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, 

11!15 cr:c 1 b A e: sa 

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. Thomas is also an advanced Ground Instructor. Thomas is active participant in 

approved FAA training dasses 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 dear 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 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 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 (Eachine Racer 250). 

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 dose 

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 

Your Comment Tracking Number: 1jz-8jxx-mdl8 

Your Comment Tracking Number: 1jz-8m4o-yb8r