By way of introduction I'm Australian so a 333 is not something I've looked into in detail. I'm a private pilot with a couple of hundred hours experience and an air traffic controller with 15 years experience in Tower and Tracon roles. I've also got 4 quad copters multiple heli and fixed wing Rc aircraft and I'm in the process of commercial UAV certification in Australia.
Primarily consider that ATC exists to facilitate Safe and Expedition flow of air traffic. If your drone doesn't have a transponder, ADS-B transmitter or equivalent and is too small to be easily seen (a 737 will be traveling at probably 120kt or faster and not looking for little drones, but rather big things like Cessnas and airbuses), then you are just making life difficult for everyone else in the skies.
The flexible use of airspace is where UAVs and other non-transponder aircraft fit. Pain in the butt but do it when you can.
0) Request the issuance of a NOTAM 24hrs prior to flight operations
(Hopefully the FAA will expedite this process for commercial operations) NOTAM publishing organisations will usually have a priority list largely based on when it goes active.
1) NLT 30 min prior you flight must contact them and request authorization/approval.
(Why? they don't have the authority to approve or disprove flight operations) plans can change (yours) this also is a last chance to get everyone on the same plan and make sure radar maps have been made etc.
2) Provide them the operating areas as defined by the NOTAM
(Because they're too lazy to read the NOTAM) different radar systems work different ways, a lat long might be less useful than a bearing and distance.
3) Provide them PIC name, Phone number time of flight and proposed duration
(There is no requirement to provide pilot names when operating in airspace) tracking aircraft after the fact is easy by pulling radar playbacks, a UAV could be difficult, but this would help
4) Notify them immediately prior to flight to ensure the area is steril
(Not required that is what the NOTAM is for, there is no FAA sterile area requirement) even with 30 minutes prior notice I think you'd agree that an air ambulance flight should probably result in you getting grounded till it's clear
5) Conduct operations based on VFR flight conditions
(not required because the FAA creates flight visibility limitations) if they organise a standard LOA then if a rare case comes along authorised for non VFR OPS, they know it would need to be specially considered. A 333 is an exemption from rules, why couldn't there be exemptions from other rules?
6) Remain 200' or below within 3nm of airport
Okay seems reasonable.
7) Remain 400 or below when operating 3-5NM from airport
Okay seems reasonable
8) Maintain VLOS of UAS
(requirement already set forth in the COA) See point 5
9) Comply with FAA Requirements
(Not Required by airport because it is an FAA Requirement) but they can't control the FAA and it is a simple way of defining thief assumptions are valid
10) Perform Lost link procedure in the event of a lost-link
(requirement already set forth in the COA)
11) Notify airport of an emergency
Okay seems reasonable
12) Notify airport of the termination of operations
(Not Required its in the NOTAM) what you are always going to use exactly all the time covered but your NOTAM? This just lets them use your snippet of airspace if you don't need it.
Sure look at getting your own LOA up, but have good reasoning and an understanding of the other side before you ask, otherwise you might get taken for a fool and find your operations more difficult in future.
Primarily consider that ATC exists to facilitate Safe and Expedition flow of air traffic. If your drone doesn't have a transponder, ADS-B transmitter or equivalent and is too small to be easily seen (a 737 will be traveling at probably 120kt or faster and not looking for little drones, but rather big things like Cessnas and airbuses), then you are just making life difficult for everyone else in the skies.
The flexible use of airspace is where UAVs and other non-transponder aircraft fit. Pain in the butt but do it when you can.
0) Request the issuance of a NOTAM 24hrs prior to flight operations
(Hopefully the FAA will expedite this process for commercial operations) NOTAM publishing organisations will usually have a priority list largely based on when it goes active.
1) NLT 30 min prior you flight must contact them and request authorization/approval.
(Why? they don't have the authority to approve or disprove flight operations) plans can change (yours) this also is a last chance to get everyone on the same plan and make sure radar maps have been made etc.
2) Provide them the operating areas as defined by the NOTAM
(Because they're too lazy to read the NOTAM) different radar systems work different ways, a lat long might be less useful than a bearing and distance.
3) Provide them PIC name, Phone number time of flight and proposed duration
(There is no requirement to provide pilot names when operating in airspace) tracking aircraft after the fact is easy by pulling radar playbacks, a UAV could be difficult, but this would help
4) Notify them immediately prior to flight to ensure the area is steril
(Not required that is what the NOTAM is for, there is no FAA sterile area requirement) even with 30 minutes prior notice I think you'd agree that an air ambulance flight should probably result in you getting grounded till it's clear
5) Conduct operations based on VFR flight conditions
(not required because the FAA creates flight visibility limitations) if they organise a standard LOA then if a rare case comes along authorised for non VFR OPS, they know it would need to be specially considered. A 333 is an exemption from rules, why couldn't there be exemptions from other rules?
6) Remain 200' or below within 3nm of airport
Okay seems reasonable.
7) Remain 400 or below when operating 3-5NM from airport
Okay seems reasonable
8) Maintain VLOS of UAS
(requirement already set forth in the COA) See point 5
9) Comply with FAA Requirements
(Not Required by airport because it is an FAA Requirement) but they can't control the FAA and it is a simple way of defining thief assumptions are valid
10) Perform Lost link procedure in the event of a lost-link
(requirement already set forth in the COA)
11) Notify airport of an emergency
Okay seems reasonable
12) Notify airport of the termination of operations
(Not Required its in the NOTAM) what you are always going to use exactly all the time covered but your NOTAM? This just lets them use your snippet of airspace if you don't need it.
Sure look at getting your own LOA up, but have good reasoning and an understanding of the other side before you ask, otherwise you might get taken for a fool and find your operations more difficult in future.
