USA Section 333 / COA confusion!

Jim Z · May 2, 2016

I just received my Section 333 and Blanket COA (after 6 months). I do not have a pilot’s license.

Perhaps my questions have been addressed in previous posts, but I’ve spent a good deal of time searching, and found conflicting information.

Can I legally operate commercially along with a Sports Pilot License holder who does not have a 333?

Can I legally operate commercially along with a Commercial Pilot who does not have a 333?

The 333 refers to both “The Operator” and the “PIC”. Can I be the 333 Operator, while a non-333 PIC is the Visual Observer?

The Blanket COA that came with my 333 is confusing. Does this COA apply to ALL my UA operations?

Apparently, when I am operating “Over or near people directly participating in the operation of the UAS”, I do not need to notify the FSDO, but I DO need to notify the FSDO 72 hours in advance when operating “Near but not over people directly participating in the intended purpose of the UAS operation.” Huh?

I see that on the COA, I need to file monthly reports. I have the FAA website, looks simple enough (except, what is the “Proponent” field?)

What exactly are “negative / zero flights”?

I’ve regularly been flying at an unpopulated soccer field along with an associate. This is for practice / recreational, not for commercial purposes? Is this legal for me to do, and how would I report that on the monthly report?

Any insights would be greatly appreciated.

SanCap · May 2, 2016

Jim Z said:
I just received my Section 333 and Blanket COA (after 6 months). I do not have a pilot’s license.

Perhaps my questions have been addressed in previous posts, but I’ve spent a good deal of time searching, and found conflicting information.

Can I legally operate commercially along with a Sports Pilot License holder who does not have a 333?

You Can hire someone that has a sports pilot license to fly your registered UAV under your 333 exemption as long as they have knowledge and are capable of flying your UAV

Can I legally operate commercially along with a Commercial Pilot who does not have a 333?

You Can hire someone that has a Commercial Pilots License to fly your registered UAV under your 333 exemption as long as they have knowledge and are capable of flying your UAV

The 333 refers to both “The Operator” and the “PIC”. Can I be the 333 Operator, while a non-333 PIC is the Visual Observer?

The Operator is the owner of the 333 exemption. The PIC is the Licensed Pilot whom is capable of flying your registered UAV.

The Blanket COA that came with my 333 is confusing. Does this COA apply to ALL my UA operations?

YES, it applies to all your commercial operations.

Apparently, when I am operating “Over or near people directly participating in the operation of the UAS”, I do not need to notify the FSDO, but I DO need to notify the FSDO 72 hours in advance when operating “Near but not over people directly participating in the intended purpose of the UAS operation.” Huh?

You can not fly over people within 500 feet without letting them know what you are doing, getting their approval and disclaimers and contacting the local FSDO. Period

I see that on the COA, I need to file monthly reports. I have the FAA website, looks simple enough (except, what is the “Proponent” field?)

You need to register with your 333 exemption # and whatever name you filed your exemption under, that would be your proponent field.

What exactly are “negative / zero flights”?

You need to file your monthly reports even if you had none, saying you had no flights for that month.

I’ve regularly been flying at an unpopulated soccer field along with an associate. This is for practice / recreational, not for commercial purposes? Is this legal for me to do, and how would I report that on the monthly report?

I consider those flights as training and do not report them, or any flight not intended to use for commercial gains.

You also need to file a Distant NOTAM 24 hours before any commercial flight under your 333 exemption and Blanket COA.

Any insights would be greatly appreciated.

Jim Z · May 3, 2016

I can't thank you enough for your prompt and thorough response. This definitely clears things up, and allows me to make further progress legally. Sorry if I seemed a bit pedantic or ignorant, but I REALLY wanted to make sure I'm getting this right, and I do believe that "the only stupid question is the one that wasn't asked!" Thanks!

SanCap · May 3, 2016

Jim Z said:
I can't thank you enough for your prompt and thorough response. This definitely clears things up, and allows me to make further progress legally. Sorry if I seemed a bit pedantic or ignorant, but I REALLY wanted to make sure I'm getting this right, and I do believe that "the only stupid question is the one that wasn't asked!" Thanks!

You are welcome but do not take the way I intemperate the rules as law. I may be wrong on some counts so use my info as a reference to learn and educate yourself more. Don't be afraid to call your local FSDO and ask their interpretations on some of your questions.

Jim Z · May 3, 2016

SanCap said:
You are welcome but do not take the way I intemperate the rules as law. I may be wrong on some counts so use my info as a reference to learn and educate yourself more. Don't be afraid to call your local FSDO and ask their interpretations on some of your questions.

Yes, calling my local FSDO is on the agenda for tomorrow.

SanCap · May 3, 2016

Jim Z said:
Yes, calling my local FSDO is on the agenda for tomorrow.

Let me know if any of the advice is somewhat accurate.

ianwood · May 4, 2016

Two things:

Your mileage with the FSDO will vary. They don't all operate the same way and some are better versed than others. They're not always right.
All your operations need to fit under the blanket COA. If they don't, you need to file for a special COA which can take 60 days to get approved. An example of this would be flying within 5 miles of an airport.

SanCap · May 4, 2016

ianwood said:
Two things:

Your mileage with the FSDO will vary. They don't all operate the same way and some are better versed than others. They're not always right.

All your operations need to fit under the blanket COA. If they don't, you need to file for a special COA which can take 60 days to get approved. An example of this would be flying within 5 miles of an airport.

Ian, have you filed for any special COA's and have had them approved? I have 7 filed for about 4 weeks ago and they have gone to the second stage of approval/denial.

ianwood · May 5, 2016

Yes. All for airports. The last batch are taking exceedingly long.

licensed pilot · May 5, 2016

Anyone here ever received a COA inside class B airspace? Doubtful but just checking...

SanCap · May 5, 2016

ianwood said:
Yes. All for airports. The last batch are taking exceedingly long.

Do you set one location with lat and lon or give them a 4 corner area with 4 lats an lons?

Jim Z · May 6, 2016

Jim Z said:
Yes, calling my local FSDO is on the agenda for tomorrow.

I left a voicemail with the FSDO on Wednesday. Have not heard back. Will try again Monday.

ianwood · May 6, 2016

SanCap said:
Do you set one location with lat and lon or give them a 4 corner area with 4 lats an lons?

I identify a radius from the center of the airport along with a height limit.

SanCap · May 6, 2016

ianwood said:
I identify a radius from the center of the airport along with a height limit.

Thanks for the reply Ian, what is the largest radius you have gotten approved?

hoverkat92 · Jan 15, 2017

SanCap...........You answered some questions I had about the 333 as well, thank you. I,ve had my 333 for about 5 month's and just recently took the pilot rated 107 review and test. I'm ashamed to say that I just reviewed my 333 to compare it to 107 requirements. Negative flight reporting was a big miss. Fortunate I've not done any commercial flying.

USA Section 333 / COA confusion!

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