hey RCAPA guys, fill us in! (UAS regulations)

[jetblackaircra]

Egan, I'm sure you can tell this is directed at you. You've mentioned on several occasions having information about how the FAA intends to deal with UAVs in the future. So lets hear it.

I want everyone to understand, however, that any regulations made by the FAA always first are published as an NPRM or Notice of Proposed Rule Making. This means that the general public gets to see the actual text of the regulation and respond with comments or suggested changes. Typically people who are unreasonably affected by the rule are accommodated if they have a legitimate complaint and solution.

So, lets hear what you think they have in store for us. I'm sure it will help us all to know in advance so we can have our responses to the NPRM ready.

[Cort]

love when someone stirs the water. I am glad that someone has finally called it. I am getting a little tired of the negative and would like to here more of the positive. I am a licensed pilot and involved in Ap and know that a lot of GA whats to see integration happen. The fear and possible misinformation just keeps the masses at bay and others working behind the curtain.....Just my opinion of course.

Keep up all the good work

[patrickegan]

Well, here is the Cliffs notes version…
There is an sUAS ARC on http://www.faa.gov/about/committees/rulemaking/media/order1110_150.pdf
Furthermore there are other global airspace initiatives happening simultaneously UK CAA CAP 722, EUROCAE wg-73, Canada has a SFOC process.
We’ve (ARC participants), been asked not to disclose who is on the ARC and what exactly is happening. So, if you were hoping for specifics you may very well be disappointed. I will say that we are up against people who are concerned about their safety and others who are concerned about their business model. However, the RCAPA has made as much of what is going on available for public review.
http://rcapa.net/RCAPA%20Reporter/site/
http://www.rcapa.net/forums/index.php
Being on the pro-sUAS side is a difficult place to be, we have several 800lbs gorillas in the room and are by no stretch of the imagination calling the shots. We are under staffed and are underrepresented in certain aspects of the ARC. We as a community lack the resources to keep a presence with the ASTM, RTCA, EUROCAE etc. We also lack the money to attend the other meetings like UVS Canada, TAAC http://www.psl.nmsu.edu/uav/conferences/2008/ or the other various meetings that happen monthly around the world. We also lack cohesion that might support information sharing white paper writing and other research projects.
Some of the hurdles and misnomers we face…

Those with interest’s way outside of our scope will take care of our interests.
An unrealistic view of how the other airspace stakeholders see this new technology.

Lack of investment in the integration effort, from top to bottom.

Years of denial that changes in regulations are coming and the ongoing lack of unity from within the community.

Contempt from end users who feel they are safe and don’t need regulation, or will be unaffected by any FAA regulation.

The notion that common sense from government regulators will prevail.

People that post pictures and video thread titles that suggest unsafe use of the NAS.

Again, I can’t really discuss who and what besides we will be limited to visual line of sight, and that is not changing until a certified sense and avoid system is developed. RTCA guidelines for a sense and avoid system 2013 to 2017. There will be a pilot in the loop (PIC), for the foreseeable future. Many of the projects I see you guys working on may not fit into what is being proposed. The notion that there is some amateur UAV exclusion is a misnomer. Right now it is more of a loophole that will more than likely get closed.True there will be an NPRM, but I’m not holding my breath. Finally, the notion that the FAA can’t enforce their own regulations doesn’t make for a good business plan.

[jetblackaircra]

I totally agree that hoping for the FAA to not enforce is a bad business plan. However, I have no problem with the idea of flying my UAV for hire while following reasonable guidelines like line of sight, etc. The question becomes what is reasonable and what is unreasonable. In my past experience with changes in regulation and how they affect businesses... When the FAA intends to put a regulation in place which a business can show will unfairly affect their business practice (i.e. cost too much to comply, or a regulation which will add cost but add no benefit/safety to anyone) the FAA has been reasonable about working with that business. They are not out there to put rules in place for no reason, so, during the NPRM process it is not simply a one way street where people are sending in complaints and they look them over and take the ones they like. They are REQUIRED to respond to each issue that is brought up specifically. And in my experience they are typically asking questions, sometimes they will ask for the company to explain their question, sometimes they will explain why they feel the change is necessary and ask the company for more input.

