request

1 3 March 2015This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 2 of 35 To: Docket Operations M

- 30
US Department of Transportation (DOT)
1200 New Jersey Ave., SE
Room W12

- 140 West Building Ground Floor Washington, DC 20590

- 0001

From: RD Group
David w Mansen 10736 Vista Heights Blvd

. Fort Worth, TX 76108

682

- 239

- 0778 (Tel)

817

- 394

- 1583 (Fax)

dwm0315 @gmail.com

Date: 1 3 Mar 2015

Re: Exemption request p ursuant to Section 333 of the FAA Modernization and Reform Act of
2012

In accordance with the FAA Modernization and Reform Act of 2012 (FMRA), Section 333 Special
Rules for Certain Unmanned Aircraft Syst ems, RD Group seeks an exemption from FAA regulations restricting COMMERCIAL operation of small Unmanned Aircraft System (sUAS).

RD Group specifically requests relief from the listed FAA Regulations to permit COMMERCIAL operation of small Unmanned Aircraft System (sUAS) under the conditions outlined herein or as
may be established by the FAA.

RD Group also request relief from such other FARS as the FAA deems appropriate to enable RD Group ’ s requested operations.

The FAA make any modifications it det ermines necessary in the granting of this Section 333 Exemption request

. FAA has permission to utilize any or all RD Group proprietary documents as necessary to facilitate approval of this requested exemption.

RD Group seeks relief to permit commercial ope rations utilizing sUAS to conduct aerial video and photo graphy services for real estate and construction, surveying and inspection, marine and wildlife, agriculture and for special events.

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

## Section 333 Exemption Request

- RD Group

Table of Contents

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 3 of 35 

# 1 ) Table of Conte nts

1) Table	of	Contents

................................ ................................ ................................ . 3
2) Abbreviations	Used

................................ ................................ ............................. 5
3) Overview

................................ ................................ ................................ ................. 6
4) Regulations	Relief	Sought	For

................................ ................................ .......... 8

14	CFR	§	61.23	(a)(2)

................................ ................................ ................................ ................................ ....................... 8

14	CFR	§	61.113	(a)	and	(b)

................................ ................................ ................................ ................................ ........... 9

14	CFR	§	91.7	(a)

................................ ................................ ................................ ................................ .............................. 10

14	CFR	§	91.119	(c)

................................ ................................ ................................ ................................ ......................... 11

14	CFR	§	91.121

................................ ................................ ................................ ................................ ................................ 12

14	CFR	§	91.151	(a)	and	(b)

................................ ................................ ................................ ................................ ......... 13

14	CFR	§	91.405	(a)

................................ ................................ ................................ ................................ ......................... 14

14	CFR	§	91.407	(a)(1)

................................ ................................ ................................ ................................ ................... 14

14	CFR	§	91.409	(a)(1)	and	(2)

................................ ................................ ................................ ................................ ... 15

14	CFR	§	91.417	(a)	and	(b)

................................ ................................ ................................ ................................ ......... 16 

## 5) RD	Group

................................ ................................ ................................ ............... 18
6) sUAS	Aircraft

................................ ................................ ................................ ........ 19

sUAS	Operated	by	RD	Group

................................ ................................ ................................ ................................ ........ 20

DJI	Phantom	2	Vision+

................................ ................................ ................................ ................................ ................... 20

DJI	Phantom	2	Vision+	Safety	Features:

................................ ................................ ................................ .................. 21 

## 7) sUAS	Flight	Crew

................................ ................................ ................................ . 22

Private	Pilot	Certificate

................................ ................................ ................................ ................................ ................. 22

Third	Class	Medical	Certificate

................................ ................................ ................................ ................................ ... 22

Flight	Operator	(Pilot)	Requirements:

................................ ................................ ................................ ..................... 23

Visual	Observer	(VO)	Requirements:

................................ ................................ ................................ ....................... 23

## Section 333 Exemption Request

- RD Group

Table of Contents

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 4 of 35 

## 8) sUAS	Operating	Parameters

................................ ................................ ........... 24

sUAS	Requirements	for	Flight:

................................ ................................ ................................ ................................ .... 24

sUAS	Documentation	Requirements

................................ ................................ ................................ ......................... 24

sUAS	Pre

- Flight	Requirements

................................ ................................ ................................ ................................ .... 24

sUAS	Flight	Requirements

................................ ................................ ................................ ................................ ............ 25

Accident/Incident	Reporting

................................ ................................ ................................ ................................ ....... 27 

## 9) sUAS	Maintenance

................................ ................................ .............................. 28

Preventative	Maintenance

................................ ................................ ................................ ................................ ........... 28

Maintenance/Corrective	Action	Documentation

................................ ................................ ................................ . 28 

## 10) sUAS	Training

................................ ................................ ................................ ... 29

Flight	Operator	(Pilot)	Training

................................ ................................ ................................ ................................ . 29

Visual	Observer	(VO)	Training

................................ ................................ ................................ ................................ ... 29

Maintenance	Training

................................ ................................ ................................ ................................ .................... 29

Training	Sources

................................ ................................ ................................ ................................ .............................. 29

Training	Requirements	Table

................................ ................................ ................................ ................................ ..... 30

Training	Guide

................................ ................................ ................................ ................................ ................................ .. 31 

## 11) For	the	Good	of	the	Public

................................ ................................ ............ 33

Equivalent	Level	of	Safety

................................ ................................ ................................ ................................ ............. 33

Public	Interest

................................ ................................ ................................ ................................ ................................ .. 33

Privacy

................................ ................................ ................................ ................................ ................................ ................ 34

National	Security

................................ ................................ ................................ ................................ ............................. 34

Conclusion

................................ ................................ ................................ ................................ ................................ .......... 35

## Section 333 Exemption Request

- RD Group

Ab breviations Used

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 5 of 35 

# 2 ) Abbre viations Used

sUAS small Unmanned Aircraft System Unmanned Aircraft

- Light weight

– less

than 55 Lbs. Gross Vehicle weight including payload

FPV First Person View FPV is the video feed from the camera mounted in the sUAS that is displayed to the Flight Crew on the ground.

AGL Above Ground Level Above Ground Level

NAS National Air Space National Air Space

Flight Crew Flight Crew Flight Operator (Pilot)

Visual Observer (VO)

PIC Pilot in Command Pilot in Command

VO Visual Observer Member of the Flight Crew. Responsible
for visual observation and visual assistance to the Flight Operator (Pilot)

GPS Global Positioning System A navigational system using satellite signals to accurately determine a user ’ s location.

AMA Academy of Model Aeronautics Academy of Model Aeronautics

FAA Federal Aviation Administration Federal Aviation Administration

FAR Federal Aviation Regulation Federal Aviation Regulation

AC Advisory Circular FAA issued publication to provide guidance for compliance with airworthiness regulations.

