USA §333 Process - After/During Comment Period

[jdpeagle]

There are plenty of threads on "delays to initial posting" and §333 exemption request content, syntax and requirements. Curious as to recent personal experience regarding timelines after open comment posting. Based on my recent database surveying, it's looking like about 90-days after initial posting (opening of the comment period) before you can expect your exemption to be granted (60-days after the closing of the comment period). Is this the experience of recent exemption recipients?

I have already reserved N-numbers, registered and placarded the aircraft. I am turning down well-paying jobs weekly, and my unregistered/unlicensed competition is gladly accepting my turned-away business with open arms (by the way, the FAA isn't even responding violation reports/complaints at this time). To echo the masses, these delays are ludicrous. No wonder so many (otherwise) honest folks are being forced to operate "illegally" while the FAA plays paper-shuffle. In addition, in order for us to collect compensation (of any type or amount), we must give up abilities afforded to a 12-year old hobbyist (reduced altitude allowances, daytime flight only, etc.). "Look not for logic here."

Have a great weekend, everyone!

 

[RKDauph]

I feel your pain, I am in almost the exact position. Funny after sending in additional information and waiting 3 months without an acknowledgement of its receipt, I called. Next day, it was updated.

 

[kcobello]

I have been waiting over 2 months since listed. I was just updated by my attorney that it will be 3-4 months more before it may be granted. I worry also, while the hobbyist can fly and capture imagery for others use. Where do we find others willing to pay when we are legal? We have seen our professional photography business go downhill because of the influx of cheap good cameras. I know it's a waiting game, but all the hoops to jump through and the exemptions of your limitations on what you can do is beyond belief.​

 

[takean]

I'm curious how this new HR 4432 is going to affect us. I upgraded from the P2 to the Inspire pro just to have a better platform and to be ready for commercial use. I'm solo and so I cant use the Exemption 333. But sounds to me Phantom pilots may get a pass on everything and those of us above 4.4 lbs with have to jump through hoops. And I'm fine with that, I just don't know if I'll still be in the same boat or if there is a little more light at the end of the tunnel. Will this new bill be easier or will I still be in the same boat and need to get the exemption 333?

 

[RKDauph]

HR 4432 isn't law yet and I personally think the unless Quad makers are required to limit both distance and altitude from the operator the FAA will lobby hard to squash it.

I am curious about your statement above "I'm solo and so I cant use the Exemption 333." What do you mean 'solo' and how does that prevent your applying and/or receiving the exemption?

 

[Dr. Ifly Drones]

HR 4432 isn't law yet and I personally think the unless Quad makers are required to limit both distance and altitude from the operator the FAA will lobby hard to squash it.

I am curious about your statement above "I'm solo and so I cant use the Exemption 333." What do you mean 'solo' and how does that prevent your applying and/or receiving the exemption?

All FAA 333 exemption require an "observer" as well as a PIC.

 

[SanCap]

I have been waiting over 2 months since listed. I was just updated by my attorney that it will be 3-4 months more before it may be granted. I worry also, while the hobbyist can fly and capture imagery for others use. Where do we find others willing to pay when we are legal? We have seen our professional photography business go downhill because of the influx of cheap good cameras. I know it's a waiting game, but all the hoops to jump through and the exemptions of your limitations on what you can do is beyond belief.​

Do you already have your pilots license or will you hire a pilot?

 

[takean]

Do you already have your pilots license or will you hire a pilot?

I cant really afford to hire a pilot...and I cannot afford to gain a pilots license as well. So that is why I go at this solo. Where I live no one is even going after this so at the moment I do it all for free just to build up a portfolio and get my name out while waiting for rules to be released. I know the Exempt 333 could help, but I haven't the resources to get a pilots license and I cannot find nor afford to hire anyone. That is why I'm curious about this proposed bill. Unfortunately all I can find is everyone praising the micro drone part and not even discussing the small drone section and what it might open up for people like myself. I love my Inspire pro and I dont want to downgrade just so I can finally start working.

 

[takean]

Do you already have your pilots license or will you hire a pilot?

Thats the other issue I have. I don't have a pilots license...and honestly I dont want to allow someone else to fly my drone. The PIC must be the pilot according to the rules. I can see hiring someone when the business begins making money (once rules are in place), but starting out its just me and limited overhead.

 

[kcobello]

Do you already have your pilots license or will you hire a pilot?