Granted, my experience comes from working for a large aircraft company who deals with the FAA daily.

But, I agree with you on one thing... I think we need to organize a group of BUSINESSES, not hobbyists, to group together and as a whole discuss the NPRM when it comes out and either submit the same suggestions seperately, or as a whole. I think that if 10 or 15 UAV businesses had a well formatted and well thought out submission of changes and they were all the same, the FAA would get the idea that maybe we know what we're talking about and maybe we need to be heard.

Not to belittle your efforts thus far. I'm glad someone is out there on the ground floor. Someone has to be there in the beginning stages to make sure the FAA isn't incredibly off base.

But lets talk about what businesses would like to be involved in a gathering of minds when the NPRM comes out.

If you own a business, or are involved in a business which uses or plans to use UAVs, either autonomous or otherwise, to provide any service for hire, post a response and tell us about your company.

I'll start.

----------------------------
Jet Black Aircraft Company
Norman, OK
405-501-6556

In business for 15 months. Developing an unmanned aerial vehicle to provide aerial live video feed for surveillance, search and rescue, video coverage of sports/news, etc.

Aircraft designed in house called PD2A is in flight testing stages. Autopilot being designed by Jet Black and Synappsys Digital Services is in advanced stages of testing.
-----------------------------

So, give us somthing like that

[patrickegan]

What you can do

http://www.rcapa.net/forums/showthread.php?t=10

[patrickegan]

Anyone going to TAAC? http://www.psl.nmsu.edu/uav/conferences/2008/

It would be a good opportunity for those that may be thinking about a future in UAS to get the lay of the land .

[octane-link]

I can tell you about my experiences.

I work in research at CU-Boulder. For us, it is mandatory to fly with a COA (Certificate of Authorization). It is my belief that since we are a public institution, we don't have to go through the process of getting a tail number like Raytheon did with their Cobra UAS. We have gotten two COA's for two of our aircraft, one in-house design and one COTS plane that we modded for our payloads. We are working on a third COA right now too.

The first COA took about 6 months to get, we made mistakes that slowed down the process. The second took a few months and was relatively mistake-free, its just that the FAA UAS office is overwhelmed and understaffed (old story in govt work).

Hopefully this helps a little bit. I don't think hobbyists are affected yet, that would be an administrative nightmare to police everyone who flies model airplanes.

[patrickegan]

Octane,
Thank you for your insight. Maybe we should do a poll to find out what folks are up to. From I’ve got bucks to burn, to someday I hope to be Boeing. It could be advantages to people entertaining the idea of a business venture or shed light on what the hobby costs… :)

[jetblackaircra]

*looks at his previous post* yeah, a poll to see what people are up to is a GREAT idea! why didn't I think of that?

Octane,

I would love to be able to get some input on applying for a COA. How willing would you be to help us out a bit with guidance?


Thanks
Mike

[patrickegan]

They have enough time to attend the TAAC show. :rolleyes:

[octane-link]

Mike,

I was not intimately involved in the COA process, so I wouldn't be of much help with the nuts and bolts. However, I think your company would have to apply for a tail number since you are a private commercial entity. I know nothing about that end of it.

[patrickegan]

You need a public sponsor, but I know a guy who got one (COA), for the local sheriff and knows the in's and out's.

[jetblackaircra]

Have a contact email? Sounds similar to what we're wanting to do.

[patrickegan]

Poll done!

After a quick peruse of the threads it has become apparent that most here have interest (financial), besides the occasionally Sunday outing. The “I’m an amateur UAV guy” lacks plausibility, especially from a group with some much technical skill. That’s all fine and dandy, but there are questions that remain unanswered, these are question any serious investor and or client would ask.

Drone ask, drone tell (stole that from another article), is a poor excuse for a business plan.

[lvspark]

Did I miss a poll somewhere?

[jetblackaircra]

No, Egan did his own "poll". The 15 year old in me is just aching to say something about that, but.....

[patrickegan]

Go for it...

[jetblackaircra]

Lol, I'm sure everyone can figure it out... sometimes a little immature humor helps me get through the day.