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Where do I start............You submit your 13-75 page 333 to regulation.gov and wait, and wait, and wait, and......................well 2-3 months later you have your business listed on their docket, then another two months later you wait and wait for the flag to be changed to approved so you now have  your official 333 number.  Now what.........well you have to purchase N#'s from the FAA website which is a GREAT smooth easy process and only cost $10.  Next you have to request an FAA Form 8050 duplicate copy to hand write your serial number and the N tail # that you purchased and place the hand written document into snail mail and send off to Oklahoma City, then the next wait is on.............waiting for your official aircraft registration certificate. Now that six, eight, or ten months have gone by you might be all set to start flying commercially................OH WAIT!!!!!!!  I listed my DJI Phantom 3 Pro on the original 333 request and now that 6-8 months have passed, I have upgraded to the new and improved DJI Phantom 4 aircraft. Now you are in a real pickle............you have to submit an addendum to your original 333 and wait for that entire process to take place before you are legally able to fly your P4 as part of your 333. Well I have my 333 approved, and my good ol P3 Pro approved so now what. Well you are approved with a blanket COA (certificate of authority) up to 200 feet AGL. But the customer wants an aerial survey of their entire 3,000 acre property from 400 feet AGL. Now you get to learn what a COA is, what it stands for and the next .......the waiting process to submit your request to fly in a certain area. I hope your customer is not within 5 nautical miles of an airport, or you may never get it approved!!! Next you call the air traffic control tower and advise them of your intentions, PLAD - Plane, Location, Altitude, Destination or Length of flight in our UAV world. They will want to know who the PIC (Pilot in Command) is and the cell phone to that person. They might also require you to have a two way aircraft radio on hand and advise you to tune into the local approach or tower frequency. I recommend a nice Sporty 400 radio, nice unit for around $300.  Well it has been almost a full year since you started your 333 process, purchased UAV's, purchased N Tail #'s, Registered the tail numbers, have received the airworthiness certificates and are finally ready to go fly your first job. Make sure you have copies of everything with you at all times....................thats a good start, Thanks Alan for such an awesome site for the community!!!!

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Lol, puts things into perspective.

I guess how I view all this is that when it comes to rules/regulations (not just in the U.S., but in Canada, the UK, Australia--we have a lot of international community members in here), it's not something you can really control. It's a system. You just put your head down and get it done. All the bullet points are there. You just buckle down and do it. Every other person is facing the same constraints you are.

But when it comes to building a business...that's much harder. Getting website traffic and "found" online without having to spend money on paid advertising. Nurturing your leads and educating them so at the end of the day, they're the ones picking up the phone, not you. Creating solid SOPs to help facilitate service delivery and to instill confidence with your clients, and knowing how to properly price/package your services.

I wasn't really planning to cover regulations in this course, but it might be something I need to revisit given how many people are complaining that it's taking them too much time.

Re: the Phantom 4 (or any new model that comes on the market until the sUAS regulations change):

  • Get an N-number for your new model ASAP.
  • Go ahead and submit an amendment to your existing paperwork.
  • Don't wait 5+ months to start flying. That's ridiculous. I'm all for following the rules, but when they don't make sense and the risk is incredibly low, I'm not going to let this quirk hold me back from pushing my business forward. I spoke with a prominent UAS lawyer about this...he said, and I quote, "We do not see a high risk of flying prior to getting approval of (especially) DJI products from the FAA. Many clients will decide to take the risk while they await their amendment approval."

There are far more important things to be worrying about.

Those of you who are risk-averse will undoubtedly disagree with me here :)

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4 minutes ago, Alan Perlman said:

Those of you who are risk-averse will undoubtedly disagree with me here :)

It's all relative to what you are trying to do. As a one man startup you don't have much to lose and will pretty much be off the radar of the FAA. Just don't post "evidence" they can use against you online. That would be my advice.

For an existing business that is looking to integrate UAV's it's a different story. They should walk the line since they are a bigger target and have much more to lose. There is also more to consider than just the FAA. Your insurance company could potentially deny claims for operating "rouge". On that note you might want to add information about insurance.

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40 minutes ago, Keith said:

It's all relative to what you are trying to do. As a one man startup you don't have much to lose and will pretty much be off the radar of the FAA. Just don't post "evidence" they can use against you online. That would be my advice.

For an existing business that is looking to integrate UAV's it's a different story. They should walk the line since they are a bigger target and have much more to lose. There is also more to consider than just the FAA. Your insurance company could potentially deny claims for operating "rouge". On that note you might want to add information about insurance.

YES. Thank you, Keith.

