333 Exemption process

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

  1. James Adkins

    James Adkins Member

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    I can't fathom why any truly experienced pilot would crash a multi from being disoriented. If the rig doesn't respond as expected you just stop giving commands if flying in GPS. Short of a malfunction, you have time to sort it out without pushing sticks the wrong way.

    RC pilots come in a million flavors. It sounds like you haven't flown with the type I am referring to yet. There aren't that many of them out there. Over the last 40 years I have lost count of how many people I have taught to fly RC. Some were immediate prodigies and others were forced to admit they couldn't afford all the crashes.

    Many doing drone filming now don't understand that the true pioneers in this arena flew helis 100% manually with no flight stabilization. Their flying skills are off the charts. Also tossing about doing stunts at the local AMA field isn't helpful for flying on a movie set.
     
  2. Shaun Stanton

    Shaun Stanton Active Member

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    That will be a question that will plague aviation in general until the end of time. Why does a combined 35,000 hours of flight experience in a cockpit crash an Asiana 777 at San Francisco? There are different behaviors in flying and there are many subjects in human factors where you change a few variables and that can cause human factors issues. There are probably several PHD thesis being done in our industry as we speak to study this.

    In the above case he was nose out trying to bring it back got a spacial disorientation and thought that the copter was moving away from him. He racked the pitch stick all the way back causing it to come back at a high rate of speed while rapidly descending and it crashed. This is a situation that can plague multi-rotor pilots. At certain angles and distances the copter looks the same pitching forward as it is does pitching back. I have experienced this illusion before. In my case I did not panic, I trusted that my sticks did reverse, and went immediately to see what pitch ladder was doing and determine that it was coming back towards me by seeing the distance meter. I can see how it can happen to someone not used to flying an equidistant flying spider in the air.

    There are a lot issues on why someone may do something irrational in the air.

    That's possible. I have flown with some who can rack a helicopter all over the sky.

    That's true there are those that don't understand that. I get that it was originally done by people strapping gimbals to trad helis, like the owner of Freefly. In some cases it still is. At the same not having flown trad helis does not mean one can't figure out how to fly these systems to meet a client's needs and do it safely. Obviously a robust training regime would help someone get there sooner. Who is qualified to do that training? That needs to be figured out.

    No argument there, one skill set does not translate to another. Just like on the camera side some skilled camera guys don't do aerial cam oping that well.
     
  3. MIke Magee

    MIke Magee Active Member

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    Has anyone taken a peek at some of the most recent approved exemptions at The FAA Approval list?

    As an example, no longer is your exemption ties to specific aircraft. There's a list with almost 1,000 of them and you appear to be able to fly any of them - "The List"

    There seems to be a totally different list of conditions and requirements. Most were previously unspoken and are now very specific. Closed set seems to have been merged in, along with FSDO POA requirements.


    Wow, it sure looks different than it did a few weeks ago. Could someone who has a 333 from a couple months ago opine on whether the stock ones coming out now are more restrictive?

    Or, is it just me?

    Best,m
     
  4. Dave King

    Dave King Well-Known Member

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    Yes they have changed. Mine looks completely different. Mine mentions nothing about heliports for example which begs the question what are you to follow? I would imagine that you follow the 333 exemption that you have been given.
     
  5. Andy Johnson-Laird

    Andy Johnson-Laird Administrator
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    The Commonwealth Edison 333 grant has some interesting provisions:

    21) The PIC is prohibited from beginning a UAS flight unless (considering wind and​
    forecast weather conditions) there is enough power to fly at normal cruising speed to​
    the intended landing pint and land the UA with at least 20% battery power remaining.​

    Glad to see the FAA has agreed to the idea of marking the intended landing with a pint of something....hopefully beer. :rolleyes:
    (NOTE: The quoted text was cut and pasted from the FAA document. You can't make this stuff up.)

    That 20% power remaining is conservative. I'm sure we all do that. We do, right? Don't we? :)

    18) The UA may not be operated less than 500 feet below or less than 2,000 feet​
    horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.​

    That's an interesting altitude limitation in that it does not reference ground level. I certainly hope the PIC's that fly can actually measure 500 feet vertically below a cloud and 2,000 feet horizontally. I've not met a pilot who can do that yet and I used to do cloud flying in a sailplane (it is permitted in the UK provided that you're not on an airway and you call on a special frequency used for sailplane pilots to announce their entry into the cloud, "November Mike, 2,000 feet over Basingstoke, anyone else in this cloud?" :) )

    Joking aside, cloud-base in Nevada around, say, Minden-Tahoe, can sometimes be at 10,000 AGL or more (been there even with full air-brakes open). Could be interesting.

    And then there's the old chestnut from the first Section 333 exemption grant:

    19) If the UAS loses communications or loses its GPS signal, the UA must return to a​
    pre-determined location within the private or controlled-access property and land or​
    be recovered in accordance with the operating documents.​

    By "communications" I infer that means "command and control" (aka C2 link) and not telemetry.

    But if the UAS loses its GPS signal I wonder how it could ever return to a predetermined location? The only other option is for it to be flown manually -- but note that when flown manually, the mission must be aborted so that the aircraft can "be recovered." Hmmm.

    I'm sure there are other interesting variations, but it appears that the FAA is not sending out a "cookie-cutter" exemption grants but is responding to each petitioner's requests (but maybe not granting each of them).

    Andy.
     
