Representation for Commercial sUAS

[Old Man]

Pepper,

We're about to move in one way or another into the real aviation community. That will happen without our input while we go down kicking and screaming, or with our input proposing regulatory alternatives to what we can expect based upon what they have done so far. I'd prefer having some ideas that will work for most than a dictated set that will work for few. In aviation, commercial operators are held to a much higher standards than the average flyer. You might want to view LSA operations like one would view higher end entry level multirotors. Yea, they can fly but are pretty limited in range, equipment, and speed capability. Having a minimum level medical is something the big UAV players have been insisting of their operators for at least the last 5 years and let's face it, the FAA will be pandering to those players so we would be foolish to think such standards will not become mandatory.

As you mentioned, a Class III doesn't require much more than you can see well enough to find the doctor's office, aren't color blind, can hear the doc tell ya how much the bill will be, and that you don't have diabetes. So one of those every couple of years should not hurt anyone that's well enough to keep breathing, may help a few find out they had something that needed attention they were unaware of, while creating a sense of "feel good" with the public at large. The public we'll be flying around.

We're going to have rules, so how about discussing rules that would be beneficial and improve safety instead of thinking we can do without? Far too many have already demonstrated that without rules they'll do anything they can think of without regard to anybody or anything around them. BTW, I hold Commercial ASMEL instrument airplane tickets and ground/flight instructor so I have a fair understanding of manned aviation. I also spent 5 years in the field as a military grade UAV flight and payload operator with another 5 as a UAV tech so I kind of understand how they go about things. We don't need to be burdened with all the stuff they place on manned aviation, but what do we need that we can live with?

 

[Str8 Up]

There are so many problems right now it's hard to get your brain around them all.

The FAA is about as well equipped to stop careless and reckless Phantom2 pilots as Federal Marshalls are staffed to stop texting and driving. The only way this is going to work is if FAA leaves enforcement of SUAS' flying below 400' to local law enforcement. And for this to work the rules need to be very simple, like traffic law simple. Local law enforcement are the only one's with enough boots on the ground to make a dent in the issue. I guess once you have total control (or the illusion of having it) it is hard to relinquish even the smallest portion of it. It's like they can't or aren't willing to admit they can't or shouldn't be the ones to handle the small potatoes, even though they have to know that. The PPL requirement is the perfect example; it is not even close to being the best answer but it is the most convenient one for them. TSA check, felony record check, medical check, knowledge check and a pull the card threat all in one neat little package. Never mind that seat time in a Piper or Cessna is all but worthless to our ends.

I am taking a mental break from pulling together my Section 333 exemption manuals to post here. When I look at what the FAA is asking for it is painfully clear they don't know how to craft SUAS regs that a small business can live (survive) with. Other countries are figuring it out. They need to understand that if the copter is not flying over people, your don't need emergency procedures and accident reporting. You can't fill out 15 minutes of paperwork between every flight. It's no big deal to fly a copter from a moving vehicle or at night either. Do they have anyone on their staff that has spent some time with a good SUAS operator? They just can't seem to let go of the manned aircraft mentality and I am afraid that once they finally do, it will be all too late.

As someone with 20,000 SUAS flight hours I can tell you that what they have proposed so far has zero chance of working as a viable business framework.

 

[Old Man]

That's the point. The regs being proposed through the 333's are what has been presented for use by the aerospace corporations. The ones that have thousands of people working for them, the ones that additional regulatory steps won't have any real impact on. I've already seen company departments starting to suggest implementing those steps to get a head start on compliance and process familiarization. What is in the 333 stuff is intended to be time consuming, burdensome, and senseless in some areas, Be advised, the big boys don't report all their incidents by any means.

What is critical is having a plan to present alternatives. This is what I'm trying to have ya'll to lay out for presentation moving forward. I have a real long list of my own but I'd sure like to see the creative thoughts from others. Meetings start happening on some of the subject matter starting this week, leaving precious little time for generating speaking points from our population.

