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Need help navigating drone law? Tired of wasting time? Feeling frustrated because you can’t find reliable or experienced advice?

Rupprecht Law, P.A. is a boutique law firm that practices in the area of drone law. That’s it. We do only drone law all day every day.

I love transparency. Here are some open-source things you can look at to verify I’m not making anything up:

  • Google reviews here. And no, I didn’t pay for any of them!
  • Jonathan is a licensed attorney in good standing with no disciplinary history.  Florida Bar website.
  • All of my filings are on Regulations.gov. Just skim through and see if you recognize some of the major multi-billion dollar companies.
  • Media mentions citing me as an expert. Directory here.
  • I’m a contributor at Forbes.com for Aerospace & Defense.

Rupprecht Law currently advises a wide variety of companies interested in using drone technology, from small start-ups to many companies that generate revenue in the billions of dollars per year. Don’t believe me? Go click the regulations.gov link and see the companies I’ve worked with.

The Drone Dealer Package

This package is designed just for manufacturers and drone dealers. I’m now offering two new petitions for exemptions, along with instructions on obtaining a special type of registration. Let’s dive into each one. Here is what the package includes:

  • Exemption 1 to Teach Students/Customer. We are now filing petitions for the facilitation of flight experience. Most of the 55-pound and heavier exemptions all prohibit the training of students who are not employees. This is really annoying if you a manufacturer, drone seller, or teacher. The solution to this is to obtain an exemption that allows you to facilitate a non-employee to fly a drone…even if they do not have a Part 107 remote pilot certificate. The student does not have to be an employee. We have obtained multiple of these exemptions for clients. HSE was not the first to obtain this exemption. I obtained this exemption before them. I
  • Exemption 2 to Demo Fly, Evaluate, R&D, and Other Commercial Ops. This exemption is to evaluate, test and demonstrate unmanned aircraft, as well as to conduct surveying and mapping, industrial-site inspection and monitoring, and other commercial services using such products. This exemption is like a Swiss Army Knife. If you are a manufacturer or drone seller, this one allows you to demo-fly different aircraft for potential customers. It also allows you to conduct R&D and test the aircraft. If you are an operator, you can also use this exemption to allow do various commercial operations such as surveying, mapping, and industrial-site inspection and monitoring.
  • Drone Dealer Registration. (For Sellers and Manufacturers) Don’t you wish there was a way to quickly assign a registration number to a drone and take off quickly?  None of that hassle with registering the drone and waiting for weeks before an N-number is returned. There is a solution! This is extremely valuable for doing demo flights for potential customers, doing a quick checkout flight for a potential customer wanting to check it out prior to delivery, for a manufacturer who needs to test fly a repair on an unregistered drone, etc.  You don’t have to have extra inventory lying around or a “seasoned” N-number registered drone. You can just file some quick paperwork, put a temporary registration on the drone, and fly it. If you sold the drone, just peel off the decal and head back to the office to use it on another drone. One benefit of this is that it allows you to be asset-light. You can just open your inventory and then go demo fly it. You don’t keep an older demo unit around. You just use fresh drones. To be legal you need to obtain a dealer registration AND one more approval to make everything legal.  We’ll help you obtain both approvals.
    • Who can apply for Dealer’s Aircraft Registration Certificates?
      • Manufacturers
      • Distributors
      • Dealers
    • What can we use a dealer registration for? 14 CFR 47.61 says, (1) Allow manufacturers to make any required flight tests of aircraft. (2) Facilitate operating, demonstrating, and merchandising aircraft by the manufacturer or dealer without the burden of obtaining a Certificate of Aircraft Registration, AC Form 8050-3, for each aircraft with each transfer of ownership, under subpart B of this part.

DELIVERABLES:

  • We will file one petition for exemption for the facilitation of flight experience.
  • We will provide you a training manual and operations manual for the facilitation of flight experience exemption.
  • We will file one petition for exemption to demo fly, evaluate, R&D, and other commercial ops.
  • We will provide you a training manual and operations manual for demo fly, evaluate, R&D, and other commercial ops.
  • The following three documents:
    • Subcontractors vs. employees in Drone Operations  (since the one exemption allows for commercial operations, we include this).
    • 40+ Drone Crashes to Learn from (great to teach students from)
    • Contracting Strategies and Provisions for Drone Operations (since the one exemption allows for commercial operations, we include this).

PRICE:

Non-refundable out-the-door flat fee of 2,000.

