FAA 333 Exemption letter...how many have one & how long did it take?

[GadgetGuy]

A drone photography/videography business is no different than any other photography business. The ones who are most successful are not the most talented, but are those that are the best at business and marketing and sales. That usually involves outsourcing the photography because a person can only be in one place at a time, while a business owner can double and triple book jobs at the same time, while outsourcing the actual work, and focus exclusively on the marketing and sales. However, I doubt that a licensed pilot's time can be bought cheaply enough to make it profitable, when those operating without the 333 Exemption are your competition and can easily undercut you. Similarly, why wouldn't the licensed pilot get his own 333 Exemption and cut out the middleman, since the pilot's license is far more valuable than the jobs secured by the business owner without a pilot's license who currently has a 333 Exemption, but needs a licensed pilot with the necessary drone skills to do the actual drone photography. The 333 Exemption is and has been readily available for anyone that wants one with a reasonable business need. The only limiting factor is the time for processing and approving the application. There also is no doubt that the value of holding a pilot's license is a limited window, before less restrictive requirements are adopted, which will remove that requirement. It's not a sound business model going forward. However, let's compile a list of licensed pilots that have drone skills and see whether anyone with a 333 Exemption wants to pay what they are willing to work for, assuming they don't have the pilot's license themselves already, or even if they do, are overbooked and need to outsource.

 

[auen1]

Not exactly on topic, but I was wondering how much it costs to get a 333, w/o an attorney?
Is it just a matter of paperwork?

And then, are you legal to shoot film commercially, say for real estate, assuming that you have the appropriate business licenses?

Thanks!

 

[GadgetGuy]

Not exactly on topic, but I was wondering how much it costs to get a 333, w/o an attorney?
Is it just a matter of paperwork?

And then, are you legal to shoot film commercially, say for real estate, assuming that you have the appropriate business licenses?

Thanks!

The333.org - Professional Drone Operators
No cost for the 333. Just a matter of paperwork, and waiting 7 months to reach the top of the pile. $5 to register your drone, if you are granted the 333 Exemption. You must then also comply with all of the onerous restrictions imposed upon those flying with a 333 Exemption. Or, just fly "under the radar!"

 

[SteveMann]

However, I doubt that a licensed pilot's time can be bought cheaply enough to make it profitable, when those operating without the 333 Exemption are your competition and can easily undercut you.

I think you would be surprised how many pilots are current (medical, BFR, etc) who would PIC a drone for a 333 exemption holder as extra help when things get busy. As I have said in the past, no drone operator that I am aware of has ever received a letter of violation for flying a personal drone for commercial purposes. Threatening letters are not letters of violation. There is no FAA rule that an uncertificated pilot would be violating. But a certificated pilot would be risking a certificate action and a fine for flying a personal drone commercially. 14 CFR §61.101 'Recreational pilot privileges and limitations' and 14 CFR §61.113 'Private pilot privileges and limitations-Pilot in command' both have specific prohibitions for flying for compensation.

But, yes, you do have to pay them and a project may not be profitable as a result, but it beats turning down a client due to overbooking. There are also quite a few corporations obtaining Section 333 exemptions with the intent of hiring a pilot.

Besides, getting a Section 333 exemption will make it easier to negotiate for insurance and some clients, (whom you probably don't want anyway) are simply looking for the lowest bidder even if he is working out of his mom's car. I wouldn't consider those low-budget operators my competition because I don't want those low-budget clients. They are welcome to them because it just makes me look better.

 

[SteveMann]

if you are granted the 333 Exemption.

Of the almost 2,000 exemption petitions in the queue, the FAA has rescinded some 300 or so. Mostly due to the failure of the applicant to respond to a request for additional information in the time alloted. (How many copies of the Phantom 2 manual do they want?) Some were rescinded because of technical errors, and a couple because the petitioner did a lousy job of 'cut and paste' on a petition they are copying, leaving the original petitioner's contact information in the document.

 

[Bob G]

I support organizing forum members to provide FAA 333 Exemption pilots. I am currently challenging a local utility flying drones by persons with no electrical experience. I am finding there is a need for drone pilots also with unique experience like the electrical mentioned.
I suggest we fill the need for pilots and also help FAA set some precedents here. In dealing with FAA, without being insulting, they really need some help. I have a meeting with FAA in San Diego soon and I'll be discussing pilot qualifications.

 

[SteveMann]

I support organizing forum members to provide FAA 333 Exemption pilots. I am currently challenging a local utility flying drones by persons with no electrical experience. I am finding there is a need for drone pilots also with unique experience like the electrical mentioned.
I suggest we fill the need for pilots and also help FAA set some precedents here. In dealing with FAA, without being insulting, they really need some help. I have a meeting with FAA in San Diego soon and I'll be discussing pilot qualifications.

I am having a problem wrapping my head around your meeting with the FAA. (FSDO, I assume?) What precedents? You are either certificated or you are not.

 

[Bob G]

I am not "certificated". I'm just Joe Blow citizen who is challenging FAA Exemption No. 11238 on a number of administrative issues. And I'm seeing a need for qualified operators. Organizing yourselves in this direction would be helpful.
I will keep you advised on my meeting if desired.