FCC Federal Communications
Commission Federal Communications Commission

## Section 333 Exemption Request

- RD Group

Overview

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 6 of 35 

# 3 ) Ove rvie w

In accordance with the FAA Modernization and Reform Act of 2012 (FMRA), Section 333 Special Rules for Certain Unmanned Aircraft Systems, RD Group seeks an exemption from FAA regulations restricting COMMERCIAL operation of small Unmanned Aircraft System (sUAS).

RD Group specifically requests relief from the listed FAA Regulations to permit COMMERCIAL operation of small Unmanned Aircraft System (sUAS) under the conditions outlined herein or as
may be established by the FAA.

RD Group also request relief from such other FARS as the FAA deems appropriate to enable RD Group ’ s requested operations.

The FAA make any modifications it determines necessary in the granting of this Section 333 Exemption request

. FAA has permission to utilize any or all RD Group proprietary documents as necessary to facilitate approval of this requested exemption.

Existing FAA Regulations burden RD Group ’ s sUAS operations by preventing RD Group from performing commercial sUAS operations to conduct aerial video and photography services

. RD Group seeks relief to perm it commercial operations utilizing sUAS to conduct aerial video and photo graphy services for real estate and construction, surveying and inspection, marine and wildlife, agriculture and for special events.

All RD Group sUAS flights will operate in a tightly controlled area, below 400 feet AGL, and over private or controlled property and with the permission of the property owner.

RD Group seeks relief from these FAA Regulations because:

1) Existing FAA Regulatio ns provide and undue burden upon RD Group ’ s commercial sUAS operations

. a) RD Group operations are described in detail in section 5 (RD Group)

2) Equivalent Level of Safety

a) O peration of small Unmanned Aircraft Systems (sUAS) by RD Group with the sUAS

A ircraft, s UAS Flight Crew, sUAS Operating Parameters, sUAS Maintenance and sUAS training requirements as outlined in this request for a Section 333 exemption provide an equivalent level of safety
3) Public interest
a) Granting these requested exemptions is in the public interest

. b) For the public interest is described in detail in section 11 (For the Good of the Public)

The FAA ’ s authority to issue exemptions from current operating rules and regulations, and the Secretary ’ s authority granted by section 333 of P.L. 112

- 95 (S pecial Rules for Certain Unmanned Aircraft Systems) provides an opportunity to authorize certain sUAS operations into the National Airspace System (NAS) prior to implementation of the final sUAS rule.

Granting of this exemption request will permit RD Group to safely and legally utilize sUAS in the
NAS.

## Section 333 Exemption Request

- RD Group

Overview

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 7 of 35 * * *

Enclosed are the following documents to support RD Group ’ s Section 333 Exemption request:

1) DJI Phantom User ’ s Manual
2) DJI Phantom Pilot Training Guide

* * *

Safety is achieved through the relentless pursu it of quality training and adherence to FAA Approved Operating Procedures and FAA Regulations.

RD Group adheres to the Academy of Model Aeronautics National Model Aircraft (AMA) Saf ety Code. A copy of this code is included with this Section 333 Exemption r equest. All RD Group Flight Operators (Pilots) and Visual Observers (VO) are trained on the standards of this safety

code.

Our approach to the safe operation of small Unmanned Aircraft Systems (sUAS) is three fold: Operational Procedures ( Adherence to FAA Regulations )

- Training

– Intelligent Aircraft

.

* * *

RD Group operates small, lightweight r otorcraft ( multi

- rotor / quad

- rotor) sUAS weighing less than 6 Lbs. (gross weight including payload). These intelligent GPS enabled sUAS have the ability to “ auto hoover ” and “ auto return home ” in the event of a loss of RF control signal.

sUAS aircraft operated by RD Group are discussed in detail in S ection 6 (sUAS Aircraft).

* * *

Flight crew for RD Group sUAS operations will be a Flight Operator (Pilot) and a Visu al Observer (VO).

The Flight Operator (Pilot) will possess a current FAA private p ilot license and a current FAA
C lass III medical certificate. The Visual Observer (VO) will have received required RD Group training to qualify for Visual Observer (VO) dutie s.

RD Group Flight Crew requirements are discussed in detail in S ection 7 (sUAS Pilot in Command).

* * *

RD Group flight operations are conducted over private or over controlled access property , below
400 feet AGL and with the permission of the property ow ner/controller or authorized representative.

During RD Group flight operations the sUAS will always be within visual line of sight (VLOS) of either the Flight Operator (Pilot) or the Visual Observer (VO).

sUAS flight operations will always be operated in areas that are clear of people, except for personal directly involved with sUAS operations.

RD Group flight operations are discussed in detail in S ection 8 (sUAS Operating Parameters).

## Section 333 Exemption Request

- RD Group

Regulations Relief Sought For

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 8 of 35 

# 4 ) Re g ulatio n s Re lie f Sought For

Listed below are FAA regulations for whic h RD Group is seeking relief

.
RD G roup also request relief fro m such other FARS as the F AA deems appropriate to enable RD Group ’ s requested operations.

The FAA make any modifications it determines necessary in the granting of this Section 333 Exemption req uest

. 

## 14 CFR § 61.23 (a ) (2)

§ 61.23 Medical certificates: Requirement and duration.

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section, a person

— (2) Must hold at least a second class medical certi ficate when exercising:

(i) Second

- in

- command privileges of an airline transport pilot certificate in part 121 of this chapter (other than operations specified in paragraph (a)(1)(ii) of this section); or

(ii) Privileges of a commercial pilot certificate; or

(3) Must hold at least a third

- class medical certificate

— (i) When exercising the privileges of a private pilot certificate;

Relief from 14 CFR § 61.23 (a ) (2) is sought from the requirement to hold a Second Class Medical

Certificate for commercial flight operations

. For sUAS operations a Third Class Medical
C ertificate (as required for Private Pilot Privileges ) provides an equivalent level of safety as that
of a Second Class Medical Certificate given that:

1) No persons (crew/ passengers) or cargo are carried onboard the sUAS.

2) The sUAS has the ability to “ auto hoover ” and “ auto return home ” at the touch of
a button.

3) In the event of incapacitation of the Flight Operator (Pilot) t he sUAS will automatically begin a descent and landing when the battery leve l is reduced to
below 15%.

## Section 333 Exemption Request

- RD Group

Regulations Relief Sought For

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 9 of 35 

## 14 CFR § 61

. 113 ( a ) and (b)

§ 61.113 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as p ilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in comma nd of an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation

or hire.

Relief from 14 CFR § 61.113 (a) and (b) is sought from the requirement for the sUAS Flight Operator (Pilot) to hold a FA A Commercial Pilot Certificate.

RD Group Flight Operator (Pilot) will hold a FAA Private Pilot Certificate.

A pilot with a FAA Private Pilot C ertificate and a pilot with a FAA Commercial Pilot C ertificate have both demonstrated a parallel level of required aeronautical kno wledge. A FAA Commercial
Pilot C ertificate requires demonstration of further airmanship skills to safely carry passengers and cargo for hir e. RD Group sUAS will not carry onboard any persons ( passengers /crew) o r cargo for hire.

