333 Exemption process

Discussion in 'Flight Regulations' started by MIke Magee, Jun 6, 2015.

  1. MIke Magee

    MIke Magee Active Member

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    Thanks for setting up this forum for discussion Andy.

    We are into the process of applying for an exemption for
    • Aerial Photography
    • Aerial Videography
    • Closed-set motion picture and television filming and production
    We see that the process is straight forward but have hired an aviation lawyer to process it for us. There are hundreds of applications that are filed and visible that can be used as a basis to avoid alot of work.

    It appears that the FAA is leveraging precedent to approve similar applications, and EVERYONE hits on relief from the same regs, ALL using the same general arguments:
    • 14 CFR Part 21 subpart H
    • 14 CFR 61.113
    • 14 CFR 91.7
    • 14 CFR 91.9
    • 14 CFR 91.103
    • 14 CFR 91.109
    • 14 CFR 91.119
    • 14 CFR 91.121
    • 14 CFR 91.151
    • 14 CFR 91.203
    • 14 CFR 91.405
    • 14 CFR 91.407
    • 14 CFR 91.409
    • 14 CFR 91.417
    SO, here's my question for the forum of Freefly Brothers.

    • Have you obtained an exemption? if so, what have been your experiences and advice for moving forward?
    • Do you see a reason NOT to pursue an exemption?
    • How did you prepare the critical appendixes - Aircraft Ops Manual, Flight Ops Manual and other (for instance we need to produce a Motion Picture and Television Flight Operation Manual (MPTOM) for closed set stuff)
    • Can you share these documents with board members to save time and share experience. These are seriously thought out documents and will serve to increase safety and professionalism.
    It may be that several topic threads discussing various areas such as self imposed currency and experience levels used etc.

    All of us here have decided to invest in serious gear and procedures. I hope that we can share our professionalism with each other and further set ourselves apart from the folks that are giving the industry a bad name.
     
  2. Gary Haynes

    Gary Haynes Administrator
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    And to add to Mike's question. If you used an outside company to build your application can you share who you used, were you successful and a ballpark range of costs and time to have someone else build your 333 exemption application?
     
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  3. Pablo Barrera

    Pablo Barrera Member

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    He guys,
    My company is currently going through the process. From what I see, the exemptions are taking half the amount of time to get approved. We have applied approx 2 months ago, should be getting it within another month or so. From what I see, ( I keep in touch with many aerial video services) the ones that have already received there exemptions are very busy, to the point where they essentially need to farm out work to one another. So it is definitely worth it. As for preparation we hired a great company called Aerial data systems based in Colorado. We had our exemption filed and docketed within 2 weeks of establishing contact with them. They were very professional. I cannot share these documents because it is property that we have paid a fee for and have been prepared for us. However I highly encourage you to give them a call and talk out whatever issues or questions you may have. They are very knowledgeable. Hopefully this helped a bit. Check out there web site here http://aerialdatasystems.com
     
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  4. Jonathan Ross

    Jonathan Ross Member

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    Hi Guys,

    We are in the process ourselves should be cleared inside of three weeks. If you need help getting your 333 exemption you are welcome to contact me we offer a step by step process that is tested with 25 others already approved. Cost is very reasonable and can be discussed drop me a PM if you need assistance. The list is getting longer resulting in longer wait times.

    Cheers,
    Jonathan
     
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  5. MIke Magee

    MIke Magee Active Member

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    Gary, when the first 4 or 5 of these came out, I contacted the D.C. firm that handled all of them. He said (at the time) the it was a $20K - $30K process.

    NOW, if you review the submitted and approved applications (FAA Site), you can see that many of the approved applications are so terse that they are only 7 pages of boilerplate, submitted by individuals, not lawyers. So there is a wide range of possibility. It seems that if you scour the recent approvals, AND HAVE SOME SPARE TIME to author your own, the expense is very minimal.
    -m


     
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  6. Nathan Flynn

    Nathan Flynn New Member

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    Hi All,
    We are the company Pablo referenced above: Aerial Data Systems. Our training and 333 Exemption business now operates as UAS Professionals (UASPI.com) - we wanted to keep custom manufacturing separate (ADS). We are seeing that the FAA is accelerating the process as long as you are able to "fit" into one of their familiar business buckets - which is why it's important to have a well-crafted, and proven application process. Our latest client received their 333 exemption and COA on Friday in a little over 90 days. So we are feeling very confident that we can achieve approvals in substantially less time than the FAA quoted 120 days. Let us know if you have any other questions - always happy to help. Nathan (nathan@uaspi.com)
     
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  7. Pablo Barrera

    Pablo Barrera Member

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    Hey, I wrote a comment above about aerial data systems assisting my company with the 333 process. They came through on their word and my company Xizmo Media in NYC after having operated for many years is now FAA exempt thanks to Aerial Data Systems,
     
  8. Dean Roczen

    Dean Roczen New Member

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    Greetings,
    Currently evaluating working on the 333 exemption and perusing other applications/approvals on the Federal Docket.

    One question I have is it appears that part of the application requirement is aircraft registration. FAA Form 8050-1 asks for information Im not really sure how to provide regarding my C8. Examples are "sUA Maximum Takeoff Weight", Engine Power Output, among others. Im curious how other Cinestar owners are handling this. The rest of the 333 process does not seem too difficult.

    Thanks.
     
