BR Capital, Inc.

Page 1 of 11 Pages August 4, 2015

August 4, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Petition of BR Capital, Inc. for Exemption Pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012.

FAA Regulatory Docket
BR Capital, Inc.

Page 2 of 11 Pages August 4, 2015

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, BR 

Capital, Inc. (BRC), hereby applies for an exemption from Federal Aviation Regulations (FARs) 

identified below, to allow commercial operations of small unmanned aerial systems (UAS).

This exemption is in accordance with protocols outlined in this petition for exemption, the enclosed BRC

Motion Picture and Television Flight Operations Manual (BRCMPTFOM), UAS User’s Manuals, UAS 

Quick Start Guides, and any other requirements established by the FAA pursuant to Section 333 of the 

Reform Act.

This exemption would permit BRC to use the DJI Phantom 3 Advanced and the DJI Phantom 3 

Professional for commercial operations. It will conduct UAS flight training, agriculture, education, real 

estate photography, videography, film and movie production, and demonstration flights. BRC’s operation 

under the exemption will be subject to operating requirements and conditions to ensure an equivalent 

level of safety to currently authorized operations using manned aircraft and under conditions as may be 

modified by the FAA as required by Section 333.

BR Capital submits the BRC Motion Picture and Television Flight Operations Manual as a confidential 

document under 14 CFR § 11.35(b), the entire content of the manual is confidential commercial and 

proprietary information that BRC has not and will not share with others. This manual contains operating 

and training procedures that are not available to the public and is protected from release under the 

Freedom of Information Act, 5 USC § 552 (b) (4).

BRC will operate under controlled VFR conditions at low altitude in airspace that is permitted in 

accordance with BRC’s approved Certificate of Authorization (COA). It will operate the UAS’s with 

pilots who are current and qualified with FAA Pilot Certificate after completing BRC’s training program. 

The FAA ATC will approve the airspace in which the UAS will operate in advance.

BR Capital respectfully submits this request for an exemption because it intends to commercially operate 

small UAS’s. The operations BRC will conduct will be in lieu of more hazardous operations conducted 

with conventional fixed and rotary wing aircraft. Operations will be conducted at an equivalent level or 

greater level of safety. Approval of this exemption would enhance safety and fulfill the Secretary of 

Transportation’s and FAA Administrator’s responsibilities under Section 333(c) of the Reform Act to 

“establish requirements for the safe operation of such aircraft systems in the national airspace system.”

BRC has organized this Petition for Exemption request as follows:

I. Description of Petitioner

II. Statutory Authority

III. Qualifications for Approval under Section 333 of the Reform Act

IV. Description of Proposed Operations

V. Regulations From Which Exemptions are Requested

VI. Public Interest
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VII. Privacy

VIII. Federal Registry Summary

IX. Conclusion

I. Description of Petitioner:

BR Capital, Inc. is headquartered in Vancouver, Washington. It is a registered investment advisory firm. 

The company is expanding into UAS flight training, support to news services, real estate photography, 

film and movie production, education, and demonstration flights in a compliant and safe environment. 

BRC plans on providing a wide range of services as the UAS market expands.

The president of BRC has over thirty-two years of experience in aviation and is a current Commercial 

Pilot ASEL, AMEL, instrument airplane. He also has twenty-two years of experience in video production 

and understands the requirements to integrate the UAS into the movie sets.

BRC's goal is to operate without accidents by:

1. A commitment by management and employees to operate safely.

2. Identify hazards while controlling risks. It will use steps to intervene and report when unsafe 

work practices exist.

3. Training employees involved in flight operations to operate at the highest standards.

Contact information for Petitioner: 

Physical address:

BR Capital, Inc.

4400 NE 77th Avenue, Ste. 275

Vancouver, WA 98662-6857

Mailing address:

BR Capital, Inc.

P.O. Box 3160

Vancouver, WA 98668-3160

William C. Roller, President

Phone: 360-735-1900

II. Statutory Authority:

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of 

the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned 

aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to consider whether certain unmanned aircraft systems may operate safely in the 
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National Airspace ("NAS") before completion of the formal UAS rulemaking, based on the following 

considerations:

1. The UAS's size, weight, speed, and operational capability;

2. Operation of the UAS in close proximity to airports and populated areas; and

3. Operation of the UAS within the visual line of sight of the operator.

If the Secretary determines that such vehicles "may operate safely in the National Airspace System, the 

Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace 

System".