 

[pepper]

is the FAA just looking at it from a bigger picture. meaning the father/son teams that have no idea that the present under the Christmas tree will have potential of a fly away and hurting someone? will the FAA understand us business people out there need to make money and WE understand the safety issues? they HAVE TO understand there is a difference. i feel it must be stressed! can we just file a NOTAM if we fly close to the airport? even on that subject. any person can go to the local uncontrolled airspace airport and fly anything. during fly-in's we bring the local RC club out and have them fly for the kids, to include me and my rc heli. it takes nothing more than communication on both parts but it also takes aviation knowledge on both parts to keep it safe.

@Old Man , what talking points will you have? will you be talking to the FAA? maybe we can add to what you already know instead of saying the same things.

 

[scotth]

http://www.astmnewsroom.org/default.aspx?pageid=2061
http://www.astmnewsroom.org/default.aspx?pageid=3408

They did wonders for the light sport failure.

 

[Old Man]

Pepper, I understand where you're coming from, I really do. The FAA for the most part is not looking at things from a father/Son perspective but one that aligns more with large commercial operations such as those conducted by aerospace manufacturers. I believe that for those organizations the stuff we fly and the customer base we target could be viewed as a hindrance and competition to the big aerospace players so the regs will be biased against us. Since they already have massive employee staff that are already used to working with heavily detailed processes they can afford to comply with cumbersome and nit picking regulatory requirements, we cannot. For a little more illumination on what is happening right now I post the following for those that are not already aware. http://www.forbes.com/sites/gregory...ical-moment-as-white-house-prepares-to-act/2/

As for what I'm doing, I'm part of the ACUAS (and other organizations) and with luck we will have someone in Washington shortly in some of the meetings. Our talking points need to revolve around cost versus benefit, and how excessive safety regulations will do nothing for safety while severely inhibiting small business. For that to get across with any level of success a rule set will need to be presented as an alternative to what the FAA is likely to propose. The alternate rule set will need to create a new class of air vehicles and operators for them to function within existing regulations. The FAA has traditionally been decades behind technology current at the moment so don't expect this time around to be any different. The only real difference is the big commercial players have been coaching the FAA for the past 7 years on how they want their products integrated, not ours. So we are at a disadvantage unless and until we present intelligent solutions that could be incorporated into the FAR's.

As for what I have, those concepts are spread widely to encompass equipment functionality and safety, maintenance practices and documentation, operator and observer training, airspace deconfliction with full scale, ground to ATC communications, chart reading and airspace recognition, safe flight practices, and minimization of BLOS operations except under very specific conditions. From what I understand FPV flight will no longer be an option regardless of how hard we lobby so I'm avoiding that sticking point until later. Bear in mind all of what I prepared is focused on commercial operations, not the casual hobbyists since commercial operators should be held to higher standards.

If ya'll really want to see what I've proposed I'll post it while understanding that some won't like it and comment accordingly. However, I'd really like to obtain the independent input of the people that use this forum in order to gain a better balance and to learn what each finds to be most important to them. To do that people need to post their thoughts without being influenced by my concepts.

 

[Old Man]

Scott,
The Light Sport concept was and is well intentioned to get new blood into aviation. There was hope people would transition from Light Sport into the more formal aviation classes but that hasn't gone as well as hoped for. The general aviation manufacturers have pretty much priced themselves out of affordability. One pretty much needs to be wealthy to afford flying their personal aircraft from point A to point B. Regulations and tax structure make tax benefits for business purposes difficult to take advantage of. It's better than it used to be but still a pain.

If FAA proposed regs go as expected being priced out of affordability is what will happen to those of us that see multirotors as a means of employment. We must get it together an communicate in order to act with intelligent alternatives. We cannot sit back and think/hope someone else will do it for us.

