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Old March 24th, 2015, 03:26 PM   #1
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FAA Streamlines UAS COAs for Section 333

FAA Streamlines UAS COAs for Section 333
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Old March 24th, 2015, 04:53 PM   #2
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Re: FAA Streamlines UAS COAs for Section 333

That's a pretty liberal policy, although the "major cities" part might be problematic for some:

The “blanket” 200-foot COA allows flights anywhere in the country except restricted airspace and other areas, such as major cities, where the FAA prohibits UAS operations.
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Old March 24th, 2015, 04:58 PM   #3
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Re: FAA Streamlines UAS COAs for Section 333

but it doesn't ease the restriction on getting a section 333 exemption, which requires an actual licensed pilot to fly the darn thing.
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Old March 24th, 2015, 05:32 PM   #4
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Re: FAA Streamlines UAS COAs for Section 333

The 200 foot limitation seems a bit arbitrary, but its all trending in the right direction. The FAA probably wants to keep the license requirement because the 333 exemption is for commercial operation that can't comply with the proposed NPRM.
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Old March 25th, 2015, 10:08 AM   #5
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Re: FAA Streamlines UAS COAs for Section 333

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Originally Posted by Chuck Spaulding View Post
The FAA probably wants to keep the license requirement because the 333 exemption is for commercial operation that can't comply with the proposed NPRM.
It's mentioned in the NPRM Docket that even though they would like to NOT REQUIRE a license for these types of ops, their hands are tied due to the need to hold an Airman Certificate in the existing regs.

That's why reading the entire NPRM, although lengthy, is interesting because for each facet of sUAS proposals, they talk about their thoughts and what they want to do, and what their criteria is for making each proposal. In each of those areas, they point out that they would like to receive comments on why, or why not.

The long range goal of all this rule making is to SAFELY incorporate sUAS ops into the NAS system without being overly burdensome on the owners/operators. In fact, they are obligated by congress to do so, in the Airspace Modernization Act of 2012.

They seem to "get" balancing the desire for commercial ops with common sense requirements for safety. They acknowledge the rate of technological innovation as an opportunity to update the rules to relax certain limitations when the technology matures.

-gb-
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Old March 25th, 2015, 01:26 PM   #6
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Re: FAA Streamlines UAS COAs for Section 333

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Originally Posted by Chuck Spaulding View Post
The 200 foot limitation seems a bit arbitrary, but its all trending in the right direction. The FAA probably wants to keep the license requirement because the 333 exemption is for commercial operation that can't comply with the proposed NPRM.
200 feet is in line with Part 77 Obstruction Lighting requirements. Towers and other obstructions 200 feet AGL or less do not require lighting. Going above 200 feet AGL requires the obstruction to be lit to a specification of given intensity and visibility. [flashing red an/or white strobe(s)]
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Old March 25th, 2015, 09:10 PM   #7
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Re: FAA Streamlines UAS COAs for Section 333

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In fact, they are obligated by congress to do so, in the Airspace Modernization Act of 2012.
It will be interesting to see what the FAA can do to make this process less burdensome "because they are obligated by Congress".

What they could have done is classify drones flying 200 feet (better even, if 500 feet) AGL like un-manned balloons with very few and reasonable regulations. What they did (want to do) is make a whole new classification with drones considered as a new category requiring a pilot's license, ground school and likely a squadron of new FAA inspectors with eyes tilted skyward to identify the tiny tail numbers that must be placed on these things and handing out tickets for anyone who makes the slightest infraction.

At least we have some streamlined rules for those who already have a 333 exemption, which no doubt was obtained by a bevy of Wall Street attorneys. But since only people with those very difficult to obtain exemptions are affected by this latest news flash, I really don't see the FAA announcement as very positive.
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Old March 26th, 2015, 01:30 AM   #8
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Re: FAA Streamlines UAS COAs for Section 333

You guys should check out and sign up at ACUAS.org.

The NPRM is there in its entirety plus a summary of what the FAA intends the regulations to be. In the current proposal the altitude limit is 500' if this differs from the current 333 exemptions then the proposed rules will eventually supersede the 333 rule.

I believe the only reason to apply for a 333 exemption now would be if the new NPRM still doesn't allow a company to commercially deliver packages beyond line of sight, weights more than 55 pounds or needs to exceed the 500' limitation for example.
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Old March 26th, 2015, 03:16 PM   #9
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Re: FAA Streamlines UAS COAs for Section 333

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Originally Posted by Chuck Spaulding View Post
You guys should check out and sign up at ACUAS.org.

The NPRM is there in its entirety plus a summary of what the FAA intends the regulations to be. In the current proposal the altitude limit is 500' if this differs from the current 333 exemptions then the proposed rules will eventually supersede the 333 rule.

