FAA certification, what will it cost?

[patrickegan]

Anyone have a ballpark number they'd like to throw out? Has anyone factored that into their system business plan?

[Ginger Adam]

Just a guess, but I'd imagine it will be just enough to make 95% of the market quit before they even start?

Adam

[bmw330i]

Will the FAA even certify a FunJet?

[Tom Harper]

If you are not a government agency, don't even try.

[patrickegan]

Will the FAA even certify a FunJet?

How about certify and register

[brnjones]

Anyone have a ballpark number they'd like to throw out? Has anyone factored that into their system business plan?

I don't think you could make a cost estimate until you meet with the FAA and discuss the particulars of your system, its intended use and purpose. The required documentation would vary based on those factors. Check out this website for some good info, in particular FAA 8130.34:

http://www.faa.gov/about/office_org/headquarters_offices/ato/service_units/systemops/aaim/organizations/uas/coa/faq/

[CenTexFlyer]

You could go with some of the estimations given of early ultra-light aircraft. It was estimated that if full certified, the ULA costs would go up by 3 to 5 times the cost of the airframe itself.

[fnev]

I am new here and lucky enough to work in the industry (chief designer for UAV's). This is a VERY costly exercise if you fly as a civilian. The requirements are as well EXTREMELY stringent. Go to the link mentioned above and you will understand what I mean. Good luck!

[patrickegan]

Even if one goes to the link above it is on a case by case basis with (in most cases), a very limited area of operation. There are not commercial guidelines to follow, but using manned as an example I think we would be looking at six figures.

[fnev]

Sorry, but you may not do a comparison with a manned aircraft. One of the requirements is to justify and qualify the range limitation. Just this in itself opens a big can of worms.
If you are flying with remote HOW you do GUARANTEE the plane WON'T go beyond the fixed range (even in visual)? Just GPS coordinates won't be enough because what they want is TOTAL guarantee that the plane won't fly further AND will stay in its fixed range radius (or square, but even more difficult).
So, you will have to do ALL the qualifications required by an experimental aircraft PLUS all the qualifications/justifications of the ground control segment! Believe me this is NOT trivial and requires a level of data link(s) and navigation system(s) very complex AND sophisticated.
BTW you have the very same problem for the altitude limitation(s)... And how you justify failure(s), lost of coms, etc.
What the authorities want is to ensure that NOBODY plays FREELY anymore in this field because of the (unfortunately) to many ways to use these (too simple) technologies for "nasty" applications/uses.

[brnjones]

Concur with fnev...you have a lot to prove to the FAA before you can get a airworthiness certificate and COA. It is all on a case by case basis. If you come up with some novel methods of answering the FAA concerns fnev listed maybe it won't be insurmountable. However, there are strict limitations on commercial use of UAVs at this point. My best suggestion would be to go meet with the FAA and discuss your plans early. Have them involved in the design so you don't go down a dead end and waste time and money.

[patrickegan]

You are partially correct. You also have to understand the manned community is nervous about this technology and rightfully so. The AOPA sponsored me to fly a 182 out of Palo Alto airport http://skyvector.com/airport/PAO/Palo-Alto-Arpt-of-Santa-Clara-Co-Airport
Flew a round trip out to Half Moon Bay and back. The traffic is so heavy that a hotdog stand could clean up in there. SFO, San Jose, Oakland and Moffett all types of fixed wing and rotor craft in the area. Then you have the mountains, it’s a populated area and to top it all off some areas were stormy that day. The goal wasn’t all to have a nice day of flying, but to share perspectives about the airspace. Talking from my personal experience I would have to say that it would be very difficult to see anything coming up at you or something traveling laterally or from behind. They have much more to lose in an airspace conflict than you.

[bmw330i]

fnev/brnjones: Are there any companies/consultants that assist with this process? I am sure when RC aircraft were born there was similar concerns. An organization AMA was born to help keep it legal. This is simple the next evolution of model aircraft. I wonder if the AMA will step up to the plate or not or some other entity. However, calm, reasonable good information like what you to have posted sure will go a long ways vs the emotion driven imagination fed stuff I usually read online in forums.
-BMW

[patrickegan]

emotion driven imagination fed stuff I usually read online in forums.
-BMW
Just substitute forum for process

[spitfiremk9]

[
What the authorities want is to ensure that NOBODY plays FREELY anymore in this field because of the (unfortunately) to many ways to use these (too simple) technologies for "nasty" applications/uses.[/QUOTE]

I don't agree, what the authorities want is to ensure they can continue pissing in the pockets of large global companys, scince when has the nasty element ever given two hoots about registration!?

[brnjones]

You are partially correct. You also have to understand the manned community is nervous about this technology and rightfully so. The AOPA sponsored me to fly a 182 out of Palo Alto airport http://skyvector.com/airport/PAO/Palo-Alto-Arpt-of-Santa-Clara-Co-Airport
Flew a round trip out to Half Moon Bay and back. The traffic is so heavy that a hotdog stand could clean up in there. SFO, San Jose, Oakland and Moffett all types of fixed wing and rotor craft in the area. Then you have the mountains, it’s a populated area and to top it all off some areas were stormy that day. The goal wasn’t all to have a nice day of flying, but to share perspectives about the airspace. Talking from my personal experience I would have to say that it would be very difficult to see anything coming up at you or something traveling laterally or from behind. They have much more to lose in an airspace conflict than you.