For sUAS operations a pilot with a FAA Private Pilot Certificate will provide the equivalent and required level of safety to operate the sUAS as would a pilot with a F AA Commercial Pilot
Certificate

.
These enhanced airman ship skills are not utilized in flight of the sUAS , thus a Flight Operator (Pilot) holding a FAA Private Pilot Certificate with sUAS flight training will provide an equivalent level of safety.

In the granting of exemption #11062 to Astraeus Aerial the FA A determined that a PIC with a

FAA Private Pilot C ertificate operating the sUAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground.

In similar fash ion to Astraeus Aerial operations, RD Group operations are conducted over private property or over controlled access property and with the permission of the property owner/controller or authorized representative.

The FAA has previously issued an exemption to this rule [14 CFR § 61.113 (a) and (b)] in
exemption # 11062 to Astraeus Aerial

.

## Section 333 Exemption Request

- RD Group

Regulations Relief Sought For

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 10 of 3 5 

## 14 CFR § 91.7 (a)

§ 91.7 Civil aircraft airworthiness.

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

Relief from 14 CFR § 91.7 (a) is sought requiring Civil Aircraft Airworthiness because:

1) The sUAS will not receive and Airworthiness Certificate under 14 CFR § 21.

2) Compliance with RD Group Operating Documents will provide a means of insuring an equivalent level of safety.

3) The Flight Operator (Pilot) of the sUAS has final authority to determine whether the sUAS in a safe condition for flight.

I n the granting of exemption #11188 to State Farm the FAA determined that even though the sUAS is not required to have an airworthiness ce rtificate per 14 CFR § 21 Subpart H, relief from the requirements of 14 CFR § 91.7 (a) [Civil Aircraft Airworthiness] is required.

The FAA considers compliance with operating documents to be a sufficient means of determining an airworthy condition in accor dance with the requirements of this part.

Additionally, in accordance with 14 CFR § 91.7 (b), the PIC is responsible for determining whether the aircraft is in a condition for safe flight. The FAA found in the granting of exemption

#11188 to State Farm Mut ual Automobile Insurance Company that the PIC can comply with this requirement.

The FAA has previously issued an exemption to this rule [14 CFR § 91.7 (a)] in exemption

#11188 to State Farm Mutual Automobile Insurance Company.

## Section 333 Exemption Request

- RD Group

Regulations Relief Sought For

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 11 of 35 

## 14 CFR § 91

. 119 (c)

§ 91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface,

except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or

structure.

Relief from 14 CFR § 91.119 (c) is sought because :

1) All sUAS flights are conducted below 500 feet AGL.

2) All sUAS flights operate in a tightly controlled area below 400 feet AGL over private or controlled property with permission of the property owner.

In the granting of exemption #11188 to State Farm Mutual Automobile Insurance Company the FAA determined that sUAS op erations should remain 500 feet from all persons not directly involved with sUAS operations. The FAA also has determined that operations of closer than 500 feet may be permitted if:

1) All non

- participating persons are protected by a suitable shelter.

2) Permiss ion has been granted by the property owner/controller or authorized representative

. The FAA has previously issued an exemption to this rule [14 CFR § 91.119 (c)] in exemption

#11188 to State Farm Mutual Automobile Insurance Company.

## Section 333 Exemption Request

- RD Group

Regulations Relief Sought For

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 12 of 35 

## 14 CFR § 91.121

§ 91.1 21 Altimeter settings.

(a) Each person operating an aircraft shall maintain the cruising altitude or flight
level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The curre nt reported altimeter setting of a station along the
route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriat e available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92 ′′ Hg.

(b) The lowest usab le flight level is determined by the atmospheric pressure in the area of operation as shown in the following table:

(c) To convert minimum altitude prescribed under §§ 91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equi valent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the current reported altimeter setting:

Relief from 14 CFR § 121 is sought because:

1) The sUAS is not equipped with an altimeter.

2) All sUAS flights operate in a tightly controlled area below 400 feet AGL over private or controlled property and with the permission of the property owner.
3) All sU AS flights are conducted below 4 00 feet AGL.

a. GPS altitude information from the sUAS will be via a data down

- link and will be displayed to the Flight Operator (Pilot) in real

- time..
4) This provides an equivalent level of safety.

In the granting of exemption #11188 to State Farm Mutual Automobile Insurance Comp any th e FAA determined that:

1) All sUAS flights operate in a tightly controlled area below 400 feet AGL over private or controlled property and with the p ermission of the property owner and within VLOS of the Flight Operator (Pilot) or Visual Observer (VO).

2) The us e of onboard GPS altitude information is provided via a data down

- link and
to the PIC
The FAA has previously issued an exemption to this rule [14 CFR § 91.121] in exemption

#11188 to State Farm Mutual Automobile Insurance Company.

## Section 333 Exemption Request

- RD Group

Regulations Relief Sought For

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 13 of 35 

## 14 CFR § 91

. 151 (a) an d (b)

§ 91.151 Fuel requirements for flight in VFR conditions.

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landin g and, assuming normal cruising speed

— (1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly
after that for at least 20 minutes.

Relief from 14 CFR § 91. 151 (a) and (b) is sought because:

1) Complying with the 30 minute fuel reserve would unnecessarily limit the length of the sUAS flights. The DJI Phantom 2 Vision+ has a endurance limit of 25 minutes.
2) All sUAS flights operate in a tightly controlled area below 400 feet AGL over private or cont rolled property and with the permission of the property owner.

3) The DJI Phantom 2 Vision+ sUAS has the enhanced safety feature that it will automatically descend and land when the battery level falls to below 15%. Upon landing the DJI Phantom 2 Vision+ moto rs will stop.

4) The DJI Phantom 2 Vision+ sUAS provides the Flight Operator (Pilot) real

- time display of available remaining battery power for flight.

5) An equivalent level of safety can be achieved by limiting flights to 25% available battery power.

6) The DJI P hantom 2 Vision+ sUAS operated by RD Group is a rotorcraft (multi

rotor / quad

- rotor) unmanned aircraft.
The FAA has previously issued an exemption to this rule [14 CFR § 91.151 (a) (1) ] in exemption

#11188 to State Farm Mutual Automobile Insurance Company.

## Section 333 Exemption Request

- RD Group

Regulations Relief Sought For

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 14 of 35 

## 14 CFR § 91

. 405 ( a )

§ 91.405 Maintenance required.

Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter;

Relief from 14 CFR § 91. 405 (a) is sought because:

1) Given that these sections and Part 43 apply to Certificated Aircraft, these sections do not apply to the operation of sUAS.
2) M aintenance and preventative maintenance will be performed in accordance with the sUAS manufacturers (DJI) operation and maintenance instructions.
The FAA has previously issued an exemption to this rule [14 CFR § 91.405 (a)] in exemption

#11188 to State Far m Mutual Automobile Insurance Company.