Its up in the air. I still am not a believer in needing the license other than a cert for airspace knowledge, rig check, and test. Its overkill. We fly in a "box" carry no passengers, and are under 7lbs.... I have a buddy who is a glider pilot that has offered training for me to get the sport license. By the time I get my 333 I was told there should be a cert process in the works. 80 percent of what we do or did is hobbyist grade anyhow. Payers are few and far between. We will see. We have people working in our area for 3 years without a pilots license and they are on FB and have a webpage and have not been flagged by the FAA. Drives me crazy but I will not turn them in.. Check them out Security Check Required.....

 

[licensed pilot]

I appreciate your feelings on this subject, but keep in mind that what you "believe in" is irrelevant to the FAA if you are caught flying commercially w/o a 333. In my opinion, any individual who hopes to fly legally some day is jeopardizing her/his chances by doing so illegally today. Once the feds issue a warning letter to you, a file is going to be created and you are on their "radar. I don't know that, just my 2 cents
.
If you are aware of illegal commercial operations and do not report it it then, sorry but you are part of the problem. Aviation safety relies on self-policing as there are not enough FAA inspectors to catch everyone.

 

[andrew259]

Not sure about the USA - but flying for free in the UK isn't necessarily non commercial... If the images captured in anyway are used in any commercial sense, (website etc...) then you need a licence... Even if it's all for no pay.




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[acoll123]

Submitted my 333 exemption request on 2/4/16 and checked today (2/10/16) to see if it showed up in the comment docket. It's There! Hopefully it won't take the 120 days they advise to allow for. I have also already reserved an N-Number and requested the form 8050-1 to register my SUAS and assign my N-Number to it. I hope to have my check-ride in the next few weeks to get my private pilot certificate.
Anything else I need to do?

 

[kcobello]

I appreciate your feelings on this subject, but keep in mind that what you "believe in" is irrelevant to the FAA if you are caught flying commercially w/o a 333. In my opinion, any individual who hopes to fly legally some day is jeopardizing her/his chances by doing so illegally today. Once the feds issue a warning letter to you, a file is going to be created and you are on their "radar. I don't know that, just my 2 cents
.
If you are aware of illegal commercial operations and do not report it it then, sorry but you are part of the problem. Aviation safety relies on self-policing as there are not enough FAA inspectors to catch everyone.

I dont dissagree with you. Our aerial imaging started 7 years ago before much if any attention was given to what was happening. We have applied for our 333, have an aviation attorney, Traverse Legal and are following the protocol Enrico and crew of Traverse Legal have given to us. I do not want others working all around me while my wife and I jump through the hoops and pay thousands to become legal. Our attorney has seen the site and he mentioned it may be tough to prove they are doing anything illegal because if the pilot of the craft isnt in view there is not much the FAA can do unless he is filmed or an FAA rep is on the site they are working. The website doesnt mean a thing unless there is signs of selling imagery.

 

[licensed pilot]

I dont dissagree with you. Our aerial imaging started 7 years ago before much if any attention was given to what was happening. We have applied for our 333, have an aviation attorney, Traverse Legal and are following the protocol Enrico and crew of Traverse Legal have given to us. I do not want others working all around me while my wife and I jump through the hoops and pay thousands to become legal. Our attorney has seen the site and he mentioned it may be tough to prove they are doing anything illegal because if the pilot of the craft isnt in view there is not much the FAA can do unless he is filmed or an FAA rep is on the site they are working. The website doesnt mean a thing unless there is signs of selling imagery.

All due respect to you and your attorney but his opinion that "it may be tough to prove they are doing anything illegal..." reminds me of the thousands of people who I met in 32 years of policing who "thought" there may be a crime occurring, but never reported to the police because they didn't think they "had enough." That is backwards thinking , it is not up to the citizen to determine if a crime is being committed but to the police to investigate and make that determination.No one needs an attorney to drop a dime on illegal operators, I've done it twice and will continue to do it.

I too spent lots of $$ becoming legal and I'll be dipped if I am going to allow some clown to ignore 333 requirement at my expense. Anyone I suspect is flying commercial w/o a 333 I will report. It is not up to me to investigate but up to the FAA.

 

[kcobello]

All due respect to you and your attorney but his opinion that "it may be tough to prove they are doing anything illegal..." reminds me of the thousands of people who I met in 32 years of policing who "thought" there may be a crime occurring, but never reported to the police because they didn't think they "had enough." That is backwards thinking , it is not up to the citizen to determine if a crime is being committed but to the police to investigate and make that determination.No one needs an attorney to drop a dime on illegal operators, I've done it twice and will continue to do it.

