“We don’t need common sense, we’ve got RULES!”

That strange statement came, intended in jest, (I hope), in a phone conversation with an FAA employee who shall remain nameless. I generally resist being negative with regard to the FAA and leave that to Patrick Egan, (who is quite good at it, actually). But sometimes it gets just too crazy to overlook or excuse.

Case in point: Under the requirements of a COA from the FAA, a UAV operator/pilot, civil or public, has certain record-keeping obligations. Filing flight plans is a logical and reasonable requirement. Maintaining flight and maintenance logs is also logical and reasonable. Both of these make sense. The next requirement does not.

There is one more requirement, and this last one clearly comes under the heading of the title of this blog because there is no trace of common sense in this rule.

FAA Form 7711-1 UAS COA lists a requirement to provide monthly “reports” which basically duplicate the flight plan and logging requirements. But this information is not to be filed online in any data portal. There’s not even a special form, specific email subject or special email address. No, all the information, in no particular organization, is to be submitted to 9-AJV-115-UASOrganization@faa.gov.

confettiThese “reports” are to be submitted, even if there are “zero flights”.  If you have nothing to report: report it anyway. There are currently 2,000+ section 333 exemptions and a number of other currently active civil COAs. Just with the approved 333 exemptions that comes to something like 24,000 emails per year  …assuming everybody with a COA read past page 2 of their exemption, in no specific format. The process amounts to the electronic version of confetti, and managing or finding anything in that much random data is a task that would be like alphabetizing confetti. It is totally unmanageable, totally redundant, totally worthless, unworkable and totally crazy.

The tale gets even more curly.

The blanket COA was published in July (2015). The blanket COA was added to Section 333 grants AFTER that date. There was no attempt to provide that form to the recipients of 333 grants PRIOR to that date. The people at the FAA were under the impression that the blanket COA had been “mailed to everybody” with a 333 grant. It had not and has not.

When I suggested it might be more cost effective, less labor intensive and more efficient to send the blanket COA by EMAIL, they said:

“That’s a wonderful idea.  Feel free to submit your suggestion to  333exemptions@faa.gov.”

…from which I assume means nobody there had thought of it, but so far it hasn’t happened.

By the way, if you received a Section 333 Exemption prior to July 1, 2015 you will have a hard time even finding the blanket form online. It’s apparently not found in the faa.gov/forms page, not even mentioned in the FAA’s UAS FAQ page. Google is no help either. We finally found it through an online forum. In case you haven’t found it, here it is: Section 333 Blanket 200 COA Effective 7-1-2015.

Make a copy and add it to the documentation you take with you on each flight (N registration, exemption letter, etc.).

The fun part comes in section C, beginning on page 3: duplicated information, in a totally unorganized form, flooding into an already overloaded email address.

What could possibly go wrong?

But then we find this statement with regard to the COA reports was found in the online FAA’s COA request portal:

“Operators are strongly encouraged to provide documentation of all operations associated with UAS activities regardless of the airspace in which the UAS operates. This information will only be used for the development of civil standards and not released without prior consent of the owner. The operator is strongly encouraged to submit the following information through the UAS Civil COA Portal on a monthly basis: NOTE: Negative (zero flights) reports are requested.”
Due within 5 business days after end of reporting month.

(Italics above added) An online form that goes into a database makes sense.  Sending information in an unspecified form by email does not. So why doesn’t the Blanket COA form list the reporting URL? (Note: the form does not submit if the COA number field is not valid and there is no “valid COA number” for the blanket COA, and therefor the “look up” function …doesn’t).

So on COA form 7711-1 activity reports are “required” but at the COA online portal web site, the reports are “strongly encouraged”.  In either case if nothing happens, reports of “nothing” are still required…. or was that encouraged.

The online form requires entry of  “Proponent” with no explanation of what the term means.

Now there will be a new requirement for registering all “drones”.  That makes just one more gigantic database for the FAA to manage. In typical fashion, at present it might be assumed but is not clear if the requirement will include previously purchased drones, the minimum size (I can’t see registering palm-size drones), how the registration is to be enforced, and so on. This sounds more like another “legislative solution” with no visible means of support or fully rational thought process.

There are two new faces at the FAA now, Marke “Hoot” Gibson, senior adviser on UAS integration Education and Earl Lawrence who will be the director of the UAS Integration Office within the agency’s Aviation Safety organization. Hopefully as these two begin their duties at the end of this month (September) they can begin to sort out this mess.

We can only hope….