  9. Jonathan Ross

    Jonathan Ross Member

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    Best to have someone do it for you. We have learned a lot about 333's over the past 6 months and the biggest was not doing it ourselves.

    Best of luck,
    J
     
  10. MIke Magee

    MIke Magee Active Member

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    Here is a great update for those in the 333 arena.

    • We have been holding off on our submission because we are submitting for the Alta and Inspire1. The Alta was delivered today, so the submission is imminent. I will post the submitted documents here for the benefit of others when completed.
    • I have great news to report! Mike McVay, a regular poster, Amazing photographer and great guy, got his pilot's license at about 3:30 this afternoon. He's worked very very hard to accomplish this in about a month following an immersion program. I need to CONGRATULATE Mike for his effort, commitment and achievement!
    WHY is Mike's accomplishment significant? Well, it's because, as far as I have read, EVERY 333 exemption granted REQUIRES the person on the sticks to hold a license of some type (look at all of the approvals). Even if you get a 333, if the PIC (pilot in command) is NOT a certified pilot in the FAA's eyes, the flight is illegal. We need to be very careful, and acknowledge the expense and effort side of the equation that folks like Mike have committed to so that they can represent us as a professional community.

    I got my license 30 years ago, as well as an instrument rating. I didn't do it because I knew it would be required to be legal in these UAS days. I did it because it was what I wanted to do.

    Mike did it because he knew that it was the best way to adhere strictly to the FAA guidelines and avoid legal issues with the FAA going forward. Good job Mike.

    DO YOU have a license? Add a note if you do!
     
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  11. Andy Johnson-Laird

    Andy Johnson-Laird Administrator
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    Until the FAA issues the so-called "Final Rules" derived from the NPRM and comments, anyone in the USA who flies an aircraft in the National Airspace System (NAS), other than someone who flies a model aircraft for hobby or recreation, has to have a current pilots certificate (which can be anything from a sport pilots certificate up to air transport certificate).

    That's why, even with a Section 333 Exemption, the PIC needs a pilots certificate.

    If the NPRM is to be believed, that will change when the Final Rules are issued. Then you will only need to pass an FAA-approved knowledge test every two years and have a Department of Homeland Security screening to operate an sUAV (MTOW < 55 lbs). You would not even need to take the knowledge test if you fly a micro UAV (< 4.4 lbs). In neither case would you need a Class II Airman Medical Certificate. Nor would you need to take a flight proficiency test.

    However, these are the proposed rules. Who knows how the Final Rules will look like? We should know early in 2016.

    What's not yet clear is what the insurance companies might require....in terms of flight experience, etc.

    Also it remains to be seen what the rules will be for commercial flight operations over people, or for extended visual line of sight and beyond visual line of sight.

    Andy.
     
  12. Steve Maller

    Steve Maller UAV Grief Counselor

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    Very interesting info. Thanks, folks.
     
  13. Jason Herring

    Jason Herring Member

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    If local 600 has there way you will have to be a camera op as well to operate the camera,
     
  14. MIke Magee

    MIke Magee Active Member

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    This IS very interesting stuff indeed. Thanks Andy.


    Almost lost in my message was the great job Mike did getting his certificate. Welcome to the Pilot's club Mike.

    -m
     
  15. Michael McVay

    Michael McVay Active Member

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    Thanks Mike...I'd say I was a frequent poster until I started the Pilot License process - and now I can be again! It was a lot of time and effort to learn to fly.

    I had told my wife about a new problem we have: I had started this process to fulfill the 333 requirement of being a pilot, but since then I have really come to love flying! And, my 5 and 7 year old kids had me make them pancakes for breakfast - in the shape of airplanes and foggles. I think we are all addicted.

    Thanks again for the comment...
     
  16. MIke Magee

    MIke Magee Active Member

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    Mike, The expenses of the average aviation addiction makes buying a boat look like a wise investment.
    Congrats.

    (promise not to dilute this thread any longer.)

     
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  17. Andy Johnson-Laird

    Andy Johnson-Laird Administrator
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    The only difference is whether you throw your money up towards the sky or down into the water.

    Andy.
     
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  18. Dave King

    Dave King Well-Known Member

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    I have been weighing the options of whether or not to get my pilot license and after talking to my brain trust I think its the right thing to do moving forward as a professional even if the FAA does not require it next year or when they finally put rules in place which is looking more like 2035 at this point.
     
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  19. Gary Haynes

    Gary Haynes Administrator
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    As a long time ago flight instructor my advice if you want to get a license would be to get a sport license and do a total immersion course to reduce the overall cost. Michael took the right path, just get it done. A full private pilot license is 40 flight hours. But to do it in that time you would need to be flying multiple times per week if not more.

    Good comparison at http://www.aopa.org/letsgoflying/ready/time/options.html

    Mike McVay which license type did you get?

    And Andy's post about the proposed testing in the NPRM draft is interesting. It sounds like if they go that route you will need to retest every 2 years regardless if you have a current other type of pilot certificate. Which is strange since the current regulations have you do a bi-annual flight review (every 2 years) and you can do that in any aircraft type applicable for your license. So in an extreme case a pilot flying 777's could do his bi-annual in a hot air balloon and then be able to fly the 777 for another 2 years.
     
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  20. Dave King

    Dave King Well-Known Member

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    HI Gary

    Thanks for the reply. That was very helpful.
     

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