RSC Aviation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 1

d

1553 East Race Ave.

Searcy, AR 72143

501-279-6575

August 12, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”)

and 14 C.F.R. Part 11, RSC Aviation, LLC seeks an exemption from Federal Aviation Regulations

(“FARs”) detailed below for the DJI Inspire 1 Unmanned Aircraft System manufactured by DJI.

The requested exemption would permit RSC Aviation’s DJI Inspire 1, to conduct commercial

and public service operations in the following sectors: 

 Aerial filmmaking, photography and real estate

 Public entity support operations

 Construction site inspection and monitoring

 Oil and Gas drilling, exploration and production

 Flare stack inspection

 Pipeline inspection and patrolling

 Power and pipeline service and maintenance

 Agriculture mapping, survey, crop analysis 

In addition to the commercial sector, RSC Aviation, LLC seeks to apply its unmanned system

towards public service support. The DJI Inspire 1 would be used for public service in emergency 

response events for police, fire and rescue pre and post natural disasters. The system would be used for

public entities for the purpose of land, forestry, and water management surveying.
RSC Aviation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 2

Description of the Petitioner

RSC Aviation, LLC is owned by Wayne Robertson, a US citizen. RSC Aviation, LLC is a manned aircraft 

operation with experience operating and maintaining single piston engine and dual turbine engine 

aircraft. In addition, the petitioner owns Softmart Computers & Electronics, Inc. and RIG SITE 

Communications. The ownership has over 35 years of experience in the electronics field, staying current

on trends and technology and intends to use the UAS and sUAS platforms to complement and offer 

further value to its clients.

RSC Aviation employs current qualified commercial pilots. The current chief pilot has over 

10 years of experience in Aviation with a Bachelor in Professional Pilot at Henderson State 

University in Arkadelphia, Arkansas and over 2100 hours total flight time in National Airspace

System (NAS). RSC Aviation also employs private pilots with over 500 hours that are eager to

further their knowledge and experience in Aviation. This experience and knowledge allows RSC

Aviation to understand the procedures and regulations to operate safely in NAS with Small

Unmanned Aircraft Systems (sUAS).

PETITIONERS CONTACT INFORMATION:

RSC Aviation, LLC

Attn: Jeffery W. Robertson

1553 East Race Ave.

Searcy, AR 72143

501-279-6575

softmartwr@gmail.com
RSC Aviation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 3

PETITIONER HEREBY REQUESTS EXEMPTION FROM THE FARs: 

• 14 C.F.R. 21, subpart H 

• 14 C.F.R. 61.3 

• 14 C.F.R. 61.113(a)&(b) 

• 14 C.F.R. 61.133(a) 

• 14 C.F.R. 91.9(b)(2) 

• 14 C.F.R. 91.103(b) 

• 14 C.F.R. 91.105 

• 14 C.F.R. 91.109(a) 

• 14 C.F.R. 91.119 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.203(a) & (b) 

• 14 C.F.R. 91.319(a)(1)

• 14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417)

The requested exemption would authorize RSC Aviation to conduct commercial operations using one of 

the DJI Brand/Series UAS, primarily DJI Inspire 1, for mapping, inspection and photography of oil & gas 

facilities, , utilities, agriculture, construction sites, landfills, mining facilities, engineering assessments, 

damage assessments and fire investigation applications. 

In order to ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft, all operations will be subject to the strict operating requirements defined in the RSC Aviation

UAS Flight Operations Manual and Preflight Checklist (RSC Aviation will provide these documents if 

required, but requests that the FAA treat them as proprietary under 14 C.F.R. 11.35(b) and not include 

this document in the public docket). Additionally, this petition for exemption is supported by the 

information contained in the DJI Inspire 1 Pilot Training Guide, and the Smart Flight Battery Safety 

Guidelines (hereafter collectively referred to as “Manufacturer’s Operations Manuals”).

