FAA Petition

[Chuck Spaulding]

As many of you know I've been quite vocal regarding the use of sUAV's for commercial work. Some have even accused me of being an anarchist not wanting any regulations of this activity. Quite the contrary. A group of us have submitted a petition to get some interim rules adopted until the FAA's final ruling and we could use your support.

As many of you are aware from discussion in this thread, the FAA has created a rule making committee for the development of the rules for using UAV's for commercial purposes.

For reference here are the entities on the FAA's rule making comitee:
UAS ARC MEMBER ORGANIZATIONS
• General Atomics
• MITRE
• GE
• New Mexico State University
• Raytheon
• National Business Aviation Association (NBAA)
• Northrop Grumman
• Insitu/Boeing
• Rockwell-Collins
• Honeywell
• PBFA
• DHSCBP
• ALPA
• AOPA
• AUVSI
• NASA
• Aero Vironment
• Lockheed Martin

There is no representation for rules governing sUAV (small UAV's) being used for low to the ground industrial aerial applications. The FAA is moving very quickly to prohibit the commercial use of Small Unmanned Aerial Systems, sUAS or “drones”, until a complete regulations document can be drafted.

Commercial sUAS operators have already been providing safe and affordable aerial services to a wide range of industries in other countries by following common-sense guidelines, many of which strongly resemble the current commercial sUAS guidelines in use in the UK.

This is not a fight with the FAA but a respectful assertion that the UK commercial sUAS regulations are a worthwhile way to move forward with sUAS integration while preserving the positive economic contribution that they are already making in the United States. We have a petition that asks the FAA to adopt the UK's common sense approach to these regulations until the FAA is prepared to make its final ruling on this issue. Our intent is to protect the rights of small businesses to operate and remain competitive in this industry.

Could you guys sign and pass along our petition to people you know have a vested interest in this issue and ask them to sign it?

Her'e the link:

https://petitions.whitehouse.gov/pet...ately/2vbvcC0C

Thanks

~chuck

Here's the petition:

WE PETITION THE OBAMA ADMINISTRATION TO:
Compel the FAA to adopt the UK's commercial sUAS standards immediately
Small Unmanned Aerial Systems (sUAS or "drones") are already providing valuable services safely and for-hire to a wide range of industries (real estate, agriculture, public safety, etc)

The FAA's present interpretation (FAA-2014-0396) shouldn't seek to indirectly regulate commercial sUAS operations by better defining hobby usage

Commercial sUAS operators should be managed by an sUAS member-operator interest group to be overseen by the FAA

Peripheral issues such as privacy can and should be handled at the local/municipal level

Therefore, the FAA should adopt the UK commercial sUAS standards immediately so as to preserve the benefit of safe and low-cost sUAS aerial services for the tens of thousands of small business people that are already operating and employing them

[Chuck Spaulding]

Its amazing to me that so many have such strong opinions regarding commercial use of sUAV's yet when given the opportunity try to get involved in regulating them there's not much of a response.

I could understand if you don't agree with the petition that you might comment on it instead of sign it, maybe everyone who has read the petition has signed it, thanks for those that have, but we're also interested in feedback for dissenting opinions or I guess maybe its easier to just post stupid YouTube examples of why this industry needs to be regulated.

[Ed Roo]

If you want to operate commercially, get a commercial pilot's license and purchase commercial liability insurance. You need to know the rules/laws and accept the financial responsibility if you want to share the airspace with other users who invested in earning their ratings.

[Jim Michael]

Originally Posted by Ed Roo

If you want to operate commercially, get a commercial pilot's license and purchase commercial liability insurance. You need to know the rules/laws and accept the financial responsibility if you want to share the airspace with other users who invested in earning their ratings.

What you propose is not on the table for pilots of unmanned aerial vehicles, which is what the petition is attempting to change. Also, from an artistic perspective the viewpoint fromGA aircraft and small craft flown very close to the ground can be quite different, e.g. a shot of someone running along a trail at 50 feet AGL vs. 500 feet from a helicopter. Not to mention the ability to make small scale rapid changes in direction. As for the proposal as outlined in the petition, it seems reasonable to me.

[Ed Roo]

You are missing my point. Certification and regulation should be required to operate commercially in US airspace. There should also be a means of identifying UAVs in flight so that they can be tracked back to their operators. This has to do with responsibility and accountability. Many of the videos posted online display a lack of knowledge as to the dangers they pose to other aircraft, people and property on the ground. Every pilot knows that it is not the FAA that makes the rules, it is the insurance companies and local laws. Operate in an irresponsible manner, regardless of the FAA regulations, and local laws will become more onerous. Violate the local laws and the regulations and your insurance is null and void. Scofflaws will only increase the insurance premiums for the complying operators.

