I Authored One of the First FAA 333 Exemptions for Commercial Drone Operations. Here Is What That Means in 2026.

Most drone operators working in film and television today became licensed in 2016 or later, when the FAA introduced Part 107 and created a clear, accessible path to commercial drone operation. Pass a knowledge test, get your certificate, go to work.

That is a legitimate credential. But it is not the whole story of what experience in this industry actually looks like.

In 2013, I authored one of the first FAA 333 Exemptions for commercial drone cinematography in the United States. I did it without an attorney, over several months of work, at a time when the commercial drone industry was operating in a regulatory gray area that most operators preferred to ignore. Here is what that was, why it mattered, and what it still says about how we operate today.

What the Gray Area Actually Looked Like

In the early years of commercial drone operation, 2011, 2012, 2013, the FAA had not yet created a formal licensing structure for commercial unmanned aircraft operators. The rules that existed were written for model aircraft hobbyists, not for a film industry that was beginning to recognize what drones could do on a production.

Operators were flying commercially. Some were doing it responsibly. Many were not. The question of whether commercial drone operation was legal was genuinely unsettled, and most people in the industry were content to operate in that ambiguity rather than engage with the federal government to resolve it.

I was not content with that. I had five years of background as a DoD contractor, engineering and flying unmanned aircraft systems for Army and Marine programs. I understood how regulatory frameworks around unmanned aircraft worked at a federal level, and I could see that commercial drone use was not going away. The question was not whether the FAA would regulate it. The question was when, and whether you would be ahead of that moment or scrambling to catch up with it.

What a 333 Exemption Was

Section 333 of the FAA Modernization and Reform Act of 2012 gave the FAA Secretary authority to determine whether certain unmanned aircraft operations could be conducted safely under existing regulations. An operator who wanted to fly commercially could petition the FAA for an exemption from the rules that otherwise prohibited commercial operation, essentially asking the federal government to evaluate your specific operation and grant you permission to proceed.

This was not a test you passed. It was a legal petition. You had to document your aircraft, your operating procedures, your safety protocols, and your qualifications. You had to demonstrate that you understood the airspace, the risks, and the mitigation strategies for everything that could go wrong. And under the 333 structure that existed at the time, you had to hold a private pilot’s license for manned aircraft. The FAA’s position was that commercial drone operators needed to understand the airspace the same way manned aircraft pilots did, not as a drone concept, but as a fundamental aviation concept.

I held that license. I had obtained it specifically because I could see this requirement coming.

The petition I submitted ran approximately 30 pages. It took roughly three to four months to move through the FAA review process. There was no template, no attorney, no precedent to follow. I wrote it from the ground up, and it was approved.

What Changed When Part 107 Arrived

In August 2016, the FAA introduced Part 107, a simplified regulatory framework for small commercial drone operations that replaced the 333 Exemption process. Part 107 is a knowledge test: study the material, pass the exam, receive your Remote Pilot Certificate. No private pilot’s license required. No petition process. Accessible to anyone who puts in the study time.

Part 107 was a good development for the industry. It created a clear, consistent standard and brought a large number of operators into a legitimate compliance structure.

It also meant that someone who passed a Part 107 exam in September 2016 was now operating under the same basic licensing category as someone who had been flying commercially since 2013, had authored a federal exemption petition, held a private pilot’s license, and had spent years navigating complex airspace for professional productions.

The credential looks the same on paper. The operator is not the same.

What Four Years of Experience Before Part 107 Actually Built

When Part 107 launched, we had already been operating commercially for three years under a federal exemption. We had flown alongside manned helicopters on motorsports shoots in Mexico. We had navigated the Los Angeles airspace, Class B, Class C, TFRs, temporary flight restrictions around productions and public events, in real conditions, on real productions, with real consequences if something went wrong.

The private pilot training built something specific: an understanding of weather, airspace classes, airport operations, and air traffic control that goes beyond what the Part 107 curriculum covers. When we approach a shoot near Burbank Airport or in the LAX Class B airspace, we are not just checking a drone app for a green light. We are reading a NOTAMs, understanding the traffic pattern, and coordinating the way a manned aircraft pilot would.

That knowledge does not appear on a certificate. It shows up in how a shoot runs.

What This Means If You Are Evaluating Operators

When you are hiring a drone operator for a film or television production, the Part 107 certificate is the floor, not the ceiling. Every legitimate professional operator has one. The questions that actually differentiate operators are the ones that do not appear on a licensing certificate:

How long have they been operating commercially? Under what regulatory structure did they start? Have they navigated complex Los Angeles airspace on a live production? Have they coordinated with manned aircraft? Have they operated under the scrutiny of a federal compliance framework, or did they start after the pathway was already paved?

We have been doing this since 2013. The 333 Exemption is no longer in use. It was superseded by Part 107, and we operate under that framework like everyone else. But the foundation it required us to build is still the foundation we operate on.

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