Meeting the requirements to fly commercially
After the FAA announced that exemptions were granted to seven production companies, RotorDrone published two articles by aviation attorneys regarding the legal implications of this FAA action. As a commercial pilot with 20 years of flight experience, including owning and operating an FAA certified air charter company, I carefully studied the grant of exemption and found that the list of “conditions and limitations” required for unmanned aircraft in the film industry was strikingly similar to the requirements for manned air carrier operations. The following is my interpretation of these conditions, based on years of experience in conducting FAA certified passenger-carrying operations and complying with FAA regulations. I will explain the implications and the requirements necessary to be in compliance and maintain the status of a granted petition for exemption.
PRIVATE PILOT REQUIREMENT
To fly under this exemption, the Pilot In Command must possess at least a private pilot’s license. On average, it will take between 60 and 75 hours of flight training prior to taking a practical flight test. Depending on your location, the cost of this training may approach $10,000. In addition, you will need to pass a written knowledge test and obtain a third-class medical certificate. The medical requirement is a physical examination administered by an FAA-authorized aviation medical examiner.
The grant also requires that the pilot meet the currency requirements of the full-scale aircraft on his/her license. In other words, even if you received your pilot’s license many years ago and have not been flying, you must become current by meeting the requirements of a bi-annual flight review. You will need to have a certified flight instructor endorse your logbook after evaluating your pilot skills and aeronautical knowledge.
VISUAL OBSERVER
All flight operations must utilize a visual observer. The visual observer must ensure that the unmanned aircraft remains within visual line of sight at all times. The observer and pilot must be able to communicate verbally and efficiently throughout flight operations.
Also required is the development of a Flight Operations and Procedures manual that will include training procedures and tests for the pilot, the visual observer and the maintenance technician. The operations manual must include logbooks for the pilot and also for the aircraft records. Writing these manuals is a very challenging task that will require extensive knowledge of flight operations and aviation maintenance.
MANDATORY MAINTENANCE
In addition, maintenance procedures must be developed to document and maintain a record of aspects of the unmanned aircraft, including the total time in service of the airframe and all components. Complying with this requirement will be a very time-consuming and complex process. Essentially, these are the same requirements for maintaining manned aircraft. Writing these maintenance procedures is just the beginning; documenting all maintenance actions in a logbook must be done for the duration of the exemption that is two years from the date of issue.
CONCLUSION
When the FAA reviews the petition for exemption, it will look for the operator’s “proprietary” operations manual. A granted exemption is only the beginning of this process. When the FAA comes calling for an inspection (and it will), you must demonstrate that you have been in and are in compliance with all their conditions and limitations in your operating manual.
By Gus Calderon Photo by Tony Donaldson
ABOUT THE AUTHOR Gus Calderon is a commercial pilot with multi-engine and instrument ratings. He has over 3,500 hours Pilot in Command of many aircraft including corporate jets. He developed an FAA-Certified Part 135 Air Carrier Operation and wrote his own Operations Manual, Compliance Statement, and Training Manual. He has owned and supervised the maintenance of six aircraft over the past 20 years.
Large drones like the one he’s holding and larger should have special rules but not to the extent mentioned in the article.
This is a perfect example of what happens when any governmental body gets its fingers in the pie.
It is as sad as it is ridiculous.
What’s even sadder is that we pay the salary of these people to spew out the red tape that slows progress and innovation.
It sounds more like the author is trying to discourage all but the annointed from pursuing the Part 333 exemption. What is involved is painfully obvious as you write up and flesh out your application.