USA to #333 or not? This is a very sincere info request.

[rmb]

All,

I am posting to this forum looking for sincere advice and information from a professional body. I say upfront that I am an unlicensed flyer but am hoping that you will still read below, and perhaps offer me and others like me tangible and practical advice.

I am a professional videographer of 30 years and a UAV pilot for 5 years without incident. I use my inspire to add big production values to my projects and now have begun earning good money helping others. 100% of my aerial work keeps me WELL below 400 ft in fact I spend 90% of my time between 20ft and 80ft. I have a preflight check list that I made my self based on common sense and torture my clients with my preflight lectures on safety and rules. i.e. I only fly in winds below 8 knots, to 50% of battery, line of sight, etc. Its a full one page check list. I get $750 for 4 hours and I work 2 - 3 times a month as a supplement to my full-time videography work. Like most of us it started as a hobby but now that I am working commercially I realize that I am outside of the law. And before you hate me, there are no 333 exempt companies or pilots anywhere near me so I don’t compete with anyone that has gone to the trouble or expense. That said, I am a licensed driver, I own hand guns and have a permit and have taken countless safety courses. Good lord I even took safety courses for boating and my quad. I am not boasting, I just want to convey that I am a stickler on being on the up and up. Now my long awaited question. I have saved the money ($3,500) and am about to engage a very reputable firm to get my #333 exemption. A) for the legal aspect and B) I believe that advertising as a fully insured, FAA compliant vendor will be very appealing to legit businesses and will virtually crush the illegal competition. So what’s the problem? I have the cash and perhaps the time, but absolutely no interest whatsoever in becoming a licensed pilot! nor do I believe it relevant. Ground school and aviation education absolutely! but learning to fly a plane before you can operate a small quadcopter is neither safe or relevant to the end goal. That said it is my understanding that the 333 is totally useless to me (other than marketing) if I am not a licensed pilot. Is this true? and if so do any of you think that there will be a meaningful change that will allow and encourage otherwise safe and conscientious UAV pilots to operate safely within the law?

Thank you for taking the time to read this. I hope that I did not overstep by posting in your Professionally Certified Forum. I hold you guys in the highest respect!

~ R

 

[SanCap]

"That said it is my understanding that the 333 is totally useless to me (other than marketing) if I am not a licensed pilot. Is this true?"

Yes that is true, the only thing you could do would be to hire a quadcopter operator who has a Pilots License to use your 333 Exemption. We do not know when the rules will change.

 

[rmb]

Sigh...

Thanks, r

 

[Gregoryv022]

"That said it is my understanding that the 333 is totally useless to me (other than marketing) if I am not a licensed pilot. Is this true?"

Yes that is true, the only thing you could do would be to hire a quadcopter operator who has a Pilots License to use your 333 Exemption. We do not know when the rules will change.

After Spending 2 days at the Drone World Expo this last Tuesday and Wednesday talking with an FAA representative as well as attending MAPPS conferences, we can expect new rules to start being implemented in June of 2016. That is if nothing delays it. There is still no word on what the new rules, (Section 107) will be but they will be less restrictive than a 333.

 

[rmb]

That sounds encouraging. And, thank you both for your response. The next time I join your forum I hope to be #333 except. My parting thought is this. What I would have loved to have been able to say to an FAA rep and I know I will probably come across as a rant, but...

The problem we are all seeing with these mindless yahoos out there tarnishing the industry is in big part created or at lease sustained by the FAA itself. If drones were classified into categories like cars, trucks, taxi cabs, etc. and required an appropriate license and education appropriate to each, and everyone had to take and pass a $500 - $1000 - $2500 course and re-certify every year, etc. 90% of these idiots would simply go away, the desired safety goals would be achieved and the Feds would put enough money in their pockets to fund real enforcement. But alas, name me 5 things our government does well?

Fly safely all!
R

 

[kcobello]

All,

I am posting to this forum looking for sincere advice and information from a professional body. I say upfront that I am an unlicensed flyer but am hoping that you will still read below, and perhaps offer me and others like me tangible and practical advice.

