Applying for FAA permission

[Robert Benda]

Is anyone doing this?

I've begun reading through the materials and will be applying so we can get started using the footage in our work.

For those who are thinking about it: Business Users | Know Before You Fly

You need a Section 333 exemption. Here is the material you'd need to apply: Guidelines for Submitting a Petition for Exemption

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My other challenge will be insurance. I'll be forming an LLC expressly for this new venture.
Anyone know of specific providers?

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As for actual clients, I live around a lot of farms. Field inspections and maybe some industrial work of towers, roofs, grain elevators. Aerial photography/video, of course.

[Chris Medico]

I suggest everyone applying for an exemption please post here their answer to this question from the FAAs checklist:

How your request (for exemption) would benefit the public as a whole?

That is in line with one of the questions my wife was asked during an immigration interview - Are you here to overthrow the government of the United States?

[Jim Michael]

You can read other folks' applications on the FAA website for examples.

[Robert Benda]

Good notes. Looks like this exemption still requires a pilot's license (airman certificate) and it specifically mentions that the exemption doesn;t get you around that.

If you don't have one, the fastest (sport pilot) requires 20 hours of flight time. My local instructor bills at $40 an hour (+plane/fuel costs). Though the petition I read through mentioned a private pilot license, so its not clear if a sport license would be OK.

Section 333 does not provide flexibility for the statutory requirement to hold an airman
certificate under § 44711. Therefore the PIC, who has final authority and responsibility for the
operation and safety of the UAS flight, must possess the appropriate airman certificate as
prescribed by 14 CFR part 61 for the proposed operation and the appropriate medical certificate
as prescribed by 14 CFR part 67

[Chris Medico]

A sport license isn't going to be accepted. There is no medical required for a sport license. You are allowed to use your drivers license to establish medical fitness. A full private is required with its minimum 40hrs seat time.

[Jim Michael]

Not only a pilot certificate, but also substantial stick time, e.g.

"The operator may not permit any PIC to operate unless the PIC meets the operator’s
qualification criteria (400 hours PIC experience, 100 hours of total time as a UAS rotorcraft
pilot and at least 20 hours logged as a UAS pilot with a similar UAS type, 5 hours in the
make and model UAS authorized under this exemption), training requirements, and currency
requirements (10 take-offs and 10 landings in the preceding 30 days). "


Better spend a lot of time flying & logging that time while you're waiting for your exemption approval.

[Ed Roo]

As it was told to me...

FAR Part 61 tells you what you have to know to get your pilot's license

FAR Part 91 tells you what you have to do to keep your pilot's license.

You need to take an approved ground school and be signed off by an certified flight instructor that you are ready to take the written test.

You must complete a minimum of 40 hours of flight instruction. (I got my license 35 years ago, so I don't remember how many hours of dual/solo/simulator are required.) I should look it up. :-)

[Tim Paynter]

This is an outrageous burden on the public.

Here is a well drafted petition. Big news organizations have the budget to hire expensive lawyers to meet the requirements. If you are endlessly wealthy, then you have your hands full with more paperwork and standards to meet.

We will soon see the drone industry bypass the U.S. as other countries find a less obtrusive way for this industry to move ahead.

file:///C:/Users/Precision/Downloads/Travis_Lee_Berry_-_Exemption_Rulemaking.pdf

[Robert Benda]

Don't worry, Tim, they're working on it .A simple certification, renewable every 2 years, costing $300(?) will be the new standard. Basically, a UAS pilot license for under 55lbs.

Looking at the public docket, the comments on the new, less strict, rules closes April 24th. How long until they're in effect, who knows.

[Chuck Spaulding]

You should check out, and sign up at http://www.acuas.org, there are links to the 333 process, explanations of the current NPRM and other drone related issues.

The FAA's NPRM is far less restrictive than anyone anticipated and I believe there are still less than 600 comments. many of which are people complaining there shouldn't be any regulations at all??, many that support the NPRM and a few well presented arguments for things like flying beyond line of sight etc. So its not likely that weeding out the nut jobs will take that long.

After the 60 day public period the FAA has 30 days to respond. I think the fastest this process could be accomplished was 120 days from the posting of the NPRM for public comment.

The FAA did a fantastic job of not bending to the pressure of large DoD contractors and lobbyists to draft an NPRM that doesn't appear to be onerous on small businesses and provides a great foundation for allowing commercial sUAS. The 333 exemptions will only be necessary for people who can't comply with the new regulations. If I were Amazon I'd be pretty upset with the lobbyists who represented them...

The fact that there are so few comments about the NPRM means that the vast majority of people who complained about the FAA are hypocrites, they don't understand what the NPRM means, or the majority of people agree with the NPRM.

[Tim Paynter]

I like the part about the aircraft having to be registered and marked, maybe with a D number instead of the traditional N number. D=Drone. Not really, it will surely be an N number.

I can imagine the boys at the FAA with their binocs trying to read the number of the craft. Here is what they say about markings:

"Aircraft markings required (same requirements that apply to all other aircraft). If aircraft is too small to
display markings in standard size, then the aircraft simply needs to display markings in the largest
practicable manner."

Here is a link to the proposed Rule: http://www.faa.gov/regulations_polic..._signature.pdf

I have had a few careers in my life and one of them was in aviation. Most of the FAA boys are pretty good, but not all of them. One experience was so bad I won't even repeat it here, as many would find it difficult to believe and others would just shake their heads. Maybe, though, Chuck, those who complained about the FAA have some foundation...

[Roger Keay]

Originally Posted by Robert Benda

...
My other challenge will be insurance. I'll be forming an LLC expressly for this new venture.
Anyone know of specific providers?
...

Getting permission to operate will be the easy part. The hard part will start when a few commercially operated drones drop out of the sky for whatever reason and third parties experience property damage or personal injury. A 50 pound drone dropping 400 feet could do serious damage. Who will sell insurance and what will it cost? What pilot qualifications will insurance companies require?

[Tim Paynter]

If you can get insurance, surely they will accept FAA certification. They call it "ground school" for pilots for a reason. This is not a driver's license exam, it will be challenging enough.

If drone insurance is like normal aviation insurance, "PIC" time will be critical. Those with more pilot in command time and zero accidents or incidents (a favorite FAA term) will surely get a better price.

The "not flying above a crowd" requirement will surely be interesting. What is a "crowd"? 2 people? That lets most wedding videographers out. Those planning to "skirt" the rules will soon find how inventive regulators can be in applying rules to situations that were not originally contemplated when the law was passed. (law=rule) here.

[Jim Michael]

The catch all is FAR 91.13 careless or reckless operation, sort of a wild card they can play. Re the insurance PIC time I wouldn't be at all surprised at a requirement for something like 500 hours including 100 in make & model for commercial ops.

[Robert Benda]

I already ordered a flight log to pair with ours in anticipation of flight hour questions.

The distance from people rule pairs nicely with concerns over noise and distraction. I thought the weddings will be restricted but creativity could be rewarded.

For instance, using the drone to dolly in or out, paired with an ascent or descent, at appropriate distance (Hello, 4K GoPro!).

Option 1: There is an outdoor venue I'm picturing, the drone could follow the bride on her walk to the ceremony, until X number of meters away, then descend, camera still on her, until at eye level, as she walks the aisle.

Option : During the recessional at a church, the B&G burst out of the door, camera at eye level, then it dollies out, then up and away (the new DJI had an example in its announcement video).