Jeffrey Ingersoll, Jr.

3211 King Richard Court

Seffner, FL 33584

813.732.7911

jingersolljr@msn.com

I am submitting my request for a Section 333 Exemption in order to allow myself as pilot in command, 

and a visual observer to perform aerial site investigations and data collections for various mining, 

environmental and geological applications. With the emerging technologies in the UAS industry and my 

interest in hobby participation several of my colleagues have asked if I can integrate my knowledge and 

abilities into a business that will allow me to provide them with high quality information that may be 

difficult, or impossible for people to obtain.

I am asking for exemptions in the following areas:

14 C.F.R. Part 21, Subpart H

Until the need arises, I don’t believe that my UAS falls under a category to need an airworthiness 

certificate. As rules and regulations change and the need arises I will be happy to provide for inspection 

to the FAA at any time.

14 C.F.R. Part 61 Certification: Pilots, Light Instructors, and Ground Instructors

Though I am a licensed pilot, certificate # 3805613, I do not currently have a valid medical certificate. I 

will be happy to provide one if necessary as I can schedule and complete the physical during the review 

period.

14 C.F.R. Part 91 General Operating and Flight Rules

 .103(b)(2) – Preflight actions

Due to the rather simple nature of my drone preflight inspection is rather easy. LED indicators specify 

the state of charge for both the drone battery and the remote. Once the battery is inserted in the drone 

and the power button is turned on compass calibration is achieved by rotating the drone 360 degrees on 

two axis. Wi-Fi connection is achieved and confirmed by any Wi-Fi capable video monitor or computer. 

At this point flight parameters can be programmed in such as areas of interests, waypoints, and 

maximum altitude above ground (400ft).

 .105 – Flight crewmembers at stations

Flights will originate and terminate at the same location making flight crews unnecessary. In the event 

of repeat flights from the same, or alternate locations on the same day batteries can be easily charged 

and replace by the PIC.

 .109 – Flight instruction

An electronic version of flight training is included with the drone so the PIC can acclimate themselves 

with the controller and the drones’ capabilities. In addition, there are several areas that I am able to 
access close to my home that would keep me 500 feet or more from pedestrians and traffic that would 

allow me to further build my skills with the drone.

 .119 – Minimum safe altitudes

Though most of the requests for performance that I have had put me in very remote unpopulated areas 

I have every intention of paying close attention to local laws and rulings in regards to safe altitudes and 

distances if jobs require me to operate in areas closer to homes or roads. Safety and privacy are 

paramount.

 .121 – Altimeter settings

My drone does not use altimeter settings that are based on barometric pressure, rater they are based 

on gps and reference above ground level. The sensors are state of the art and accurate to within about 

a half meter accuracy with a programmable “do not exceed” ceiling.

 .151 – Fuel requirements for flights in VFR conditions

In a perfect setting with no wind the battery for the drone has the capability to maintain flight for about 

25 minutes. In addition, it will only be operated in visual line of sight conditions as specified by 

standards.

 .405 – Maintenance required

Maintenance is minimal and because of the simple quad-copter design there are redundancies built in 

to the platform. In the event of a failure the drone will compensate for the loss and be controllable in 

order to safely land and allow for diagnosis and repair.

 .407 – Operation after maintenance

Once repairs have been made a test flight is easily accomplished in a safe area away from populations to 

ensure that all systems are operating effectively.

 .409 – Inspections

Inspections will be completed prior to every flight by the PIC. When the drone is activated it is fairly 

simple to identify whether it is operating to normal standards or not. In the event of a failure repairs are 

easily made and the inspection repeated until the drone will be able to operate normally.

 .417 – Maintenance records

Typical aircraft are required to be maintained on a specific maintenance schedule to insure the safety of 

passengers. Drones are much different in that failure that occur are typically immediately evident and 

repair can be accomplished without endangering anyone. Records will be kept for maintenance; 

however, they will not need to be the same as would be required for passenger aircraft.

In closing, it would be beneficial to approve my exemption for use of my drone. My intent is to use it as 

a tool to cover more ground than people can, or that people can’t either due to safety or access. In the 

end it will allow myself and my clients to gather information that can make positive impacts on our 
workplaces, or our world depending on the assignment. From inspecting areas that may be dangerous 

to humans, to cataloging species and numbers for environmental impacts, the drone will help simplify 

and improve how we act and interact with our planet.