A very good article in the Unmanned Systems News section of the AUVSI web site lays out a strategy for requesting a Section 333 exemption for commercial operation of a UAV system. (How to Fly Commercially: A Complete Guide for Section 333 Exemptions by Scott Kesselman)
It should be noted that Section #333 exemptions are for a duration, usually about two years, and most likely be replaced by licensing when that becomes available. There have been continued hints that a preliminary set of proposed regulations could appear as soon as this November, along with the standard 60 day comment period. After that, with the potential for an extension of the comment period, it’s anybody’s guess how long it will take for finalization, but my guess, or hope, is that by perhaps March or April we may see the door being opened for applications, along with a revised “ground school” FAA written test with the new requirements and standards.
Change is coming, as indicated by an email sent by the FAA last month to “current government, university and organization operators of unmanned aircraft” which outlined guidelines for registration and marking the systems. In short, it means “N” numbers will now be required so new applicants for COAs or Section #333 Exemptions will need to add that step to the process.
“UAS, other than those owned by the armed forces, intended to operate under a new COA [certificate of authorization] must be registered and marked prior to COA application.” Applicants must now enter the aircraft registration number, or N number, in COA online.
“Additionally, commercial UAS currently operating under a COA must be registered and marked within 90 days or risk suspension. Users must update their monthly operational reports with the registration number.
Markings must be painted on the aircraft or affixed with a similar degree of permanence. Any UAS with size or shape limitations for marking may seek approval for alternative marking and must attach an approval letter for any such marking to the application in the ‘Aircraft Registration’ field.
“N” numbers and aircraft registrations will be required in the licensing or certification/permitting process.
But the “800 pound gorilla in the room” is aircraft certification. If the FAA test centers are testing DJI, AR Drone or any of the more common or popular UAVs, there hasn’t been any mention of it. Actually what has been mentioned is that official test centers may not knowing what the FAA wants them to be testing. That being said, there have been several popular models included Section 333 approvals. But then, that’s no guarantee of anything. My inquiries to DJI remain unanswered.
If you are a movie production company or a public safety entity (police, fire, emergency response), by all means jump into the COA process. For potential commercial UAV/UAS operators who would prefer to wait for the certification process to be finalized (and public begging is not your style) you will want to take the logical steps in preparation.
By now we can pretty much gather what the requirements could include:
- Pass an FAA test – Prepare by taking an online “ground school” course like that provided by Gold Seal and sample or one of several free study courses. Sample test questions and study materials can found at Sporty’s Study Buddy (also available for mobile media). There are many places to take the test and the cost can range from $150 at a local technical school to $300 at a local flight school. The private pilot’s test (PAR) is overkill but it should cover the initial FAA test requirements. Currently licensed pilots will be ahead of the game, but may need to obtain an endorsement for UAS and maintain specific Recency of Experience requirements.
- Insurance coverage. One good source is TransportRisk.com As we have mentioned before, it is a good idea to check into the online UAV safety and operations course provided by Unmanned Experts which may be used to qualify for better rates.
- Log your flying time and flights. Back in March the FAA published a Notice (N 8900.258) recommending that potential applicants should be logging their flight time experience. From that suggestion and based on the pattern of existing FAA licensing it can safely be assumed that there will be some requirement for a specific amount of flying experience for UAS pilot certification. Such a requirement would be fully consistent with all other pilot certifications and it is a logical and reasonable requirement for unmanned aircraft (UAS) operation. My hope-slash-guess is that the number of hours required would probably fall in the range of 20 to 25 hours which amounts to about 80 to 100 flights. Eventually there will be a requirement to demonstrate practical flying skills for a Certified Flight Instructor (CFI). Several UAV Log apps and such can be found here, here, here and here. The common thread in FAA approvals is that the pilot in command will need 200 flight cycles and 25 hours of UAS (rotorcraft) experience and 5 hours with the aircraft to be used.
- Reserve an “N” number for each aircraft. The process is simplem easy and inexpensive. Start here.
- Aircraft Registration: The next step after reserving the N number will be to apply that number to an aircraft registration by requesting an aircraft registration form (by mail only) from the FAA. That would be Form AC 8050-1.
(Ref: Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate ; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft Registration Application as provided for in §47.31(c))
- Develop formal safety and maintenance procedures, including checklists for pre-flight, inflight and post flight. Checklists are SOP for all pilots and always a good idea. That means make a safety notebook and check list form and use them. It’s probably a good idea to carry along a first aid kit, spare props, safety zone marking cones, perhaps a helmet and even an aircraft radio to monitor local activity.
- Practice your flying skills. Whether you intend to fly fixed-wing or multi-rotor, the “use it or lose it” phrase applies. Licensed pilots are required to stay current and to practice specific tasks at specified intervals, like touch-and-go landings. It’s a good idea to practice your UAV skills at least every 90 days. Check out YouTube for some suggestions, including something called “walking the dog” (flying at low level just ahead of yourself while walking) for multi-rotors, as well as “S”, “Box” and “Circle” patterns for both fixed wing and rotories. If you can find videos with Colin Quinn you will find them among the best for DJI instruction. It goes without saying that the most critical skills are those required for safe take-offs and landings. Learn how to deal with ground-effect, prop turbulence and crosswinds.
- Purchase Sectional Aeronautical Charts for your intended flying area and learn how to read them. Be aware of airports, heliports, congested population areas, restricted areas and other obstacles. The charts are low cost and can be purchased online. They are also available as mobile apps by subscription. Keep in mind that the charts are revised and updated every six months.
- Medical Certificate – This one just won’t go away and keeps popping up in reference to future requirements for UAS operators. As currently written, the rules require that aviation medical certificates can only be obtained from an FAA Medical Examiner.
Commercial UAV operation is already a reality in Australia, Japan and the United Kingdom. Worldwide “Unmanned Aircraft” related business already accounts for $2.5 billion this year and that is expected to increase by 15% to 20% even if the FAA does not open the US to commercial operation. Before you start wishing for the FAA to copy Australia, note that the process there is complex and expensive. There are signs that China, the home of DJI, may be the next to open the skies to UAVs.
Honda’s ASIMO in the last century was only a hint of what was to come. With undersea ROVs (Remote Operated Vehicles), development of autonomous automobiles (putting the Auto in “Automobile), and all sorts of unmanned aircraft for an ever expanding list of uses, from the weather bureau and insurance companies investigating storm damage to dozens of other uses we haven’t heard of yet, it can be said that we have now entered into the Age of Robotics.
Oh, and for those who may not think safety is a big issue with flying UAVs, may I present exhibit one:
Always fly safe and carry a first aid kit when you fly.