All RSC Aviation UASs will be operated only by individuals who hold at least an FAA issued private, 

recreational, or sport pilot certificate and who have successfully completed RSC Aviation UAS Training 

Program (the RSC Aviation UAS Training Program Outline will be submitted separately if required and 

RSC Aviation requests that the FAA treat this document as proprietary under 14 C.F.R. 11.35(b) and not 

include this document in the public docket). 
RSC Aviation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 4

The characteristics of the sUAS, detailed sUAS operator requirements, and sUAS operating parameters 

given below will ensure that all RSC Aviation UAS operations are carried out with an equivalent or higher 

level of safety than currently authorized manned aircraft operations. 

The details below regarding RSC Aviation’s intended UAS applications provide clear evidence that 

approval of this exemption is in the public interest. 

CHARACTERISTICS OF THE sUAS

The DJI Brand/Series of sUAS are all very similar. An exception is that the Phantom 3, Vision+ and Inspire 

1 include an integrated camera, while a second exception is a third party camera can be affixed to the 

Phantom 2. The Phantom 2 Vision+, Phantom 2, and Inspire 1 have a diagonal motor-to- motor distance 

of approximately 14 inches. The Phantom 3 is approximately 27 inches across, measured diagonally and 

including the propellers. All four UAS are constructed primarily of frangible materials (plastic) and weigh 

less than 3 pounds each. The Vision+ and Phantom 2 are powered by a 5200 mAh 3S LiPo battery. The 

Phantom 3 is powered by a 4480 mAh 4S LiPo battery. The Inspire 1 is powered by a 4500 mAh LiPro 6S 

battery. The max flight speed of the all DJI UAS is approximately 30 to 36 mph. All DJI UAS contain an 

on-board GPS and an internal measurement unit for flight stabilization and automatic failsafe return to 

home in case of a lost control signal. Additionally, these UAS offer geo-fencing and max altitude features 

to restrict the maximum vertical and horizontal distance the aircraft will fly from its home point. The 

Phantom 3, Vision+ and Inspire 1 offer the added feature of displaying real time flight data, including 

battery status, altitude and distance from home, within the DJI App. 

Each sUAS operated by RSC Aviation for commercial use will be registered in accordance with 14 C.F.R 

Part 47, and will be marked in accordance with 14 C.F.R. Part 45, , Subpart C, in a size as large as 

practical for the size of the sUAS. 

All sUAS operated by RSC Aviation will be maintained in accordance with the manufacture’s 

maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft 

components and all pertinent instructions in the user manuals. Repairs, component changes, and 

software/firmware updates will be recorded in the UAS maintenance log. Maintenance log entries will 

include the date, sUAS ID number, registration number, current sUAS flight time, a description of work 

performed, and the name of the individual who completed the work. Any sUAS that has undergone 

maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a 

flight critical component, must undergo a functional test flight, prior to use in any commercial 
RSC Aviation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 5

operations. The functional test flight must be conducted in such a manner so as to not pose an undue 

hazard to persons and property. The PIC who conducts the functional test flight must make an entry in 

the aircraft records. A pre-flight inspection of the UAS will be completed by the PIC prior to each flight 

operation as specified in the RSC Aviation UAS Flight Operations Manual. If the inspection reveals a 

condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. All 

RSC Aviation UAS will comply with all applicable manufacturer safety bulletins. 

Additional information on the aircraft specifications, performance limitations, operating procedures, 

and pre-flight inspections is contained in the attached document. The safety and reliability of the DJI 

Phantom 2 Vision+ and DJI Phantom 2 sUAS is further supported by the fact that numerous FAA 

exemptions have previously been approved for their use in commercial operations. As noted above, the 

DJI Phantom 3 and Inspire 1 are very similar to these sUAS and incorporates additional safety features. 

UAS OPERATOR REQUIREMENTS 

All RSC Aviation UAS operators will hold at least an FAA issued private, recreational, or sport pilot 

certificate and will have successfully completed RSC Aviation’s UAS Training Program. Completion of the 

RSC Aviation UAS Training Program will ensure safe operations by not allowing any PIC to operate a UAS 

unless that PIC has demonstrated, that he/she is able to safely operate the UAS in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. All operators will either meet the flight review 

requirements specified in 14 CFR § 61.56 or will annually complete and log at least 4 hours of ground 

instruction with a Certified Flight Instructor (CFI) covering regulations and issues pertinent to 

commercial operation of the Phantom 3, Phantom 2 Vision+ and Phantom 2 sUAS. 