Concur! The first thing the FAA will ask you is, "where do you want to operate this UAV you want to get a COA for?"

If you have technology that can adhere to the "see-and-avoid" rules of the national airspace, then you could at least discuss with them eventually flying in the bay area airspace you describe. However, you'll be sanctioned into a restricted airspace for a while until you could demonstrate such technology.

[brnjones]

fnev/brnjones: Are there any companies/consultants that assist with this process? I am sure when RC aircraft were born there was similar concerns. An organization AMA was born to help keep it legal. This is simple the next evolution of model aircraft. I wonder if the AMA will step up to the plate or not or some other entity. However, calm, reasonable good information like what you to have posted sure will go a long ways vs the emotion driven imagination fed stuff I usually read online in forums.
-BMW

I am not aware of any specific companies for hire. I am sure some defense contractors that have experience getting a COA that one could hire for help.

For hobby UASs, I think some sort of AMA for UAS could be setup with the support of one of these contractors with a government agency that can get airspace.

The FAA is stuck in the middle of keeping the public safe, fostering innovation and private industry. If someone has a viable UAS they want to test out, the FAA will work with you, if you are willing to work with them. Another example of a potentially dangerous aerospace technology in the hands of hobbyists are are extreme model rockets. Granted, you have to go out into the middle of the desert to use them, the FAA is willing to work with those folks.

[patrickegan]

How's that?

[fnev]

When I started working in the (at the time) UAV business, it was almost only for military applications. Most of the companies involved at this time were part of the defense industry. Because of the progresses in technology, things were getting more affordable and not as cumbersome: civilian applications started to be considered. Private companies, often coming from or subsidiaries of the initial defense industry, started to invest in this aeronautical segment.

At the same time, civilians (both governmental agencies and private identities) realized the potential for unmanned air vehicles and their (perceived) lower cost for some applications. We are speaking first of paramilitary applications (i.e. law enforcement, surveillance, monitoring, etc) but as well for geological survey, disaster area monitoring, wildlife monitoring…the list is rather long. Some of these applications belong more to the sci-fi or the dream as they call for systems that are so complex and expensive that only the military can afford it. Some others are really feasible.

Now the problems arise when these companies need to develop, test, qualify and eventually train personal. This is the reason for the beginning of the regulation under the experimental aircraft umbrella. It is VERY important to say that this is under NO circumstance a regulation to operate COMMERCIALY these UASs.

Yes, the authorities are regulating. But WHO you think is behind this: these companies investing millions of dollars in the hope of selling their systems. They do not want to see all their efforts ruined by an advanced amateur getting involved in a very bad accident (i.e. air collision with a commercial aircraft or a crash in a populated area with in both cases fatalities). Let face it and be honest, the definition of model aircraft as a hobby is stretched to the extreme and legally not justify for this. If something drastic happened, the first reaction from any authority will be to forbid everything and then discuss… It will take a LOT of time to (re)negotiate a basic set of regulations.

Please, don’t come with you freedom rhetoric: already on this forum freely available information could be used for VERY bad applications…. Combine this with the air space control nightmare and you have enough (for any one with some common sense) to justify regulations. Now, the few very serious individuals that still want to be involved with this activity will have to become more professionals and eventually part (or create) a commercial identity. For the rest, this is the end of free play and experimenting.

I am not jugging or expressing my (philosophical) opinion, simply telling some of the more critical facts leading to the URGENT need of regulations as far as “amateur” UAS are concerned. It is going to be more and more difficult to fly remote controlled aircrafts outside of a controlled environment. I can already hear the screaming. Do you know that any flying club as to register and get its flying area approved? Sometime a NOTAM will be issued, restrictions of flight space imposed on the users.

Oh, yes, we still have the 0-500 feet at “our disposal”… Officially: yes, practically: very difficult to achieve unless… you are flying a model aircraft within its intended envelop!!! OR: you have a very sophisticated system for guidance and a very solid link….

[patrickegan]

Fnev
A lot of what you say has validity. This industry is suffering from being told how we can do business and that will never work! Everyone is trying to sell the notion that we are all hobbyist (wink, wink, nod, nod) All of the loopholes are going to get closed up and we are going to go from the closet to the grave unless this groups gets proactive real quick.

[DT56]

Liability insurance may be the most limiting of factors for you.

[Gary Mortimer]

I reckon it will be an FPV flyer that has the first big off!!

Oh I'm inviting flames there.

Just because there are a lot more of them.

Also its plain that many people are flying in city centres and over built up areas.

It won't be a fatality that triggers it but somebody putting something through an expensive greenhouse or parked car. The owners will then complain to the FAA and they will have to act.

Maybe.

All that said large companies should not be allowed to close the door on shed science development. I don't mean to discredit any of the exciting work thats around when I say that.

Thank goodness I'm not in the USA!!

[Gary Mortimer]

Sorry thats a pretty horrid post.

I will leave it up to create the storm it no doubt might, you never know something constructive might come out of it!

