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tl;dr: How do I go from non-airman to commercial UAS pilot under an FAA 333 exemption?

I understand that the rules are imminently changing, but waiting for the formal implementation of the NPRM could mean a very long wait before even getting started, and there is already a backlog of section 333 petitions.

Say I have a small (under 55 pounds) quadrotor aircraft, and I want to fly it for "civil operations" (commercial). As a non-airman, what do I need to do before I can operate the craft in this manner?

As near as I can determine, the process is something like this:

  1. Obtain a pilot license
  2. File a petition for part 333 exemption
  3. Acquire either a SAC or Waiver/CoA

Do I really need to obtain a pilot license of some sort for real aircraft (either PPL, sport, or recreational) for this purpose, or can I legally operate the craft using some other short-cut? Is there a difference if I plan to fly a craft with a SAC rather than a craft which has none?

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The FAA's FAQ says:

Is an FAA-issued pilot certificate required to operate a civil UAS under an experimental airworthiness certificate or a grant of exemption under Section 333?

If the aircraft is issued an airworthiness certificate, a pilot certificate is required.5

Pilot certification requirements for petitions for exemption under Section 333 are evaluated on a case-by-case basis.

The footnote links to this FAA order called Airworthiness Certification of Unmanned Aircraft Systems and Optionally Piloted Aircraft, which says:

b. UA PIC Certification and Ratings Requirements.

(1) The PIC must hold and be in possession of, at a minimum, an FAA private pilot certificate, with either an airplane, rotorcraft, or powered-lift category; with single- or multiengine class ratings, appropriate to the type of UA being operated.

(2) The PIC must have and be in possession of a valid second-class (or higher) airman medical certificate issued under 14 CFR part 67, Medical Standards and Certification.

So, it looks like there are two possibilities:

  1. Your UAS has an airworthiness certificate, therefore you need a pilot's license per the Order (private at least, not sport or recreational)
  2. Your UAS doesn't have an airworthiness certificate, therefore your section 333 petition will be evaluated individually and the FAA will tell you if you need a license or not
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  • $\begingroup$ Since the OP asked for "commercial UAS pilot", wouldn't the minimum license be commercial rather than private? $\endgroup$
    – Dan Pichelman
    Commented Apr 1, 2016 at 13:02
  • $\begingroup$ @DanPichelman No, the order says private is good enough. But interestingly, it does say you need a second-class medical (which is required for commercial pilots). Private pilots only need a third-class one. $\endgroup$
    – Pondlife
    Commented Apr 1, 2016 at 13:56
  • $\begingroup$ Go figure. Thanks $\endgroup$
    – Dan Pichelman
    Commented Apr 1, 2016 at 14:00

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