Drones + 117

Mattio

Well-Known Member
Does anyone here work for a part 121 carrier and also fly commercial drones on the side? I have an informal interview coming up for a side job flying commercial drones and I'm wondering how flying the drone may affect my airline job. I've been doing a bit of research but there's some gray area and I've got a million other things going on in between now and the interview so I was wondering if someone could help me from re-inventing the wheel..

From what I've read in the FAR's and the 333 exemption for this company, drone flying is logged by the PIC and the definition of Flight Time in the FAR's includes drone flying. However, it only requires a sport, rec, private or above license.. I would be doing flying that I'm getting paid for, however it wouldn't require a commercial license. Kind of a catch 22. Is there a precedent here? Would commercial drone flying count towards part 117 limits?

Thanks!
 
Good question! On a related note for the uneducated GA folks like myself, does 91 flying count towards your 117 limits? Say, flying jumpers or instructing (assuming your company permitted it)?
 
Company policy notwithstanding, it does not count towards FAR 117 limits. Only flying for the certificate holder (airline) counts.
 
Well.....I could be totally wrong here, but doesnt 117 only apply to flying? If you've got both feet on terra firma cant you do whatever you want?
 
Company policy notwithstanding, it does not count towards FAR 117 limits. Only flying for the certificate holder (airline) counts.

I was reading through part 117 and I didn't see anything that says other flying is included in the time/duty limits, but I also didn't see anything that says it isn't. Is this your personal interpretation of the reg or are you going off of another reference?
 
Well.....I could be totally wrong here, but doesnt 117 only apply to flying? If you've got both feet on terra firma cant you do whatever you want?

Here's the definition of Flight Time from part 1.1 of the FAR's:
Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing

As you can see, it says nothing about whether the pilot is inside the aircraft. (In the exemption I would be working under, the FAA also defines the person flying the drone as the "pilot")

There are a surprising number of regulations that apply to flying commercial drones. There's more that apply than those that don't apply, including many of the same regulations that apply to pilots of manned aircraft. Still trying to sort through them all, though.
 
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I'd use a bit more due diligence than normal with this setup.

With all the attention drones have been getting lately, and the position that the FAA seems to have taken that they will pursue certificate enforcement actions against pilots operating drones in a, um, wayward manner, I'd be super extra careful with any drone operations. You wouldn't want your side gig messing with your day job.

This goes for any side gig, not just this kinda thing.

Not sayin' anything...just sayin'

Richman
 
I was reading through part 117 and I didn't see anything that says other flying is included in the time/duty limits, but I also didn't see anything that says it isn't. Is this your personal interpretation of the reg or are you going off of another reference?

§117.23 Cumulative limitations.
(a) The limitations of this section include all flying by flightcrew members on behalf of any certificate holder or 91K Program Manager during the applicable periods.

So if your flying is not on behalf of a certificate holder, it is not included in these limitations.
 
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I think you're over thinking this.

Exactly ZERO of my unmanned flight time is "loggable" as far as any employers or the FAA is concerned so I wouldn't give it a second thought. If I were able to count my unmanned time, flying "actual" airplanes and not RC toys, I'd be a shoe-in at a major.

If you're flying those little quad-copter toys and are really concerned then don't log the time.
 
Be VERY careful with a "drone" job. Is it for video shoots and what not? VERY CAREFUL. You spent $$$$$$.$$ to get your certificates, and from what I have seen, most folks want certified pilots to comply with their 333 exemption. They pay very little, but you are putting your hard earned certificate to risk. If it is for a big defense contractor, great, no problem. If it is for Spidey Joes aerial photography business, well, you've been warned.
 
The FAA successfully got a fine against an RC foam plane operator to stick. $2500 for careless and reckless operation, IIRC. Originally it was $10k.
 
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