[patrickegan]

We have liability insurance and if we didn’t this industry would be laughed out of every meeting and or symposium. We also have made great inroads putting together the AMA safety code supplement 550

[fnev]

Well, by the look of it these regulations issues are not perceived the way they should. An other tread that started on a technical issue is ending up almost with name calling because people disagree…, sad indeed.

Patrick, you have the right attitude. Being new on this forum, I thought that people were mostly responsible and open about all the safety issues regarding the operation of UASs. Some “good” souls try to operate (commercially) in an environment full of grey areas and UNDERSTAND the needs for regulations. Unfortunately, as usual, they will pay the price for the ones that feel that these regulations are a just there to limit their freedom. In this context how can you blame the “big” companies pushing to limit, or shut down, all activities from “amateurs” in this field?

Someone mentioned that it would be “arrogant” (maybe not in this term but with this meaning) for the “big” companies to “look down” on these individuals that are full of (some time very innovative) ideas. WAKE UP guys, what do you think the purpose of these very official “contests” (in Australia, Europe, USA) is? Just LOOK at the list of the sponsors for such events… It is a very simple and cheap way to gather ALL these innovative ideas. The very smart individuals participating might get eventually hired. But most of the times, once an idea is public, they will use and develop further this idea if they feel it has value.

Don’t get mixed up with the issues of DEVELOPPING a system and OPERATING (commercially) a system. I believe that the existing regulations to DEVELOP a system are NOT too difficult to follow. Yes it is a pain in the behind to go trough ALL the paper work and requirements. But if you are SERIOUS, this shouldn’t be an issue and you will realize at the end that it HELPED you. It helped because it FORCED you to see the problems under different angles and lights… AND this is the price to pay if you want to keep your freedom to develop such systems.

[patrickegan]

When the DARPA gang is grousing that the system is too onerous it can only mean one thing for the little guy! These guys aren't thinking ahead, but only how to make it to the bank. They don't share the passion for the tech beyond the grant or multi-million dollar contract. Less than 5 years ago I was arguing with DoD about sUAS and how they could be effective in IED defeat.

[Andrew McGregor]

Look guys, this is NOT about money or freedom. It's about safety, and the manned aviation community will not compromise about that... and rightly so. And yes, it is hard to do safely in congested airspace.

[CenTexFlyer]

Look guys, this is NOT about money or freedom. It's about safety, and the manned aviation community will not compromise about that... and rightly so. And yes, it is hard to do safely in congested airspace.

Agreed Andrew... however......

There are many venues far away from the congestion that you mention that could benefit from the use of a UA. Or, in environments that manned aircraft would never venture, but we are being lumped into the same environment that Patrick took his flight in. That's not apples to oranges by any stretch of the imagination.

[Gary Mortimer]

Thats very true. I would be flying miles from any CAS whatsoever.

[Andrew McGregor]

Sure... however. So can a manned aircraft, and they won't be expecting you.

Nevertheless, I agree that some discrimination about airspace is in order. Glad I only have to deal with the NZ CAA, who are far more reasonable... basically, if you can show you have the safety aspects sufficiently under control for the environment you're working in and your aircraft could conceivably get to, you'll be fine.

[Gary Mortimer]

Also true Andrew, but I would not fly out of visual range (binos or slowly keep up)

There are tasks that I need that really require loiter over a relatively small area.

Having an air band radio with local frequency selected would also be in the mix.

Like many people here I am a licenced pilot so operating that would not be an issue.

And like you, thank goodness I'm not in the USA!

[fnev]

The company I work for (not in the US) is involved with the local CAA for the regulations of UAS. Guess what? They (CAA) want to base their regulations on the existing US regulations…

Patrick in his cynical way is right: as long as the serious “amateurs” or “low key” pro don’t coordinate drastic actions and try to clean this segment of the “hobby”; the authorities will do it. Unfortunately without ALL the (very valid) input some of you (and more anonymous) could have…

And YES safety is the number one issue for the manned aircraft community. When I speak of the technical difficulties regarding some requirements from the regulations this is ALWAYS in the background.

One of my latest designs (relatively small at 120 to 200 lbs) is fitted with a transponder, voice communication (air traffic and aircrafts) from our ground station. Do you realize the power requirement and mass penalty this impose if you don’t want to go crazy on highly sophisticated links??? The full redundancy and the (almost) mandatory emergency recovery parachute are not making it easier either.

BTW, our test pilot HAS its commercial IFR rating… and we only test in visual (binoculars if needed) range. For “out of sight” flight tests, we RENT a test range (military). I am speaking of systems for civilian applications.

[Gary Mortimer]

Yeah even the military in UK have based their UAV squadrons in far away places and openly speak of the difficulty with mixing with civil traffic.

The boys at Boscombe seem to have managed to get a block of airspace above FL80 and theres a bit in Wales http://www.caa.co.uk/docs/7/20081216AirspaceChangeProposalsTracker.pdf

Probably for playing like this http://www.gizmag.com/go/7072/

I know a couple of the guys from Boscombe watch these threads.

Perhaps someone fom here could join them for this job http://www.jobsearch.co.uk/search.cgi?cat=4&lo=Wiltshire&t=&k=support%20management%20airspace&radius=16000&a=3

And get on the inside track




I guess when it comes down to it though most of us would be in the MAV frame.

