I'm in whichever format is selected to pursue. I
do have some thoughts on what we may need to do to obtain separation from hobbyists though, which I believe to be critical to our recognition/acceptance as a separate air space use body.
We'll need to define the differences between the professional MR or aerial RPV operator and the RC enthusiast, and provide some self generated rules of operation. I do not believe the FAA will even remotely consider any commercial operation that does not comply at some level with existing commercial regulations so I propose the following with the understanding that after a certain point we'll run into some onerous equipment requirements.
- Mandate that all RPV operations be conducted only during visual flight conditions as defined by the Federal Aviation regulations and the Code of Federal Regulations (CFR).
- Establish that commercial operations be conducted only by individuals or firms that have passed at minimum a Private Pilot written test.
- Require commercial MR operators have obtained an FAA Class II or Class III medical certificate.
- This requirement aligns with the standards already in use with larger sUAS operations and maintains a level of consistency with current domestic commercial sUAS operations. Class II is Commercial Pilot level, Class III is Private Pilot level.
- No flight operations above 250' AGL within 1 mile of a civil or military airport without approval of the airport management.
- Require altitude reporting devices that can be continuously viewed by the operator on all commercially operated multirotor or miniature helicopter.
- Non-towered, uncontrolled and private airports generate some special issues since many full scale pilots ignore published FAA regulations at such locations.
- Airport approach profiles utilize a 3 degree glide slope descent profile so 250' AGL at 1 mile provides adequate separation between full scale and MR type aircraft. At no time permit any RPV operated aircraft to fly at an altitude and location that intercepts an airport glide slope or precision/non precision instrument approach profile.
- Require all commercial MR operations to have in immediate possession a current Visual Flight Sectional Chart depicting airport locations and communications frequencies, including the contact information of the airport manager and Control Tower.
- Maintain line of sight with the MR/helicopter for all use below the altitude of 250' AGL.
- Establish a maximum permissible distance between flight operator and aircraft of 1 mile or less when operating commercially.
- Require dedicated "spotters' to scan for manned aircraft and assure clearance of persons/structures on the ground when operating in an FPV mode using goggles.
- Mandate means of two way air frequency monitoring when operating above 250' AGL, using local tower or approach frequencies.
- For flights above 250' AGL require remotely piloted aircraft to possess a Mode C transponder that is fully functioning prior to the launch of the aircraft.
- These are available and in current use but quite expensive in the sizes we would require. The technology we currently use will require upgrading to comply with "see and avoid" requirements and to enable TCAS activation aboard full scale aircraft.
- For flights above 250' AGL, maintain the ability to assure visual contact with the remotely piloted vehicle (RPV) using enhanced visual devices.
- For flight during the period spanning from 1/2 hour after official sunset to 1/2 hour before official sunrise require all RPV be equipped with lighted visual aids.
- For flights during the hours of darkness restrict all FPV flights to an altitude of 250' AGL or less.
- For commercial RPV operations develop a flight training curriculum for all FPV operators. Operators must obtain a passing grade of at least 80% to become qualified to operate commercially.
- Develop RPV aircraft equipment lists that demonstrate that all equipment in use has been tested as safe and reliable during use in VFR flight conditions.
That's a start, and I expect that others will want to add, subtract, or pick it apart. I'm all for that because the above provides some ideas that will hopefully trigger thoughts and input from others to better define what we need to do. The downside is we do not have much time. I do think we should use an entity already established, such as the AMA, to help us move forward. I do not believe we have the time to organize a brand new "national organization" to promote or needs. Presented correctly to the AMA they might recognize the benefits of being able to represent a revenue generating operational group and proceed accordingly.