How to Get a Section 333 Exemption from the FAA – with Tim Ray of Pravia


Droneblog talks with Tim Ray of Pravia, LLC, a company that serves multiple agricultural locations throughout North America and abroad using unmanned aerial systems. This paddle boarding, fishing, family man / business man shares about how Pravia started and how they got an FAA exemption to use drones commercially in the agriculture industry.


What can you tell us about yourself and your background?

I have three children and am happily married to my wife of over 15 years. I was a prop and engine mechanic on C-130s before going to pilot training to fly them for the Wyoming Air National Guard. While there I was an Aircraft Commander on a C-130 modified to fly as an aerial tanker for our firefighting mission. I flew on several fires, dropping fire retardant in Colorado, California, Wyoming, Idaho and Nevada. I also flew as a first officer and captain for a commuter airline out of Denver International Airport for about 4 years before leaving that job to run my businesses full time. Those business are an aerial photography company called Vantage Point Imagery ( and a real estate marketing company called Colorado Virtual Tours ( I am currently enrolled in Colorado State University’s MBA program and expect to graduate in May, 2015. I enjoy paddle boarding, fishing, flying and spending time with my family taking trips, having adventure days and doing in-home movie nights with popcorn and smores.


Tell us about your company, what it is, and your role there. Where did the idea for your company come from? Share your story on how the company started.

Pravia, LLC (pronounced Prah-vee-uh) was founded in 2013 by myself and Scott Brink, both co-owners. We both shared experience as commercial pilots and military aviators with experience in everything from rotary wing to business jets to C-130s and large UAS. Realizing commercial UAS would be the growth industry of the future, we began to research markets that would be best suited for UAS use. Based on a relationship of Vantage Point with a major agricultural firm, we started Pravia, LLC to develop a distributed scalable business that could serve multiple agricultural locations throughout North America and abroad using unmanned aerial systems.

On Feb 6th we were granted a section 333 exemption from the FAA allowing us to operate SUAS for commercial agriculture use. We are currently finalizing contracts with our customer and working on the required COAs and other documentation in order to proceed with flight operations for the 2015 growing season.


Pravia fields


It looks like all the members of your team have served in some capacity in the military. Was that a factor in bringing the team together, and how does your military background play a role in your drone expertise?

We all worked together at one point or another in the military and have gained valuable experience there – not the least of which is how to navigate regulations and bureaucratic obstacles to achieve an objective!


What type of services does your company provide to industries like agriculture, forestry and search & rescue?

Currently our exemption covers only agricultural use. We plan to amend our exemptions or file new ones as required to allow us to expand into other areas. We are working with customers to provide services for oil and gas, landfills, survey and other applications.


The company is currently working on imaging and automated analysis using multi-spectral and thermal sensors for the 2016 growing season.  Can you explain what is involved with this technology and how your potential clients will benefit from it?

We are currently offering visual and NDVI imagery and associated data processing. We are in the planning and development stages to offer the same data processing services for thermal imagery and multispectral imagery. Benefits to customers include drought tolerance analysis, watering decisions/planning, stress monitoring, VRT integration, identification of low spots and soil deficiencies and more.




Currently Pravia is working with a major agricultural firm to provide calibrated NDVI, thermal, multi-spectral imagery and automated analysis of crops for seed research, drought resistance and yield prediction/improvement. Can you tell us more about this project?

Last year was a test and prototype year for our imagery to data system. We did a series of test flights in manned aircraft and developed a software system that enables us to fly over a field, provide calibrated NDVI imagery and convert that imagery into actionable data for our customer. By automating the imagery analysis and removing atmospheric bias, we can provide spreadsheet-format and graphical-format data for change detection and plant monitoring.

We are currently providing calibrated NDVI and/or visual spectrum imagery for the 2015 growing season. The level of services depends on the needs of our customer. It can range from basic aerial NDVI or visual spectrum imagery delivered as a stitched mosaic to a complete data solution. The complete solution includes site survey, ground control points, NDVI calibration (removes atmospheric bias for consistent baseline imagery regardless of lighting changes, haze, humidity and other factors), orthorectified NDVI imagery and plot-level analysis accurate to within a few centimeters. Bottom line is that instead of simply delivering our customer a photo, we deliver data in spreadsheet and graphical form.


Pravia thermal imaging


How did you get awarded a section 333 exemption by FAA? Please tell us about the process you went through and what was involved.

We contracted the right person, then hired her! Brittany Duensing, our new Director of Flight Operations did an outstanding job of researching the section 333 exemption process and navigating the paperwork to make it happen.

It would take pages and pages to cover all the details of a section 333 exemption, so I’ll try to cover a few high points. Anyone can find more information on the FAA website at this link:

At the time we started our application, all this information was not available online. Essentially the FAA is making exceptions to existing Federal Aviation Regulations (FARs) on a case-by-case basis through the section 333 process. The applicant must cover company information, historical safety record of the UAS being used, size, weight, speed and other tech data, operations manuals, justification for use in terms of benefits to the public, training plan, pilot qualifications, reason for use, locations for use and more.

We turned in our exemptions on September 30th and were approved on February 6th – just over 4 months. We noticed our exemptions were approved ahead of other requests submitted before ours. We are not certain why but guess it may have had something to do with either our background/experience, level of pilot certificates specified (commercial), quality of the submission or quality of SUAS. Either way, we’re glad to be the 22nd company to receive an exemption and are glad to see commercial UAS operations finally getting off the ground in the US!


Does the exemption only cover the use of unmanned aircraft systems for precision agricultural applications?

For now, yes. We are filing for other uses as well.


What type of drones and gear are you flying?

The senseFly eBee Ag and the Event38 E-384. We also plan to utilize the DroneDeploy system on the E-384.


Pravia UAS


What advice would you give to others who want to get started flying drones?

Safety first and insurance always. It’s easy to get lulled into a false sense of reliability or predictability with modern SUAS. However, from my experience flying these systems from back in the day when they were called “radio controlled helicopters” to the multi-rotors of today – failures happen. Don’t fly without insurance and don’t fly over anything that you’re not willing to crash into. Insurance can cover property damage but nothing is worth injuring people.

Also consider the current regulatory climate. Right now there is far more involved than just flying the SUAS. That’s the fun part, to be sure, but to be in compliance, a pilot’s license must be held, maintenance records and flight records maintained, Certificates of Authorization (COAs) must be approved, NOTAMS must be filed before each flight and other stringent requirements must be met. The compliance requirements are significant, but not insurmountable.


Thank you so much for your insights. Is there anything else that we haven’t touched on that you would like to share?

Thank you for the interview! Hopefully I’ve been able to lend some help to the industry on the whole. I would encourage your readers to follow us on Twitter @praviallc or Facebook to keep posted on our progress and the latest regulatory updates.

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