Lets hope regulations for sub 7KG stuff sort of CAP 722 will be friendly!

[patrickegan]

I am cynical, heck I was even President of the Sacramento Cynics Society (a short lived entity and a story for another time.) The crux of the biscuit here is even if you can test on the range (or under the radar), who the heck are you going to sell it to? The military avenue here is locked up tight and the other avenues are too small to produce a sustaining income stream.

[jetblackaircra]

I am cynical, heck I was even President of the Sacramento Cynics Society (a short lived entity and a story for another time.) The crux of the biscuit here is even if you can test on the range (or under the radar), who the heck are you going to sell it to? The military avenue here is locked up tight and the other avenues are too small to produce a sustaining income stream.

First Egan, you actually joined an organization called the Sacramento Cynics Society? W T F? lol

I disagree that "other avenues" are too small to produce a sustaining income stream. I feel very strongly from speaking with local law enforcement officials and people involved with department of agriculture crop inspection, etc that there exists in the government (maybe not federal, but state and local) a need for our aircraft. The trick is proving the cost effectivity of the UAV to these organizations. Or, having a cousin who is the mayor of a city or something.

Also, cost of certification is a difficult number to nail down. The engineers on staff here are working on certification as well as many other aspects of the UAV design. It will take up some of our time, but say it took two engineers working half time for a year (which I don't think it would) Then I'd put the cost at $100,000 or less. Very reasonable considering that it costs million(s) to certify a full sized aircraft.

[patrickegan]

First Egan, you actually joined an organization called the Sacramento Cynics Society? W T F? lol

Joined no, founding member! It never really got off the ground as there was deep underlying tension(s) and unanticipated misgivings amongst the chairs :confused:

I’m not talking about the would be legal avenues, but the avenues available in today’s regulatory climate. :(

Most start ups or little guys hanging in there would find 100K a little steep.

[CenTexFlyer]

I disagree that "other avenues" are too small to produce a sustaining income stream. I feel very strongly from speaking with local law enforcement officials and people involved with department of agriculture crop inspection, etc that there exists in the government (maybe not federal, but state and local) a need for our aircraft. The trick is proving the cost effectivity of the UAV to these organizations. Or, having a cousin who is the mayor of a city or something.

The trick you speak of is no trick at all - that's the easy part. A UA can be more cost effective than full size, no question. But what you don't seem to understand is that all the agencies you mention, get matching federal funds for their operations. Because of that they must adhere to all applicable local AND FEDERAL regulations governing their operations. First, they would want to use Federal grant money to purchase your aircraft. Guess what? They can't get that money because it is not legal to operate that aircraft. Second, even if they did purchase the aircraft from local tax revenues, the would stand to lose matching Federal funds because of the illegal operation of said UA. They ain't gonna risk it!

I've been building/flying/demonstrating the Spectra UA now for just over 5 years now. Every law enforcement/fire agency that sees the aircraft and data it produces exclaim "We gotta have one of those!".... until they get into the nuts and bolts of procurement. I commend your spirit and drive but methinks you might need to lift the rose colored spectacles a bit. Believe me, if we had been given the green light 5 years ago, I would very likely NOT be typing anything in this forum!

Gene

[fnev]

The last couple of comments are SPOT on. We develop UAS for military applications. It used to be an insane amount of money for any development for a military requirement. Nowadays in the current economy things are getting way tighter. Combine this with all the potential customers knocking on our doors for civilian UAS and our decision was strategically pretty easy: we have to get in that segment.

Several years down the road, with a couple of very good systems in line with most of the current regulations anywhere (not cheap by any means), we are still alive because of the military business. We are still convinced that a well designed UAS for a specific task has its place. BUT it is NOT going to be CHEAP and we, as a designer/manufacturer, have to get involved with the authorities to ensure that we will be able to operate our systems AND sale them to customers that WILL BE able to operate them commercially…

We have looked at the small UAS business (under 10 lbs). This is where a lot (most?) of the applications exists. The problem is to keep things at a relatively low cost so the potential customer can afford it. This is a VERY difficult exercise as the developments cost are very high if you don’t want to fall in the “gadget” category and have a fairly “robust” system. The biggest problem is visual, radar, radio signature to operate in the civilian airspace. Even out in the boonies you have to make SURE that you are not creating a hazard for ANY air traffic. Working with NOTAM is not a consideration as it requires planning long ahead and therefore limits considerably the use of any small, portable UAS. If you want to achieve this it becomes a major mass/packaging issue. Let say a sheriff wants to use a UAS for search and rescue in Canyon Land. Even without a lot of air traffic you have the odd plane or chopper taking tours. If you fly only within visual range you limit your search area to the extreme especially in a very rugged country. If you fly out of visual range (provided that you have solved the link issues) in a 5 miles radius, how you stay at a preset 300’ altitude, or carry all the stuff on board for inserting you aircraft in the airspace? Give me slack there, it is a lot more issues involved. I am just trying to make a point with an application perceived as “easy” to comply with…

An other big application is surveillance in rural areas. You need to demonstrate that in case of (any) failure you aircraft WON’T fall (crash, land, whatever) on private property and/or individual(s) with “bad” consequences. For this you need to do a failure analysis (NOT trivial), demonstrate redundancy for critical subsystems (easy?) and/or have a recovery system like a parachute (again, possible failure story). Once again it is way more complex than the few items listed here.