I am a professional videographer of 30 years and a UAV pilot for 5 years without incident. I use my inspire to add big production values to my projects and now have begun earning good money helping others. 100% of my aerial work keeps me WELL below 400 ft in fact I spend 90% of my time between 20ft and 80ft. I have a preflight check list that I made my self based on common sense and torture my clients with my preflight lectures on safety and rules. i.e. I only fly in winds below 8 knots, to 50% of battery, line of sight, etc. Its a full one page check list. I get $750 for 4 hours and I work 2 - 3 times a month as a supplement to my full-time videography work. Like most of us it started as a hobby but now that I am working commercially I realize that I am outside of the law. And before you hate me, there are no 333 exempt companies or pilots anywhere near me so I don’t compete with anyone that has gone to the trouble or expense. That said, I am a licensed driver, I own hand guns and have a permit and have taken countless safety courses. Good lord I even took safety courses for boating and my quad. I am not boasting, I just want to convey that I am a stickler on being on the up and up. Now my long awaited question. I have saved the money ($3,500) and am about to engage a very reputable firm to get my #333 exemption. A) for the legal aspect and B) I believe that advertising as a fully insured, FAA compliant vendor will be very appealing to legit businesses and will virtually crush the illegal competition. So what’s the problem? I have the cash and perhaps the time, but absolutely no interest whatsoever in becoming a licensed pilot! nor do I believe it relevant. Ground school and aviation education absolutely! but learning to fly a plane before you can operate a small quadcopter is neither safe or relevant to the end goal. That said it is my understanding that the 333 is totally useless to me (other than marketing) if I am not a licensed pilot. Is this true? and if so do any of you think that there will be a meaningful change that will allow and encourage otherwise safe and conscientious UAV pilots to operate safely within the law?

Thank you for taking the time to read this. I hope that I did not overstep by posting in your Professionally Certified Forum. I hold you guys in the highest respect!

~ R

We do 99 percent work for charities and local chamber of commerce, with no pay. We just received a polite letter from the FAA to follow the current regs and safety rules. From the opinions on this site you may want to refrain from talking about working illegally. Your work is probably good and that will agitate the commercial operator even more because they cant compete with your good uncertified work. We have flown for 6 years and follow the rule/laws as far as up to this/last year where they stepped up enforcement. I could care less really about the money grab from it because it will be very little. Just a FYI and great luck with your business. With your Pro photography background you will generate some good imagery...Kevin

 

[rmb]

That was a very thoughtful response and your point is well taken. Thank you. BTW I am pretty sure that I am looking at the same info, but if you would, please pass me along a link to what you have seen as far as the "Current regs and safety rules" It would be much appreciated in case I have missed something or am now out of date.

R

 

[SanCap]

Here are the current guidelines for Hobby or Recreation Uses https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_91-57A.pdf .

 

[kcobello]

SanCap
That's exactly what I received. I think that doesn't mention anything about taking pictures. That's the area I think the above reference is. What can you do with pictures that you take.

 

[SanCap]

SanCap
That's exactly what I received. I think that doesn't mention anything about taking pictures. That's the area I think the above reference is. What can you do with pictures that you take.

Make Christmas Cards or make beautiful web pages with no mention of for sale!

 

[hoverkat92]

Please Google FAA fines Skypan 1.9 million.

 

[Dr. Ifly Drones]

All,

I am posting to this forum looking for sincere advice and information from a professional body. I say upfront that I am an unlicensed flyer but am hoping that you will still read below, and perhaps offer me and others like me tangible and practical advice.

I am a professional videographer of 30 years and a UAV pilot for 5 years without incident. I use my inspire to add big production values to my projects and now have begun earning good money helping others. 100% of my aerial work keeps me WELL below 400 ft in fact I spend 90% of my time between 20ft and 80ft. I have a preflight check list that I made my self based on common sense and torture my clients with my preflight lectures on safety and rules. i.e. I only fly in winds below 8 knots, to 50% of battery, line of sight, etc. Its a full one page check list. I get $750 for 4 hours and I work 2 - 3 times a month as a supplement to my full-time videography work. Like most of us it started as a hobby but now that I am working commercially I realize that I am outside of the law. And before you hate me, there are no 333 exempt companies or pilots anywhere near me so I don’t compete with anyone that has gone to the trouble or expense. That said, I am a licensed driver, I own hand guns and have a permit and have taken countless safety courses. Good lord I even took safety courses for boating and my quad. I am not boasting, I just want to convey that I am a stickler on being on the up and up. Now my long awaited question. I have saved the money ($3,500) and am about to engage a very reputable firm to get my #333 exemption. A) for the legal aspect and B) I believe that advertising as a fully insured, FAA compliant vendor will be very appealing to legit businesses and will virtually crush the illegal competition. So what’s the problem? I have the cash and perhaps the time, but absolutely no interest whatsoever in becoming a licensed pilot! nor do I believe it relevant. Ground school and aviation education absolutely! but learning to fly a plane before you can operate a small quadcopter is neither safe or relevant to the end goal. That said it is my understanding that the 333 is totally useless to me (other than marketing) if I am not a licensed pilot. Is this true? and if so do any of you think that there will be a meaningful change that will allow and encourage otherwise safe and conscientious UAV pilots to operate safely within the law?