The individual acting as PIC of a UAS will be identified prior to any flight and will not change once the 

flight has begun. The PIC is the individual in operational control of the flight operation from beginning to 

end and is responsible for safe flight of the UAS. All PIC flight hours used to demonstrate qualifications 

and currency will be logged in a manner consistent with 14 CFR § 61.51(b). 

In order to act as PIC, all RSC Aviation UAS operators will hold a current FAA airman medical certificate 

or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a 

possession, or the Federal government.
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OPERATING PARAMETERS of the UAS

In order to provide for a level of safety at least equivalent to operations conducted using manned 

aircraft, all RSC Aviation commercial UAS operations will be conducted in accordance with the following 

specific operating limitations: 

o The UAS may not be operated at a speed exceeding 30 knots (34 miles per hour). In no case will 

the UAS be operated at airspeeds greater than the maximum UAS operating airspeed 

recommended by the aircraft manufacturer. 

o All operations shall be conducted in accordance with an ATO-issued COA. 

o All UAS operations will occur at or below 500ft AGL or the maximum altitude specified in the 

COA limitations, unless the purpose of the flight is to inspect a building or structure which is 

taller than 500 ft. If the purpose of the flight is to inspect a building or structure which is taller 

than 500 ft then the max altitude of the UAS will be restricted to 20ft above the highest point of 

that building or structure. All altitudes must be reported in feet AGL. 

o No UAS will be operated within 3 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center of the airport symbol as denoted on the current FAA published aeronautical chart, unless 

a letter of agreement with that airport’s management is obtained or otherwise permitted by a 

COA issued to RSC Aviation. The letter of agreement with the airport management must be 

made available to the Administrator or any law enforcement official upon request. 

o No UAS will be operated within class B, C, D or E airspace unless a letter of agreement from the 

controlling ATC office is obtained or the flight is otherwise permitted by a COA issued to RSC 

Aviation. The letter of agreement from ATC must be made available to the Administrator or any 

law enforcement official upon request.

o The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses, as 

specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 

o All operating documents and a grant of exemption must be accessible during UAS operations 

and made available to the Administrator upon request. If a discrepancy exists between the 

conditions and limitations in the grant of exemption and the procedures outlined in the 

operating documents, the conditions and limitations in the grant of exemption take precedence 

and must be followed. Otherwise, the PIC must follow the procedures as outlined in the 

operating documents. RSC Aviation may update or revise its operating documents. However, it is 

RSC Aviation’s responsibility to track such revisions and present updated and revised documents 

to the Administrator or any law enforcement official upon request. RSC Aviation must also 

present updated and revised documents if it petitions for extension or amendment to the grant 

of exemption. If RSC Aviation determines that any update or revision would affect the basis 
RSC Aviation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 7

upon which the FAA granted the exemption, then RSC Aviation must petition for an amendment 

to the grant of exemption. 

o UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized. The UAS may not be operated less than 500 feet below or 

less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from 

the PIC. 

o Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. 

If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. All maintenance and alterations must be properly 

documented in the aircraft records. 

o Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test 

flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 

o If the UAS loses communications or loses its GPS signal, the UAS must return to a 

predetermined location. 

o The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

o The PIC is prohibited from beginning a flight unless the UAS battery level is at 75% or higher. 

The PIC must begin returning the UAS to the designated landing area when the battery level 

drops below 25%. 

o Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the

Ground Control Station of the UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

o The UAS must remain clear and give way to all manned Aviation operations and activities at all 

times. 

o The UAS may not be operated by the PIC from any moving device or vehicle

o UAS will not be operated directly over nonparticipating persons unless barriers or structures are 

present that sufficiently protect nonparticipating persons from the UAS and/or debris in the 

event of an accident. UA will not be operated over any open-air assembly of people. 

o Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National 
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Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.

PUBLIC INTEREST BENEFITS

Inspections and investigations completed on both residential and commercial properties are typical of 

operations in support of some entity. Use of UAS for many applications will offer significant advantages 

related to safety, time, and cost. 