Our conclusion is that the market is more “feasible” in the 120 to 200 lbs aircraft segment as it is easier to implement ALL the “nice to have” stuff plus a decent payload with a link solid enough to go far enough and with enough endurance (6 to 10 hours). Such system could be on the market for 1.5 to 2 millions dollars. I can already hear the screaming…
We, as airspace company (not only dealing with UAS), consider that the development of any UAS requires more resources than the development of any other aircraft (plane or chopper). It calls for so much expertise in so many different fields that any development team is rather large for the tasks. And believe me, with numbers above you are not getting rich either! But we are getting paid to “play”…

[Gary Mortimer]

Humm thats locgical thinking and very interesting fnav.

Thanks for that.

A Predator has been configured for environmental work so maybe it will all shake down to only being able to hire that for tasks I have in mind! Hammer to crack a nut.

For the hobbyist small business market perhaps moving the goal posts is more appropriate.

Especially all this talk of over the horizon flights, most desire for that is coming from people new to the hobby that need to get a few more hours on the sticks. Or rather trips home with a plastic bag full of bits. Frightening thought for aviation authorities around the world.

Lots of people would like a device that makes an inherantly stable small aircraft more stable and perhaps hold it over a point in order to take photos.

So getting that legal would be a good starting point.

Both the device in the aircraft and the taking of photos for compensation.

I think the UK is making that happen this year.

Anybody that needs to fly for perhaps 5km or x hours is in a different league and needs to start playing better with the grown ups.

So lets get regs shaped in an image we like for MAVs and let grown up UAVs be just that.

[patrickegan]

Really the marketing is one thing as the technology has the ability to sell itself. The secondary problems are many, but not insurmountable. The damper on the whole deal is regulation that is so anti-business that a viable price point would have to be so low that many manufacturers couldn’t survive. There will be some business when the SFAR comes out (DHS grants), but some will have the market sewed up tight.
Those getting in the game are entering a market were the competition has focus groups, overhead slush funds, contacts, inside access to the markets and procurement people, and that’s just for openers. Spending that much time interfacing with the regulators allows some to learn the needs, wants and potential future markets. This intel puts some folks so far ahead of the curve and leaves others only developing to moving targets. Most of what is being develop has capabilities so far beyond what will be allowed that it amounts to just flushing R&D money down the toilet.

[Ginger Adam]

It would be nice if this was looked at from another angle - the equipment mentioned above is in a totally different league to how some of us would like to operate.

As an example, if it were possible to make a sub-2Kg foamie that I would be happy to fly into my own child and fit it with a system preventing it from flying more than 400 feet above launch point and with an RTL system triggered by radio failure - is it not reasonable that this could be safely operated by someone with (say) a BMFA Model B qualification ?

It seems to me that some of the 'safety' requirements will actually help contribute to the very mass that ends up being dangerous when it lands on someone/something ?

Adam

[patrickegan]

I've made that very point about TCAS. What is effectively accomplished is an increase in lethality with little or no benefit. Even if you could turn it on it isn't very effective at 400'

[lvspark]

There was a time I could get a slowstick EAC for less than 5k, most of that being a trip to DC. I assume that is still a viable price but the waiting list might be long, and why would you want a EAC for a SS anyhow?

5k might not sound like much, but for me, someone that dd it for fun and a little extra cash, it is way to much to justify. Why should the family suffer just so I can go snap a pic or 2 of a fire buring, or a drug grow, or a vineyard, or a road project? Even with a EAC, these activities would not be possible on short notice.

[patrickegan]

They are like hens teeth these days... :)

[jetblackaircra]

The trick you speak of is no trick at all - that's the easy part. A UA can be more cost effective than full size, no question. But what you don't seem to understand is that all the agencies you mention, get matching federal funds for their operations. Because of that they must adhere to all applicable local AND FEDERAL regulations governing their operations. First, they would want to use Federal grant money to purchase your aircraft. Guess what? They can't get that money because it is not legal to operate that aircraft. Second, even if they did purchase the aircraft from local tax revenues, the would stand to lose matching Federal funds because of the illegal operation of said UA. They ain't gonna risk it!

I've been building/flying/demonstrating the Spectra UA now for just over 5 years now. Every law enforcement/fire agency that sees the aircraft and data it produces exclaim "We gotta have one of those!".... until they get into the nuts and bolts of procurement. I commend your spirit and drive but methinks you might need to lift the rose colored spectacles a bit. Believe me, if we had been given the green light 5 years ago, I would very likely NOT be typing anything in this forum!

Gene



What makes you think it's illegal for local law enforcement to get a COA?

http://www.faa.gov/aircraft/air_cert/design_approvals/uas/reg/media/uas_guidance08-01.pdf

read the definition of a "Public Aircraft" All public aircraft are eligible for COA.

[patrickegan]

Centex has one, they are just hard to come by.

[brnjones]

I've made that very point about TCAS. What is effectively accomplished is an increase in lethality with little or no benefit. Even if you could turn it on it isn't very effective at 400'

TCAS is awesome, huge situational awareness benefit, and effective from my experience.

