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 We st Building, Ground Floor, Room W 12

- 140 Wa shington, 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 Certifi cated 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 an d 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 FA A 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 e xemption 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. W e 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 experienc e.

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 ex emption 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. Dat a 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,

we ighs less than five pounds.

In the event a loss of communications occurs the craft will rise up vert ically 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 cra ft 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, has programmed no

- fly zones for controlled airports, 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 ins pections, 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 operati ons 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, pref light 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 ne w issues involved in UAS operations and would greatly like to assist public education to fly with common sense and safety first in mind. Wi th 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