Current options for gathering data which under this exemption would be collected using UAS, include 

use of ladders, lifts, and manned aircraft. Use of ladders and lifts are inherently dangerous and result in 

numerous injuries each year. Use of manned aircraft is typically not feasible and therefore valuable 

information remains beyond the reach of the investigator. In most cases, use of a UAS is quicker and 

easier than any other alternative and often yields better information. 

Due to their small size and the fact they carry no fuel, all four models of the DJI UAS pose a very low risk 

of damage to persons or structures on the ground. Because these UAS are electric powered, they create 

no harmful emissions and make very little noise. The added advantage of attaching various types of 

cameras (i.e. FLIR, heat sensing, 3D...) also offer benefits on an affordable level not available to many 

public interests.

SUMMARY OF PETITION

RSC Aviation requests the grant of an exemption to the following specific sections of the Title 14 Code 

of federal Regulations which would allow it to operate micro UAS for commercial use:

14 CFR 21, subpart H, 14 C.F.R Sections 61.3, 61.113(a)&(b), 61.133(a), 91.9 (b)(2), 91.103(b), 91.105, 

91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.319(a)(1), 91.405, 91.407, 91.409, 91.417 

CONCLUSION

RSC Aviation respectfully requests that the FAA grant the exemption sought in this request. RSC 

Aviation believes that given its familiarity with FAA regulations from its current manned aircraft 

operation and considering the small size and weight of the UAS, along with the UAS PIC training and 

certification requirements stipulated above and the strict operating guidelines proposed herein, it is

clearly demonstrated that the UAS will be operated safely in the national air space (NAS) with an 

equivalent or greater level of safety compared to manned aircraft.
RSC Aviation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 9

Granting this exemption will benefit the public interest as a whole in many ways including, but not 

limited to, significantly improving safety and reducing risk by alleviating human exposure to danger and 

improving the quality of services and decreasing operating costs compared with conventional flight 

operations.

We are prepared to modify or amend any part of this request to satisfy the requirements of the Federal 

Aviation Administration. We look forward to working with your office. Please contact me personally if 

you have any questions or concerns.

Respectfully submitted,

Jeffery W. Robertson

Managing Member, RSC Aviation, LLC
RSC Aviation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 10

DJI Inspire 1 UAS Specification

RSC Aviation will employ the primarily use of a quad copter aircraft developed by DJI named the

DJI Inspire 1. Other models by other vendors may be used but in all cases will comply with FAA 

regulations as pertain to UAS.

UAS Aircraft DJI Inspire 1

Model

T600

Weight (Battery Included)

2935 g

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

-10° to 40° C

Diagonal Distance

559 to 581 mm
RSC Aviation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 11

Dimensions

438x451x301 mm

Gimbal

Model

ZENMUSE X3

Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°

Mounting

Detachable

Controllable Range

Pitch: -90° to +30°

Pan: ±320°

Mechanical Range

Pitch: -125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera

Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

ISO Range

100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed

8s - 1/8000s

FOV (Field Of View)

94°

CMOS

Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion

Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames
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Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time-lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required.

Operating Temperature Range

0° to 40° C

Remote Controller

Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstructed)

2 km

EIRP

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini-HDMI

Power Supply

Built-in battery

Charging

DJI charger

Dual User Capability

Host-and-Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0-40° C

Battery

6000 mAh LiPo 2S
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Charger

Model

A14-100P1A

Voltage

26.3 V

Rated Power

100 W

Battery (Standard)

Name

Intelligent Flight Battery

Model

TB47

Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Battery (Optional)

Name

Intelligent Flight Battery

Model

TB48

Capacity

5700 mAh

Voltage

22.8 V

Battery Type

LiPo 6S

Energy

129.96 Wh

Net Weight

670 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C
RSC Aviation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 14

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Vision Positioning

Velocity Range

Below 8 m/s (2 m above ground)

Altitude Range

5-500 cm

Operating Environment

Brightly lit (lux > 15) patterned surfaces

Operating Range

0-250 cm

DJI Pilot App

Mobile Device System Requirements

iOS 8.0 or later

Android 4.1.2 or later