Additionally, the FAA Administrator has general authority to grant exemptions from its safety regulations 

and minimum standards when the Administrator decides a requested exemption is in the public interest. A 

party requesting an exemption must explain the reasons why the exemption: 

(1) Would benefit the public as a whole, and

(2) Would not adversely affect safety, or would provide a level of safety available under the existing 

rules.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under 40101 of the Act, 

from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any of sections.

III. Qualification for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 

of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied.

The proposed operations would permit BRC the use of small UAS under controlled conditions in airspace 

that is: 

(1) Predetermined

(2) Controlled access

(3) Provides safety beyond that when fixed or rotorary wing aircraft are used.

BRC’s submission places a duty on the Administrator to not only process applications for exemptions 

under Section 333, but for the Administrator, if he deems the conditions proposed herein require 

modification in order to allow approval, to supply conditions for the safe operation of the UAS. BRC

welcomes the opportunity to consult with FAA staff in order to address any issues or concerns that this 

proposal may raise that they believe may require modification.

BRC will use multirotor UAS’s that weigh less than 55 pounds, including the payload. They operate, 

under normal conditions, at speeds not to exceed 50 mph. The multirotor has the capability to hover and 

move in the vertical and horizontal plane. BRC’s UASs will operate in line of sight, during daylight 

hours, and will only operate within a sterile area described in the enclosed Operations Manual. BRC will 
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operate at or below 400 feet AGL and will file a NOTAM for each flight operated in controlled airspace 

that is required. All required permissions and permits would be obtained from territorial, state, county or 

city jurisdictions, Including local law enforcement, fire, or other appropriate governmental agencies prior 

to operating a UAS.

Given the small size of the UAS’s involved and the restricted sterile environment within which they will 

operate, this BRC’s exemption falls within the zone of safety and demonstrate an equivalent level of 

safety, in which Congress desired the FAA to permit commercial UAS operations by exemption pending 

completion of formal rulemaking. Also, due to the size of the UAS’s and the confined area in which the 

UAS’s will operate, approval of the application presents no hazard in the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, the grant of the requested exemptions is also in the public interest.

IV. Description of Proposed Operations

The enclosed BR Capital, Inc. Motion Picture and Television Flight Operations Manual (BRCMPTFOM) 

describes in detail, the policies and procedures for BRC's proposed UAS operations. To assist the FAA in 

its safety assessment of BRC's proposed UAS operations, below is a summary of the conditions that will 

insure an equivalent or higher level of safety for operations conducted under current regulatory 

guidelines:

(1) The UAS will weigh less than 55 pounds.

(2) The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour) based on 

groundspeed or calibrated airspeed. In no case will the UAS be operated at airspeeds greater 

than the maximum operating airspeed recommend by the aircraft manufacturer. 

(3) Flights will be operated within line of sight of the PIC and visual observer.

(4) Maximum total flight time for each operational flight will be limited to the amount of time 

the UAS can be flown and maintain a reserve battery power or fuel quantity of no less than 

25%.

(5) Flights will be operated at an altitude of no more than 400 feet above ground level (AGL).

(6) Flights will be operated at a lateral distance of least 100 feet from any inhabited structures, 

buildings, vehicles, vessels, people not associated with the operation or who have not signed 

a waiver in advance of the operation.

(7) Minimum crew for each operation will consist of the UAS Pilot-in- Command (PIC) and a 

Visual Observer (VO). Additional crewmembers may include a second pilot and a camera 

operator.

(8) The UAS Pilot-in-Command (PIC) will hold either an airline transport, commercial, private 

recreational, or sport pilot certificate, as well as hold a current FAA airman medical 

certificate or a valid US driver’s license issued by a state, the District of Columbia, Puerto 

Rico, a territory, a possession or the Federal government. In addition, the PIC will meet the 

flight review requirements specified in 14 CFR Part 61.56 in an aircraft in which the PIC is 

rated on his or her pilot certificate.

(9) BRC will designate a Pilot-in-Command ("PIC") for each mission.

(10) The UAS will operate only within a confined "Sterile Area" as defined in the Operations 

Manual.

(11) Prior to the operations at a particular location, a site inspection will have been conducted. On 

the day of the mission the management person with operational control and the PIC will 

concur on dispatching of the mission.
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(12) In accordance with the BRCMPTFOM, a briefing will be conducted regarding the planned 

UAS operations prior to each day's missions. It will be mandatory that all personnel who will 

be performing duties within the boundaries of the sterile area be present for this briefing.

