Two years ago I decided to expand my repertoire and do aerial photography and videography. This month I had to renew my Part 107 license in order to continue to legally fly my sUAS commercially. In this post, I am going to talk about why I almost decided not to renew, why ultimately I did, what the process is like, and some issues that are coming in the future of being an sUAS pilot.
Why did I consider not renewing?
The rules governing sUAS pilots are getting more confusing. Despite the horror stories about people who have been fined for not properly flying or conducting commercial activity without a license, I can find very little evidence of actual enforcement. There are laws and regulations on the books to enforce the proper use of sUAS but little support to enforce them. So, I am less afraid of big fines than I was at the start. It’s not a good reason, but it ran through my head.
Also, my area is a bit saturated with people who think they can make a living on sUAS piloting. I know that many of them are not Part 107 licensed. I don’t begrudge them (much), although I wish they would get the license. Right now the market does not support it. I find this is especially true in real estate where people hit and run and the agents either don’t know or don’t care to ask for a license. In those cases, I blame the agent more than the pilot but the pilot should know better too. The market around here trends more to agricultural, land survey and construction activities for sUAS use. I want to build demand for drone imagery in Public Relations and marketing. The market exists, just not much around here, yet.
Aside from that, I and most of my sUAS pilot friends fly for art, fine art photography, and photography. There is an important difference between each of those. Technically, if you expect to sell any photos or art derived from the photos you need a Part 107 license. Since when in history have artists adhered strictly to the rules? Artists and photographers that I know fly under the hobby category with hopes that someday they can sell some of their photos but they are not strictly engaging in commercial activity. Is that a Part 107 gray area? I don’t think so but an argument can be made.
Finally, I am worried about Remote ID. I think Remote ID is dangerous, invasive and will kill the industry and hobby. I have written a previous blog post about Remote ID and I am working on another. Please check it out. I am already looking into sub-250g (.55lbs) options that can give me more capabilities for my clients and allow me to be different from the glut of operators in my area. Technically commercial activities using sub-250g sUAS are still governed by Part 107 but there is even less ability to enforce that. More on that in another post.
The Process
Two years snuck up on me. I scrambled to schedule my recurrent test before my license ran out otherwise I’d have to take the full test again. The first lesson, you have until the end of the month that your license runs out to take the recurrent test.
The first thing I had to do was schedule to take the test. That’s not hard, the Northampton Airport is right down the road. What was more difficult was dealing with PSI, the private company contracted by the FAA to run the tests. It was pretty clear that the contractor I spoke with did not like his job. The second lesson was don’t expect friendly or good service.
The third lesson, PSI has an archaic way of scheduling with the airports. Since it was a new year, PSI had not entered any of the 2020 scheduling information into their system. Even then they only put two weeks of scheduling into the computer at a time. I wanted to take my test on the 13th so I could have a weekend to study. I am in the National Guard and had drill the previous weekend so I had no time to study. The only way I could have taken the test on the 13th would be to call on the 13th to schedule for the same day. No kidding! That’s how they do it! So I scheduled it for the 10th instead.
I thought that when I got my license initially that the first test was $150 and the renewal was $50 every two years. I was wrong, you pay the whole amount every time and the test cost had gone up to $160. To me, it seems logical that the initial test would cost more and a renewal, which is just recertification of what you already know, would cost less. Apparently, that logic does not also exist at the FAA.
I crammed to remember the oddball intricate questions that make no sense for an sUAS pilot to know because they only apply to fixed-wing aircraft or flying in areas and ways that are not legal for a Part 107 license. The same resources I used to pass the test the first time were still great for the recurrent test. I watched Tony Northrup and DroneU, looked at the study guide took practice tests over and over again until the information was burned into my brain. Honestly, in my previous two years of flying, I have hardly used any of the information on the test.
I went into Northampton Airpost where the guys are great and helpful. I took the test and passed with an 83. You can see what questions you got wrong but not the answers. I am licensed for another two years. Lesson 5 came when out of curiosity I asked how much the airport got of the testing fee. While the guys couldn’t tell me how much they did say it was “next to nothing”. We know that the FAA doesn’t make money off the tests, and the airport gets a minimal fee despite the fact that they do basically all the work. So PSI gets the lion’s share for grumpily answering the phones and doing a very poor job of scheduling. This seems to me to be a very bad deal that the FAA has contracted.
Why did I renew then?
Simple. It is the right thing to do.
I consider myself an ambassador for the business, hobby, activity and (as I get into FPV) the sport. I want people to fly safely and to follow the laws. I want to stop the cycle of over-regulation that happens when people, including the FAA, don’t understand the technology. Part 107 licensing is an acceptable regulation of sUAS activity that takes into account the public interest, the requirements of the FAA to manage airspace and the rights and opportunities of small private pilots.
If I am going to help fight against overregulation and the influence of big companies like Amazon and Verizon who want to gobble up all the airspace for themselves, then I need to be following regulations that make sense. I can’t fight the bad if I am not complying with the good. Being an ambassador means having to be a paragon of what you stand for while negotiating what is acceptable and fighting what is not. Drone pilots, sUAS enthusiasts, and hobbyists need more ambassadors. That is the only way to get the public on our side before we get pushed out.