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Section 333 exemption - training program

Discussion in 'General Discussion' started by RHunter, Aug 2, 2015.

  1. RHunter

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    So our company is going to start up a "UAV Division". We've purchased a P3 and are going to be getting a section 333 exemption.

    One thing we're struggling with finding out is the types of training programs that the FAA is accepting for their exemptions.
    Does anyone know where we can find something online (the FAA doesn't appear to release that information, just the exemption itself) that we can look at for ideas?

    (I'd previously posted this in the P3 area and was told "do a search, this has been asked many, many, many times".. and that I'd posted it in the wrong area, and the thread was then locked...well, I'd already DONE a search here. I'd read through every single reply in the thread links I was told about -- including the ones where someone was ticked at someone else and posted their info here and reported them to the FAA -- and not a single one actually addressed my question, so I'm trying again)


    We're under the belief that as part of our exemption application we have to submit a self-administered training program to the FAA that we're going to have our pilots do (100 hours total I believe?).

    We're simply looking for some sort of idea as to what that training program should all entail.

    Does anyone with an exemption have any suggestions?

    Thanks
     
  2. msinger

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    There is no such requirement.

    You can find a complete list of actual exemptions that were approved at the link below. Find a company that has a similar operation/mission to yours and you might get some ideas as to what you need to submit in order to get your petition for exemption approved.

    https://www.faa.gov/uas/legislative_programs/section_333/333_authorizations
     
  3. RHunter

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    There is no requirement for a self-administered training program as part of the exemption? Oh wow, if that's the case I need to talk to the people in our office and find out exactly where this idea came from.
    Thanks!
     
  4. msinger

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  5. RHunter

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    Thank you for the links, I'm going to have to have a sit-down with a couple people at work tomorrow and get this all sorted.
     
  6. SteveMann

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    They may be confusing the Section 333 exemption with the Part 107 rules currently in development. But the Part 107 rules are at least a year from being finalized. Realize that the Section 333 exemption still requires that whomever is at the controls (PIC- Pilot in Command according to the FAA) will be required to hold an FAA-issued pilot certificate.
     
  7. RHunter

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    That could be the issue...

    As for the license part; some of the approved exemptions I've read through talk about the PIC being currently enrolled in a "FAA NPRM compliant ground school certification program". I'm not sure (yet) what, exactly, that is but just by the name it doesn't sound like a full-blown pilot's certificate as I would have imagined it.
     
  8. SteveMann

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    I've never seen one - what is the exemption number?
    There is no such thing as an NPRM Compliant anything. The NPRM is a notice of Proposed Rulemaking and is not a rule until the NPRM is finalized.

    The administrator may be authorized to exempt the pilot certificate requirement in CFR 49 §44701, but I've never seen it done.
     
  9. RHunter

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    The one I downloaded to take to work tomorrow is 12246. Page 8 is where the PIC's qualifications are mentioned.
     
  10. SteveMann

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    On the copy I downloaded, Page 8 is the signatures.
    Exemption No. 12246 is issued to:
    Mr. Michael T. Melton
    President and CEO
    Birdseye, LLC

    Are we discussing the same exemption?

    In Conditions and Limitations:
    "13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate."
     
  11. RHunter

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    Go to the first page of the Birdseye application.. you'll see it there.
     
  12. SteveMann

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    I found what you are possibly referring to. This is in the petition for the Section 333 exemption:

    "UASs and is enrolled in a FAA NPRM compliant ground school certification program offered through Fly Robotics"

    This is the BirdsEye petition. This is what they used to ask the FAA for an exemption. But in granting the exemption, the conditions and Limitations are what is required.

    Fly Robotics says "FLY ROBOTICS “FAA NPRM Compliant” Ground School is an E-Learning sUAS Center of Excellence designed for self paced and asynchronous learning. "

    I can only guess that they claim to be teaching toward the FAA Part 107 written test. Which is quite a feat since the Part 107 rules are not final and no test standard from the FAA has been published. Any pilot ground school will be just as good as you would learn 90% of what will be on the Part 107 test. Besides, if you plan to be the drone operator, you will need to pass the FAA private pilot written test anyway to get your airman's certificate.
     
  13. LUISMARTINEZ

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    Beating a dead horse again, I suppose, No 333 has been issued that exempts the PIC from holding, as a minimum, a sport pilot license. Right Steve?
     
  14. RHunter

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    Luis, I'm trying to find out information here. Please don't troll this thread, ok? (yeah, I read all the replies on the other threads with all the squabbles) If you have something helpful to add, that's great.....

    Steve - yes, that's the part I was referring to. Maybe I missed it, but I didn't see anywhere in Birdseye's application where they stated their PIC was going to be taking an FAA private pilot's written test and also didn't see anywhere in the approval letter from the reviewer that stated Birdseye's PIC was required to get a pilot's license either.
    I would think that, if it's a requirement put forth by the FAA, there'd be verbage to the effect that Birdseye's exemption would be conditional on them getting their PIC a pilot's license?
     
  15. SteveMann

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    It is. Number 13 from the "Conditions and Limitations" in the Birdseye Section 333 exemption letter is quoted below:

    "In this grant of exemption, Birdseye, LLC is hereafter referred to as the operator.

    Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

    13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate."​

    Luis, the first Section 333 letter required a commercial pilot certificate. It was later amended to allow a Private or better. Only recently have the exemption letters relaxed the requirement and allow any pilot certificate for flight.

    The FAA has also dramatically reduced the requirements for flight experience as well. This is from the first (amended) exemption letters' Conditions and Limitations:

    "10. The Pilot In Command (PIC) must possess at least a private pilot certificate and at least a current third-class medical certificate. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
    11. Prior to operations conducted for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under this grant of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119."​
     
  16. SanCap

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    I am glad they got rid of the 3rd class medical requirement, that saves some money.
     
  17. kirk2579

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    wow, a bit hard on Luis.

    All he said is something very clear even though you want to argue ..
    Pilot cert is needed along with the 333 exemption.

    all the links folks found for you can be located on google with a moment or so of good search key words all by ones self.
     
  18. LUISMARTINEZ

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    I answered your question, bud. A simple "thank you" will do. Read it, re-read it, turn it upside down, and read it again, the words will not change, ALL 333s REQUIRE A MINIMUM OF AN FAA SPORT PILOT LICENSE. If you don't want to get one wait another year, the FAA proposed rules will do away with that, and only a written test akin the private pilot written will be required.
    Don't kill the messenger.
     
  19. LUISMARTINEZ

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    Just more of the same attitude we've seen here so much lately; don't like the message so attack the messenger. If someone doesn't like the pilot requirement go ***** to the FAA, not us.
     
  20. Youngbill

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    These guys have a good podcast that has some very useful info in regards to commercial use and 333's. http://www.thedroneu.com/

    I have NO affiliation with them, I just enjoy their podcast.
     
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