 

[scotth]

Scott,
The Light Sport concept was and is well intentioned to get new blood into aviation. There was hope people would transition from Light Sport into the more formal aviation classes but that hasn't gone as well as hoped for. The general aviation manufacturers have pretty much priced themselves out of affordability. One pretty much needs to be wealthy to afford flying their personal aircraft from point A to point B. Regulations and tax structure make tax benefits for business purposes difficult to take advantage of. It's better than it used to be but still a pain.

If FAA proposed regs go as expected being priced out of affordability is what will happen to those of us that see multirotors as a means of employment. We must get it together an communicate in order to act with intelligent alternatives. We cannot sit back and think/hope someone else will do it for us.

Agreed! Just think if they had upped the weight limit for LSA to accommodate the C150. Now THAT would have given GA a boost. There are trillions of them sitting around. But no.

The thing that concerns me about ASTM being part of this is, as far as I know, they are a group of the heavy hitters in this business.. and they will be driving the standards by which the rest of us have to operate.. or not. They could very easily come up with a standard for example that requires redundant flight controllers, etc. or something similar that prices most of us out. Hopefully I'm wrong about the way I've been reading this.

 

[pepper]

oh man... light sport. let me tell ya. lol. I was in aircraft sales along with flying aerobatics for a company out of Denton tx. we were on the front end of the LSA sale with Remos and Tecnam aircraft. we even folded the Remos up and took it to boat shows to get out of the norm. worked VERY well and brought in about 1000 more tire kickers. lol. I agree 1000% that weight increase to include a C150 would have helped a great deal!

@Old Man you have a very heavy and daunting task ahead of you my friend! complete respect and I wish there were ways I could help beside an opinion on a forum. I would like to see what you have proposed. a healthy discussion never hurts anything.

 

[Old Man]

There's a meeting with the ACUAS tonight and this topic is part of the conversation. In all probability my proposed regulation suggestions will end up posted on the ACUAS site. If that occurs I'll post a link to the location and perhaps get some people engaged with their opinions. Those opinions matter-a lot! It would be pretty arrogant on my part to think that what I proposed to the FAA back in July is exactly what everyone else wants or is willing to live with. Everybody has different requirements and variability in operations so one size cannot fit all. The game is getting people to state their needs and adaptability to specific operating environments.

Your opinions are everything to this process. Without sharing them you are assured to receive what someone else believes you should have to live with, as long as they get what they want.

 

[pepper]

yes sir. I would love to see a link an update on the topics discussed. I COMPLETELY agree with you are NOT going to make everyone happy. it just simply never happens.
I'm just ready for something to be laid down so we can move forward and work on progress.

I kind of feel like we're on impractical jokers and the FAA are the jokers. lol

 

[Old Man]

I'm just ready for something to be laid down so we can move forward and work on progress.

I kind of feel like we're on impractical jokers and the FAA are the jokers. lol

Don't feel that way because each and every one of us can play an integral part in what we will have to live with as the process moves forward. All that's required is a willingness to put in print our individual opinions, some background on how that opinion was formed, and submit it during the upcoming NPRM process. From experience I can tell you that no retaliation occurs after presenting those opinions. The process is intended to obtain public input and make appropriate changes if enough evidence is presented to justify the opinion. Takes a little time and effort but it's not that big a deal, especially if you have long term interests that need addressed.

Before I post an extremely long set of bullet points I want to point out the information involved was developed by me and not representative of any group or organization. What should be pointed out is that much of the thought that went into the formation of the presentation was from the perspective of a full scale aviator and of an UAV operator and very long time RC modeler. I firmly believe in training and preventative maintenance. Record keeping is key to remembering what was done to what and when, which helps to establish what else may need to be done, in what manner, and at what time. Knowing your equipment is a very large part of aviation success and safety. The document was submitted to the FAA for review and consideration back in one of the open comment periods back in July, so everything following is now public record via the Federal Register.

