This seems unclear. The rule seems to allow RCS to raise the Pe to the requisite orbit. What parts are and are not allowed?
Are batteries , solar panels, or RTGs allowed?
Are reaction wheels allowed?
What about Probe bodies?
Nose cones / fairings?
Control fins?
Passive fins?
If a probe body is allowed, then what about using said probe body's reaction wheels to provide torque?
Personally, I would clarify by prohibiting everything but unused fuel tanks, passive aerodynamics / fairings, and decouplers, and one probe body (KER gets weird if you don't allow this).