MORE INFO:

  • Time: The whole process is going to take you around 90-180 calendar days to obtain the exemptions. Obtaining the dealer registration and associated document could take 60-180 calendar days total to obtain both.
  • Cost:  Flat fee out-of-the-door price of $2,000 for everything.
  • Duration:  As long as you keep renewing things with the FAA, the registration numbers stay good.  I can see you say now… “Ha! I see you now. And what is that going to cost us?”   Nothing. Just use the instructions again to renew things.

FAQs

  • Can I train customers on spraying drones and non-spraying drones? Yes, you can provide facilitation of flight experience on different type of aircraft provided they are on the FAA-2023-1271 list.
  • Can I do anything else with the 2nd exemption? Yes, the 2nd exemption is like Swiss Army Knife and allows for all sorts of demo flying, testing, R&D, inspections, and other similar commercial services. You could do a demo flight with it for a potential customer and then use it later to go and obtain data using LIDAR
  • Are there are any “gotcha”s I should know about? A lot of it is the typical stuff you deal with in other exemptions but there are some noticeable differences.
    • Both exemptions require a visual observer which is very unlike the Part 137 exemptions that do not.
    • They both have 500ft buffers with no reductions like we have the Part 137 exemptions.
    • They both require 3rd class medical certificates for the RPICs. The student doesn’t need a medical.
    • They both allow for only one drone per remote pilot in command. (No swarming)
    • Both are daylight only. No night.
    • For the facilitation of flight experience exemption to educate students, the RPIC must have passed either a sport, recreational, or private pilot FAA airman knowledge test before acting as PIC, or, in the alternative, hold any 14 CFR part 61 pilot certificate (other than a student pilot certificate) and meet the flight review requirements of § 61.56.
  • I want to know the real limitations. Where are the exact conditions and limitations? Sure. I love transparency. Here they are. Exemption 1.  Exemption 2.

NEXT STEPS:

You have 2 things to do.

  1. Fill Out The Contract  You can fill out the contract using the RSign links below. Click the link and fill it out. It asks for all of the information I need to know to start the process. If I have questions, I’ll contact you.   https://sign.rsign.org//SignDocument/StaticTemplate?uBsWi6e3zUtDJYKKi4ra%2fV5Qm9%2fvmzyaMWm3XDDy2AFLQnB3M37%2fFEQbBRIWe7UD
  2. Payment. You Have Three Different Ways To Pay.

Consultations

Remember that saying, “There are no stupid questions.”  That’s wrong. There are stupid questions …. those are the questions you didn’t ask me, and then you ended up getting yourself and your company into trouble because you failed to ask them. :)  The attorney-client privilege is a wonderful thing. It protects the content of our conversations so we can have open conversations without fear it will be used against you. Please note that this does not apply to consultants. It’s attorney-client privilege, not attorney-consultant. If I were a prosecutor or plaintiff’s attorney coming after you, the first person I would send a subpoena to would be the consultant you are working with. They have 1 of 3 choices: (1) lie and risk going to jail, (2) not talk and risk going to jail, or (3) rat you out. As an attorney, I have a fourth option, the attorney-client privilege would shield our conversations and I stay quiet. The other benefit to being an attorney is that if your question really is a stupid question, I can’t tell anyone it was really stupid so your secret is safe with me. ;)

I have streamlined the process people can use to hire me.  This is how I handle consultations. I charge a flat rate of $200 for 30 minutes. During that time, you can ask me as many drone questions as time permits. I can also ask you questions to clarify things. I can also sometimes see some issues you might not be aware of and answer those issues. For example, I might just respond, “That’s a great question but here is the big gotcha on the backend that you need to know about.”

To get started, scroll to the bottom and contact me. I’ll send you two links so you can sign a digital contract and pay via credit card. We’ll schedule a time to talk. You can also send over a list of questions you might have before we hop on a call. You ask me as many questions as you want during that time.

Here are some of the questions I get asked:

  • Are there any good business opportunities right now?
  • How do the regulations influence my aircraft purchasing decisions?
  • We want to start a business doing  X.  What issues do you see?
  • I received a letter from the FAA saying they are investigating me. What do I do?
  • What are some ways I can mitigate my risks?
  • How do I set up a drone training program?
  • I took photos for fun and now I want to sell them. Can I do this?