A few months later I became affiliated with the ACUAS, largely because the group did not limit their concerns to only a specific class or type of operator. Their focus is primarily towards the multirotor professional but they recognize that professionals started out somewhere else as amateurs and amateurs should have an avenue to follow as their skills and interests progress. A divided population cannot be effectively represented so a means to link as many like minded people as possible is necessary for our mutual protection and advancement. That the cost of membership at the moment is zilch didn't hurt either I do expect that to change or see requests for donations to cover event expenses to occur eventually, but that's not happening yet.

So I'll post my submission here and I absolutely expect a lot of questions, a little outrage, perhaps a lot, and reader suggestions for improvement in some things. Perhaps everything, who knows? But if I can get a few, or preferably many, people to comment and provide input and opinion the heat inside my flame suit will be well worth the sweat. Nobody can do it all alone so what ya'll are willing to give up helps others better prepare that which needs prepared. Oh, since I've already mentioned it, join the ACUAS. www.acuas.org The website is starting to look pretty good and there's work in play to make it more interactive. We don't want to take anyone away from sites such as this one and we absolutely aren't trying to steal anyone's site sponsors. Our mission statement revolves around organizing people that do what we all do in order to develop a sensible regulatory and operational environment as our airspace opens up to sUAS. We think that everyone with the talent and ability should be able to run a business doing what we do using what we do it with. The "little guy" should not be locked out because the game was made too expensive to play. General aviation did that to itself, through regulations and product liability, and look where they are today. Sweating how they will survive to see tomorrow. One should not need to be an air carrier to conduct aviation related business. OTH, if one wants to work along side pilots, they need to be able to think and act like one.

A little personal background to close this post. I've been involved in most genres of winged RC for the past 45 years or so. I am a UAV professional for the previous 10 years through a couple of military grade Tier 1 UAV's as a flight operator, aircraft maintainer, and customer trainer. I've been a licensed Commercial Pilot since 1989, done on my own dime and time. I have been an RC two stroke subject matter expert and adviser on several RC forums under the name Silversurfer and Tired Old Man for the past 10 years or so and at one time a product review writer for Wild Hare RC. That company was responsible for the initial proliferation of the 50cc class of RC aerobat in the day when most involved in RC were still in awe of those invited to fly at the Tournament of Champions. 3D aerobatics were just getting started. As most know, the giant scale RC aerobatic community took off like a rocket after that. I haven't been flying multirotors all that long, about a year or so, but I've been heavily involved in some R&D at different levels that, unfortunately, cannot be shared with the public. I've come to enjoy multirotors so much I've pretty much stopped flying my fixed wing stuff. I do not fly aerobatic or racing multirotors. Everything I fly is intended to be task specific at a commercial level.

I believe we have a future in multirotor professionalism but we need to become involved, as individuals or groups, in the planning and become actively involved in the promotion of that future. We cannot afford to let those with zero comprehension of what we fly or do dictate that future. We cannot permit the unthinking or the unknowing to precipitate aerial acts that will threaten our very existence. To do so will be a disaster that will require decades to correct, and cause many professionally involved to go bankrupt after their profession and equipment became valueless due to excessive regulation.

 

[Old Man]

In all its glory, the following was presented to the FAA for consideration in July of this year. My flame suit is on, all three of them. I have to post in 2 parts since the total exceeds maximum character count.

Background
Current and pre-existing Federal Aviation Administration (FAA) regulations do not accurately represent the capabilities and limitations of modern Very Low Altitude Unmanned Aircraft Systems (VLAUAS), regardless of hobby or corporate aerospace design and manufacture. An interim set of regulations and training guidelines needs to be adopted to recognize and encompass current technologies (at all levels of manufacture and operation), as well as to establish a safe and effective flight environment. These guidelines, when properly incorporated and utilized, will provide for safe and coordinated access to the National Airspace (NAS). These regulations also need to recognize the inherent limitations in the range and flight duration of VLAUAS. By doing so, safe exceptions can be made to some current Federal Aviation Regulations (FAR) that are not compliance achievable for VLAUAS. The following guidelines are both are proposed and currently in use. They are intended to mitigate any conflict with full-scale aviation, personnel, or structures on the ground during VLAUAS operations.

