BR Capital, Inc.

P age 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 DocketBR Capital, Inc.

P age 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 system s ( 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 D J I Phantom 3 Advanced and the D J I 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 autho rized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333.

B R Capital submits the BRC Motion Picture and Television Flight Operations Manual as a c onfidential

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

. Th is m anual contain s operating and training procedures that are not available to the public and is protecte d 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.

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

BR Capital respectfully submits this request for an exe mption because it intends to commercially operate
small UAS ’ s. T he operations BRC will conduct will be in lieu of more hazardous operations conducted

with conventional fixed and rotary wing aircraft

. O perations 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 P etitioner

II. Statutory Authority

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

IV. Description of Proposed Operations

V. Regulations From Which Exemption s are Requested

VI. Public InterestBR Capital, Inc.

P age 3 of 11 Pages August 4, 2015 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 presid ent 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 accident s by:

1. A c ommitment by management and employees to operat e safely

.

2. Identify hazard s while controlling risk s

. It will use steps to intervene and report when unsafe work practices exist.

3. Train ing employees involved in flight operations to operate at the highest standard s

.

C ontact information for Petitioner:

Physical address:

BR Capital , Inc.

4400 NE 77 th 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 FA A "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 theBR Capital, Inc.

P age 4 of 11 Pages August 4, 2015 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) W ould benefit the public as a whole, and (2) W ould 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 exemp tions. 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 com mercial 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) C ontrolled acce ss (3) P rovides safety beyond that when fixed or rotor ary wing aircraft ar e 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 U AS

. 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 willBR Capital, Inc.

P age 5 of 11 Pages August 4, 2015 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 fro m 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

i nsure 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 le ss 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 p ilot and a c amera

o perator

. (8) The UAS Pilot

- in

- Command (PIC) will hold either a n 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, P uerto 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 c ontrol and the PIC will concur on dispatching of the mission.BR Capital, Inc.

P age 6 of 11 Pages August 4, 2015 (12) In accordance with the BRCMPTFOM, a briefing will be conducted regard ing 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

- C ommand and Visual Observer will be able to communicate by voice at all

times

. (17) The Pilot

- in

- C ommand 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) th at 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 pre

determined 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 in sure that no one’s privacy is violated. (24) P rocedures 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 Exemption s are Requested

(1) 14 CFR § Part 61.101 (a) and (b) Recreational pilot privileges and limitations ; Part 61.113 (a) and (b) Private p ilot p rivileges and l imitations; 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 Inspection s

(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 section s c ite d limit Recreational, P rivate , 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 P IC to hold a Commercial pilot certificate. Instead, the actual operation require s a Recreational, Sport, or P rivate pilot certificate.BR Capital, Inc.

P age 7 of 11 Pages August 4, 2015 (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 planne d 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 Manual s that contain takeoff and landing distance data.

Equivalent Level of Safety

T here are procedures in the BRC Motion Picture and Television Flight Operations Manual that descr ib e the steps the PIC must follow to assure that the weather will be adequate to complete the mission in VFR

condition s . 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

ope rations.

(3) 14 CFR 91.113: Right

- of

- Way Rules

BRC request s 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 aircr aft 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 n ormal operating altitude of other

aircraft. The BRC MPTFOM specifies that a P IC 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 AltitudesBR Capital, Inc.

P age 8 of 11 Pages August 4, 2015 BRC requests an exemption from th e 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 re gulations. 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 t he altitude of the launch site shown on the GPS altitude indicator before flight. T he 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 Fligh t in VFR ConditionsBR Capital, Inc.

P age 9 of 11 Pages August 4, 2015 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 locat ion 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 a dequate 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 i nclude 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 h ave 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 pa rt 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, whi ch 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. T he PIC will i nsure 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 b est 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.BR Capital, Inc.

P age 10 of 11 Pages August 4, 2015 VI. PUBLIC INTEREST

Granting BR Capital , Inc. an exemption furthers the public interest. National policy se t 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 i nsure that UAS Operators can accomplish their goals with their UAS operations

and are properly trained and certified to safely operate the ir 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 vide ography, 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 UA S can and will be operated in a sterile area away from the public, while the traditional helicopter must hover over persons and property i ncreasing the danger to individuals.

4. Real Estate

-- The UAS can be used in all areas of real estate, i ncluding commerci al, 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 residen ce. 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 perso nnel 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 pote ntial ‘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 deploy ment 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 qu ickly 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 ma nagement

, and conservation efforts by assessing crops, mapping flood zones, measuring snow pack and more. The UAS can fly pre

saved missions via the fully automated ground station, which allows for time

- lapse photos ofBR Capital, Inc.

P age 11 of 11 Pages August 4, 2015 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 to pography 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 u nderstands the need to protect the privacy of members of the publi c

. M any individual s are

concern ed 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 C apital , 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 CF R 91.121; 14 CFR 91.151(a); 14 C FR 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 enhanc ing 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 w ith manned aircraft flights.

The operation of this small UAS will provide an equivalent level of safety, supporting the grant of the exemptions requested herein, i ncluding 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 conven tional aerial survey and inspection operations conducted with fixed wing aircraft or helico pt ers.

Please contact me immediately i f 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