[Mark Dobson]

Originally Posted by Chuck Spaulding

Its amazing to me that so many have such strong opinions regarding commercial use of sUAV's yet when given the opportunity try to get involved in regulating them there's not much of a response.

Hi Chuck,

my perspective from here in the UK is that the FAA Petition you have posted is an essential step in protecting the concerns of legitimate and professional sUAV operators.

From what I have seen of the various sUAV videos posted on YouTube and Vimeo is that most of them demonstrate a high level of responsible use. But unfortunately there are those that don't, and it is these gung ho operators who will steer legislation against the legitimate use of sUAVs.

Here in the UK the situation is pretty clear. If you want to use sUAVs in a professional environment you need to attain the Basic National Unmanned Aircraft Systems Certificate ( BNUC-S). This requires an investment in both time and money and demonstrates a commitment to operating in a professional and safe manner. One of the factors that defines whether you are a professional or amateur operator comes down to whether you are insured or not. And here in the UK it is not possible to get insurance for sUAV operations without the BNUC-S certificate. So it’s a clear choice, to carry out commercial work you need this qualification.

Good luck with your petition.

[Jim Michael]

I take it these are the UK rules which the petition references:

Small Unmanned Aircraft (20kg or less) | Aircraft | Operations and Safety
Do I need a Permission for an Unmanned Aircraft (UAS)? | Aircraft | Operations and Safety
Apply for a Permission for an Unmanned Aircraft (UAS)? | Aircraft | Operations and Safety

Regarding local authority as referenced in Ed's post,

"By law, the FAA is charged with ensuring the safe and efficient use of U.S. airspace. This authority generally preempts any state or local government from enacting a statute or regulation concerning matters – such as airspace regulation—that are reserved exclusively to the U.S. Government."

Source: Fact Sheet ? Unmanned Aircraft Systems (UAS)

[Ed Roo]

There is something known as "home rule" (local and/or state) which supercedes the FAA regulations. While the FAA can set national guidelines (regulations), home rule is more of a nitty gritty about how you operate over and above those regulations.

[Jim Michael]

Ed, I'm not aware of any such rules other than those which have to do with airport management and similar local issues. Do you have an example you'd like to share to illustrate how I as a private pilot might be affected by such a home rule?

[Ed Roo]

I live in Ohio. There is a website for Ohio Code that contains aviation specific laws (I don't have the link offhand). Do a web search for "state aviation laws". That should bring up something. Also, the city where I live has its own laws, one of which is banning helicopters (except emergency medical and police) from landing within the city limits.

[Jim Michael]

OK I see what you mean. For instance there are state regulations pertaining to where you can land your seaplane.

[Ed Roo]

In the United States, one must remember that any power/authority not expressly granted to the federal government by the constitution falls to the states and local governments.

[Chuck Spaulding]

Originally Posted by Ed Roo

If you want to operate commercially, get a commercial pilot's license and purchase commercial liability insurance. You need to know the rules/laws and accept the financial responsibility if you want to share the airspace with other users who invested in earning their ratings.

First off we're not talking about sharing the airspace, except for landing, taking off and emergencies full size aircraft are prohibited from flying in the same airspace. That's not to say that full size aircraft don't break the rules nor that MR's don't venture into airspace that they don't belong. But you don't have to be a commercial pilot to understand the rules but you do need the rules.

I hear people make the comment about getting a commercial pilots license all the time and for the life of me I don't understand the logic. I am a pilot and I fly MR's and the two have nothing in common. In fact I have almost 2000 hours of turbine helicopter time and I can't fly an RC Helicopter to save my life. Yes it true that I'm more aware of what a full sized aircraft will do in certain situations, but chances are that if I encountered a full sized aircraft in the vicinity of my MR that pilot has much more on their mind than my MR nor would my MR be responsible for the situation.

Originally Posted by Mark Dobson

Hi Chuck,

my perspective from here in the UK is that the FAA Petition you have posted is an essential step in protecting the concerns of legitimate and professional sUAV operators.

From what I have seen of the various sUAV videos posted on YouTube and Vimeo is that most of them demonstrate a high level of responsible use. But unfortunately there are those that don't, and it is these gung ho operators who will steer legislation against the legitimate use of sUAVs.

Here in the UK the situation is pretty clear. If you want to use sUAVs in a professional environment you need to attain the Basic National Unmanned Aircraft Systems Certificate ( BNUC-S). This requires an investment in both time and money and demonstrates a commitment to operating in a professional and safe manner. One of the factors that defines whether you are a professional or amateur operator comes down to whether you are insured or not. And here in the UK it is not possible to get insurance for sUAV operations without the BNUC-S certificate. So it’s a clear choice, to carry out commercial work you need this qualification.

Good luck with your petition.

Thanks