[patrickegan]

Even under 400' AGL?

[CenTexFlyer]

What makes you think it's illegal for local law enforcement to get a COA?

http://www.faa.gov/aircraft/air_cert/design_approvals/uas/reg/media/uas_guidance08-01.pdf

read the definition of a "Public Aircraft" All public aircraft are eligible for COA.

I did not say it was illegal for law enforcement to get a COA, they are certainly eligible for one. So let me clarify that statement from my previous post....

Second, even if they did purchase the aircraft from local tax revenues, the would stand to lose matching Federal funds because of the illegal operation of said UA outside the confined area of operations defined by their COA.

As Patrick stated, I wrote the standing COA for our county a year and a half ago, so I think I can speak to the subject. Our COA is issued for "training and development" and is in a very remote area and covers 3nm from the epicenter.

Most law enforcement agencies wish to fly their UA's in the very environment SPECIFICALLY excluded from ALL COAs..... "aircraft not to be operated over heavily travelled roadways/highways, over populated areas, or areas where bystanders or open air venues operate"

Yes, law enforcement can apply for an "Emergency COA" and I've gotten those as well. But it had better be a life or death situation or the FAA will flat out deny it. 24 hours advance notice requested!

I have been on SAR missions where the person has been missing 7 days and have requested an emergency COA and have been denied because "chances are, they are already dead, so it's not a crisis anymore". This has happened more than once!

So does that "clarification" help?

Gene

[bluesk1d]

http://lemonodor.com/archives/001405.html

How is LASD planning on getting around all the restrictions related to the FAA/COA? I work for a small PD in CA (50 Officers and about 10 square miles of land ranging from residential to commercial to rural hiking/wilderness parks, along with about 7 miles of coastline) and I know we would love to have something with a decent camera platform for S&R or foot pursuits or what have you but the sea of red tape is seemingly endless and quite treacherous.

Octatron's website states the SkySeer requires an FAA license to operate but info is sparse. I am sure LASD would not be purchasing these @30k if they could only fly over open land and count the rabbit population. The onboard video (http://video.aol.com/video-detail/uavs-skyseer/3500913679) leaves a lot to be desired but portability comes at a price I suppose.

This (http://www.uavm.com/uavregulatory/airworthinesscertification.html) also provides some good tidbits but I am not sure how recent it is.

[Andrew McGregor]

Ye gods, am I ever glad I don't have to deal with organisations like that... here, SAR missions get whatever they ask for, within reason, and even unreasonable things with a bit of organisation. For example: You want to spend an hour loitering over the beach exactly in line with the flight path from an international airport? Sure, we'll keep the jets out of your way for you... we got exactly that for a manned SAR *training mission*!!! We even get ATC popping in on VFR frequencies for flights outside their zones and telling them about search missions and to contact our pilots or IFCs on the mission frequency for collision avoidance... ATC and CAA are absolutely brilliant. I'm quite sure they'd be just as helpful if we were operating UAVs.

[bluesk1d]

Ye gods, am I ever glad I don't have to deal with organisations like that... here, SAR missions get whatever they ask for, within reason, and even unreasonable things with a bit of organisation. For example: You want to spend an hour loitering over the beach exactly in line with the flight path from an international airport? Sure, we'll keep the jets out of your way for you... we got exactly that for a manned SAR *training mission*!!! We even get ATC popping in on VFR frequencies for flights outside their zones and telling them about search missions and to contact our pilots or IFCs on the mission frequency for collision avoidance... ATC and CAA are absolutely brilliant. I'm quite sure they'd be just as helpful if we were operating UAVs.
Theres no need to gloat :p

[Andrew McGregor]

Well, I'm not exactly gloating... I'm more pointing out that a CAA that is quite influential in world aviation affairs is prepared to allow all sorts of things, and perhaps that might be used as leverage with the FAA. Unfortunately, NZ doesn't have any UAV regulations per se, although there are a few operators and they must have done something.

[CenTexFlyer]

How is LASD planning on getting around all the restrictions related to the FAA/COA?

If you'll look at the date on the article, it's back in 2006. Commander Sid Heal of the LASO is now retired, LASO got their hands slapped pretty firmly by the FAA for even making the public statement they were going to proceed with their program. To the best of my knowledge they do not currently have a COA, but would like one if they could fly in urban areas. Incidently, the Houston Police (TX) had a demo with the Insitu Scan Eagle not too long ago and it ended up being a PR nightmare! Secret ops, press not allowed, TV helicopters being warned off a "restricted area" (it was not) and a host of other televised PR gaffes. An embarrassing display for both the HPD and the FAA.

Well, I'm not exactly gloating... I'm more pointing out that a CAA that is quite influential in world aviation affairs is prepared to allow all sorts of things, and perhaps that might be used as leverage with the FAA. Unfortunately, NZ doesn't have any UAV regulations per se, although there are a few operators and they must have done something.

Andrew,

I think you might be surprised at the reception you might get now if you announced there was going to be a UA in the approach path... :eek: I will say that the disconnect seems to be between FAA HQ and the rest of the world! We have successfully flown off the active end of a runway(s) while maintaining coms with the tower. Worked great! It's just when you ask "Pretty PLEASE?" from the troops in DC do you get the big fat "NO! - are you crazy?!?!?" response.