  6. Jose Luis Ocejo

    Jose Luis Ocejo Active Member

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    Guys how long is it really taking to get an answer from the FFA I mailed mine at the beginning of September of 2015 it was posted in the FAA webpage mid november 2015 and here I am getting closer to mid march and nothing I guess is 120 days from when they post in the webpage any thoughts?
     
  7. Howard Dapp

    Howard Dapp Active Member

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    You should be good this month. Took ours exactly 6 months.
     
  8. MIke Magee

    MIke Magee Active Member

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    9/2/15 submission, still waiting, expecting 4/6 or so based on what we are seeing. Do you have closed set?
    Regards,

    M


     
  9. Jose Luis Ocejo

    Jose Luis Ocejo Active Member

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    Yes I did apply for close set, thanks guys knowing that indeed takes that long helps to tame the waiting
     
  10. Sam Fleishman

    Sam Fleishman Member

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    I read an FAA notice yesterday that said the blanket COA does not cover class A,B,C,D airspace and a "standard COA" is needed. Of all the blanket COAs and 333s ive read there is no mention of this. How can anyone operate a business when a client calls for a simple task for an episodic or tv commercial and you have to tell them it's going to be 60-90 days for a COA? Keep in mind most tv commercials do the location scout 2 days prior to shooting. There isn't enough time. They need to make this process acomodate the industry.
    image.png

    On this map of LA a great deal of it is Class B,C,D airspace. This doesn't include airports or heliports.
     
  11. Shaun Stanton

    Shaun Stanton Active Member

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    If you look close at the area you want to fly you look like you are not anywhere near an airspace. Here is the thing about class C. Class C you would need it always 5 and less because of the 5 mile rule. Outside 5 you are under class C but not in it. So therefore the Blanket COA applies. This is the same for many class D airports. Most class D airports have a 4 to 5 NM ring. Class B gets trickier, becuase it is tailored for specific airports and is not always a ring. The thing to look for on a Class B chart is where it is class B at the surface. If you are under the the class be airspace you are not in it. Class B does complicate the matter a bit because sometimes it has Class C and D airports underneath and even inside the Class B ring. This is why it may take longer I have found that if the airspace is not complicated it does not take 60 days to get. If you are inside LAX and are in vicinity of Class C and D airports collocated in the C ring then they have to do more coordination. Key thing is to stay ahead of the process with all involved.
     
  12. Dave King

    Dave King Well-Known Member

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    Go by the sectional map and if your 333 doesn't say anything about heliports don't worry about that part of it. You will need to worry about the 5 NM range of the airspace. Yes you are correct a COA will take about 2-3 months and there's nothing you can do about it and I have serious doubts they would allow any exceptions to class B in Los Angeles which again is the major heart of the city. The official rules (when released) will not have as strict and of a far radius. It will be more like what planes have to follow in class B. We should be able to skirt under the upper tiers the further the site is away from the airport.
     
  13. Shaun Stanton

    Shaun Stanton Active Member

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    Yup my 333 only says public use airports and heliports. I have a COA to work in downtown ABQ I am inside 2 NM of two hospital pads. It never once came up in any conversation to get coordination with them, as they are private vs public.
     
  14. Alex Fuller

    Alex Fuller Member

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    A
    Do you have a PDF of this List? The link seems to be down and we need it since we are about to amend our 333. Should have downloaded it before, d'oh!
     
  15. MIke Magee

    MIke Magee Active Member

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  16. Shaun Stanton

    Shaun Stanton Active Member

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    I am guessing that we will need our 333's amended to reflect the list. Luckily, I put down the majority of commercially available systems that are most likely the ones that I would use already. But having all of the ones on the list available may provide to be useful.
     
  17. MIke Magee

    MIke Magee Active Member

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    Specially since they will continue adding latest models to this. It appears that there have been ~ 200 added since the rev 2 weeks ago.


     
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  18. Shaun Stanton

    Shaun Stanton Active Member

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    Hopefully this new exemption does not cause confusion in the industry.

    The interesting thing that I see now is that they include closed set filming is in the body of listed acceptable activities. My exemption grants us a weird blanket clause of aerial data gathering, which they defined as using the aircraft for any purposes to gather data including image and video gathering and other sensory data. Then I like everyone else with the old exemption has the permission to conduct closed set filming in paragraph 2. Now this might become confusing as people who do not have the words not permitting them may be able to get on set now to an unbeknownst producer.

    I do like that they move the Pilot Licence Requirement up a bit.

    It looks like in the previous iteration you could follow the aircraft on a boat but no other moving vehicle. Now following it from any vehicle is prohibited.

    They used to make the VO as an as-needed option. The VO is not allowed to do any other ancillary duty. The question here is does this only pertain to the aircraft in flight? My VO does other duties commensurate with a 2nd AC except when in flight. Now a VO is mandatory. Which is fine because I bring in a 1st and a 2nd AC. The 2nd who is my VO was a former AC for Freefly Cinema I use him as the VO.

    It looks like now you have to submit a POA for every flight regardless if it is to be used on set. This is probably so the FAA can track who is flying and when to discern incursions. As two days after I flew on set. A guy flying near my COA area flew over Albuquerque Intl at night. I got a call from the FSDO asking if it was us:eek:

    It will be interesting on how they proceed in the next few months. I wonder if we all end up with amended 333's at some point.
     
  19. Alex Fuller

    Alex Fuller Member

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  20. MIke Magee

    MIke Magee Active Member

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