## 14 CFR § 91

. 407 ( a ) (1)

§ 91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by a person authorized

under § 43.7 of this chapter; and

Relief from 14 CFR § 91. 407 (a) (1) is sought because:

3) Given that these sections and Part 43 apply to Certificated Aircr aft, these sections do not apply to the operation of sUAS.
4) Maintenance and preventative maintenance will be performed in accordance with the sUAS manufacturers (DJI) operation and maintenance instructions.

The FAA has previously issued an exemption to this rule [14 CFR § 91.407 (a)(1)] in exemption

#11188 to State Farm Mutual Automobile Insurance Company.

## Section 333 Exemption Request

- RD Group

Regulations Relief Sought For

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 15 of 35 

## 14 CFR § 91

. 409 ( a ) (1) and (2 )

§ 91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate an
aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform a nnual inspections and is entered as an “ annual ” inspection in the required maintenance records.

Relief from 14 CFR § 91. 409 (a) (1) and (2) is sought because:

1) Given that these sections and Part 43 apply to Certificated Aircraft, these sections do not apply to the operation of sUAS.

2) Maintenance and preventative maintenance will be performed in accordance with the sUAS manufacturers (DJI) operation and maintenance instructions.
The FAA has previously issued an exemption to this rule [14 CFR § 91.409 (a)(1) and (2)] in exemption #11188 to State Farm Mutual Automobile Insurance Company.

## Section 333 Exemption Request

- RD Group

Regulations Relief Sought For

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 16 of 35 

## 14 CFR § 91

. 417 ( a ) and (b)

§ 91.417 Maintenance records.

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or opera tor shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration

and records of the 100

- hour, annual, progressive, and other required or approved inspect ions, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft.

The records must include

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving

the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhau led on a specified time
basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applica ble airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and
date when the next action is r equired.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for
each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the per iods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

## Section 333 Exemption Request

- RD Group

Regulations Relief Sought For

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 17 of 35 (2) The records specified in paragraph (a)(2) of this section shall be
retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under
§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is appro ved for return to service.

Relief from 14 CFR § 91. 417 (a) a nd (b) is sought because:

1) Given that these sections and Part 43 apply to Certificated Aircraft, these sections do not apply to the operation of sUAS.

2) RD Group sUAS Maintenance/Corrective Action Documentation procedures are described in detail in section 9 (sUAS Maintenance).
The FAA has previously issued an exemption to this rule [14 CFR § 91.417 (a) and (b)] in
exemption #11188 to State Farm Mutual Automobile Insurance Company.

## Section 333 Exemption Request

- RD Group

RD Group

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 18 of 35 

# 5 ) RD Gro up

RD Group is an American owned and operated company that performs commercial aerial video and photography services for real estate and construction, surveying and inspection, marine and wildlife, agriculture and for special events.

In the United States we utilize C ertified manned aircraft and Certified manned helicopters with a pilot who holds a FAA Pilot Commercial Certificate

.
In numerous International C ountries we are permitted by law to utilize small Unmanned Aircraft System ( sUAS ) to perform these same commerci al aerial video and photography services

. The use of sUAS provides an increase in operational flexibility and provides h igher quality images at

a greatly reduced economic cost.

However in the United States (our country of residency and citizenship) we are permitted to fly a sUAS for hobby or recreational purposes only (commercial operation is prohibited)!

Existing FAA Regulations burden RD Group ’ s sUAS operations by preventing RD Group from performing commercial sUAS operations to conduct aerial video and p hotography services for real estate and construction, surveying and inspection, marine and wildlife, agriculture and for special events

RD Group is owned and operated by Mr. David w Mansen.

With over thirty years ’ experience in the airspace industry interacting with the FAA as a Pilot,

as a FAA Part 145 M aintenance Inspector and as a FAA Part 145 Repair Station “ FAA Accountable Manager ” Mr. Mansen has demo nstrated an exemplary record of safe operation and
of adherence to FAA regulations.

Mr. Mansen cu rrently holds a FAA Private Pilot License with ASEL (airplane single engine land)

and AMEL (airplane multi engine land) ratings. Since the issuance of this license in the early
1980 ’ s, Mr. Mansen has had ZERO FAA safety incidents, ZERO FAA infractions, and ZERO FAA
citations

– an impeccable and spotless record of adherence to safety and adherence to FAA regulations.

Mr. Mansen founded TexasGYRO (T69R487X)

, a FAA Part 145 Licensed Aircraft M aintenance facility and through smart business practices, a relentle ss pursuit of safety and adherence to FAA regulations was able to sell TexasGYRO as a successful business after ten years of operation.

Mr. Mansen served as the FAA Accountable M anager at TexasGYRO for ten years with ZERO FAA safety incidents, ZERO FAA inf ractions, and ZERO FAA citations. Mr. Mansen has proven
that he has the skill, knowledge and experience necessary to instal l a successful training program and to manage and operate a FAA Certified Aerospace facility

.

Mr. Mansen has an impeccable record of safety and adhering to FAA regulations.

## Section 333 Exemption Request

- RD Group

sUAS Aircraft

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 19 of 35 

# 6 ) sUAS Aircraft

Hobbyist and aircraft enthusiast have been safely flying remotely controlled aircraft for decades. In June of 1981 the FAA publish AC 91

- 57 (Model Aircraft Operating Standards). This set the standard for operation by which we have safely abided by for over thirty years.

Accepted safe practices for hobby and recreation flying of a remotely controlled aircraft are that a vehicle must weigh less than 55 lbs., must be operated within line

- of

- sight of the operator and must not exceed an operating altitude of 400 feet AGL (above ground level).

Technology advances

– Time passes. With today ’ s technology we have the capability to mount a lightweight still or video camera in a remotely controlle d aircraft and monitor this video feed in

real

- time during flight

. This ability to capture video and still images is the foundation for commercial sUAS operation today

.

* * *

With the technology available today the safety of a sUAS has been in creased dramatically. On today ’ s sUAS there is an intelligent Flight Co ntrol System coupled with built

- in GPS providing

accurate GPS position information

. Telemetry provides real

- time data to the Flight Operator (Pilot ) with altitude (AGL), flight speed

and distance from the Flight Operator (Pilot) . The Flight Operator (Pilot) is also provided in real

time the available remaining battery power for flight and the number of GPS satellites in view. A

“ radar style display ” provides real

- time location and hea ding relative to the Flight Operator (Pilot).

The Flight Operator (Pilot) is no longer estimati ng his/her altitude, speed, distance and heading

or available flight power . He /she views these critical flight parameters live and in real

- time.

The intelligent Flight Control System onboard the sUAS is programmed via software to limit the flight altitude to 400 feet AGL. There will be no inadvertent flight above the restricted operating
altitude.

The intelligent Flight Control System onboard the sUAS is programme d via software to prevent motor start within 5 nautical miles of an airport or in restricted or in prohibited airspace. This prevents inadvertent flight within 5 nautical miles of an airport or otherwise restricted airspace.