Issues you might not have thought about:

  • The FAA’s view of how operations should be done (under a waiver/exemption/authorization) and how that interacts with employment classification (1099 vs W2). This is a big issue when it comes to setting up an operation with multiple pilots.
  • How the Department of Transportation’s regulations affect your operations. The FAA has safety authority while the DOT has economic authority. Many people are unaware of some of these DOT regulatory “gotchas” until I tell them they have been violating the law for years.
  • How the TSA regulations might apply to your internal in-house training operations.
  • How you might want to obtain a particular type of rarely asked-for insurance if you are providing drone flight instruction. Or is that even an issue?
  • How certain items of technology might be regulated.
  • How certain types of equipment attached to a drone might trigger certain federal laws or hazmat laws.
  • Where to incorporate your business and what state laws should govern your business contracts?

Applying for a Waiver (Beyond Line of Sight, Swarming, Reduced Visibility/Cloud Clearance, Etc.).

Are you interested in a Part 107 waiver or a Part 91 waiver? I can help with some of them. I have helped over 100 clients obtain waiver approvals. My waiver passage rate for waivers overall is 90+%.

Before you send me a quick email, I created an in-depth FAQ post on waivers and authorizations.

We can also schedule a 30-minute road mapping session ($200) where you and I can come up with a legal/business game plan to achieve your goals with waivers. You might think you have it all figured out but……sometimes there are some fun “gotchas” on the backend that you might not be aware of. We can discuss those during the road mapping sessions.  Waivers involve risk assessments, waiver applications, training manuals, operation manuals, checklists, emergency procedures, etc. Yes, I’ve done all of those.  The more complex the operation and the waiver, the more complex the paperwork.

On top of that, certain waivers have certain issues that others don’t you might not be aware of. One may have a ground risk issue while another may be air and ground risk.

To obtain waivers, I’ve created (I’m a current FAA certificated flight instructor so I don’t outsource my work to pilots like other well-known drone attorneys with no aviation background):

  • Operations Manual
  • Training Manual
  • Safety Management System Manual
  • Safety Security Instruction Manual
  • Qualitative risk assessments
  • Quantitative risk assessments (these are my favorites).
  • Concept of Operations (CONOPs) documents.

Scroll to the bottom and complete the contact form to start the process.

Applying for a Certificate of Authorization (COA) (To Not Broadcast Remote ID or to Fly Near an Airport)

Airport COAs. I have helped clients obtain over 50 COA approvals. I’ve even obtained COAs to fly at an airport while operating under a waiver.  Commercial drone operators sometimes need help operating in Class B, C, D, or E at the surface associated with an airport airspace. The LAANC system is beneficial for many operations but not all such as when you need to operate really close to the airport (one of those zero areas on the airport facility maps) or when you want to use a waiver or exemption in the airspace (e.g. flying at night in controlled airspace). For situations like those, you might want a Drone Zone COA. I have helped clients obtain airspace COAs (including exercising their night waivers at the airport).

I currently charge a flat rate of $500 per COA per airport provided there is no waivers involved. Scroll to the bottom and fill out the contact form to start the process.

Remote ID COAs. There are times when you might want to obtain authorization to deviate from the remote identification broadcast requirements such as when you’re law enforcement and you don’t want the drug dealers to be able to detect your drone or your operations cannot comply due to some physical/technical reason (FPV racing is an example).

Scroll to the bottom and fill out the contact form to start the process.

Petitioning for Exemption (Flying Aircraft 55-Pounds & Heavier, Part 137 Drone Spraying Operations, package delivery, etc.)

In July 2016, the FESSA changed what is allowed under the Section 44807 exemptions (formerly called Section 333 exemptions). While Part 107 replaced the need for many exemption operations, there are very good reasons to have an exemption such as:

  • Drone spraying operations (crop dusting, pesticide spraying, pollinating, etc.)
  • Operations involving aircraft that are 55-pounds or heavier (because Part 107 is only for under 55-pound aircraft).
  • Part 135 package delivery.

I have helped clients obtain 300+ granted exemptions.

Scroll to the bottom and fill out the contact form to start the process.

Starting a Drone Spraying Operation

One thing I’ve been focusing heavily on is assisting clients with starting their drone spraying operations. I have obtained 300+ exemptions for drone spraying and 50+ operating certificates.

Based upon FAA provided data from 6/3/2022, you’ll see some interesting stats. In the interest of truth and transparency, the FAA database providing me that information appears to not be complete. I know this because some of my certificated clients did not show up. I pointed this out to the FAA and they are looking into it. If some of my guys were missing, others might be missing also. Take it for what it is worth but it is the best data was have.

Part-137-operators-Rupprecht-helped-start-1
Part-137-operators-Rupprecht-helped-start-1

Interestingly, you’ll also notice a few consultants and other attorneys who have helped clients get all the way to an operating certificate. I focus on getting clients up and running, not just filing paperwork and leaving them to flop around like they were some newborn baby giraffes.

