T.Brusehaver Aviation

9155 W Staring Ln

Eden Prairie, MN 55347

tom.brusehaver@gmail.com

FAA Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

West Building, Ground Floor, 

Room W12-140 

Washington, DC 20590 

Dear Exemption Manager, 

We are submitting our Petition for Exemption for Unmanned Aircraft Systems operations. We

currently are experienced UAS pilots and Tom Brusehaver is An FAA Certificated private pilot, 

since 1991. Tom is also an advanced Ground Instructor. Tom is active participant in approved 

FAA training classes for recognized educational hours through the FAA. 

As professional instructors, we take the skills and education for safe operation of UAS, very 

seriously. Our request is for a waiver of the sections identified below in an effort to operate a 

UAS in use of commercial applications for agriculture field management, Real Estate and 

Marketing Purposes, Structural Inspections and Training. 

This request specifically serves the public and economic interest to aide in the areas stated 

above. The granting of this exemption would make logical sense because of our professional 

approach to UAS operations, our clear understanding of FAA rules, our awareness of 

operational and restricted airspace, our experience as pilots, as well as our ongoing FAA 

approved educational activities, and our attitude of safety first when it comes to flight operations. 

We believe with the granting of this exemption and the additional operational experience we will 

gain from flight operations that we will be able to have a much larger impact for the future of 

UAS. More flight experience now will be invaluable for us to assist the general public in the 

future to provide services and training in UAS operations. There is much work to be done in 

developing the best use of UAS in the public, and training procedures. The coursework and 

training for best use of the UAS, best operational utilization, best role for the UAS pilot, etc. has 

yet to be developed in the general public arena. We would like to play a role in that development 

but we need more operational flight experience with the public to do that. This exemption would 

allow us to get that real world experience. 

We are currently seeking exemption of: Section of 14 CFR: parts 21 Subpart H, 27, 45.23(b), 

45.27(a), 61.113(a) and (b), 61.133(a), 91.7(a), 91.9(b)(2), 91.103, 91.109(a), 91.119, 91.121, 

91.151(a), 91.203(a) and (b), 91.319(a) (1), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) 

and (b) If we have erroneously omitted any other relevant section for our intended operations, 

please feel free to suggest the missing section(s). 
Suggested Public Federal Register Summary: 

"The petitioner is seeking an exemption to operate unmanned aircraft systems (UAS) with a 

maximum weight of less than ten pounds to perform Professional Marketing Services, for 

agriculture field management, Real Estate and Marketing Purposes, structural Inspections and 

training, Etc. Data gathered may include still and moving images captured with onboard 

cameras and other environmental sensors." 

UAS Description: 

We are asking for an exemption for a UAS up to 10 pounds because we forecast we may be 

testing, evaluating and training with a UAS for the training role. These tests would occur in a 

controlled environment and a flight safe range. The initial craft we would fly operationally, 

weighs less than five pounds. 

In the event a loss of communications occurs the craft will rise up vertically to a safe height 

before beginning an automatic return to home function. The control signal may be reconnected 

in flight and the pilot can take over safe operations again if communication is reestablished. 

However in the case of a GPS failure the craft will be able to be manually flown to a safe landing 

by the pilot. The craft operates electrically, carries no flammable fuel, has an integrated GPS 

pilot system, provides location information along with height AGL, speed, battery life, and 

provides direction of travel and distance from the pilot. 

Flight Operations: 

We are well aware of conducting safe flight operations and planning flight paths that minimize 

any overflight of crowds. Any flight operations in congested environments would typically be for 

close air support for very focused events such as structural inspections, or real estate 

marketing. These operations occur in a very limited area and would not need to overfly densely 

populated areas in general. Operations would be more vertical in nature above the specific 

event. Our proposed public safety UAS operations are typically conducted at low altitudes less 

than 400 Feet AGL (within Class G airspace), not over crowds, and not near airports. Flights will 

end when battery reserve reaches 25 percent. Operations will not occur under IFR conditions. 

In addition, preflight and post-flight checklists and UAS examinations will help detect any 

abnormalities prior to flight and after flight. Any UAS unable to satisfy safety checklists will be 

removed from service until the issue can be resolved. Granting this request would not adversely 

affect safety since operations would be in accordance with current UAS rules. 

Section 333 Compliance and Appropriateness: 

Based on the size of the craft, experience of the pilot, and operational goals, this request 

appears to be well suited for approval using the criteria outlined in Section 333 of the FAA 

Modernization and Reform Act of 2012 and will move safe flight operations forward in 

accordance with the intent of Section 333. 

Ongoing Efforts: 
We are also keenly aware of the new issues involved in UAS operations and would greatly like 

to assist public education to fly with common sense and safety first in mind. With your help we 

hope to obtain this exemption in order to use my exempted flight experience to help new 

operators off on the right foot, learn what they don't know, and help them to move forward to 

operate safer while they utilize the UAS. 

Sincerely, 

Tom Brusehaver