I too spent lots of $$ becoming legal and I'll be dipped if I am going to allow some clown to ignore 333 requirement at my expense. Anyone I suspect is flying commercial w/o a 333 I will report. It is not up to me to investigate but up to the FAA.

Gotcha!!

Some day I will discuss with you all the politics we are seeing in my area with people who are officials of various areas but still are not in the know of what is required for the aerial work. Trust me when I say I know a lot of these officials and they are great people but my wife and I are already seeing some imagery being sold of scenic shots of Towns that I know was done with an aerial rig and we also know the pilot that are not legal.. I know of 2 people who have posted on FB that are in our area about starting up AP business's and I know will not carry through on the requirements. My wife and I are going through the process because its right but to be honest when dealing in govt at high levels like the FAA, you are usually guilty until proven innocent in matters and we are too old to be trying to be sneaky....

 

[jhardway]

The 333 process is an upside down cake that does not address much other being a hindrance in the path of commercial operations. I could write a book on my issues. A hobbyist has way more freedom to fly in the same if not more areas then the commercial operators. Out of the box the hobbyist can fly anywhere, basically ( we use to say anywhere you can fly a kite), but there is a whole another process for the commercial guy.



It extremely interesting to me how a person who have gone through the FAA system, vetted their abilities in FAA ways to understanding airspace, risk management, Flight Planing, and FAA safety. Somehow is more taxed on their ability to fly a UAS in general. I am not stating just because they have a pilots license they are a better flyer then an non pilot. However I can tell you their approach in putting a drone in the sky is different then a person who never has piloted an aircraft up there.

I can say I do not understand if you are requiring a person to have a pilots license to fly a UAS then, that person should have the same ability to make the same sound judgment calls they are able to have with a traditional aircraft.

I think the bigger issue comes with the laws, the FAA says it controls the airspace from the grass up but where the authority starts is very interesting. I actually have not issues for the FAA in this matter but what I feel is the bigger problems are the rules they are applying to our drones/aircraft. These rules were crafted for flying in navigable airspace, and where it starts, if feel is not well defined (above 500ft - look up the term navigable airspace there are law suits over it), the rule also accommodate aircraft of different categories and class.

Flight characteristics vary greatly when you look at the different categories - Hotter than air, Fixed Wing, and Rotor-craft. When they clump a UAS into one group, now you are way out of phase with the relationship of how the different characteristics of these device perform when they fly; and attaching the same rules that are used for traditional aircraft. Simple example Helicopter vs Fixed wing rules are way different when you talk about safe distances. If the FAA is using the same rules for UAS's as they do for aircraft in general then they should do the same for the type of UAS's device that are being used, not just one clumped together response that is sent out in a 333 exemption

I wish they would look a these factors over, look at the hobbyist situation, and reevaluate the 333 limits and operations.

best every one.

 

[licensed pilot]

Agree. The FAA, in its zeal to appear to be in control when in reality they ignored the burgeoning UAV industry until 2013, when Congress forced them to begin addressing the issue, went overboard with regulations. IMHO, the FAA, an organization for pilots manned by pilots was hoping the whole pesky "drone" issue would go away once they made the process to fly commercially so onerous and complicated. Well, they now realize we ain't going away.

BTW, the FAA does not require 333 holders to have insurance, that's a business decision, and a smart one. Customers can chose to hire an insured operator or not. I have aviation insurance but I wanted to point that out.

 

[Jimmykjimmy]

The FAA has

I appreciate your feelings on this subject, but keep in mind that what you "believe in" is irrelevant to the FAA if you are caught flying commercially w/o a 333. In my opinion, any individual who hopes to fly legally some day is jeopardizing her/his chances by doing so illegally today. Once the feds issue a warning letter to you, a file is going to be created and you are on their "radar. I don't know that, just my 2 cents
.
If you are aware of illegal commercial operations and do not report it it then, sorry but you are part of the problem. Aviation safety relies on self-policing as there are not enough FAA inspectors to catch everyone.[/QUOte
The FAA has never sent a letter to anyone flying commercially without a 333. They don't want to be challenged in court.

 

[licensed pilot]

"The FAA has never sent a letter to anyone flying commercially without a 333. They don't want to be challenged in court."
How do you know this?