Thank you for taking the time to read this. I hope that I did not overstep by posting in your Professionally Certified Forum. I hold you guys in the highest respect!

~ R

I completely understand your position in that I'm very nearly in the exact same. I did go through the UVU certification course and that's a great start but, at present I can't apply for the 333 either because while I'm a certified UAV pilot, I'm not licensed by the FAA. The problem is that technology far surpassed the FAA and they are applying 20th century regulations to 21st century products. The issues go further. To operate commercially without risking everything you need insurance. To get the insurance you either have to be a certified UAV pilot of a FAA licensed pilot. The FAA sees commercialization of the airspace as it's domain and thus, any commercial gain made without a 333 and CoA at present represents a violation of federal regulations. The illusion of some sort of clarity by June of 2016 is optimistic in my opinion as that I've been waiting a year to see what was mandated by congress to happen by last Sept.

I think the FAA, once they finally do get something enacted, will require some sort of formal training and a certain number of documented flight hours, to be eligible to take a written examination that will supersede the 333. At the same time I think they will grandfather anyone who has a pilot's license into that program. If I had to run this race again I would have taken the money I spent of the UVU certification and gotten a sports license instead. It would have cost me less and I could have mastered the UAV training on my own. I would have had a 333 and CoA in my hand by now and could be openly commercially viable.

 

[SanCap]

I completely understand your position in that I'm very nearly in the exact same. I did go through the UVU certification course and that's a great start but, at present I can't apply for the 333 either because while I'm a certified UAV pilot, I'm not licensed by the FAA. The problem is that technology far surpassed the FAA and they are applying 20th century regulations to 21st century products. The issues go further. To operate commercially without risking everything you need insurance. To get the insurance you either have to be a certified UAV pilot of a FAA licensed pilot. The FAA sees commercialization of the airspace as it's domain and thus, any commercial gain made without a 333 and CoA at present represents a violation of federal regulations. The illusion of some sort of clarity by June of 2016 is optimistic in my opinion as that I've been waiting a year to see what was mandated by congress to happen by last Sept.

I think the FAA, once they finally do get something enacted, will require some sort of formal training and a certain number of documented flight hours, to be eligible to take a written examination that will supersede the 333. At the same time I think they will grandfather anyone who has a pilot's license into that program. If I had to run this race again I would have taken the money I spent of the UVU certification and gotten a sports license instead. It would have cost me less and I could have mastered the UAV training on my own. I would have had a 333 and CoA in my hand by now and could be openly commercially viable.

You certainly can apply and receive a FAA 333 Exemption without being a pilot. You will have to hire a pilot to fly for you until you get a pilot or sport pilots license.

 

[Dr. Ifly Drones]

You certainly can apply and receive a FAA 333 Exemption without being a pilot. You will have to hire a pilot to fly for you until you get a pilot or sport pilots license.

Yes, you could hire a licensed pilot but, would they know anything about piloting a UAV? I think that's the point, they are not mutually inclusive. Additionally, current regulations require both a PIC and observer and if you're trying to get a business off the ground that last thing you want is to be required to hire 2 people right out of the gate. Also, it's not enough to have a licensed PIC to "oversee" operations but, they actually have to be at the controls during operation.

