No, Part 107 Does Not Fix Everything.

No, Part 107 Does Not Fix Everything.

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Since Part 107 is coming out in the next 1-3 years, will anyone use the Section 333 process anymore?

Many people mistakenly believe that Part 107 is the answer to all their needs. This is not true as there are certain types of operations that are not covered under Part 107 which leaves individuals and business with only one alternative – Section 333.

Part 107 does NOT cover:

  • Beyond Visual Line of Sight
    • Power line inspections in those really remote areas
    • SAR
    • Firefighting
  • First Person Viewing
  • Night Operations
    • SAR
    • Firefighting
    • Inspections using thermal equipment in hot environments
    • Cinematography for tv/movie scenes
    • Inspections on critical time/sensitive material (example: turbidity monitoring for dredging operations)
    • Sports
  • 55 pounds and heavier
    • Package delivery
    • Crop dusting
    • Firefighting retardant delivery
    • High-end LIDAR to monitor crops such as lumber. The LIDAR is used to detect the diameter of the wood so the loggers know which forest to harvest first.
    • Cinematography (Dual Red Epics for 3d filming or full Arri Alexa with lens and large stack of batteries for extra flight time.)
  • 500ft and higher
    • Large radio towers
    • Large bridges (Gold Gate Bridge is 746 feet above the water)
    • Large buildings (Inspecting the facade of large buildings and also the towers on top of the buildings).
  • 100 mph and faster
    • Survey large areas fast
    • Fast package/medical delivery
  • Operation Over Persons
    • Concerts
    • Live News Events
    • Sports
  • Operations from a moving vehicle
  • Aircraft conducting an external load operation (carrying stuff outside the fuselage).
    • Life preserver
    • Medical supplies
    • Tree lifting
    • Supply dropping
  • Any aircraft towing another aircraft or object
    • Banner tower
    • Glider tower
  • Operations conducted outside the United States
    • Delivery to boats outside of the United States’ territorial waters.
    • Delivery to Caribbean Islands near Florida, Puerto Rico, or the U.S. Virgin Islands.
    • Delivery to Canada or Mexico
  • Training provider of one of the above types of operations.

So if you are currently thinking these areas could be potentially beneficial or lucrative, I would suggest looking into getting a 333 exemption for one of these types of operations because when the competition floods into the market when Part 107 becomes final, these areas will remain untouched.

http://jrupprechtlaw.com/

 

Jonathan Rupprecht

Jonathan is an aviation attorney who focuses on unmanned aircraft. He holds an FAA Commercial Pilot certificate and is also an FAA certified Flight Instructor.