FAA 333 Exemption letter...how many have one & how long did it take?
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Been researching this topic a bit, and sounds like technically the operator needs to have a pilots license. I did not realize this. It seems that there are many out there who have received the 333 exemption who don't actually have a pilots license of any kind. I guess I'm surprised the FAA is granting exemptions without them, though I'm not complaining as I intend to apply for an exemption as well (and don't have a pilots license). Let's hope they don't close this loophole anytime soon.
You do not have to have a pilots license to apply for an exemption and they are not granted weather you do or do not. All 333 exemptions are issued with the requirement the pilot in command, PIC, must have a current airman's certificate and medical or state issued drivers license depending on type of certificate held. Even the exemptions I have read that were granted to large corporations have the same wording.
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The exemption is issued to a commercial business entity. The owner/333 applicant doesn't have to have the pilot's license. Just the person flying the drone for the commercial business. However, it is an absolute requirement.
A 333 exemption without a licensed pilot available to always fly the drone is of no value. However, you just need to hire a pilot to fly, and build that expense into your bids.
A 333 exemption without a licensed pilot available to always fly the drone is of no value. However, you just need to hire a pilot to fly, and build that expense into your bids.
The exemption can be issued to an individual not just a commercial business entity. I've noticed many many more are issued to an individual over the last couple months.
I have applied for mine and am still in the "submitted but not yet posted to the public docket" section. I've got a tracking # but that's it. Dang nabbit LOL
I have applied for mine and am still in the "submitted but not yet posted to the public docket" section. I've got a tracking # but that's it. Dang nabbit LOL
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Commercial business entities, of course, includes individuals running a sole proprietorship. Drone photography tends to be a solo owner business, but the requirement of a pilot's license requires the owner to already have one, or hire out the photography to a licensed pilot. The latter significantly cuts into profits, and frankly, I wouldn't trust my drone in the hands of any licensed pilot! I have far more experience flying my drone than any pilot flying real airplanes will ever have! 
Trust me - I've analyzed 1,700 exemption letters. The really short ones always had some additional information requested by the FAA. Use one of the longer ones, but this petition is a pretty good example to model yours on: Image-Effects-12583 8/25/2015 (David Hunt)
All that David's petition didn't have was his Motion Picture and Television Flight Operation Manual (MPT-FOM)
The first two petitions for exemption voluntarily included their MPT-FOM with the petition, and now if any petition mentions film for cinema, television or motion picture, you will be expected to produce an MPT-FOM. No one reads these and they are mostly just a repeat of the petition conditions in the first-person. David's is a pretty standard template for the petition and the MPT-FOM.
There is a summary of the steps at the333.org
Just a quick check, Exemption 13276 (Michael C. Bitzko, Hill Country Aerial, LLC, San Antonio, TX) is dated 10/21/2015. His original petition was dated May 20, 2015. Five months.
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Having a pilot's license does absolutely nothing to guarantee public safety if the PIC does not have a proficiency in flying the aircraft in question. There is no way I would give my controller to a pilot without at least 20-30hrs of flight time. I agree that licensed Pilots will have an understanding of the FAA airspace others will not, but what good is that w/o "stick time?" After about 5 Phantoms, a few crashes, (zero property damage) 1 flyaway loss, 1 flyaway recovery, about 300+ flights, who has more experience, someone with license and a new Quad or even MY Quad? I don't think so. I'd be happy to take a flight proficiency test and even a written test, if that is what it takes to fly commercially.
All the exemptions I am seeing have the same restrictions of 100 mph, 400 feet high and 500 feet away. Does this cover your areal photography also. A local drone shop said figure six months for the exemption.
You're completely missing the point of the "Pilot Certification". It has nothing to do with flying a Cessna 172 (or any other full sized manned aircraft) but everything to do with training and testing about the OTHER aspects of flying such as National Air Space. Having a pilot certification is the only way the FAA knows for sure you've been exposed to, tested on, and passed a proficiency test on things to do with National Air Space (NAS).
Once you've completed (and passed) the Pilot Certification (Sport Pilot on up) then you at least have a basic knowledge of the different types of airspace, how they are depicted on Aeronautical Charts, Able to get a weather briefing (and understand what that is), and how to communicate with ATC should the need arrive. If there was something better that was available you can bet it would have been part of the criteria but the FAR mandate who can operate in the NAS and what training is required. Hopefully in the next year (or so) new training can be designed, certified, implemented, and rolled out in Federal Testing Centers so we can obtain the needed certification to operate without the Pilot Certification.
You're mostly right.
The FAA can waive FAA rules in 14 CFR under Section 333 of the FMRA to give pilots the opportunity to fly personal drones for commercial purposes and more than 1,700 have received the exemptions. The requirement for a pilot certification is in 49 USC § 44711 which the FAA cannot exempt. However, the Part 107 rules when effective will create a new class of airman certificate unique to small UAS operation that only requires a written test.
Thanks for quoting that. I knew the "basics" but didn't know enough details to say it like that. I knew why they couldn't exempt but didn't know exactly where they were listed to mention them.
It's always good to learn more.
Allen
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GadgetGuy
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If, under the 333 Exemption, you are still restricted to 400 feet AGL and VLOS with a spotter and daylight, and 5 minutes of remaing battery upon landing, and require prior written permission to fly over any private property, and are not allowed to fly over people, most of the understanding of NAS and weather required of a pilot is complete overkill. Just sayin'!
Perhaps all the forum members here who have claimed to be real pilots in various posts they've made could hire themselves out to those with 333 exemptions? Certainly as forum members they must be experienced Phantom Pilots as well as manned aircraft pilots?
Maybe a directory should be started. Steve, you are a pilot, aren't you? Take on this project?
Maybe a directory should be started. Steve, you are a pilot, aren't you? Take on this project?
Challenge Accepted.
It may take me a while to get back up to speed on PHP and MySQL, but it sounds like a needed project.
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