Description
VLAUAS are:

· Designed for hobbyists or professional use

· Limited to a maximum gross takeoff weight (GTOW) of 55 lbs (24.95 kg) or less

· Typically generate flight times of 2 hours or less

· Primarily use batteries as an electrical propulsion power source

· Controlled using hand-held, radio-control transmitters and/or small base stations

· Flown at distances of 1.00 statue miles (1.61 kilometers) or less from the point of takeoff

· Configured as fixed wing, rotary wing, or multi-rotor aircraft

Guidelines
Airspace
1. All personnel, structures, and manned aircraft, as defined by FAA regulations, have priority at all times over VLAUAS equipment and flight operations.

2. VLAUAS operators will take any and all steps necessary, up to and including deliberate grounding of the VLAUAS to avoid conflict with manned aircraft and assure the safety of persons and structures.

Proximity
1. No VLAUAS flight operations shall be made directly over a person, crowd or gathering at any time.

2. No VLAUAS flight operations shall be made within 50 vertical and horizontal feet (15.24 vertical and horizontal meters) of any structure at any time.

3. No VLAUAS flight operations shall be made within 75 horizontal feet (22.86 horizontal meters) of a person, crowd, or gathering.

Certification
1. All VLAUAS commercial operations shall be conducted only by personnel that have passed, at minimum, an FAA private pilot written examination and received training with the type of aircraft and aircraft systems to be operated.

2. All VLAUAS commercial operators shall possess a current Class III or Class II aviation medical certificate.

Inspection
1. Flight areas of operation – All VLAUAS flight locations will be inspected along the entire anticipated route of flight to note any obstacles, persons, or structures that might otherwise be obscured from the takeoff/launch point prior to commencing flight operations.

2. Flight control systems – All VLAUAS will be equipped with flight control systems that provide an automated/pre-programmed landing in the event of a flight control or propulsion system failure, or loss of communications with the aircraft.

3. Batteries – All VLAUAS using batteries as the primary source of flight systems and propulsion shall be pre-programmed to automatically land should the battery state of charge decrease to less than 20% of the rated capacity of the flight battery (as measured in milli-amperes).

a. A record log will be maintained for each battery showing:

i. Battery serial number

ii. Number of cells

iii. State of charge, in volts, prior to the start of flight

iv. Post charge battery voltage

v. Amount of capacity replaced during the next charge cycle

vi. Numbers of charge cycles to date

b. The useful capacity of a battery will be determined during flight-testing of each battery size, type, and manufacturer prior to being accepted for VLAUAS use.

c. A fully serviced battery unable to maintain at or above 85% of its original rated capacity before use shall be considered unfit for VLAUAS operations.

d. Record logs of battery tests will be maintained by the VLAUAS operator for a period of two calendar years.

A certified copy of the battery test log will be submitted to the VLAUAS Administrator or National Transportation Safety Bureau (NTSB) upon demand

 

[Old Man]

Part 2

Minimum Flight Conditions
1. All VLAUAS operations will be conducted only during VFR conditions as defined by the FAR and the Code of Federal Regulations (CFR).

2. VLAUAS operations are permissible during meteorological conditions that define special visual flight rules (SVFR) as long as the requirement of 1.00 statue miles (1.61 kilometers) visibility and remaining clear of clouds can be maintained during any period of time the aircraft is in flight.

3. Flight is not permitted during SVFR conditions after legal sunset or before legal sunrise.

4. Flight is not permitted during periods defined as meeting instrument flight rules (IFR) conditions.

5. All VLAUAS flights will remain within 0.5 statute miles (0.80 kilometers) or less from the point of takeoff or launch, or a lessor distance should the VLAUAS be of such size that it would not be visually discernable unless closer to the operator.

All VLAUAS flight operations will be conducted with a minimum of one flight operator and one observer.