I believe the only reason to apply for a 333 exemption now would be if the new NPRM still doesn't allow a company to commercially deliver packages beyond line of sight, weights more than 55 pounds or needs to exceed the 500' limitation for example.
Yeah, I read the entire NPRM.Applying for FAA permission

I also reviewed a couple of the granted 333 exemptions. One for a real estate aerial video company in Tucson, AZ was interesting. Basically, the ALPA and the organization representing aerial applicators objected to the petition.

The 500' AGL rule will satisfy many of the aerial video/photo needs, but other applications like tower inspections are going to need higher altitude limits.

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Old March 26th, 2015, 03:31 PM   #10
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Re: FAA Streamlines UAS COAs for Section 333

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It will be interesting to see what the FAA can do to make this process less burdensome "because they are obligated by Congress".
For starters, recognizing that an airman certificate for manned aircraft has very little to do with piloting an unmanned aircraft. Therefore, a new 'operator' certificate will be issued. They don't even want to call it a pilot certificate. Also, you will not need a medical certification, only self certifying. That's one cost eliminated.

Since Airworthiness Certificates often take 3 to 5 years to process for manned aircraft, the FAA has decided not to require sUAS to have an AC due to the rapid pace of innovation. They know that by the time you could get an AC, the technology of your current UAS would be obsolete. Parts won't require TSO, and since there are no AC requirements, there won't be any Airworthiness Directives issued after the fact. Again, mitigating the cost of operation to sUAS owners.

Daytime only ops are mandated in the NPRM because the requirement for specific aircraft lighting would place additional burden to the operators.

They stress that they are taking a tiered approach to implementing sUAS into the NAS system. I can see larger UAS down the road being used for things like package delivery when technology matures a bit more.Those UAS will likely need to go higher than 500' to accomplish their delivery routes.

I foresee a day when we might have a delivery chute incorporated into our homes so that the UAS could land on or hover above the roof, and release the package into chute, where we could retrieve it, but would keep the UAS and the package from human intervention.
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Old March 26th, 2015, 06:55 PM   #11
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Re: FAA Streamlines UAS COAs for Section 333

It is great to envision the future, but also, wise to be realistic.

If you look at a V tail Beechcraft Bonanza panel, it is laid out a lot like an automobile. They envisioned everyone living on an airport and having their own private airplanes. The V tailed Bonanza was known as the doctor killer because only doctors could afford one, and a few that did, pulled the tail off in mid flight. Alas, the FAA's requirement everyone have a pilot's license and medical was a good thing for general aviation because flying is very different than driving. You can't pull over to the side of the road with a mechanical failure in the air the way you can while driving.

Unless the FAA changes the requirement drones are not to be flown over populated areas, we won't see package delivery to anyone but farmers. The line of sight and VFR restrictions will dampen development of this technology. However, as you say, using a tiered approach, there is at least hope for this emerging technology.

A dear friend of mine is one of the key players in an organization called Texas Equusearch. They use high tech to find missing people (dead and alive) which the police and military have been unable to locate. They started using drones a few years ago to search remote areas difficult to access via foot. The use of drones became one of their best tools...until the FAA sent them a nasty letter threatening their use. The proposed flying within line of sight won't help equusearch much. The 333 exemption was a nightmare for them. The FAA Implementing a complicated regulatory scheme to an industry that, with a few simple rules, has little in common with that regulatory agency, could mean someone we love is not found in time, and companies we might own one day, areal search drones with video capability, won't be practical to start.

The FAA's Cease-And-Desist Orders to Drone Pilots Are Bogus, Appeals Court Rules | Motherboard

Note, while the publicity is reported as a win against the FAA application of foolish laws, the ruling merely allowed all sides to stand down. The FAA has the authority to issue a cease and desist order. They were under pressure not to so officially. That is hardly the environment needed to finance and grow a new company, political pressure.

We need rational regulations that keep aircraft safe, so height limitations and operations in controlled airspace and at certain heights is reasonable, but requiring registration numbers be placed on some of the tiny platforms is folly, along with most of the proposed scheme by the FAA. Anyone considering a video drone business should use your voice in letting the FAA know they have over-stepped.
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Old March 28th, 2015, 06:27 PM   #12
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Re: FAA Streamlines UAS COAs for Section 333

All valid points, Tim. I am a licensed pilot and was aware of many things you stated. That's why I can see both sides of this story. I think it has been over blown by many. For example, how many aviation accidents involving sUAS have resulted in fatalities? Now, ask the same question about manned aircraft and you can come up with a laundry list of incidents that resulted in loss of life.

Someone also stated that the military has had experience with sUAS colliding with manned aircraft, and in all cases, the model was destroyed, but the manned aircraft remained flyable.

BTW, if that SAR company you mentioned is the same one I'm thinking of, they did get a brief exemption last year to search for a missing woman here in the Plano, TX area.

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