FAA 333 Approved, But are you Complying?
FAA APPROVED…BUT are you compliant?
We keep seeing more companies taking to the web to proclaim they are “FAA APPROVED” but what does that actually mean? The problem I see is that while more and more are getting their approval from the FAA, they are failing miserably at complying or not even trying at all to comply with the special conditions of their COA’s (Certificate of Authorization).
A major misconception with having a COA or flying under the 200ft “Blanket COA” doesn’t mean that you can fly anytime, anywhere with whoever you want. There are certain things that need to be done.
For my company, we are approved for Closed Set Filming for TV & Motion Picture as well as Aerial Data Collection. With our COA, there are a few extra manuals that we need to have with us whenever we fly. Not all COA’s are the same unless we are talking about categories, then they are the same within your specific industry.
1. You need to be a pilot or have a pilot fly for you. If you don’t personally or can’t meet this by hiring a person to fly your aerial system…stop here since you simply don’t qualify.
2. Report all flights to the FAA, here is the actual requirement below.
1. Documentation of all operations associated with UAS activities is required regardless of the airspace in which the UAS operates. NOTE: Negative (zero flights) reports are required.
2. The operator must submit the following information through mailto:9-AJV-115-UASOrganization@faa.gov on a monthly basis:
a. Name of Operator, Exemption number and Aircraft registration number
b. UAS type and model
c. All operating locations, to include location city/name and latitude/longitude
d. Number of flights (per location, per aircraft)
e. Total aircraft operational hours
f. Takeoff or Landing damage
g. Equipment malfunctions. Reportable malfunctions include, but are not limited to the following:
(1) On-board flight control system
(2) Navigation system
(3) Powerplant failure in flight
(4) Fuel system failure
(5) Electrical system failure
(6) Control station failure
3. The number and duration of lost link events (control, performance and health monitoring, or communications) per UA per flight.”
3. File a NOTAM when you fly (24-72hrs) in advance but nothing less or more. (We’ve had to file a NOTAM for simply flying 10ft AGL over a pool for a shot)
4. Have all of your FAA documents, manuals, COA, Exemption, Pilots License, Medical Certificate, Aircraft Registration and EVERY OTHER required piece of information as stated in your COA.
5. File and have approved your POA (Plan of Action) if required in your area and COA. (If required by your COA)
6. Request a special COA if flying within 5/3/2 Nautical Miles of an Airport or Helipad.
The above are just a few of the basic things that you need to do, if you can’t or don’t meet any of them; While you may be “FAA APPROVED” on paper you do not meet the requirements to fly “legally” according to the Exemption and COA that you have requested from the FAA.
Just a bit of info to help you out and give you some insight as to what it takes to have and maintain your 333. We are all looking for an easier solution but at this point in time this is what we have to work with as an industry.
If you are considering or even have a 333 presently you really need to rethink what you are or will be doing and if you can’t comply don’t waste your time, money or energy since in reality you will still be flying “rouge” except if you hold a 333 and don’t comply you can easily have it revoked in an FAA Enforcement Action.
Any questions, don’t be afraid to ask here or even consult with your local FAA FSDO to get more information.