FAA UAV Symposium

I don’t have the resources to attend the 2016 FAA UAS Symposium, but I did send an eMail to Joseph Geni (Joseph.ctr.Geni@faa.gov) in the UAS Integration Office with questions that should be addressed at the Symposium:

First:

Why do Section 333 exemption operators have to jump through so many damned hoops and dead-ends to make a commerce flight near an airport when a hobbyist can simply tell the tower and fly? It make absolutely no sense whatsoever.

The Section 333 Exemptions Conditions states that “The UA may not operate within 5 nautical miles of an airport reference point…unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder”, but ATC facilities are told that the operation requires a COA. Period. Don’t ask. In an FAA Memorandum from Heather Hemdal, Director of Air Traffic Procedures to ATO Service Center Directors, ATO Air Traffic Service Directors and ATC Towers and Federal Contract Towers (December 23, 2015) the memorandum says that non-hobby operations require a COA and that an airport manager or ATC do not have the authority to give permission for those flights.

The policies are clearly in conflict and simply make it impossible for a commercial operation to occur within five miles of an airport.

Complicate this with the fact that the FSDO offices are impossible to reach by phone. I had a question about a commercial drone flight I was involved with last month and wanted to talk to an sUAS specialist. My local FSDO never returned my call, so after three days, I went FSDO-shopping. I called four FSDO offices, and in every case was met with voice-mail. In every case I left a return call number. Only ONE returned my call, two days later. How is a certificated pilot supposed to do his due-diligence if the FSDO won’t even return phone calls?

This cannot contribute to safety. The commercial operator is discouraged by this tar-pit of conflicting policies. I venture that the vast majority of commercial sUAS flights less than 100 ft and one to five miles from an airport are being made, literally, “under the radar”.

This can’t possibly be what the FAA wants to encourage.
Second:

How many of the 3000+ Section 333 operators are actually reporting zero flights as required in Paragraph C of the “blanket” COA?
C. Reporting Requirements
1. Documentation of all operations associated with UAS activities is required regardless of the airspace in which the UAS operates. NOTE: Negative zero flights) reports are required

Really? the FAA wants me to report that I am not flying?
Summary:

This byzantine patchwork of conflicting and nonsensical policies do not contribute to aviation safety in the slightest. I posit that they actually diminish aviation safety by encouraging operators to simply ignore those conflicting and nonsensical policies.

Can’t we all get on the same bus here?

Thank you for the opportunity to put this issue before the FAA UAS Symposium.

Stephen Mann
Admin, The333.org

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2 thoughts on “FAA UAV Symposium

  1. Brad P

    You and others have brought up the point about how the limitations of sUAS under 333/coa nurture an environment of non-compliance. Exactly the opposite of the mission of the FAA. I sometimes wonder if any of the guideline writing FAA people understand aviation. It’s fairly obvious they do not. Which to me is a bit ironic.

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  2. DroneMann Post author

    I will be writing a post here shortly that explains how (I think) the FAA found itself in this catch-22.

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