The intelligent Flight Control System coupled with GPS position information provides the ability for the Flight Operator (Pilot) to permit the sUAS to auto

- hoover in position with compensation
for wind drift.

The intelligent Flight Control System coupled with GPS position information pr ovides the ability for the Flight Operator (Pilot) to command the sUAS to automatically return to its point of
departure.

The sUAS will return to its point of departure automatically in the event of a loss of RF Control from the Flight Operator (Pilot).

* * *

## Section 333 Exemption Request

- RD Group

sUAS Aircraft

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 20 of 35 

## sUAS Operated by RD Group

sUAS operated by RD Group do not carry on board any persons ( crew or passengers ) . No property belonging to any persons or group other than RD Group is carried on board RD Group sUAS during RD Group flight operations.

1) sUAS Operat ed by RD Group are as follows:

a. DJI Phantom 2 Vision+

b. None Other 

## DJI Phantom 2 Vision+

1) The DJI Phantom 2 Vision+ is a small, lightweight multi

- rotor battery powered aircraft. It does not carry or contain onboard any flammable fuel, explosives or

weapons sys tems.
2) Make (Manufacturer) : DJI

i. DJI is a world leader in innovation and manufacturing of sUAS. DJI has
a well

- known commitment for creating safe, easy to operate sUAS.

3) Model: Phantom 2 Vision+
4) Type: Rotorcraft (multi

- rotor / quad

- rotor)

5) Specifications:

a. Size: 14 inches (diagonal

- motor to motor)

b. Maximum Weight (gross maximum w eight including payload): 2.9 lbs.

c. Maximum Horizontal Speed 29 Knots : (15 m/s)

d. Maximum flight time : 25 minutes

e. RF Control range : 2,600 feet
6) Airframe

a. Q uad

- R otor Electric P ropulsion S ystem

b. Sa fety R otor G uards

c. Power Source ( R emovable /R echargeable Battery S ystem)

d. Brilliant Red/Green LED in dicators beneath the aircraft :

i. To differentiate aircraft front/rear

ii. T o alert the operator of loss of GPS signal
7) DJI Naza

- M V2 I ntelligent F light C ontro l S ystem
8) GPS
9) Digital Compass
10) 5.8 GHz (flight controller)

11) 2.4 GHz ( vide o and data communication)

12) All RF components are FCC certified.
13) Digital Camera and Camera Gimbal

## Section 333 Exemption Request

- RD Group

sUAS Aircraft

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 21 of 35 

## DJI Phantom 2 Vision+ Safety Features :

1) The DJI Phantom 2 Vision+ is e quipped with safety rotor guards to

prevent /reduce injury/damage in the event of accidental impact with persons or

property.
2) The DJI Phantom 2 Vision+ has an onboard DJI Naza

- M V2 I ntelligent Flight Control System with built

- in GPS providing accurate position inf ormation.
3) The DJI Phantom 2 Vision+ provides Flight Telemetry D ata in real

- time to the Flight Operator (Pilot) with the following information :

a. Display real

- time Altitude (AGL),

b. Display real

- time Flight S peed and D istance from the Flight Operator (Pilot).

c. D isplay real

- time number of GPS satellites in view

d. Display real

- time available remaining battery power for flight

. i. Audible and visual alarms alert the operator on the operator display when battery level is reduced to below 28%.

4) When the battery level is r educed to below 15% the DJI Phantom 2 Vision+ will begin an automatic descent and landing. Upon landing the DJI Phantom 2 Vision+ motors will stop. the DJI Phantom 2 Vision+ will not crash upon inadvertent exhaustion of its power source.

5) A “ radar style dis play ” provides real

- time location and heading relative to the Flight Operator (Pilot).

6) The intelligent Flight Control System coupled with the GPS position information
onboard the DJI Phantom 2 Vision+ provides the ability for the Flight Operator (Pilot) to permit the sUAS to auto

- hoover in position with compensation for wind
and drift.

7) The intelligent Flight Control System coupled with the GPS position information
onboard the DJI Phantom 2 Vision+ p rovides the ability for the Flight Operator (Pilot) to command the sUAS to automatically return to its point of departure.

8) The DJI Phantom 2 Vision+ will return to its point of departure, land and shut down the motors automatically in the event of a loss of RF Control from the Flight Operator (Pilot). Loss of signal will be displayed on the Flight Operators (Pilot) display.

9) The DJI Phantom 2 Vision+ is programmed via software to not permit operation above 400 feet AGL. This prevents inadvertent flight above the 400 feet AGL ceiling mandated by the FAA.

10) The DJI Phantom 2 Vision+ is programmed via software to prevent motor start within 5 nautical miles of an airport or in restricted or in prohibited airspace. This prevents inadvertent flight within 5 nautical miles of an airport or otherwise restricted airspace.

11) T hes e highly advanced capabilities i nsure that the DJI Phantom 2 Vision+ will not create a hazard to the public and can be safely operated in the National Airspace System (NAS) with an equivalent level of safety as a certified manned aircraft

.

## Section 333 Exemption Request

- RD Group

sUAS Flight Crew

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 22 of 35 

# 7 ) sUAS Flight C re w

Private Pilot Certificate

A pilot with a FAA Private Pilot C ertificate and a pilot with a FAA Commercial Pilot Certificate have both demonstrated a parallel level of knowledge in required aeronautical knowledge. A FAA
Commercial Pilot Certificate will demonstrate further airmanship skills to safely carry passengers and cargo for hire. A sUAS will not carry passengers or cargo for hire. Thus a Flight Operator (Pilot) with a FAA Private Pilot Certificate will provide the equivalent and required
level of safety to operate a sUAS as a Flight Operator (Pilot) with a FAA Commercial Pilot
Certificate

.
These enhanced airman ship skills are not utilized in t he flight of the sUAS thus a FAA
Certificated Private P ilot with sUAS flight training will provide an e quivalent level of safety.

In the granting of exemption #11062 to Astraeus Aerial the FAA determined that a PIC with a
FAA Private Pilot Certificate operating the sUAS would not adversely affect operations in the NAS or present a hazard to persons or prope rty on the ground.

In similar fashion to Astraeus Aerial operations, RD Group operations are conducted over private property or over controlled access property and with the permission of the property owner/controller or authorized representative.

RD Group sUAS Flight Operator (Pilot) hold s a current FAA Private Pilot Certificate.


## Third Class Medical Certificate

A Third Class Medical C ertificate provides an equivalent level of safety as a FAA Second Class

Medical Certificate given the level of safety require d for sUAS flight operations

.
A Third Class Medical C ertificate provides an equivalent level of safety as does a FAA Second
Class Medical Certificate given :

1) There are no persons (crew or passengers) or cargo onboard the sUAS.
2) The sUAS ability to “ auto hoov er ” and “ auto return home ” at the touch of a button.
3) In event of incapacitation of the Flight Operator (Pilot) t he sUAS will automatically begin a descent and landing when the battery level is reduced to below 15%.