My current services and prices are located here.

I wrote a large article on drone spraying and it is posted here. https://jrupprechtlaw.com/drone-sprayer/  It goes into economics, the law, how the law affects economics, etc.

Helping Government Entities Obtain a Public Certification of Authorization (COA)

The federal statutes that lay out what a public aircraft is can be confusing. But before you decide to obtain a public COA, it’s important to understand the best tool to help accomplish your mission. Some consultants and drone resellers push public COAs (because they aren’t proficient in aviation law) and lead government entities down a road that is not best for them.

A public COA is one of multiple legal approvals that government entities can use. See my large article comparing the different methods.  Rupprecht Law, P.A. can assist a government entity in understanding the best route to accomplish their goals which might include obtaining a public COA.

This can include drafting and seeking approval of a public aircraft operator declaration letter and filing the COA application through the portal. Please note that if a consultant offers to draft a public aircraft declaration letter, they are most likely committing the unlicensed practice of law. This can give your operation a “black eye” if it comes to light that the person helping you comply with the law is breaking it in the process. Furthermore, it’s also extremely unwise to rely on a consultant’s advice regarding public aircraft operations as a violation can be extremely unforgiving. Scroll to the bottom and complete the contact form to start the process.

Outside Legal Counsel

Are your attorneys wasting too much time trying to figure out how to navigate the Federal Aviation Regulations? Rupprecht Law, P.A. can help assist your general counsel to get through difficult problems because the firm specifically focuses on aviation and drone law. Your legal counsel can get accurate answers to the many details and complexities of this area. I’ve done this many times with companies. I can help educate your current in-house legal counsel on the major issues they need to be aware of or just take all of these issues off their hands so they are free to focus on more important work. Scroll to the bottom and fill out the contact form to start the process.

Federal Aviation Regulation Compliance

Do you have general questions about whether you can do a certain type of operation? Stop wasting time looking through articles online or searching Facebook groups. You can hire me for as little as 30 minutes at a time to answer your questions. 30 minutes costs $200 and you can ask as many drone law questions in that period of time as you want! Scroll to the bottom and complete the contact form to start the process.

Setting-Up Drone Enterprise Operations Inside a Company

Developing the manuals to scale out a nationwide program is an important task.  Rupprecht Law, P.A. is currently working with companies now on concepts of operations, putting those concepts in a manual, and then integrating those manuals into employee flight instruction operations. Scroll to the bottom and complete the contact form to start the process.

Defense in an FAA Enforcement Action

Sometimes, the FAA chooses to start an investigation against unauthorized commercial drone operations, or there is a violation of the regulations or exemption restrictions. This is more and more on the rise. I have helped counsel clients through numerous investigations. On top of that, I’ve also coordinated with their local defense attorneys in formatting the best strategy.

Assisting a Criminal Defense Attorney in a State Law Related Drone Prosecution

The states, towns, and counties are all starting to create drone laws which causes all sorts of problems. Many of the arrests that are done under state law have to do with apparent violations of federal aviation regulations. I can assist your local criminal defense attorney in preparing the best defense for you by helping him to understand what is and what is not the federal aviation law. We can develop a strategy to attack the case using my aviation law knowledge, which may involve filing certain procedural motions, formulating deposition questions, obtaining documents inside the FAA, etc. Scroll to the bottom to contact me.

All Other (Risk Assessments, Manuals, Business Advice, Reports, Roadmap, Etc.)

The firm gets all sorts of requests relating to drones and law. Here is a list of some of what I have done (I don’t outsource like other law firms):

  • Developing quantitative risk assessments for drone operations under a proposed waiver. I love doing these where you calculate the probability of fatality per hour for a given operation and location.
  • Created:
    • Safety management system (SMS) manuals.
    • Operations manuals with emergency procedures, checklists, down aircraft recovery plans, accident/deviation reporting procedures, etc.
    • Training manuals for company-wide operations.
    • Special Security Instructions (SSI) manual.
  • Created Concept of Operations (ConOps) documents for waiver operations.
  • Set up an Other Transaction Authority (OTA) agreement between my client and the Federal Aviation Administration.

If you have a legal question regarding drones, contact me.

Other Services (Not Aviation Related)

Over the years of practice, I have become familiar with other areas of law.

  • Farm leases.
  • Solar leases for real property.
  • Florida trusts.
  • Public records laws.

My Google Reviews

Still on the Fence About Hiring Me? Check out these real Google reviews.

Rupprecht Law's Google Reviews
Rupprecht Law’s Google Reviews

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