T.BrusehaverAviation 9155 W Staring Ln Eden Prairie, MN 55347 tom.brusehaver@gmail.com

FAA Docket Management Facility U.S. Department ofTransportation 1200 New JerseyAvenue, SE West Building, Ground Floor, Room W12-140 Washington, DC 20590

Dear Exemption Manager, 

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We are submitting our Petition for Exemption for Unmanned Aircraft Systems operations. We currently are experienced UAS pilots and Tom Brusehaver isAn FAA Certificated private pilot, since 1991. Thomas is also an advanced Ground Instructor. Thomas is active participant in approved FAA training dassesfor recognized educational hours through the FAA.

As professional instructors, wetake the skills and education for safe operation ofUAS, very seriously. Our request is for awaiver ofthe sections identified below in an effortto operate a UAS in use ofcommercial applicationsfor agriculture field management, Real Estate and Marketing Purposes, Structural Inspections and Training.

This request specifically serves the publicand economic interestto aide in the areas stated above. The granting ofthis exemption would make logical sense because ofour professional approach to UAS operations, our dear understanding ofFAA rules, ourawareness ofoperational and restricted airspace, our experience as pilots, as well as ourongoing FAA approved educational activities, and ourattitude ofsafetyfirst when it comes to flight operations. We believe with the granting ofthis exemption and the additional operational experience we will gain from flight operations that we will be able 

### to have a much largerimpactforthe future of UAS. More flight experience now will be invaluable for us to assistthe general public in the future to provide services and training in UAS operations. There is much workto be done in developing the best
use ofUAS in the public, and training procedures. The courseworkand training for best use ofthe UAS, best operational utilization, best role forthe UAS pilot, etc. has yetto be developed in the general public arena. We would liketo playa role in that development butwe need more operational flight experience with the publicto dothat. This exemption would allow usto getthat 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) Ifwe have erroneouslyomitted 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 ofless 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 indude 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 various UAS forthe training role. These tests would occur in a controlled environment and aflight safe range. The initial craftwe would fly operationally, weighs less than five pounds (Eachine Racer250).

In the event a loss ofcommunications occurs the craftwill rise upverticallyto asafe height before beginning an automatic return to home function. The control signal maybe reconnected in flight and the pilot can take over safe operations again ifcommunication is reestablished. However in the case ofa GPS failure the craftwill be able to be manuallyflown to a safe landing bythe pilot. The craft operates electrically, carries no flammable fuel, has an integrated GPS pilot system, provides location information along with heightAGL, speed, battery life, and provides direction of travel and distance from the pilot.
Flight Operations: We are well aware ofconducting safe flight operations and planning flight paths that minimize any overflight ofcrowds. Anyflight operations in congested environmentswould typically be for dose air supportfor very focused events such as structural inspections, or real estate marketing. These operations occur in avery 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 FeetAGL (within Class Gairspace), not overcrowds, 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 priorto flight and afterflight. Any UAS unable to satisfysafety checklists will be removed from service untilthe issue can be resolved. Granting this requestwould not adversely affect safety since operations would be in accordance with current UAS rules.

Section 333 Compliance and Appropriateness: Based on the size ofthe craft, experience ofthe pilot, and operational goals, this request appears to be well suited for approval using the criteria outlined in Section 333 ofthe FAA Modernizationand Reform Act of2012 and will move safe flight operations forward in accordance with the intent ofSection 333.
Ongoing Efforts: We are also keenly awareofthe new issues involved in UAS operations and would greatly like to assist public education toflywith common sense and safetyfirst in mind. With your help we hope to obtain this exemption in orderto use myexempted flight experience to help new operators off
on the rightfoot, learn whattheydon't know, and help them to move forward to operate safer while they utilize the UAS.

Sincerely,

Tom Brusehaver



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