 

[hoverkat92]

I completely understand your position in that I'm very nearly in the exact same. I did go through the UVU certification course and that's a great start but, at present I can't apply for the 333 either because while I'm a certified UAV pilot, I'm not licensed by the FAA. The problem is that technology far surpassed the FAA and they are applying 20th century regulations to 21st century products. The issues go further. To operate commercially without risking everything you need insurance. To get the insurance you either have to be a certified UAV pilot of a FAA licensed pilot. The FAA sees commercialization of the airspace as it's domain and thus, any commercial gain made without a 333 and CoA at present represents a violation of federal regulations. The illusion of some sort of clarity by June of 2016 is optimistic in my opinion as that I've been waiting a year to see what was mandated by congress to happen by last Sept.

I think the FAA, once they finally do get something enacted, will require some sort of formal training and a certain number of documented flight hours, to be eligible to take a written examination that will supersede the 333. At the same time I think they will grandfather anyone who has a pilot's license into that program. If I had to run this race again I would have taken the money I spent of the UVU certification and gotten a sports license instead. It would have cost me less and I could have mastered the UAV training on my own. I would have had a 333 and CoA in my hand by now and could be openly commercially viable.

Just wanted to thank you for your make sense remarks. Most recreational drone operators don't understand the regulatory authority of the FAA and feel its' the gu-ment imposing their authority on poor old John Q Public. Your post is dead on point. I'm AM licensed pilot that has not gone through UAS training. Being a licensed pilot does not, by any means, make me a better or safer UAV operator. There's the regulatory and operational aspect of UAS ops that have to be considered when conducting UAV ops. For example, the drone crash at the Alpine skiing event. From the information I have, which is limited, the operators took every precaution to include escape routes and plans in the event of a malfunctions. The operator may have recognized the malfunction, but I think the drone reaction to his planned escape procedure did not happen the way he had hoped. I have trained on real helicopters, turbo props and turbojets. There are failures that I've trained for through simulation over and over, but the actual event could be very different in the airplane. What the FAA is doing now is basically a band-aide until, as you said, their old technology catches up to the new technology. I'm bit old school. I got an iPad about six or seven months ago and the company had to issue it to me. If you get what I mean. Great comment..

 

[SanCap]

Yes, you could hire a licensed pilot but, would they know anything about piloting a UAV? I think that's the point, they are not mutually inclusive. Additionally, current regulations require both a PIC and observer and if you're trying to get a business off the ground that last thing you want is to be required to hire 2 people right out of the gate. Also, it's not enough to have a licensed PIC to "oversee" operations but, they actually have to be at the controls during operation.

I never mentioned anything about the the licensed pilot being an observer. I was just pointing out that anyone can petition for a 333 exemption. My point was that you could have the 333 exemption, be the observer and hire a Licensed pilot that knows how to fly a UAS, like myself. I am 6 months into the 333 exemption process and hope to have mine before February. Good luck in your endeavors.

 

[Dr. Ifly Drones]

I never mentioned anything about the the licensed pilot being an observer. I was just pointing out that anyone can petition for a 333 exemption. My point was that you could have the 333 exemption, be the observer and hire a Licensed pilot that knows how to fly a UAS, like myself. I am 6 months into the 333 exemption process and hope to have mine before February. Good luck in your endeavors.

I didn't say anything about a licensed pilot being the observer either. I think the tenor of the original post is that the 333 process is obtuse related to the actual technology, is counter productive in business development and that some of the requirements like having a licensed pilot and observer are just ridiculously expensive. I agree with those assertions. As the original post says, being a licensed pilot doesn't automatically mean you know anything about UAV operation. After waiting almost a year for the FAA to come out with new standards I've begun to loose faith they will at all. This is further complicated by pilot unions trying to gain leverage in this fray by implying all flight activities carried out for commercial reasons require a commercial pilot's license which, is patently ridiculous. Currently, there aren't enough pilots to serve current actual flight needs in non UAV applications and even the military can't source their own needs for UAV pilots and are examining pulling potential pilots from the enlisted ranks (already causing a big dust up in the services).

