Saturday, June 7, 2014


The FAA has a huge challenge, they need to get it right the first time. If they screw it up, and a UAS and a passenger aircraft have an issue, where people get hurt, there will be no more UAS allowed! Of course, the UAS industries are clamoring for changes now. Claims of huge employment are dubious, since it will only transition pilots and maintenance from manned aircraft to unmanned (peopled, what is the right non-gender word).

If people think everything under 400ft (1000ft, 2000ft, whatever) should be unregulated, what happens when a traffic accident occurs, and a medical helicopter has to thread it’s way through 5 local TV stations with their quad copters filming the carnage? What are the rules around an airport? The rules have to at least match the controlled/uncontrolled/class A/B/C/D rules that exist for manned aircraft. Rules need to be established, such that assistance cannot be delayed.

Quad copters and other UAS devices are easy to fly when the weather is nice and there is little wind and turbulence. What happens when there is turbulence, or dust or other weather that makes visual queues, and control difficult. How about a slightly damaged older device that isn’t well maintained, and the operator is inexperienced. The innocent people on the sidewalk should expect a reasonable amount of safety near these devices.

Many of the smaller quad-copters are only controllable indoors, and some of the larger ones are controllable in moderate winds. Larger UAS systems are less prone to weather, but are more dangerous to people around them. What happens when an editor or producer is clamoring for a news story on a stormy day? What is the poor UAS operator to do, fly anyway? The operators will be glad to have an FAA regulation that says it isn't safe, so they won't have to stress about it.

There will need to be right of way rules. Right of way rules make knowing what to expect from the other aircraft. It is all great to have see and avoid, but what is the understood direction to avoid things? Most R/C fliers operate with one aircraft in the pattern at a time, so they don't have too many right of way issues. Much of this will be new territory to UAS operators.

For commercial UAS operators, there will need to be maintenance programs designed. Basic maintenance will need to be regulated to insure the craft is controllable, as well as structurally sound. Having a UAS disassemble in flight will make the situation for the operator inconvenient. Inspections, and preventative maintenance programs will have to be defined. 

There will be all kinds of other regulations that most people haven’t considered.
Pilot licensing being one. If a UAS is to be operated in the same airspace as a manned system, the operator MUST know the same rules as the manned aircraft, at least to know what everyone will expect in right of way situations. 

The FAA could mess all this up and not regulate it properly, and people will get hurt. The FAA is already granting exceptions for certain groups, but this sets a bad precedence. They could rush, or some manufacturer could lobby congress to get the FAA out of the way, and people would get hurt. If a UAS took down a 737 you will see congress act!

Everyone needs to be a little more patient, and let the process work it’s way out.


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  3. First, there is absolutely no danger that the FAA will under-regulate UAV operation or anything else. If anything can be said about the FAA is that it is thorough, which is part of why it has taken so many years to develop rules applying to "Unmanned" (remotely piloted) Aircraft.

    You can be sure that there will be no UAV operations near airports (already prohibited and actually programmed into some craft now), no operation over 400 ft AGL or operation beyond VFR (1/2 mile) will be allowed without a formal flight plan or other means of coordination with other aircraft, passing a written knowledge test, logs of flights and maintenance, insurance coverage as well as formal safety standards dealing with winds, proximity of people and property and so on can also be expected requirements.

    We can also expect that operator competence verification will be there as it is with all other aviation operations under the FAA's authority. The first to be licensed as "drone" operators will be those who already holding pilot licenses, as several existing FAA documents would indicate.

    Existing privacy laws apply because on the ground or in the air: it's still a camera, just as laws apply to a GoPro on the end of a fishing pole.

    It would be simple to establish that a red or yellow tape fire or police line perimeter at a crime or accident scene includes the airspace above the tape: Nobody crosses the line, in the air or on the ground, without permission from those in charge of emergency operations. Insurance stipulations easily discourage commercial operators like news crews from operating where their coverage would not apply, like in restricted areas without permission.

    Most of these kinds of discussion contain little more than a rehash of the same misconceptions and serve little purpose beyond causing undue alarm and impeding the process.

    1. I am not trying to rehash anything, I am trying to get people to calm down, and wait for the FAA to finish. Once the exceptions start happening, then rogue operators will think they can do "the same thing" as the folks who got exceptions.

      The big fear is that it'll be the wild west, and people will just buy a UAS and fly whenever where ever. There are no rules, so they can't be enforced.

      Even the definition of commercial can be fuzzy. The manned systems have Part 121 (scheduled), 135 (on demand), and 91K (owner operators). Each type of operation have different rules, and licensing. I can see UAS operators getting a mix of the 135 and 91K matching certificates, and doing their own things.

      Your point about coordinating with other aircraft is the biggest challenge. Certainly a Taylorcraft that is operating VFR doesn't require a flight plan, or a transponder, or probably ever will need ADS-B. It was built without an electrical system, and to put one in would cost more than the airplane is worth, never mind putting in a panel mount WAAS capable GPS with ADS-B out, that will double the cost, and the airplane will still be worth only about $12000. (yes, you can buy a certified airplane that is cheaper than your car!). Coordination will be impossible, since these aircraft have no radios or flight plans to coordinate to. Many GA aircraft will wait until the last minute to get a ADS-B system installed, simply because what is out there will not add any value to the aircraft.

    2. The 12000 taylorcraft

  4. My comments were not intended to counter or argue against your points but to expand on them. I agree there are dangers associated with section 333 exemptions but there are also dangers with continued forestalling of some kind of incremental implementation.

    My view is that by failing to at least establish an interim registration process the current delay is CREATING a "wild west" atmosphere. A more logical approach would be for the FAA to begin issuing RESTRICTED operator (student pilot?) permits for use, for example, under 150 AGL with other conditions/restrictions (liability insurance, safety procedures, logging, training) and provision for upgrade to 400 ft AGL with (AKT) testing and other requirements when final rules are eventually established (hopefully before 2025).

    Do I have any delusions that will actually happen? Of course not. But I still believe it WOULD be the most logical next step at this point.

    As you indicate, Airframe Certification is going to be another major issue beyond the operator issues. There does appear to be some tendency toward a "one size fits all" solution which will simply not work because the $12,000 and $1,200 "drones" are worlds apart beyond the differences in cost. There needs to be a minimum of two or three distinct classifications with corresponding training, knowledge, and other qualifications. There is simply no way a Predator is practical for real estate photography and a DJI FC-40 or Phantom operator is not in a position to pay $10,000 a year for insurance, nor should they be, not only because the risks are far smaller but because the returns are simply not there with 15,000 competing units being sold each month. That number is the other reason why continued delay only makes the situation worse, ...which goes to support your "wild west" point.

    RE: ' Most R/C fliers operate with one aircraft in the pattern at a time,..." I have found that not to be the case at AMA club fields where many craft are flying at the same time up to the limits of available control channels. Veteran R/C flyers demonstrate unbelievable flying skills under crowded conditions at events.

  5. $12,000 was probably a bad choice for contrast. The UAV's the military manufacturers are hoping to sell for "public safety" start at more like $30,000, weigh hundreds of pounds with a range of miles. A $30- $150,000 Predator, Reaper or Hummingbird modified for civilian use does fly beyond VFR and SHOULD include ADS-B. Again, not on a scale suited for doing car lot TV commercials.