This Section 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 

13 March 2015
This Section 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: 13 Mar 2015

Re: Exemption request pursuant 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 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.

RD Group seeks relief to permit commercial operations utilizing sUAS to conduct aerial video 

and photography 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 Section 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 Section 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

Abbreviations Used

This Section 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 Section 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 permit commercial operations utilizing sUAS to conduct aerial video 

and photography 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 Regulations 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) Operation of small Unmanned Aircraft Systems (sUAS) by RD Group with the sUAS 

Aircraft, sUAS 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 (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 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 Section 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 pursuit 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) Safety 

Code. A copy of this code is included with this Section 333 Exemption request. 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 rotorcraft (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 Section 6 (sUAS Aircraft).

* * *

Flight crew for RD Group sUAS operations will be a Flight Operator (Pilot) and a Visual Observer 

(VO).

The Flight Operator (Pilot) will possess a current FAA private pilot license and a current FAA 

Class III medical certificate. The Visual Observer (VO) will have received required RD Group 

training to qualify for Visual Observer (VO) duties.

RD Group Flight Crew requirements are discussed in detail in Section 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 owner/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 Section 8 (sUAS Operating Parameters).
Section 333 Exemption Request - RD Group

Regulations Relief Sought For

This Section 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 ns Re lie f Sought For

Listed below are FAA regulations for which RD Group is seeking relief.

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.

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 certificate 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 

Certificate (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) the sUAS will 

automatically begin a descent and landing when the battery level is reduced to 

below 15%.
Section 333 Exemption Request - RD Group

Regulations Relief Sought For

This Section 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 pilot 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 command 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 FAA Commercial Pilot Certificate.

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

A pilot with a FAA Private Pilot Certificate and a pilot with a FAA Commercial Pilot Certificate 

have both demonstrated a parallel level of required aeronautical knowledge. A FAA Commercial 

Pilot Certificate requires demonstration of further airmanship skills to safely carry passengers 

and cargo for hire. RD Group sUAS will not carry onboard any persons (passengers/crew) or 

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 FAA Commercial Pilot 

Certificate.

These enhanced airmanship 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 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 property 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.

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 Section 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 35

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.

In the granting of exemption #11188 to State Farm the FAA determined that even though the 

sUAS is not required to have an airworthiness certificate 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 accordance 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 Mutual 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 Section 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 operations 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) Permission 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 Section 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 

§91.121 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 current 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 

appropriate 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 usable 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 equivalent 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 sUAS flights are conducted below 400 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 Company the 

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 permission of the property owner and 

within VLOS of the Flight Operator (Pilot) or Visual Observer (VO).

2) The use 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 Section 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) and (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 landing 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 controlled 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+ motors 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 Phantom 2 Vision+ sUAS operated by RD Group is a rotorcraft (multirotor / 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 Section 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) 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 § 91.405 (a)] in exemption 

#11188 to State Farm 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 Aircraft, 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 Section 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 annual 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 Section 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 operator 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 inspections, 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 overhauled 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 applicable 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 required.

(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 periods 

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 Section 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 approved for return to service.

Relief from 14 CFR § 91.417 (a) and (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 Section 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 Certified manned aircraft and Certified manned helicopters with a 

pilot who holds a FAA Pilot Commercial Certificate.

In numerous International Countries we are permitted by law to utilize small Unmanned Aircraft 

System (sUAS) to perform these same commercial aerial video and photography services. The 

use of sUAS provides an increase in operational flexibility and provides higher 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 photography 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 Maintenance Inspector and as a FAA Part 145 Repair Station “FAA 

Accountable Manager” Mr. Mansen has demonstrated an exemplary record of safe operation and 

of adherence to FAA regulations.

Mr. Mansen currently 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 Maintenance 

facility and through smart business practices, a relentless 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 Manager at TexasGYRO for ten years with ZERO 

FAA safety incidents, ZERO FAA infractions, and ZERO FAA citations. Mr. Mansen has proven

that he has the skill, knowledge and experience necessary to install 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 Section 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 controlled 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 increased dramatically. On 

today’s sUAS there is an intelligent Flight Control 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 realtime the available remaining battery power for flight and the number of GPS satellites in view. A

“radar style display” provides real-time location and heading relative to the Flight Operator 

(Pilot).

The Flight Operator (Pilot) is no longer estimating 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 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.

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 provides 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 Section 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 onboard any persons (crew or passengers). No 

property belonging to any persons or group other than RD Group is carried onboard RD Group 

sUAS during RD Group flight operations.

1) sUAS Operated 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 systems.

