The FAA makes it very plain:
“All UAS operations for commercial or business purposes are subject to FAA regulation. At a minimum, any such flights require a certified aircraft and a certificated pilot. (www.faa.gov/news/updates/?newsId=76381) ”
In order to be approved for a COA under Section #333 Exemptions, a public COA or later on when the FAA is licensing UAV operators, there is a requirement to have a registered aircraft with an N number. Reserving the N number is simple enough ($10 and an online form) There have been a small number that have been successful in registering DJI products (see list below) with the FAA, and registering aircraft has been a stipulation in the section 333 exemptions that have been granted, but sometime around December 2014, something changed at the FAA’s Aircraft Registration Branch in Oklahoma.
This is a list of DJI products that have been registered with the FAA, marked as “amateur built”:
- N417RS Phantom 2 Vision+
- N531CH DJI SW 1000
- N531VA DJI SW 1000
- N714UL DJI Phantom 2 Ultimate
- N5318Z DJI FC40
- N30MV DJI Phantom 1 (Bill Edwards, Tampa – www.MicroDroneVision.com)
All of these are DJI products, some just like mine, had been safety accepted into the warm arms of the FAA and rewarded with registration status. The records at the registration section of the FAA also show 9 other DJI products, assigned various “MFR” numbers, but without any N numbers, possibly stuck in a kind of “limbo”. Two on the list could have been mine.
But, of course, DJI products are not “amateur built”: the come out of a box from China, most “ready to fly”, not “amateur built”, and suddenly in the last week or so some genius at the FAA registration office in Oklahoma had a better idea…. Suddenly, anyone attempting to register a DJI product will receive a response from the Registration Branch stating that “According to our research, DJI manufacturer [sic] Phantom 2 Vision, DJI is a company in China” and as such:
“Submit a statement from the official having jurisdiction over the national aircraft registry of China that the aircraft has never been registered or that registration has ended or is invalid. The statement must show the official’s name and title, and must describe by manufacturer, model and serial number”
(Yeah, I’ll get right on that.)
I then decided (unwisely) to work the other end of this box of silly-putty: at DJI in California. After a half hour or more on hold at DJI/USA at the only extension that is not a recording, the “helpful” suggestion was to call the “home office” ….all the way over in China. Not having an English/Chinese dictionary I decided that was not a reasonably logical path to pursue.
Then I received a “survey” email from DJI about my “tech support experience”, which turned out to be the ticket to making direct email contact with DJI/China. I filled in the form stating that I was NOT AT ALL “happy”, and I actually got a response from DJI in Shenzhen, China. I informed them of the new FAA “requirement” and was assured that would not be possible. (Tell me something I didn’t know) As a possible compromise I suggested they might provide a letter from anybody at DJI, simply stating that DJI doesn’t sell “used” (previously registered) products to U.S. dealers, …to see if that might satisfy the FAA. That shouldn’t be so hard, right? Unfortunately, something got lost in the translation and DJI responded by offering some kind of import/export declaration form. …and again, I requested a simple letter to no avail.
I received a call from the FAA registry office in Oklahoma suggesting that I could respond with a letter stating that I have not been able to obtain the requested documentation from the Chinese government. That was, in fact true. I had tried contacting the Chinese Embassy, with absolutely no response at all.
Another “priority mail” back to the FAA in Oklahoma with my letter to the FAA stating the obvious….
FAA/Registration Oklahoma called to say they can now accept a U.S. retail invoice or Purchase Order in lieu of the previous requirement for documentation from the foreign (Chinese) government.
Success! A call from the FAA registration office confirmed that registration of our two aircraft has been approved. N741TT and N742TT are now registered aircraft. Persistence pays: Mission accomplished.
The “secret” appears to have been to show “DJI Innovations” as the manufacturer rather than “DJI”, although DJI Innovations is apparently now DJI North America. The other solution was to fill in the line for “serial number and model” of the motors as “no model, no serial number” (EXACTLY that way). The type of aircraft is “Electric Rotorcraft”. Anything other than these entries could send the application into a bureaucratic tail spin.