Beyond Line of Sight Flight Operations
1. Visual line of sight of VLAUAS need not be maintained if the flight is equipped with a first-person view (FPV) camera broadcasting video of flight conditions to a secondary flight operator.

2. Properly equipped VLAUAS using Beyond Line of Sight (BLOS) equipment are restricted to a maximum distance of 1.00 statue miles (1.61 kilometers) from the operator and observers.

3. FPV equipment used for BLOS flight operations must have the ability to be independently aimed in a manner that permits the secondary flight operator the ability to scan for air traffic or other obstacles to flight.

4. All VLAUAS BLOS flight operations will be conducted with a minimum of one flight operator, one FPV operator, and one observer.

5. All VLAUAS BLOS aircraft will be equipped with functioning telemetry devices that will provide real time information regarding distance from takeoff/launch location, altitude, airspeed, compass navigation data, and status of power system.

6. During BLOS flight operations all received telemetry must be visible at all times to FPV operator.

7. All VLAUAS flight operations will have in immediate possession, the current VFR navigational charts depicting airport locations and communications frequencies, including the contact information of the airport manager and control tower covering the areas of intended flight operations.

8. At such airport locations where a precision or non-precision instrument approach or departure procedure is published, operators of VLAUAS will possess a current chart showing such published procedures/altitudes and air traffic control contact information

9. VLAUAS flight operations are limited to a maximum of 400 feet (121.92 meters) above ground level (AGL) at any time unless equipped with an operating Mode C altitude encoding transponder and operating navigation lights that can be seen from all sides.

10. All VLAUAS flight operations will remain clear of all airspace under any published precision or non-precision approach or departure within 3.00 statute miles (4.83 kilometers) of an airport/heliport, or where airspace is depicted on navigational charts as extending from the surface upwards.

11. All VLAUAS flight operations will remain 500 feet (152.40 meters) below the minimum descent altitude of any published precision or non-precision approach and departure profile within 5.00 statute miles (8.05 kilometers) of an airport/heliport, or where airspace is depicted on navigational charts as extending from the surface upwards.

12. No flight operations are permitted more than 250 feet (76.20 meters) AGL within 3.00 statute miles (4.83 kilometers) of a civil or military airport without express approval of the airport management.

13. During operations within 3.00 statute miles (4.83 kilometers) of an active airport/heliport the airport management will be made aware of, and provide advance approval of, the exact geographical locations of VLAUAS activity, and the hours in which such operations will be conducted.

14. When operating with the approval of airport management within 1.00 statue miles (1.61 kilometers) of a civil airport all VLAUAS flight operations are required to maintain the ability to communicate with the airport using two-way radio communications and air traffic frequencies.

15. For flights during the hours of darkness (after legal sunset or before legal sunrise) all FPV flights are restricted to an altitude of 250 feet (76.20 meters) AGL or less.

16. No flights are permitted between the hours of official darkness within 1.00 statue miles (1.61 kilometers) of a civil airport at any altitude unless permitted under an officially released Notice to Airmen (NOTAM).

17. When operating under a published NOTAM within 1.00 statue miles (1.61 kilometers) of a civil airport or heliport, FPV operations are to be required to establish and maintain communications with civil airport air traffic control officials, of a type suitable to the airport management, at all times FPV aircraft are airborne.

18. When operating within 1.00 statue miles (1.61 kilometers) of a civil airport or heliport, VLAUAS will be equipped with functioning navigation lights that can be seen from all sides of the VLAUAS.

19. When operating within 1.00 statue miles (1.61 kilometers) of a civil airport or heliport VLAUAS flight operations will be conducted with a minimum of two observers.

20. Strobe lights are a known source of strong electrical signal interference for lightly shielded electronics systems. The use of strobe lighting for VLAUAS is not mandated.

