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Posted by on Mar 18, 2016

Three Recent Changes to 333 Exemption Amendments

The FAA started posting amendments on 3/7/2016 which are different from what the FAA has been previously doing. In the past, the FAA was granting amendments to petitions to add aircraft or to add on closed-set TV/movie filming. This created a super backlog because many of the petitioners were repeats.

The granted amendments specifically incorporate by referencing a large list (“List of Approved Unmanned Aerial Systems”) of aircraft that have been approved in other exemptions.  There is a total of 1120 aircraft in the list. Some drones you would expect to be in there are NOT (Inspire 1 Pro & Phantom 4), while other drones you would NOT expect to be in there are listed (Inspire 2).

What does this mean for businesses with a petition pending? 

This is great news for individuals with pending petitions because this means the processing times will start to DECREASE.

What does this mean for those who already have exemptions? 

Unfortunately, the amendments are being given out ONLY for those that asked for the amendments, and it is not being retroactively applied to everyone. This means you will have to petition for amendment to add this exemption. This will cause a temporary surge in amendments while at the same time cleaning out the petitions for amendment already pending.

The amendment also clarified how operators are to log their flight time. It says, “PIC qualification flight hours and currency may be logged in a manner consistent with 14 CFR § 61.51(b), however UAS pilots must not log this time in the same columns or categories as time accrued during manned flight. UAS flight time must not be recorded as part of total time.” This means it is wise to keep a separate logbook for your drone flight time. Fortunately, there is a drone logbook that I created that is COA, 333, and FAR compliant to help drone operators meet this need. http://www.amazon.com/Drone-Operators-Logbook-Jonathan-Rupprecht/dp/1519653603

Another interesting note is that it will allow drone operators to fly with drones registered via the Part 48 online registration process. Currently, the FAA is planning on opening up this process to commercial operators on March 31st.  Keep in mind that the Taylor v. FAA lawsuits are challenging the FAA on their drone registration regulations (I’m working on those cases), and there are good grounds that the Part 48 registration regulations could be held to be invalid because the FAA didn’t create the regulations according to how Congress told them to. In other words, you are going to have to register AGAIN if the court throws out Part 48. Save yourself the potential pain of reregistering and go the Part 47 paper based registration route until that case gets settled.

There are other changes but I wanted to give everyone a quick update on these three points since these are immediately applicable. If you already have a 333 and are interested in trying to get your exemption quickly amended for this “Blanket” aircraft amendment or do the Part 47 paper-based registration, please don’t hesitate to reach out to me at jon@jrupprechtlaw.com