Recent Exemption Approvals Provide Some Clues To Changes

Conditions and restrictions appear to be changing as the pace of approvals for Section #333 Exemptions increases. Noted in recent approvals granted to HUVR Data and Cinedrones is an indication of a broadening of the pilot/operator requirements to include acceptance of “recreational or sport pilot” certificates.  The requirements for COA limitations are still there, but even so some flexibility is emerging there as well.

Another item of interest is the fact that while the petition for HUVR Data, LLC was filed by an attorney, the submission for Cinedrones (Orlando, FL) was prepared by the owner, Mike Fortin.  That is a welcome development for those of us with tighter budgets.

The pilot/operator requirements listed in these two approvals were similar:


Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational or sport pilot certificate The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license…   The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.


…airline transport,private, recreational or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license

Terms of the grant to HUVR Data included some specific limitations:

Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:

Though drawn from some of the same master list of test questions, the depth of knowledge required to pass the FAA’s sport pilot (SPA) written test (40 questions) is quite a bit less than that necessary for a private certificate. Preparation for the Sport or Recreational Pilot FAA written test presents much less of a burden for prospective UAV operators.

Similarly, a current and valid U.S. driver’s license is all that is required to meet the medical requirements to exercise sport pilot privileges. Under the NPRM the proposed rules would not require a small UAS operator or visual observer to hold an airman medical certificate. The recent rulings are consistent with the pending NPRM.  It appears that UAV operators have one less obstacle.

There were been less than 100 Section #333 approvals as of April, as indicated by the list  at the FAA’s web site.  For these two selected examples (above) granted April 1, 2015, the filing date for HUVR Data, LLC was November 7, 2014 and the petition for Cinedrone was filed October 9th.  Compare that time span with the initial grant for Vortex Aerial which was placed May 27th , 2014 and granted September 25th.  Still about six months. But with the swarm of hundreds of new petitions, even with the ability for “bulk” approvals, it will be next to impossible for the FAA to maintain that six month gap. It is entirely possible that some of those submitted now could still be waiting for review when the new rules are finalized.

Online Ground Schools and Test Resources:
NOTE: You will be required to provide an FAR Part 61.105 Test Endorsement for the SPECIFIC FAA test you need to pass.  An endorsement for the Private Pilot test will be accepted for the Sport test.  You could also contact a local flight school CFI.

Gold Online (Does not include SPA test prep at this time)

Unmanned (In association with Gold Seal) Contact for specific details

Dauntless Online (Includes SPA prep)

King DVD (Includes SPA test prep)

Note: To sit for the written test you must have an original signed endorsement from a training source or local CFI. PDF endorsements are no longer accepted.

In addition to the various ground schools there are many other learning resources available, including free sample tests.

Sporty’s (Includes SPA)

Exams for

4VFR Practice

Private Written Test Audio

My Pilot

Testing center information can be found online. Other learning resources on specific topics (eg., weather, charts, aerodynamics) may be found on YouTube.