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 weight 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. Quad-Rotor Electric Propulsion System

b. Safety Rotor Guards

c. Power Source (Removable/Rechargeable Battery System)

d. Brilliant Red/Green LED indicators beneath the aircraft:

i. To differentiate aircraft front/rear

ii. To alert the operator of loss of GPS signal

7) DJI Naza-M V2 Intelligent Flight Control System

8) GPS

9) Digital Compass

10) 5.8 GHz (flight controller)

11) 2.4 GHz (video 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 Section 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 equipped 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 Intelligent Flight 

Control System with built-in GPS providing accurate position information.

3) The DJI Phantom 2 Vision+ provides Flight Telemetry Data in real-time to the 

Flight Operator (Pilot) with the following information:

a. Display real-time Altitude (AGL),

b. Display real-time Flight Speed and Distance from the Flight Operator (Pilot).

c. Display 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 reduced 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 display” 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+ provides 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) These highly advanced capabilities insure 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 Section 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 Cre w

Private Pilot Certificate 

A pilot with a FAA Private Pilot Certificate 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 airmanship skills are not utilized in the flight of the sUAS thus a FAA 

Certificated Private Pilot with sUAS flight training will provide an equivalent 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 property 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) holds a current FAA Private Pilot Certificate.

Third Class Medical Certificate 

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

Medical Certificate given the level of safety required for sUAS flight operations.

A Third Class Medical Certificate 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 hoover” and “auto return home” at the touch of a button.

3) In event of incapacitation of the Flight Operator (Pilot) the sUAS will automatically begin 

a descent and landing when the battery level is reduced to below 15%.

RD Group sUAS Flight Operator (Pilot) holds a current Third Class Medical Certificate.

 
Section 333 Exemption Request - RD Group

sUAS Flight Crew

This Section 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 Certificate.

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 training. 

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 Section 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) Display 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 flammable 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) Visual inspection to insure that the batteries are not damage, 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 Section 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 affect 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-ofsight of the Flight Operator (Pilot) or Visual Observer (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 safety 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 Section 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 will 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 Flight 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 will yield 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 altitude of 400 feet above ground level.

d) sUAS may not be flown at an airspeed exceeding 29 Knots (15 m/s).

e) Maximum sUAS flight distance of 2,600 feet from the sUAS operator.

f) sUAS operations require a minimum visibility of 3 statute miles.

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 mile 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 Section 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 miles of an airport WITH an operating 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 WITHOUT 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-Participating Persons

a) Flight Operations must be conducted at least 500 feet from any and all nonparticipating persons.

i) Flight operations with clearance of less than 500 feet are permitted if barriers 

or structures are present that sufficiently protect non-participating 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 fact that they contain 

rotor guards to protect objects in the event of impact, the fact that no flammable 

fuels or pyrotechnics are onboard:

i) sUAS operation of a micro-light (sUAS weighing less than 6 lbs.) IS permitted

with less than 500 feet clearance of objects, 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 Section 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 

Maintenance, Preventative Maintenance 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) Action taken to correct these discrepancies.

3) sUAS Inspections Performed

4) sUAS Maintenance Performed

Corrective actions and inspections documented in the Aircraft Maintenance Record will include 

at a minimum the following information:

1) Date

2) Discrepancy or corrective action taken

3) Part(s) replaced

4) Person performing the work

a) Person performing the work must have documented completion of RD Group 

required training.

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

two years.
Section 333 Exemption Request - RD Group

sUAS Training

This Section 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 safely.

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 Requirements.

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 

per 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 provide 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 Training

This Section 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 Section 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 Maintenance

c) Documentation of Maintenance Actions

3) Safety

a) How not to operation in 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 Regulations

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 Requirements for Flight

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 Section 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 which 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 Section 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 helicopter (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 mechanical 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 accident.

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 type 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 aircraft.

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 aircraft 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 well.

RD Group is permitted by law to utilize (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 Section 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 certified manned aircraft or a certified manned helicopter:

2) Because of the economic relief that it will provide to RD Group and its employees.

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

4) Will provide an economic benefit to American Citizens.

5) Because of the reduction in the number of aircraft in the NAS.

6) Because 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 parameters outlined herein 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 the FAA for the sUAS Flight Operator (Pilot) to hold 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 operate 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 within the operating parameters outlined herein present no risk to 

national security.

 
Section 333 Exemption Request - RD Group

For the Good of the Public

This Section 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 35

Conclusion 

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 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 Aircraft, sUAS Flight Crew, sUAS Operating Parameters, sUAS 

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 Citizens.

9) Is in the interest 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 (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 parameters outlined herein IS in the public interest.

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

Regulations.

Thank you,

David w Mansen