(13) BRC crew will use the checklist and callouts required in the BRCMPTFOM.

(14) All UAS’s will be maintained in accordance with inspection program specified in the 

manufacturers’ users’ manuals.

(15) In the event of an accident involving a BRC UAS, personnel will cease operations and report 

the accident to the NTSB.

(16) The Pilot-in-Command and Visual Observer will be able to communicate by voice at all 

times.

(17) The Pilot-in-Command and Visual Observer will have been trained in accordance to BRC’s 

UAS Training Manual.

(18) All required permissions and permits would be obtained from territorial, state, county, or city 

jurisdictions, including local law enforcement, fire, or other government agencies.

(19) In compliance with approved Waiver, BRC management will submit a written “Plan of 

Activities” to the local Flight Standards District Office (FSDO) that has jurisdiction over the 

area of proposed filming three days in advanced of operations during video or movie 

productions.

(20) If the UAS loses communications signal, the UAS will have the capability to return to a predetermined location within the Sterile Area and land.

(21) Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer.

(22) The UAS has the capability to abort a flight in case of unpredicted obstacles or emergencies.

(23) BRC will insure that no one’s privacy is violated.

(24) Procedures have been established in BRC’s Motion Picture and Television Flight Operations 

Manual to contact ATC prior to operating in airspace other than G.

V. Regulations From Which Exemptions are Requested

(1) 14 CFR § Part 61.101 (a) and (b) Recreational pilot privileges and limitations; Part 

61.113 (a) and (b) Private pilot privileges and limitations; Part 61.315 (a), (b), and (c) 

Sport pilot privileges and limits

(2) 14 CFR § 91.103: Preflight Action

(3) 14 CFR § 91.113: Right-of-Way Rules

(4) 14 CFR § 91.119 (c): Minimum Safe Altitudes

(5) 14 CFR § 91.121: Altimeter Settings

(6) 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR Conditions

(7) 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections

(1) 14 CFR § Part 61.101 (a) and (b) Recreational pilot privileges and limitations; Part 

61.113 (a) and (b) Private pilot privileges and limitations; Part 61.315 (a), (b), and (c) 

Sport pilot privileges and limits

Each of the sections cited limit Recreational, Private, and Sport pilots to non-commercial operations. 

Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the UAS’s are remotely 

controlled with no passengers or property of others on board. BRC proposes that the FAA take into 

account the characteristics and procedures of the particular UAS.

BR Capital proposes that the actual operation of the UAS does not require the PIC to hold a Commercial 

pilot certificate. Instead, the actual operation requires a Recreational, Sport, or Private pilot certificate. 
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(2) 14 CFR § 91.103: Preflight Action

BRC requests an exemption from the preflight actions requirements of 14 CFR 91.113 that prescribes the 

preflight actions under which aircraft may operate:

Each pilot- in-command shall, before beginning a flight, become familiar with all available information 

concerning that flight.

(a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel 

requirements, alternatives available if the planned flight cannot be completed, and any known 

traffic delays of which the pilot-in-command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing 

distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing 

takeoff and landing distance data is required, the takeoff and landing distance data contained 

therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under expected values 

of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

BRC will not operate UAS’s under IFR conditions or when the ceilings are below 1000 feet and the 

visibility is below 3 statute miles. DJI’s UAS’s do not have published approved Airplane or Rotorcraft 

Flight Manuals that contain takeoff and landing distance data.

Equivalent Level of Safety

There are procedures in the BRC Motion Picture and Television Flight Operations Manual that describe

the steps the PIC must follow to assure that the weather will be adequate to complete the mission in VFR 

conditions. When BRC is allowed to operate in other parts of the United States the UAS used in those 

locations will be test flown at gross weight to test performance limitations prior to conducting commercial 

operations.

(3) 14 CFR 91.113: Right-of-Way Rules

BRC requests an exemption from 14 CFR 91.113 Right-of-way rules, requiring vigilance by each person 

operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft 

the right-of-way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it 

unless well clear.

BR Capital will operate small pilotless UAS’s and cannot comply with these rules as written.

Equivalent Level of Safety

BRC will operate UAS’s at or below 400 feet AGL, well below the normal operating altitude of other 

aircraft. The BRCMPTFOM specifies that a PIC will oversee each mission who has knowledge of the 

see-and-avoid rules. The VO will assist the PIC in looking for aircraft entering the operations area. It is 

the responsibility of the PIC to cease operations and land the UAS immediately when ever an aircraft is 

the vicinity and is potential threat. Operations will not restart until the threat is clear.

