We recently reported that Industrial Aerobotics, LLC received their Section 333 Exemption on March 24th, 2015. We reached out to gain Section 333 Insights from Industrial Aerobotics, LLC on the process, their planned commercial uses for drones, and more. Enjoy the interview.
Q. You filed your Section 333 exemption on September 2nd of 2014, did the approval process go forward as you expected?
Not at all. The FAA listed an expected duration for approval of 120 days in their initial release. That would have put our expected approval near January 2nd. In mid January, we started reaching out to the FAA to see what the status of our exemption was. We were told that the exemptions were planned out based on complexity and estimated time to complete.
As weeks passed, another phone call was made. We were told that our exemption was in the final stages of review, but no other estimate can be given. I was actually impressed that the FAA was answering the phone and providing us any information at all.
That all soon ended. Starting in Late January a bad trend started where exemptions submitted in October, November and December were being approved while ours still was not. In a commercial situation, speed to market means everything. This process had the appearance of something very political and was allowing companies to get an unfair market advantage based on their size and lobbying ability. Luckily for Industrial Aerobotics there was not a direct competitor approved before us that had applied after us. We asked for escalation on this issue and soon we were contacted by another FAA employee that had additional information.
Apparently we were not the only company that was concerned about the trend of out of order exemption approvals. We were told that a Tiger Team had been formed to help speed up the exemption processing. He also said that as of the day he called us, they were moving to a FIFO approach where no exemptions would be approved ahead of those submitted prior to another. 2 weeks later our exemption was approved.
Q. Would you have any recommendations to others who are just beginning the exemption process?
Find an approved exemption similar to what your company plans to do and use it as a template to file your request. The FAR’s that you need an exemption from are very clear at this point. You will also need to provide the FAA documents around how you plan to manage flight operations, specific vehicle specifications and maintenance procedures. There have been multiple approvals given where these documents were provided in the initial filing and again can be used as a template to fashion your operation documents.
I would stay away from asking for exemptions the FAA has previously rejected; such as not requiring a Sport Pilot License or above. It is very clear you will have to wait until the official UAS rules are adopted before you will be allowed to fly without a manned aircraft license. However, in the last Congressional meeting the FAA made comments that seemed to leave the option open for someone to make a good argument around BLOS (beyond line of sight) operations. It is still unlikely they will approve any such request, but if you want to take a shot at it, it doesn’t hurt.
At this point the “blanket approval” process they switched to over the past week is much more streamlined and they are not specifically approving or rejecting each FAR exemption request you ask for. They are basically approving your request with a list of “conditions” that seem to be the same for all exemptions regardless of what you specifically requested exemptions from.
Q. Do you have any advice for the FAA around the process?
Based on the changes of the last few weeks, no. I think they have the process in a much better state now. They are looking for similar exemption request and if your request is similar to one already analyzed and approved, they are approving them without independently analyzing the new request. The addition of a blanket COA approval is also a nice change. It will make getting your business to revenue soon after your exemption a much easier prospect. It did take some time to determine how to manage the NOTAM-D requirement and filing, so a little more details around that process under the Section 333 FAQ would help.
Q. Your exemption paperwork notes that: “The exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to conduct precision aerial surveys”. Does this open up new businesses for you?
Not necessarily. Industrial Aerobotics was formed specifically with aerial inspections in mind. Most of what we do now has been being done in other ways for years. Utility companies have been using manned helicopters to gather images and radar (LiDAR) data for some time. They have also been using thermal imaging for some time to look at Generation, Transmission and Distribution assets from the ground as part of routine inspections. We are just providing the same services through a different, more cost effective; safer means.
Q. We noted in the exemption that you are going to use the Industrial Aerobotics SD02, why is this the right one for you use?
It is a custom vehicle that we designed to be a perfect match for our clients needs. It is specifically built to handle 3 types of payloads and various flight profiles specific to utility inspections. It can carry Thermal Imaging payloads and allow just shy of 60 minute flight times. We can swap that payload out with a Hi-Res/4K camera and gimbal to capture images and video while still allowing over 30 minutes of flight duration. It can also carry a LiDAR unit for Laser Imaging and handle just under 30 minutes in the air. It allows us to have a single vehicle with 3 missions profiles.
Although not perfect for any of the missions, the ability to handle all 3 with acceptable flight durations in the end is more cost effective and efficient than having to maintain 3 different vehicles with different components, flight characteristics, maintenance procedures, etc.