[bluesk1d]

If you'll look at the date on the article, it's back in 2006. Commander Sid Heal of the LASO is now retired, LASO got their hands slapped pretty firmly by the FAA for even making the public statement they were going to proceed with their program. To the best of my knowledge they do not currently have a COA, but would like one if they could fly in urban areas. Incidently, the Houston Police (TX) had a demo with the Insitu Scan Eagle not too long ago and it ended up being a PR nightmare! Secret ops, press not allowed, TV helicopters being warned off a "restricted area" (it was not) and a host of other televised PR gaffes. An embarrassing display for both the HPD and the FAA.

"To the best of my knowledge they do not currently have a COA, but would like one if they could fly in urban areas." Should that read SO they could fly in urban areas instead of IF? Pardon my ignorance I am just having a little trouble understanding what you mean. Did they end up proceeding with some kind of UAV solution but are currently unable to really take advantage of it? Are you aware of any LE agency that has permission or otherwise found a way to use them over anything but bushes? The debacle with HPD sounds entertaining.

[CenTexFlyer]

As stated... they would go for a COA ... IF.... they could fly over urban areas. Right now you can get a COA in a remote area that has more bushes than people. My last conversation with Cmdr. Heal was that LASO do not have a UA solution, but are waiting on the FAA to work out the details, which at this point do not look encouraging for urban area work. I am not aware of any LE agency that has an operational COA for use over their entire jurisdiction. We have made a FOIA request on COA's issued but the FAA are stalling......

Gene

[brnjones]

Even under 400' AGL?

TCAS isn't designed to give advisories below 400 ft AGL.

[patrickegan]

and...

[airmcn_3]

Hey,

I have been looking for a revised rules and regulations that are newer then 2006; does anybody happen to have the most recent documents so that we can study them? Or are there none set in stone since the 2006 doc.

Thank you,

Chris

[patrickegan]

There are interim guidelines on the FAA web page, but they only pertain to public use.(not commercial)

[airmcn_3]

There are interim guidelines on the FAA web page, but they only pertain to public use.(not commercial)


Thank you Patrick,

I am actually looking for commercial if possible, I can poke the individuals we know with the Queensland Govt. but as you may know, getting questions answered by them can take a very long time. The way it seems, they don’t even know what regs they want to put on us....

Thanks for the post.

Chris

[bluesk1d]

There are interim guidelines on the FAA web page, but they only pertain to public use.(not commercial)
Does anyone know, as it pertains to UAVs, where public stops and commercial begins? Also, is there a link to the interim public guidelines?

[patrickegan]

There is, but I'm in the airport waiting to board. Compensation or hire is the definition of commercial, but it's mighty gray if you ask me. :)

[bmw330i]

...I'm going to be soon working with a company that does C of A certs about what it would take to get one for a FunJet. Small world, a friend of a good friend does that...I will share what I find in the future. It will likely be an eye opener for them to deal with something so small and for me to learn that process and the costs and procedures.
-BMW

[Pinga_Dog]

Just saw this in an article about the FAA Reauthorisation Bill now in Congress. Someone is pushing the FAA for better or worse.

Commercial unmanned air systems would be given full access to the US national airspace by 30 September 2013 as part of draft legislation now before Congress.

The UAS airspace access initiative forms part of the US Federal Aviation Administration reauthorisation act of 2009, introduced into Congress 9 February and currently undergoing review by the House transportation and infrastructure and science and technology committees..

The draft legislation - HR915 - calls for the FAA to prepare a "comprehensive plan to safely integrate commercial UAs into the national airspace system" within nine months of the passage of the reauthorisation act.

It mandates that plan "define the acceptable standards for operations and certification of commercial UAS; ensure that any commercial UAS include a detect, sense and avoid capability; [and] develop standards and requirements for the operator, pilot, and programmer of a commercial UAS, including standards and requirements for registration and licensing."

The draft bill act calls for the FAA plan to make recommendations on how a phased approach to opening up airspace for civil UAS could be applied and the timeframe over which that could be achieved.

It says the full plan "shall provide for the safe integration of commercial UAS into the national airspace system as soon as possible, but not later than September 30, 2013."

The FAA reauthorisation act is expected to pass both houses by the end of this month, meaning the commercial UAS airspace plan would be finalised by November. The legislation calls upon the FAA to provide the document back to Congress within 12 months, or by February 2010.

The act proposes the FAA be required to issue a draft notice of rule making by May 2011 to implement the approved commercial UAS integration plan.

Small UAS operating within visual line of sight may be given fast track access ahead of the full opening up of US airspace.

The draft legislation calls for the agency to "determine if certain unmanned aircraft systems may operate in the national airspace system before completion of the plan" within six months of the authorisation act being passed.

That determination process would include assessment of "which types of UAS, if any, as a result of their size, weight, speed, operational capability, proximity to airports and population areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security".

The process would include examination of whether airworthiness certification or other certificates of authorisation would be required for such UAS.

