Kevin Rehak kevin.rehak@yahoo.com RSC Holdings, LLC 204Truman Ct Norristown, PA 19403 November29,2015

U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve. SE Washington, DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act DearSir or Madam: This petition is being submitted on ourown behalfwithout legal counsel or consulting services. Pursuantto Section 333 ofthe FAA Modernization and Reform Act

### of2012 (the Reform Act), and 14C.F.R. Part 11, RSC Holdings, LLC herebyapplies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation ofour Unmanned AircraftSystems (UAS) commercially in airspace regulated bythe FederalAviation Administration (FAA) so long assuch operations are conducted with and underthe conditionsoutlined herein oras may be established bythe FAAas required by Section 333. The requested exemption would allow RSC Holdings, LLC to pursue its commercial interests in providing services to consumers interested aerial data capture using small advanced UAS comprised 

### ofthe DJI Phantom 2, 3 and the DJI F450 in thefollowing areas: • Real Estate PhotographyNideo • Insurance Claim • GolfCourse Planning • Construction/Inspections • Land Appraisal • Resort/Recreation • Wedding PhotographyNideo • Surveying • Agriculture • Special EventsRSC Holdings, LLC states that all UAS flights thatwill occur over private orcontrolled access property, will do sowith the property owner's prior consent and knowledge and that only people who have consented orotherwise have agreed to be in the areawhere filming will take place will be filmed. Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23 {b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.11914 C.F.R. 91.121 14 C.F .R. 91.151(a) 14 C.F.R. 91.203 (a) 

### & {b) 14 C.F.R. 91.205 (b) 14 C.F .R. 91.215 14 C.F.R. (91.401- 91.417) Unmanned Aircraft Systems RSC Holdings, LLC is petitioning for exemption to enable the operation ofa DJI Phantom 2, 3 and DJI F450 equipped with a GoPro4+ Camera 

### & built-in camera combinations. These UAS have a built-in capabilityto limit the height itflies above the ground, to limit the radius ofthe distance it flies from the operator and 

## to exclude itfrom Class B, C and D airspace including a noflyzone feature. These UAS also feature a failsafe function 

### ofthe Naza-M autopilot system and/or ArduPilot Mega Flight Controller in which a Return-to-Home sequence is initiated when 1) the transmitter signal is disconnected. 2) battery power reserve reaches 25%. Additionally, since the UAS will be carrying no passengers orcrew, ratherthan a manned aircraft ofsignificantly greater proportions, carrying crew in addition to flammable fuel, operators ofthe DJI should not be required to hold a commercial or private pilot certification. The UAS of RSC Holdings, LLC will be operated in the field ofview with both a Pilot in Command (PIC) and a ground-based Visual Observer (VO) in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS"with thefollowing additional restrictions: • All UASwill weigh less than 55 pounds including payload. • The UASwill not be operated at a speed exceeding 50 knots. The use ofeither groundspeed orcalibrated airspeed will be used for compliance. • All operations will occur in Class G airspace (below 400' AGL). • The UASwill be operated within Visual Line ofSight {VLOS) ofthe Pilot in Command (PIC) atall times.

### • While the UAS are airborne, the visual observer (VO)will be positioned within voice distance to PIC. • All UAS will be maintained and inspected to ensure that it is in a condition forsafe operation. • Before each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a condition forsafe flight. • Operations will be operated over private property, commercial property, or property (not federal orstate) with permission ofthe land owner. • The UAS will not operate within 5 N Mofanyairportor heliport • Operations will be limited to day, visual meteorological conditions UAS Pilot in Command (PIC) RSC Holdings, LLC will not allow the PIC 

### to fly any aircraftwithout at least 40 hours oftraining flight time with the exactaircraft used for the business. The company has private testing areas that are in a remote locations with no vertical obstructions. This allows the PICsfor RSC Holdings, LLC to test all the systems and understand fail safe features to the fullest extent before conducting business with the UAS. RSC Holdings, LLC Contacts Kevin Rehak keyjn.rehak@.yahoo.com