RSC A viation, 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 be low 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 re al 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 pol ice, 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 A viation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 2

Description of the Petit ioner
RSC Aviation, LLC is owned by Wayne Robertson, a US citize n. 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. T he ownership has over 35 year s of experience in the electronics field, staying current
on trends and technology and intends to use the UAS and sUAS platform s to complement and offer

further value to its clients.



### RSC Aviation employs current qualified commercial pilo ts. The current chief pilot has over
10 years of experience in Aviation with a B achelor in P rofessional P ilot at Henderson State
University in Arkadelphia , Arkansas and over 2100 hours total flight time in National Airspace
System (N AS). 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 A ircra ft S ystems ( s UAS)

.

PETITIONERS CONTACT INFORMATION:

RSC Aviation, LLC
Attn: Jeffery W. Robertson

1553 East Race Ave.

Searcy, AR 72143

501

- 279

- 6575
softmartwr@gmail.comRSC A viation, 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 tha t 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 F light Battery Safety Guidelines (hereafter collectively referred to as “Manufacturer’s Operations Manuals”).

All RSC Aviation UAS s will be operated only by individuals who hold at least an FAA issued private, recreational, or sport pilot certificate and wh o 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 n ot include this document in the public docket).RSC A viation, 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
l evel 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 s UAS 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 d iagonal motor

- to

- motor distance of approximately 14 inches. The Phantom 3 is approximately 27 inches across, measured diagonally and including the propellers. All four UA S are constructed primarily of frangible materials (plastic) and weigh less than 3 pou nds 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 UA S contain an

on

- board GPS an d an in ternal 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 w ill 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, inspe ction, and life limit requirements for the aircraft and aircraft components and all pertinent instructions in the user manuals. Repairs, component changes, and software/firmware update s will be recorded in the UAS maintenance log. Maintenance log entrie s 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 s UAS that has undergone
maintenance or alterations that affect the UAS opera tion or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight, prior to use in any commercialRSC A viation, 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
haza rd 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 Fl ight 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 con tained 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 complet ed 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 hour s of ground
instruction with a C ertified F light I nstructor (CFI) covering regulations and issues pertinent to commercial operation of the Phantom 3, Phantom 2 Vision+ and Phantom 2 sUAS.

The individual acting as PI C 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 resp onsible 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.RSC A viation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 6

OPERATING PARAMETERS of the UAS
In order to provide for a level of safety at least equivalent to operations conducted using manned aircraft, a ll 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 airspeed s 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 operat ions will occur at or below 500 ft 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 f

t then the max altitude of the UAS wi ll be restricted to 20 ft 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/Facili ty 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 agreemen t 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 b e 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 exemp tion 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 pr ocedures 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 re vise 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 revis ed do cuments if it petitions for e xtension or amendment to the grant of exemption. If RSC Aviation determines that any update or revision would affect the basisRSC A viation, 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 t he 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 f light the PIC must inspect the UAS to ensure that it is in a condition for s afe flight. If the inspection reveals a condition that aff ects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintena nce has been performed and the UAS is found to be in a condition for safe flight. All main tenance 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 communication s 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. Th e 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 sa fe 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 Admini strator 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 UA S 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. A ccidents will be reported to the NationalRSC A viation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 8

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

PUBLIC INTEREST BEN E FITS

I nspections and investiga tions completed on both reside nti al and commercial properties are typic al 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 wou ld 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 investi gator. 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 structure s 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 a n 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 th e small size and weight of the UAS, along wi th 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 lev el of safety compared to manned aircraft.RSC A viation, 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 servi ces 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, LLCRSC A viation, 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 mmRSC A viation, 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 framesRSC A viation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 12 Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias Time

- lapse Video Re cording 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 2SRSC A viation, LLC 1553 East Race Ave. Searcy, Arkansas 72143 Page 13



### 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° CRSC A viation, 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