RD Group sUAS Flight Operator (Pilot) hol d s a current Third Class Medical Certificate.

## Section 333 Exemption Request

- RD Group

sUAS Flight Crew

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 23 of 35 

## Flight Operator (Pilot) Requirements:

1) Flight Operator ( Pilot ) must possess at a minimum:

a) FAA issued Private Pilot Certificate

. b) Must meet FAA flight currency requirements for FAA pilot license held

. c) Current FAA Third Class Medical C ertificate

. d) Flight Operator (Pilot) must have received and documented all required initial and recurrent training.
2) Flight Operators (Pilot) Flight Experience

a) Flight Operators (Pilot) must have accumulated and logged a minimum of 20 flight cycles and 20 flight hours as sUAS pilot.
i) At least 10 hours of this time must be in a similar type of sUAS. 

## Visual Observer (VO) Requirements:

1) Visual Observer (VO) must have received and documented all required initial and

recurrent tr aining.

2) The Visual Observer (VO) is NOT required to possess a FAA Pilot License or a FAA
Medical Certificate.

## Section 333 Exemption Request

- RD Group

sUAS Operating Parameters

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 24 of 35 

# 8 ) s UAS Ope rating Parame te rs

sUAS Requirements for Flight:

3) sUAS operator must have continuously available telemetry from the sUAS including :
a) Displa y of sUAS distance from the operator.
b) Display of sUAS altitude from the operator.
c) Display of sUAS remaining battery life.
4) sUAS may not be operated with less than 25 % useful battery life.
5) sUAS may not carry any flam m able fuel, pyrotechnic devices or weapon systems
onboard

. 6) sUAS may not carry any device which propels a projectile or drops any object that creates a hazard to persons or property. 

## sUAS Documentation Requirements

Due to the sUAS size and weight limitations and the fact that the sUAS does not contain an

operator

, these documents will be with the Flight Operator (Pilot) during all flight operations.

1) Flight Operators ( Pilot ) must have the following manuals and documents for flight.

a) FAA Exemption
b) DJI Phantom User ’ s Manual
c) DJI Phantom Pilot Training Guide 

## sUAS Pre

- Flight Requirements

A pre

- flight operations are critical to safe flight. The Flight Operator (Pilot) is responsible for completion of all pre

- flight inspections and operations.

1) Pre

- Flight Inspection
a) Batteries used on flight.
i) These batteries include, but are not limited to the sUAS primary flight battery,
sUAS remote control battery, First Person View (FPV) range extender and Flight Operator (Pilot) FPV display /control device.
ii) Verify sufficient charge for the flight to be flown

iii) Visua l inspection to insur e that the batteries are not da mage, swollen or
corroded
b) sUAS Propellers
i) Verify smooth mechanical rotation
ii) Visual inspection of all propellers for mechanical defects

## Section 333 Exemption Request

- RD Group

sUAS Operating Parameters

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 25 of 35 c) sUAS Mechanical Visual inspection of sUAS for defects that would af fect the safe operation of flight.
i) Rotor guards
ii) Landing gear
d) Camera
i) Remove lens cap
ii) Inspect for smooth motion in all axis
iii) Inspect for mechanical defects that would affect the safe operation of flight
iv) Insure installation of Micro

- SD card
2) Power Up
a) Verify that S1 and S2 on the remote control are in the “ UP ” position.
b) Power on the equipment:
i) Flight Operator (Pilot) FPV display/control

ii) Range Extender
iii) Remote Control
iv) Phantom
c) Calibrate the Phantom compass in accordance with DJI Phantom Operational Manual
d) Verify acquisition of GPS signal lock
e) Observe all devices for abnormal behavior
3) DJI Vision Application
a) Verify FPV display/control in connected to the Phantom

b) Verify Wi

- Fi signal strength
c) Initiate the DJI Vision application on the FPV display/control

d) Verify FPV camera is operational

Pre

- Flight Operations Complete

– Phantom is ready for flight 

## sUAS Flight Requirements

All RD Group sUAS flights are performed within a small geographical area defined by line

- of

sight of the Flight Operator (Pilot) or Visual Obse rver (VO) and with a maximum flight altitude of
400 feet Above Ground Level ( AGL )

. All RD Group sUAS flights operate over private or controlled property and with the permission of the property owner.

1) The Flight Operator (Pilot) is has final authority for s afety of flight.

2) A pre

- flight briefing will be performed before every flight by the Flight Operator (Pilot) with all personal involved in planned sUAS flight operations. This briefing will include at
a minimum:
a) Safety
b) Emergency Procedures
c) Planned Operations.

## Section 333 Exemption Request

- RD Group

sUAS Operating Parameters

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 26 of 35 3) A pre

- flight safety inspection will be performed before every flight segment.
4) sUAS operations w ill always utilize a Visual Observer (VO)

5) The Flight Operator (Pilot) and Visual Observer (VO) must maintain verbal

communications at all times.

6) sUAS Flight Operator (Pilot) or Visual Observer (VO) must maintain visual line of sight

and visual contact with the sUAS at all times.

a) Visual line of sight requires the unaided (corrective lenses and /or sunglasses excepted) contact between a pilot in command and an unmanned aircraft sufficient to maintain safe operational control of the aircraft, know its location, and be able to scan the airspace in which it is operating to see and avoid other air traffic or objects aloft or on the ground.

7) No member of the Fl ight Crew may participate in sUAS flight while under the influence of alcohol or any drug that would adversely affect the ability to safely participate in the flight of the sUAS.

8) sUAS may not carry any flammable fuel, pyrotechnic devices or weapon systems
onboard.

9) sUAS may not carry any device which propels a projectile or drops any object that creates a hazard to persons or property.
10) sUAS Flight
a) sUAS may not be flown in a careless or reckless manner.
b) sUAS may not be flown in areas where flight of sUAS is prohibited.
c) sUAS w ill y ield the right

- of

- way to all manned aircraft.
11) Flight Restrictions

a) All RD Group sUAS flights will operate in a tightly controlled area over private or controlled property with permission of the property owner.
b) sUAS may not operate in Class A airspace.
c) Maximum sUAS operating a ltitude of 400 feet above ground level.
d) sUAS may not be flown at an air speed exceeding 29 Knots (15 m/s)

. e) Maximum sUAS flight distance of 2, 6 00 feet from the sUAS operator.
f) sUAS operations require a minimum v isibility of 3 statute mile s

. g) sUAS must operate no closer than 500 feet below or 2,000 feet horizontally from any clouds

. h) sUAS may NOT be flown at night.
i) sUAS Flight Operator (Pilot) may not operate the sUAS from any moving vehicle.
i) Exception: sUAS operation from a boat that is located at least of 1⁄2 mil e from shore is permitted.
j) sUAS flight will be terminated when remaining battery falls to 25% capacity.