Sure, I could find someone who has a private pilot's license and current medical clearance and train them to operate a UVA and pay them to gain a few hundred hours of experience to get them where they can perform the kind of maneuvers that are needed to film for cinematographers. Sure, I could find a friend who could act as my observer and slip him a 12-pack for standing around a shoot but, in a sensible world, why in the hell would I? So, when the FAA wonders why people just do it on the DL they are delusional. Unfortunately, at the same time we have manufacturers of equipment that only care about selling units and they make them as "idiot proof" as possible thus creating significant challenges for those of us who've worked hard to gain a skill set and develop experience because of over zealous geofencing and limitations built in to the process. I also fly the S1000+ and can tell you that it doesn't have any of the limits that the DJI GO app places on the I1. But, I would rather use the I1 in 95% of my work because it's much easier to set up, transport and maintain. It also does almost everything the S1000+ with a 5D Mark III can at a fraction of the expense.

 

[Plumcrazy]

The FAA is tasked with regulating the national airspace (NAS). Commercial air travel is the safest form of transportation in the USA, mainly because of the safety rules & regs implemented by the FAA. No small feat! With the explosion of uav use in such a short time, the safety of flight operations had to start somewhere.

Requiring a pilots certificate has nothing to do with the operations of a uav, is has to do with the knowledge of the airspace environment. It's far more complex then, say, the regulations to drive a car. There's several different classes of airspace, weather and environmental issues, altitude restrictions, glide paths and moa's (military operation areas), notams (notice to airman), just to name a few.

The current commercial regs are sec. 333 exemptions! Think about this! Exemptions?? From what?? Funny you should ask! Currently, the FAA requires you to register your commercial uav with an 'N' number. This is the 'license tag' for all aircraft or registered in the US. When that's done, a uav is coming in the same category as Cessna, Learjet, or Boeing 747. The 'exemptions' you file for are so you don't have to meet certain mandatory requirements. Some are equipment related, like radios and transponders. Some are airspace, 500' agl (above ground level) is pretty much a hard limit everywhere, unless you're a crop duster or news helicopter with a proper notam filed. And then!!! You can apply for a COA (certificate of authorization) which gives you the clearance to actually fly. The FAA was being pretty generous in granting a blanket COA up to 200' agl to all who filed for the exemption! Anything higher, file for a new COA.

 

[Plumcrazy]

Anyway, could go on and on. Let's give them some credit, its safer to fly commercially then it is walk across the street!!

That being said, it's still a huge gub'ment agency that's not very able when it comes to changing fast. When the rules finally come out (they say June 2016, don't hold your breath (see above)), there will probably be a shiny new rating for a commercial uav pilot! Expect to get schooled on the things I mentioned, as well as some profiency requirements that you will have to meet. There will be a test (or 2). The FAA can and has been flexible. Used to be, private, commercial, and ATP (airline transport pilot) were the only ratings. Now there's also sport and recreational ratings, which require less training and experience. Prove a need, and the FAA will respond (just not very fast).

Ok! My rants over. ✈ fly safe!

 

[SanCap]

I completely understand your position in that I'm very nearly in the exact same. I did go through the UVU certification course and that's a great start but, at present I can't apply for the 333 either because while I'm a certified UAV pilot, I'm not licensed by the FAA. The problem is that technology far surpassed the FAA and they are applying 20th century regulations to 21st century products. The issues go further. To operate commercially without risking everything you need insurance. To get the insurance you either have to be a certified UAV pilot of a FAA licensed pilot. The FAA sees commercialization of the airspace as it's domain and thus, any commercial gain made without a 333 and CoA at present represents a violation of federal regulations. The illusion of some sort of clarity by June of 2016 is optimistic in my opinion as that I've been waiting a year to see what was mandated by congress to happen by last Sept.

I think the FAA, once they finally do get something enacted, will require some sort of formal training and a certain number of documented flight hours, to be eligible to take a written examination that will supersede the 333. At the same time I think they will grandfather anyone who has a pilot's license into that program. If I had to run this race again I would have taken the money I spent of the UVU certification and gotten a sports license instead. It would have cost me less and I could have mastered the UAV training on my own. I would have had a 333 and CoA in my hand by now and could be openly commercially viable.

Can you explain or provide links to what a UVU Certification and a Certified UAV Pilot are. I have not run into these and would like to learn more about them. Are these FAA approved or soon to be? I did find a link for UAV Pilot Training Certificate - Unmanned Vehicle University but I am not sure if that is FAA approved. I agree all this training is great but without FAA approval I think it means little. I am asking this respectfully and would like to add as many credentials to my resume as possible. Thanks