By now, it was the Q1 of 2015 and we made the decision to comply with all FAA rules. The next few months were used to complete our very extensive and laborious 333 exemption filing and wait for answers. In mid Q3, we received our 333 exemption and turned the machine known as AirFrame back on. Again positive feelings, even elation as we touted our highly coveted exemption. We could now conduct legal flights nationally. Ok, time for - “the fine print” of what was contained in our 333 exemption. “All aircraft must be registered with the FAA.” It took us another month of back and forth paper work putting us in Q4 2015 before we completed. Now with full FAA compliance, we started marketing heavily to our core industries and landed several seizable contracts. “Let's Do It” – STOP – All our contracts require a COA, Certificate Of Authorization, from the FAA, because sites are either located at the fringe of an airport “no fly zone” radius or we need to fly above 200 feet, because the tracks of land are so large we would have image counts that would be too large.
As of January 10, 2016, non of the ten plus COA’s we filed in October, November and December have been issued but we are fully compliant with the FAA rules. Our first few filings are over 65 days and counting. We understand the necessity for caution, but there needs to be a more proactive system put in place for the review and processing of COA information by the FAA. To the best of my knowledge, there is one FAA initial reviewer (person) for all commercial sUAS COA filings. He conducts a quick compliance check, if it passes,a nd all of ours did, they go to a second desk for review and finalization. It doesn’t take a genius to run the math. Two people are now responsible for COA requests from several thousand 333 Exemption holders. This is a bottle neck that has already resulted in lost contracts and revenue for AirFrame LLC.
The FAA must realize that clients can not wait three months plus for us to fly. In actuality this is hurting not only our company but also the industry as a whole. Every time a legal 333 Exemption holder loses a contract or the process exceeds 60 working days due to FAA delays in COA processing, there should be either a process of acceleration to resolve the COA in 48 hours or penalty payment made to the 333 Exemption holder by the FAA for lost time and fees. will be completed.
I believe this should be one of the most talked about subjects in the sUAS industry, yet I have never head anyone make any comments on the subject. In addition to the above, there is no quick method to do a change of address, add additional aircraft types or modify an already approved 333 Exemption. Currently any of the above tasks takes the FAA more than four to six months to complete and there is no method of “checking the status” to find out what has been done or when such tasks will be completed.
I see a bright future for our company and our industry, we just want the FAA understands that their side needs to operate more like a business.