(4) 14 CFR. § 91.119: Minimum Safe Altitudes
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BRC requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119 that 

prescribes the minimum safe altitudes under which aircraft may operate:

• Over any congested area of a city, town, or settlement, or over any open air assembly of persons, 

an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the 

aircraft.

• Over other than congested areas at an altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it can be 

operated "without hazard to persons or property on the surface," provided that "each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

To provide the intended operations, the UAS is normally operated below 400 feet AGL. Additionally, due 

to the nature of the proposed operations, the UAS will maintain a lateral distance of at least 100 feet from 

inhabited structures, buildings, vehicles, and vessels, and people not associated with the operation.

Equivalent Level of Safety

Compared to normal aircraft, BRC’s multi-rotor aircraft weigh 9.2 lbs. Since they lack flammable fuel, 

any risk associated with these operations is far less than those that presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the UAS, as 

well as the location where it is operated. As set forth in the BRCMPTFOM, the UAS will be operated in a 

sterile area, where buildings and people will not be exposed to operations without their prior consent. 

Because of the advance notice to the property owners and participants, all affected individuals will be 

made aware of the planned flight.

Furthermore, by operating at such lower altitudes, the UAS will not interfere with aircraft that are subject 

to the minimum safe altitude regulations. Finally, the successful safety record of the DJI UAS’s 

demonstrates that the UAS can be safely used at lower altitudes and closer in operating environments.

(5) 14 C.F.R. § 91.121: Altimeter Settings

BRC seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain 

cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure 

airport or barometric pressure. An exemption is required because the UAS does not have a barometric 

altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in the BRCMPTFOM

Manual. BRC will confirm the altitude of the launch site shown on the GPS altitude indicator before 

flight. The PIC will use the GPS altitude indicator to constantly monitor the UAS's height, thus ensuring 

operation at safe altitudes.

(6) 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions
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BRC requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. 

Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and 

assuming normal cruising speed–

(1) During the day, to fly after that for at least 25 minutes; or

(2) At night, to fly after that for at least 45 minutes.

The batteries powering BRC’s UAS’s provide approximately 10-18 minutes of powered flight. To meet 

the 30 minutes reserve requirement in 14 CFR 91.151, UAS flights could not be conducted. Given the 

limitations on the UAS's proposed flight area and the location of its proposed operations within a 

predetermined area, a safety margin based on a reserve amount of battery life is needed.

BRC will not conduct UAS flights at night.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted on-site without 

significant transit time by the UAS. All flights will be planned to terminate with no less than 25% reserve 

battery power still available. This restriction would be more than adequate to return the UAS safely to its 

planned landing zone from anywhere in its confined area of operation even in the event of an unexpected 

occurrence. Operation of the UAS with less than 30 minutes of reserve fuel does not include the type of 

risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS, and the 

proximity of the flight operation to the landing zone. Moreover, operation will be limited to controlled 

areas where only people and property owners, or official representatives who have signed waivers will be 

allowed.

(7) 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections

BRC seeks an exemption from the maintenance inspection requirements contained in 14 CFR 91.405(a), 

91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify maintenance and inspection 

standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) (stating that each owner or operator of an 

aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). An 

exemption to these regulations is needed because Part 43 and these sections only apply to aircraft with an 

airworthiness certificate, which the UAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the BRC MPTFOM, the DJI Phantom 3 Advanced User Manual, and the DJI Phantom 3 

Professional User Manual. The PIC will insure that the UAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. The operator is the person 

most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide 

the equivalent level of safety. If mechanical issues arise, the UAS's size and carrying capacity, and the 

fact that flight operations will only take place in restricted areas for limited periods of time during 

daylight hours, creates less risk than that associated with conventional rotorcraft performing the same 

operation.
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VI. PUBLIC INTEREST

Granting BR Capital, Inc. an exemption furthers the public interest. National policy set by Congress 

favors early integration of UAS into the national airspace in controlled, safe working environments such 

as those propose in this petition. The vision of BRC is to help facilitate safe integration of UAS’s into 

mainstream use in the following areas:

1. Training--To insure that UAS Operators can accomplish their goals with their UAS operations 

and are properly trained and certified to safely operate their UAS aircraft. 

2. Movies and Videography--Whether the shot requires unique views and expansive panning or 

extreme altitude with radical views, the UAS is designed to hold up under demanding conditions. 

