Kevin Rehak 

kevin.rehak@yahoo.com 

RSC Holdings, LLC 

204 Truman Ct 

Norristown, PA 19403 

November 29,2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam: 

This petition is being submitted on our own behalf without legal counsel or consulting services. 

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

14 C.F.R. Part 11, RSC Holdings, LLC hereby applies for an exemption from the Federal Aviation 

Regulations (FARs) listed below to allow operation of our Unmanned Aircraft Systems (UAS) 

commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such 

operations are conducted with and under the conditions outlined herein or as may be established 

by the FAA as 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 of the DJI Phantom 2, 3 and the DJI F450 in the following areas: 

• Real Estate PhotographyNideo 

• Insurance Claim 

• Golf Course Planning 

• Construction/Inspections 

• Land Appraisal 

• Resort/Recreation 

• Wedding PhotographyNideo 

• Surveying 

• Agriculture 

• Special Events 
RSC Holdings, LLC states that all UAS flights that will occur over private or controlled access 

property, will do so with the property owner's prior consent and knowledge and that only people 

who have consented or otherwise have agreed to be in the area where 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 of a DJI Phantom 2, 3 and 

DJI F450 equipped with a GoPro 4+ Camera & built-in camera combinations. These UAS have a 

built-in capability to limit the height it flies above the ground, to limit the radius of the distance it 

flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone 

feature. These UAS also feature a failsafe function of the 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 or crew, rather than a manned aircraft of significantly greater 

proportions, carrying crew in addition to flammable fuel, operators of the 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 of view 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 the following additional restrictions: 

• All UAS will weigh less than 55 pounds including payload. 

• The UAS will not be operated at a speed exceeding 50 knots. The use of either 

groundspeed or calibrated airspeed will be used for compliance. 

• All operations will occur in Class G airspace (below 400' AGL). 

• The UAS will be operated within Visual Line of Sight {VLOS) of the Pilot in Command 

(PIC) at all 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 for safe 

operation. 

• Before each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. 

• Operations will be operated over private property, commercial property, or property (not 

federal or state) with permission of the land owner. 

• The UAS will not operate within 5 N M of any airport or 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 aircraft without 

at least 40 hours of training flight time with the exact aircraft used for the business. The company 

has private testing areas that are in a remote locations with no vertical obstructions. This allows 

the PICs for 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