 

[SteveMann]

Again, still puzzling. What issues could you possibly have with SDG&E using a drone to inspect power lines? Why does the PIC need to be an electrical engineer? That is like saying the X-Ray technician in the clinic should also be a radiologist.

But, if that's what you are contending then you are way off-base. The FAA is only concerned with aviation safety. How a business uses their drones is not their problem as long as the Section 333 exemption conditions and limitations are observed. They can hire anyone qualified to fly the drone.

 

[Bob G]

Thank you for your assistance.

 

[vgt]

For those who have been approved, what was the interval between finally being posted on reg.gov, and receiving an approval (or denial)? I submitted 16JUL, it was finally posted on 21OCT. Wondering how long the next step is.

Thanks!

 

[SteveMann]

For those who have been approved, what was the interval between finally being posted on reg.gov, and receiving an approval (or denial)? I submitted 16JUL, it was finally posted on 21OCT. Wondering how long the next step is.

Thanks!

Your posted exemption is open for public comment, usually for 30-days. In the past you could expect a scathing HELL NO from the Airline Pilots Association (ALPA), but they haven't been posting comments lately. Did they give up?

 

[Sky King]

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.

Understood. However, remember...#1 Aviate & #2 Navigate. If you can't fly it, all the knowledge of NAS isn't going to do much good.

It makes me think that, #1 I get my 333 Exemption. #2 I "loan" my P3P to a Pilot until they get 100-200 flights on it so they can get proficient, burn through 2 of my batteries after they get their 2 "crashes" and then give me my bird back. #3 They buy their own, get their 333 Exemption and do the work I should be doing! (an over exaggeration, obviously and some TIC, but you get my drift)

 

[BigAl07]

With the current regulations I don't see how it can be profitable (for most business models) for a company to hire a pilot unless we're talking a very large firm with hefty and deep contracts.

Part of the 333 Exemption requires the PIC to be proficient with the aircraft so you are correct they would have to "learn" somewhere along the way or be taught. Of course with today's super self stabilized and GPS guided aircraft becoming proficient in semi-manual control is almost "Here's the battery, there's the aircraft, and this is the Tx."

When you factor in "Manual" control/flight that's a whole other story but I have seen several "competent" MultiRotor operators lose their mind when the self stabilization/guidance systems go on the blink. Once the aircraft is no longer able to fly itself it becomes a game changer which is why the PIC must be able to fly the aircraft in all configurations and scenarios.

 

[SteveMann]

With the current regulations I don't see how it can be profitable (for most business models) for a company to hire a pilot unless we're talking a very large firm with hefty and deep contracts.

Part of the 333 Exemption requires the PIC to be proficient with the aircraft so you are correct they would have to "learn" somewhere along the way or be taught. Of course with today's super self stabilized and GPS guided aircraft becoming proficient in semi-manual control is almost "Here's the battery, there's the aircraft, and this is the Tx."

When you factor in "Manual" control/flight that's a whole other story but I have seen several "competent" MultiRotor operators lose their mind when the self stabilization/guidance systems go on the blink. Once the aircraft is no longer able to fly itself it becomes a game changer which is why the PIC must be able to fly the aircraft in all configurations and scenarios.

Your view of small UAS is quite narrow. According to a review of the exemptions granted by 'www.the333.org', there are 499 different models of sUAS among 168 manufacturers. Granted DJI and 3DR provide the bulk of the aircraft represented, but there's an awful lot of heavy-lift multirotors and fixed-wing sUAS aircraft. There's also many corporations with a Section 333 exemption who hire pilots to fly their aircraft.

Granted, it would not be profitable for the one-man shop to hire a PIC at $50 per hour for a $250 project. But sometimes it may be necessary.

 

[BigAl07]

Your view of small UAS is quite narrow. According to a review of the exemptions granted by 'www.the333.org', there are 499 different models of sUAS among 168 manufacturers. Granted DJI and 3DR provide the bulk of the aircraft represented, but there's an awful lot of heavy-lift multirotors and fixed-wing sUAS aircraft. There's also many corporations with a Section 333 exemption who hire pilots to fly their aircraft.

That's precisely why I said "talking a very large firm with hefty and deep contracts".

Steve keep in mind what forum we are discussing this on and the majority of the size companies that will be reading this post. Of course there will be larger firms out there but the majority of the people visiting here are going to be flying something DJI or very close to it. Not all but I'd bet the majority purely by the name of the forum.

Granted, it would not be profitable for the one-man shop to hire a PIC at $50 per hour for a $250 project. But sometimes it may be necessary.

I completely agree.

One thing I did make mistake earlier was:

With the current regulations I don't see how it can be profitable (for most business models) for a company to hire a pilot..

What I should have said instead of hire was "contract out" a pilot. Many of the larger companies have pilots on staff but I'm more concentrating on the smaller "Mom & Pop" companies that are popping up across the country/World with the advent of a flying camera that is gyro stabilized and GPS guided.