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6 hours ago, jkeller808@gmail.com said:

Where do I start............You submit your 13-75 page 333 to regulation.gov and wait, and wait, and wait, and......................well 2-3 months later you have your business listed on their docket, then another two months later you wait and wait for the flag to be changed to approved so you now have  your official 333 number.  Now what.........well you have to purchase N#'s from the FAA website which is a GREAT smooth easy process and only cost $10.  Next you have to request an FAA Form 8050 duplicate copy to hand write your serial number and the N tail # that you purchased and place the hand written document into snail mail and send off to Oklahoma City, then the next wait is on.............waiting for your official aircraft registration certificate. Now that six, eight, or ten months have gone by you might be all set to start flying commercially................OH WAIT!!!!!!!  I listed my DJI Phantom 3 Pro on the original 333 request and now that 6-8 months have passed, I have upgraded to the new and improved DJI Phantom 4 aircraft. Now you are in a real pickle............you have to submit an addendum to your original 333 and wait for that entire process to take place before you are legally able to fly your P4 as part of your 333. Well I have my 333 approved, and my good ol P3 Pro approved so now what. Well you are approved with a blanket COA (certificate of authority) up to 200 feet AGL. But the customer wants an aerial survey of their entire 3,000 acre property from 400 feet AGL. Now you get to learn what a COA is, what it stands for and the next .......the waiting process to submit your request to fly in a certain area. I hope your customer is not within 5 nautical miles of an airport, or you may never get it approved!!! Next you call the air traffic control tower and advise them of your intentions, PLAD - Plane, Location, Altitude, Destination or Length of flight in our UAV world. They will want to know who the PIC (Pilot in Command) is and the cell phone to that person. They might also require you to have a two way aircraft radio on hand and advise you to tune into the local approach or tower frequency. I recommend a nice Sporty 400 radio, nice unit for around $300.  Well it has been almost a full year since you started your 333 process, purchased UAV's, purchased N Tail #'s, Registered the tail numbers, have received the airworthiness certificates and are finally ready to go fly your first job. Make sure you have copies of everything with you at all times....................thats a good start, Thanks Alan for such an awesome site for the community!!!!

Hey you nailed it, except it only took me 6 months from start to finish. Isn't government great?

I write 333s as a business and two items I make clear to my clients; include every business you can think of in your application even if you are not considering engaging in that activity, don't just say real estate but add industrial, construction, agricultural, inspections, etc., except motion picture closed-set filming (that's a whole separate can of worms requiring a very detailed motion picture and television flight operations manual/MPTOM, not my expertise)  AND list every UAV you own or are thinking about owning or even dreaming about owning.

I made both mistakes in my initial application and now am waiting for amendments to be approved.

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5 minutes ago, Uaviator53 said:

I write 333s as a business and two items I make clear to my clients; include every business you can think of in your application even if you are not considering engaging in that activity, don't just say real estate but add industrial, construction, agricultural, inspections, etc., except motion picture closed-set filming (that's a whole separate can of worms requiring a very detailed motion picture and television flight operations manual/MPTOM, not my expertise)  AND list every UAV you own or are thinking about owning or even dreaming about owning.

Agree with listing every sUAS you'd like to fly, but you don't have to list every application in acute detail to gain approval for those applications. My partners process 333 exemption petitions for clients as well and have found that asking for permission to conduct "photo / video / data capture" covers 95% of what you'd want to be able to do without having to go into detail with each specific use case.

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I also spoke to the folks at Drone Law and was told that you are essentially in the clear to operate aircraft not listed on your exemption so long as they have been approved by the FAA in other exemptions. Just send in the addendum and go ahead in operate in the mean time.

 

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Does anyone know if an Exemption 333 will be granted for not having a current pilot’s license? My SEL Pilots License is not current; I wrote my 333 Exemption request synthesizing a number of other requests, of which many asked for an exemption from having a pilot’s license. Or is it an absolute requirement to have at least a sports pilot license? As I understand the “new regulations” will not require a pilot license.

 

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The 333 exemption and having a pilot license are two separate issues. 333s are issued to an operator and it is up to the operator to hire the certificated pilot. The FAA will not exempt any operator from the pilot's license requirements, the operator cannot utilize anyone other than certificated pilots. The proposed new Part 107 will establish a new type of license, UAS operator (written exam only).

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Thanks Mr. U! That said:

  • Is the FAA or local authorities pursuing UAS pilots operating professionally? Are there any policies, i.e. whether or not to pursue and if so under what circumstances?
  • What are the penalties?
  • Are there criminal/civil penalties for “users” of video/images taken by an un-exempt pilot? For example, can a web designer who buys material from an un-exempted UAS pilot be sued or charged?

These would be critical answers for those of us who wish to “push the envelope”. James

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Too many legal questions for me. Here's the email address to the FAA UAS Integration Office.

9-AWA-AVS-333Exemptions@faa.gov  They prefer email and do reply, eventually. My last question took 2 weeks to get an answer.

I wouldn't expect an answer to  "Is the FAA or local authorities pursuing UAS pilots operating professionally? " That's like calling the local cops and asking if they are writing tickets for speeding today. :DNot going to get an answer. According to what I've read civil penalties can be as much as $25,000 per violation.

IMHO, and only my opinion...As a licensed pilot I know the FAA has very few inspectors and they are quite busy with manned aviation cases; I don't expect them to invest their time chasing UAS violations at the moment; unless the FAA receives a juicy appropriation from Congress to hire more staff to deal with UAS issues.  However, if they receive a complaint about an illegal commercial operations, who knows? They may come knocking on someone's door.

As a licensed pilot and 333 operator I am not into "pushing the envelope." In addition to any fines, The feds can revoke my pilot's license...Good luck to you.

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