## Section 333 Exemption Request

- RD Group

sUAS Operating Parameters

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 27 of 35 12) Operation in the Vicinity of Airports
a) An airport as is designated on current FAA Aeronautical Chart.

b) sUAS operation within 5 nautical m iles of an airport WITH an oper ating Air Traffic
Control Tower is permitted provided :
i) The sUAS Flight crew must be in continuous communication with and receive
clearance from the active Air Traffic Control Tower.

c) sUAS operation within 5 nautical miles of an airport WIT HOUT an operating control

tower is permitted provided :
i) The Flight crew must monitor and transmit position/intention reports on the local Unicom frequency when operating within this area.
13) Flight Restrictions /Clearance from Non

- Participa ting Persons

a) Flight Operations must be conducted at least 500 feet from any an d all non

participating persons

. i) Flight operations with clearance of less than 500 feet are permitted if barriers or structures are present that sufficiently protect non

- particip ating persons
from debris in the event of an accident.

ii) If during flight a situation arises where non

- participating persons leave such protection the sUAS flight must be terminated immediately.

b) Due to their small size

, light weight (less than 6 lbs.)

, the f act that they contain rotor guards to protect objects in the event of impact, the fact that no fla m mable
fuels or pyrotechnics are onboard :
i) sUAS operation of a micro

- light (sUAS weighing less than 6 lbs.) IS permitted
with less tha n 500 feet clearance of o bjects, structures or vehicles

. ii) Operation within 500 feet of non

- participating persons NOT protected by
shelter is never permitted

. 

## Accident/Incident Reporting

Any incident or accident that inflicts serious injury or death up a person or causes property damage in excess of $25,000 must be reported to the local FAA Flight Safety District Office (FSDO) within 72 hours of the occurrence.

## Section 333 Exemption Request

- RD Group

sUAS Maintenance

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 28 of 35 

# 9 ) s UAS Mainte nanc e

Proper inspection and maintenance is critical to safe sUAS operation.


## Preventative Maintenance

Maintenan ce, Preventative M aintenance and Inspections will be performed in accordance with
DJI maintenance and inspection recommendations contained in the latest DJI Manual. 

## Maintenance/Corrective Action Documentation

Each sUAS will have an Aircraft Maintenance Record. Entered into this Aircraft Maintenance

Record will be:

1) sUAS Discrepancies
2) A ction taken to correct these discrepancies.
3) sUAS Inspections Performed
4) sUAS Maintenance Performed

Corrective actions and inspections document ed in the Aircraft Maintenance R ecord will include at a minimum the following information :

1) Date
2) Discrepancy or corrective a ction taken
3) Part ( s ) replaced
4) Person performing the work
a) Person performing the work must have documented completion of RD Group requir ed training.

Actions and R ecords entered into the sUAS Aircraft Maintenance Record will be maintained for

two years.

## Section 333 Exemption Request

- RD Group

sUAS Training

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 29 of 35 

# 10) sUAS Training

Safety is achieved through the relentless pursuit of quality training and adherence to FAA Approved Operating Procedures and FAA Regulations.

This section describes the policies and procedures for training performed by RD Group.

RD Group will use all training sources and methods available to provide employees with the information necessary for them to perform their assigned duties and tasks correctly and sa fely.

The majority of the training provided by this organization will use on

- the

- job (OJT)
methodology. 

## Flight Operator (Pilot) Training

Flight Operator (Pilot) will receive and document training type and training hours as required per Training Table Requi rements

. 1) Flight Operators (Pilot) Flight Experience

a) Flight Operators (Pilot) must have accumulated and logged a minimum of 20 flight cycles and 20 flight hours as sUAS pilot.
i) At least 10 hours of this time must be in a similar type of sUAS. 

## Visual Observer (VO) Training

Visual Observer (VO) will receive and document training type and training hours as required per Training Table Requirements

. 

## Maintenance Training

Maintenance Personnel will receive and document training type and training hours as required

pe r Training Table Requirements

. 

## Training Sources

RD Group will use any and all training materials deemed necessary by RD Group and/or the FAA to provide training to RD Group Flight Crew members. The following is a list of materials that will be used to prov ide training:

1) FAA Far

- AIM
2) VFR Sectional Chart
3) RD Group Section 333 Exemption
4) Academy of Model Aeronautics (AMA) Safety Code

5) DJI Phantom Pilot Training Guide
6) DJI Phantom User ’ s Manual
7) DJI Phantom Guide

## Section 333 Exemption Request

- RD Group

sUAS Tra ining

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 30 of 35 

## Training Requirements Table

Flight Operator
(Pilot) Visual Observer
(VO)

Training Type Number of Hours training required
This is total hours of training required

Initial Ground 10 5

Initial Flight 5 N/A

Flight Operator (Pilot) must meet flight experience qualifications. These are different from the initial Flight Training requirements.

Annual Recurrent Ground 5 2

Annual Recurrent Flight 5 N/A

Initial Maintenance 2 2

Annual Recurrent Maintenance 1 1

Training Requirements (Yes/No)

sUAS Technology Yes Yes

Maintenance Yes Yes

Safety Yes Yes

FAA Regulations Yes Yes

National Airspace Regulations & Utilization Yes Yes

Documentation Requirements for Flight Yes Yes

Flight Crew Requirements for Flight Yes Yes

Weather Requirements for Flight Yes Yes

Crew Duties and Responsibilities Yes Yes

Flight Restrictions Yes Yes

Flight Training Yes No

Accident/Incident Reporting Yes No

## Section 333 Exemption Request

- RD Group

sUAS Training

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 31 of 35 

## Training Guide

This detailed training guide covers topics, information and comments about each subject that will be taught. This is not all inclusive, any/all subjects deemed necessary by RD Group and/ or the
FAA will be taught

. 1) sUAS technology
a) sUAS operator control
b) sUAS intelligent flight controller
c) GPS
d) LiPo Batteries
e) FPV Technology
f) Camera/Gimbal
g) FPV Control

- Display
2) Maintenance
a) Safety
b) Reference Material for M aintenance
c) Documentation of Maintenance Actions
3) Safety
a) How not to o peration i n a careless or reckless manner.
b) Clearance from personal not directly involved with the flight of the sUAS.
c) Model Aeronautics National Model Aircraft Safety Code
4) FAA Regulati ons a) Section 333 Exemption

– Limitations and Requirements.
b) AIM

– FAR
c) sUAS Regulations
d) Hobby & Recreation
e) Commercial Operations
5) National Airspace Regulations & Utilization
a) Detailed examination of the United States National AirSpace system
b) VFR Sectional Chart
6) Documentation R equirements for F light
7) Flight Crew Requirements for Flight
a) Flight Operator (Pilot)

b) Visual Operator (VO)

c) Flight Dispatcher
d) sUAS Requirements for Flight
8) Weather Requirements for Flight