Flight Observers Qualification Criteria
1. Flight observers for VLAUAS that weigh less than 22.05 lbs (10 kg) do not have to be flight operator qualified, however, each flight observer must:

a. Possess at minimum a valid FAA third class medical certificate

b. Have passed the FAA private pilot written exam

c. Have demonstrated proficiency in reading VFR sectional charts

d. Understand the flight capabilities and limitations of the aircraft and systems in use for the flight being observed.

e. Communicate effectively with the flight operator at all times.

2. VLAUAS flight observers for aircraft that weight more than 22.05 lbs (10 kg) must also be flight operator qualified.

Flight Operators Qualification Criteria
1. Flight operators must meet the following qualifications prior to operating any VLAUAS for any commercial operation:

a. Must possess at least an FAA second class medical certificate

b. Must have passed at minimum the FAA private pilot written examination

c. Must be able to demonstrate ability to read and understand aviation sectional and IFR approach/departure charts.

d. Must be able to effectively communicate in civil aviation terminology.

e. Must have received training in all applicable VLAUAS flight systems and demonstrate proficiency of use.

f. Must have received flight training for each VLAUAS variant to be operated.

g. Must have demonstrated proficiency in recognizing emergency conditions and effective use of emergency procedures and equipment functions.

h. Must understand VLAUAS power systems, autopilots, and limitations of each.


pr, july 2014

 

[Ronan]

Ouch... Some of those proposals are just insane... it's like they have no idea what they are talking about... It's a sUAV not a small airplane... or a DIY airplane...

How long/much does it take to get a class 2 medical done? What about the private pilot written exam?

I see no prices or time frames on any FAA websites... BTW can anyone recommend a good home-schooling/online website to get approved, study and then pass the private pilot certificate?

 

[Str8 Up]

One of our primary functions if to use sUAS to inspect large structures. To do this, the aircraft is routinely about 10' from these structures. If the operator has the owners permission to fly this close, then the listed distance restrictions are not needed. We also don't employ a VO in such cases as they add no value but do add to costs. Manned aircraft are already prohibited from flying close to these structures so they would collide with the structure if they were close to our aircraft.

I can tell you that we have an excellent understanding of what the market is willing to bear regarding costs and it is not possible to run a viable, long term sUAS business while complying with all you have listed.

 

[scotth]

I can tell you that we have an excellent understanding of what the market is willing to bear regarding costs and it is not possible to run a viable, long term sUAS business while complying with all you have listed.

Sounds like the reason we gave up our 135 certificate, haha. You want to make a million in aviation?...

 

[Ronan]

One of our primary functions if to use sUAS to inspect large structures. To do this, the aircraft is routinely about 10' from these structures. If the operator has the owners permission to fly this close, then the listed distance restrictions are not needed. We also don't employ a VO in such cases as they add no value but do add to costs. Manned aircraft are already prohibited from flying close to these structures so they would collide with the structure if they were close to our aircraft.

I can tell you that we have an excellent understanding of what the market is willing to bear regarding costs and it is not possible to run a viable, long term sUAS business while complying with all you have listed.

Agreed. The biggest issue with the VO is he is useless in most of our inspection work. That's why we have a 360 zoom camera + FPV camera installed.

As for the medical requirements, i can pass those easily, same with the written exam. I'm just worried about cost and time...

 

[scotth]

The requirement for a third class medical is absurd, at least for what we fly. The chance of having the PIC becoming catastrophically incapacitated while flying, and losing control and injuring someone is infinitesimally small. You don't even need a medical to take a passenger in an LSA, and good percentage of those pilots fly LSA because they know they won't pass the physical. Talk about backwards. I had three friends with valid second and third class medicals that dropped dead, fortunately not while they were flying. The exam is a joke. Requiring it will prohibit perfectly capable, safe pilots from participating. A driver's license ought to be sufficient evidence you are healthy enough to push a model plane around the sky.

 

[pepper]

that proposal just makes me choke. who in the world wrote that and whoever it is really needs a grasp on reality. I really hope they take away the private pilot and medical thing.