A parallel study process examining military and government owned or operated UAS would see the FAA issue guidance by November this year on how these would be given incremental expansion of access to US airspace. That guidance would "expedite the issuance of a certificate of authorisation process; [and] provide for a collaborative process with public agencies to allow for an incremental expansion of access to the national airspace system as technology matures and the necessary safety analysis and data become available."

The draft legislation also backs the development of new test facilities for government owned and operated UAS. It calls for the FAA to facilitate "the capability of public agencies to develop and use test ranges, subject to operating restrictions required by the FAA, to test and operate UAS".

[patrickegan]

Could be why they are trying to fast track the ARC. 2013 is a pipe dream as sense and avoid standards (reality) are out in 2017. We as a group need to come up with a 'real' plan or we'll be left in the dust.

Thales already beat you to the Funjet idea

[bmw330i]

It could be that I work with software engineers all day long but I am missing why if you have data on all objects in the airspace (i.e. altitude, speed, direction) how come I keep reading it's considered by so many to be difficult to write software to make decisions based on that?

The world has come a long ways in software development. Usually the struggle is trying to do maintenance on an old system on old code. But a new system using new code is far easier. Like I said take a look here: http://paparazzi.enac.fr/wiki/MultiUAV
Flying with Paparazzi if nothing else the code is there to keep the paparazzi controlled aircraft from hitting each other. Not such a stretch to throw code in there to integrate aircraft in there that are manned and have paparazzi avoid those.

I'm not saying use Paparazzi with the FAA needs but the code is open source and works so why not review it and use it as a starting point or small scale model for POC.
-BMW

[patrickegan]

^^^if it were only that easy. :)

[Real Ira]

Just saw this in an article about the FAA Reauthorisation Bill now in Congress. Someone is pushing the FAA for better or worse.

Commercial unmanned air systems would be given full access to the US national airspace by 30 September 2013 as part of draft legislation now before Congress.

The UAS airspace access initiative forms part of the US Federal Aviation Administration reauthorisation act of 2009, introduced into Congress 9 February and currently undergoing review by the House transportation and infrastructure and science and technology committees..

The draft legislation - HR915 - calls for the FAA to prepare a "comprehensive plan to safely integrate commercial UAs into the national airspace system" within nine months of the passage of the reauthorisation act.

It mandates that plan "define the acceptable standards for operations and certification of commercial UAS; ensure that any commercial UAS include a detect, sense and avoid capability; [and] develop standards and requirements for the operator, pilot, and programmer of a commercial UAS, including standards and requirements for registration and licensing."

The draft bill act calls for the FAA plan to make recommendations on how a phased approach to opening up airspace for civil UAS could be applied and the timeframe over which that could be achieved.

It says the full plan "shall provide for the safe integration of commercial UAS into the national airspace system as soon as possible, but not later than September 30, 2013."

The FAA reauthorisation act is expected to pass both houses by the end of this month, meaning the commercial UAS airspace plan would be finalised by November. The legislation calls upon the FAA to provide the document back to Congress within 12 months, or by February 2010.

The act proposes the FAA be required to issue a draft notice of rule making by May 2011 to implement the approved commercial UAS integration plan.

Small UAS operating within visual line of sight may be given fast track access ahead of the full opening up of US airspace.

The draft legislation calls for the agency to "determine if certain unmanned aircraft systems may operate in the national airspace system before completion of the plan" within six months of the authorisation act being passed.

That determination process would include assessment of "which types of UAS, if any, as a result of their size, weight, speed, operational capability, proximity to airports and population areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security".

The process would include examination of whether airworthiness certification or other certificates of authorisation would be required for such UAS.

A parallel study process examining military and government owned or operated UAS would see the FAA issue guidance by November this year on how these would be given incremental expansion of access to US airspace. That guidance would "expedite the issuance of a certificate of authorisation process; [and] provide for a collaborative process with public agencies to allow for an incremental expansion of access to the national airspace system as technology matures and the necessary safety analysis and data become available."

The draft legislation also backs the development of new test facilities for government owned and operated UAS. It calls for the FAA to facilitate "the capability of public agencies to develop and use test ranges, subject to operating restrictions required by the FAA, to test and operate UAS".


Thank You for posting that.
You beat us to the well on that one.

Ira

[patrickegan]

http://www.shephard.co.uk/news/1725/us-lawmakers-propose-commercial-uas-access-to-national-airspace-by-30-september-2013/

[jetblackaircra]

http://transportation.house.gov/Media/File/Aviation/FAA_Reauthorization_09/HR%20915.pdf

This is encouraging, huh Patrick? By the way, since we last discussed regulations, i have given myself a major sized dose of the "koolaide". Our organization has begun to look much deeper into what will be required of us to fly legally.

Patrick, can you please let me know what you know about this proposed legislation? How likely is it to pass? When do you expect it to pass? If passed, who will be making these recommendations to the FAA? It specifically mentions that:

(a), the Secretary shall determine, at a minimum—
(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and population areas, and operation within visual line-of-sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and
(2) whether a certificate of authorization or an airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).

What do you think will happen? Is RTCA the organization who will make this determination and recommend to the FAA? Do you have a way to lobby with them or whoever will be making the recommendation?

[patrickegan]

Lot's going on... We'd have to speak off line.