Because of the autopilot feature with pre-designed mission management and R/C control 

interrupt, the pilot and camera operator can easily create the ultimate shot with HD video or HD 

still photos. When working close in on a closed set the hazards to the actors are greatly reduced 

due to the size of the UAS.

3. News Gathering--Similar to movies and videography, each news assignment may require a 

completely different shot or view of a scene. With budgets for traditional helicopter use being 

greatly reduced, the UAS is the perfect solution to allow for easy news gathering for a fraction of 

the cost. The UAS can and will be operated in a sterile area away from the public, while the 

traditional helicopter must hover over persons and property increasing the danger to individuals.

4. Real Estate--The UAS can be used in all areas of real estate, including commercial, residential 

and industrial properties. Using a UAS, real estate professionals can create promotional videos, 

photos, and unique shots that normal camera aspects cannot capture. BRC’s easy-to-use video 

and photo platform enables properties to stand out, providing dazzling views that are typically 

shown via expensive computer animation or costly helicopter rentals. Imagine shooting a view 

from a high-rise condo in stunning high definition that shows your potential customer the actual 

view from the residence. The remote platform is great for new planning, zoning and large 

developments. Simple and easy-to-use video and photos allow for multiple height pictures and 

elevation views.

5. Fire and Rescue--BRC would introduce and demonstrate to fire and rescue personnel the UAS’s 

reliability and the capability to perform in extreme situations. The ability to offer real time HD 

and IR video facilitates placing personnel and equipment in the right places. Also, with modern 

FLIR cameras, areas can be identified for potential ‘hot spots’ and additional focus without 

putting personnel at risk. BRC’s mission is to assist governmental agencies safely into the NAS.

6. Law Enforcement--BRC would introduce and demonstrate to Law enforcement officers that 

UAS excel in rapid deployment and challenging situations. Most UAS’s deploy in less than 5 

minutes. With a video package, the UAS provides law enforcement with seamless Incident 

situational awareness, tactical support and accident photography. Using the UAS, police and 

SWAT can quickly assess potential threats; take HD photos of a crime scene or FLIR video of an 

area to find hidden threats.

7. Agriculture and Conservation--BRC would introduce and demonstrate to farmers and ranchers

that the UAS can aid commercial agriculture, land management, and conservation efforts by 

assessing crops, mapping flood zones, measuring snow pack and more. The UAS can fly presaved missions via the fully automated ground station, which allows for time-lapse photos of 
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fields, crops and known land tracts. It also can accurately recreate the same pattern during all 

seasons, providing invaluable data for land and soil management. Using HD video, HD photos, 

and IR cameras allows for detailed analysis and recording. With photo rendering software, 3D 

maps and topography can be used in conjunction with time-lapse photos to create highly detailed 

maps for erosion, flood mapping and other critical aspects of land management.

VII. Privacy

BR Capital understands the need to protect the privacy of members of the public. Many individuals are

concerned about threats to privacy from the operations of UAS’s.

VIII. Federal Registry Summary

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register,

should it be determined that publication is needed: BR Capital, Inc. seeks an exemption from the 

following rules:

14 CFR § Part 61.101 (a) and (b); Part 61.113 (a) and (b); Part 61.315 (a), (b), and (c); 14 CFR 91.103; 14 

CFR 91.113; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.405(a); 14 CFR 

91.407(a)(1); 14 CFR; 91.409(a)(2); 14 CFR 91.417 (a) & (b).

Approval of this exemption request allows BRC to conduct commercial operations with small and 

lightweight unmanned aerial systems. Through safety, education, and solutions and enhancing the safety 

of UAS operations in the NAS while reducing risk to the general public and property owners.

BR Capital’s uses UAS, that weigh less than 55 pounds and are powered by batteries. This eliminates risk 

given the reduced mass and lack of combustible fuel compared to manned aircraft. The UAS is 

transported to the designated mission area and set up there. The UAS will carry no passengers or crew 

and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of this small UAS will provide an equivalent level of safety, supporting the grant of the 

exemptions requested herein, including exempting the applicant from the requirements of several 

regulations and allowing commercial operations. These lightweight UAS’s operate at slow speeds, close 

to the ground, and in a sterile environment. As a result, they are far safer than conventional aerial survey 

and inspection operations conducted with fixed wing aircraft or helicopters.

Please contact me immediately if you have any questions or require additional information regarding this

Petition for Exemption.

Sincerely,

William C. Roller, President

BR Capital, Inc.

Phone: 360-735-1900

Email: billroller@brcapitalinc.com