## Section 333 Exemption Request

- RD Group

sUAS Training

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 32 of 35 9) Crew Duties and Responsibilities
a) Flight Operator (Pilot )

b) Visual Observer (VO)

10) Flight Restrictions
a) Flight restrictions/ requirements imposed by Section 333 Exemption
a) National AirSpace limitations for the use of sUAS.
b) Operation in the vicinity of airports
c) Line

- of

- Sight
i) What does line

- of

- sight mean

ii) Visual line of sight requires the unaided (corrective lenses and /or sunglasses excepted) contact between a pilot in command and an unmanned aircraft sufficient to maintain safe operational control of the aircraft, know its location, and be able to scan the airspace in w hich it is operating to see and avoid other air traffic or objects aloft or on the ground

. 11) Flight Training
a) Preflight briefing
b) Safety Pre

- Flight
c) Compass Calibration and GPS acquisition
d) Take

- off and landing
e) Use of FPV and flight mission equipment
f) Emergency Procedures
g) Successful demonstration of all flight maneuvers in the DJI Phantom Pilot Training
Guide.
12) Accident/Incident Reporting

## Section 333 Exemption Request

- RD Group

For the Good of the Public

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 33 of 35 

# 11) For the Good of the Public

Equivalent Level of Safety

small Unmanned Aircraft System (sUAS) operated by RD Group provide an increased level of safety vs. certified manned aircraft because of their small size, slow airspeed, light weight, operator license requirements , intelligent sUAS systems and operational parameters required.

A low flying aircraft or a low altitude helicopte r (operating in strict compliance with existing FAA regulations) hovering and circling over a small confined area creates an inherent safety risk. This risk can be minimized, but cannot be eliminated. Manned flight involves hazards to life and

property.

In the event of an accident or incident the damage caused by a small lightweight sUAS is considerably less than the damage caused by much larger and heavier manned aircraft. The risk of injury or death to people or persons is significantly lower with the use of a sUAS because of the small size, lightweight and slow airspeed of the sUAS.

Certified and manned aircraft are significantly larger and more complex than simple

, small Unmanned Aircraft System (sUAS). This simplicity leads to a reduced risk of mechanic al failure.

sUAS operated by RD Group carry no flammable fuel, no weapons systems or combustible
materials onboard . The risk of fire is virtually eliminated. Manned aircraft are at a constant risk
of in

- flight fire or fire in the event of an incident or ac cident.

When operated by a properly trained and qualified flight crew [Flight Operator (pilot) and Visual Observer (VO)], within approved operating parameters and an intelligent flight control system the sUAS is safer than a certified aircraft (for the typ e of operations RD Group is requesting this exemption for) due to its small size, lightweight and slow flight speed.

sUAS operated by RD Group within the operating parameters outlined herein provide an equivalent level of safety as a certified manned aircr aft. 

## Public Interest

Today ’ s current methods of commercial aerial photography and commercial aerial inspection require the use of a certified manned aircraft or a certified manned helicopter and a pilot with a
FAA Commercial Pilot License. A low flying air craft or a low altitude helicopter (operating in

strict compliance with existing FAA regulations) hovering and circling over a small confined area creates an inherent safety risk . It can often create a nuisance of noise pollution in the affected

area as we ll

. RD Group is permitted by law to utiliz e ( sUAS ) in many international countries for commercial operations. However in the United States (our country of residency and citizenship) we are only permitted to fly a sUAS for hobby or for recreational purposes only

.

## Section 333 Exemption Request

- RD Group

For the Good of the Public

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 34 of 35 These regulatory restrictions create an economic hardship for RD Group.

Granting this requested exemption will be in the public interest because of :

1) The increased level of safety that is afforded by the use of RD Group sUAS vs. the use
of a certif ied manned aircraft or a certified manned helicopter:
2) B ecause of the economic relief that it will provide to RD Group and its employees

. 3) B ecause of the positive economic impact it will provide to the community

. 4) Will provide an economic benefit to American Citizens.
5) B ecause of the reduction in th e number of aircraft in the NAS

. 6) B ecause of the reduction in the level of aircraft noise for persons on the ground.

Granting this Section 333 exemption request for RD Group for commercial operation of sUAS
within the operating parameters outlined herein is in the public interest. 

## Privacy

All sUAS flights operate in a tightly controlled area , at altitude of less than 400 feet AGL and over private or controlled property with permission of the property owner.

sUAS operated by RD Group within the operating pa rameters outlined her e in present no risk to the privacy of the public. 

## National Security

sUAS do not pose a risk to national security because of: 1) Requirement for t he FAA for the sUAS Flight Operator (Pilot) to ho ld a FAA Private Pilot
Certificate

a) Pilots Certificated by the FAA are subject to security screening by the Department of Homeland Security.
2) Due to their small size (less than 6 Lbs.)

3) Due the tightly controlled area of sUAS operation.

a) All sUAS flights opera te in a tightly controlled area over private or controlled property with permission of the property owner.
4) sUAS carry no flammable fuel onboard

. 5) sUAS carry no weapon systems onboard

. 6) sUAS carry no combustible materials onboard

. sUAS operated by RD Group wi thin the operating pa rameters outlined herein present no risk to national security

.

## Section 333 Exemption Request

- RD Group

For the Good of the Public

This S ection 333 Exemption request may
be published in the Federal Docket. Document No.: DP1001

Initial Release: 29 Sep 2014

Revision Number: 01

Revision Date: 13 Mar 2015
Page 35 of 3 5 

## Conclusion

Existing FAA Regulations burden RD Group ’ s sUAS operations by preventing RD Group from performing commercial sUAS operations to conduct aerial video and photo graphy services for
real estate and construction, surveying and inspection, marine and wildlife, agriculture and for special events

As we have clearly shown

, commercial operation of small Unmanned Aircraft Systems ( sUAS ) by RD Group with the sUAS A ircraft, sUAS Flight Crew, sUAS Operating Parameters, sU AS Maintenance and sUAS training requirements as outlined in this request for relief :

1) Will provide an equivalent level of safety as certified manned aircraft.
2) Will not adversely affect safety in the National Airspace System
3) Will reduce airspace congestion

. 4) Will reduce airborne noise.
5) Will not pose a hazard the public
6) Will present no risk to the privacy of the public
7) Will present no risk to national security.
8) Will provide an economic benefit to American Citizen s. 9) Is in the interest of the public.

The FAA ’ s authority to issue exemptions from current operating rules and regulations, and the
S ecretary ’ s authority granted by section 333 of P.L. 112

- 95 (Special Rules for Certain Unmanned Aircraft Systems) provides an opportunity to authorize certain sUAS operations into the National Airspace System (NAS) prior to implementation of the final sUAS rule.

Granting this Section 333 exemption request for RD Group for commercial operation of sUAS within the operating paramet ers outlined herein IS in the public interest.

RD Group has shown j ust cause exist for the FAA to grant relief from these Federal Aviation Regulations

.

Thank you,

David w Mansen