Ya Know It Don’t Come Easy….


FAA’s many quandries in the quest to pave the way for commercial unmanned aircraft. Do they fit UAV pilots into the existing structure or create a new classification?

Here is the first problem: commercial UAV pilots operate for hire, but private pilots are not allowed to fly for hire. Commercial pilots can fly for hire but the requirements are excessive for simple UAV operation. But if a new classification is created for UAV pilots, what about currently licensed private pilots. May they fly UAVs for hire?

According to the current rules, 12″ high “N” numbers are to be applied to all aircraft, but that is not possible on small UAVs. The simple answer is to either set a smaller size or not require “N” numbers at all, which may be the logical solution.

But that creates another problem for communications. In situations where a UAV operator or pilot may be required contact air traffic control (ATC) by radio, standard communications procedure includes the identifiable type of aircraft (eg. Cessna) followed by the N number. For UAVs a new communication standard is needed, perhaps to include the designation “unmanned” or “UAV” rather than the manufacturer, followed by the operator name rather than an “N” number, such that the communication might be something like “Tallahassee Tower this is U-A-V, Cooper Aerial, on the ground at five miles southeast, requesting… ”

And on that subject, should the UAV Observer be the one communicating with Air Traffic Control, or the pilot who may be busy with the preflight check list and satellite acquisition. The Observer is the logical choice, but what qualifications should the observer need to required to meet?

Then there is the sticky matter of Airframe Certification: There are many UAV manufacturers, many outside the country, and more are being started. In addition it is common for radio control aircraft owners to build their own, and certification of individual aircraft would be a monumental task. No easy answer here at all. The types of unmanned aircraft that have been certified are those being used by the military, which are neither practical nor cost-effective for the small commercial operator. A handful of small UAVs may be being evaluated by the FAA at thje designated test sites but the few unmanned aircraft models being tested is nowhere near comprehensive. The FAA either needs to begin evaluating a wide range of products or skip that step and postpone aircraft certification.

How many flights or hours are necessary to become proficient in flying a small remotely piloted aircraft? Certainly not the hundred hours required to tow a glider. That could amount to as many as 600 flights of 10 minutes. What is the appropriate number of hours or flights? And where can that experience be acquired? Experience gained at an AMA club field may not really prepare the UAV pilot for practical situations related to real estate or agricultural missions. Some AMA clubs are often hostile to multi-rotor pilots and the “outsiders” who are flooding their world and creating problems.

With regard to qualifications of flying experience, should there be separate designations for rotary versus fixed wing UAVs? How about large versus small? The individual skills for each are quite different, much the same as for standard aircraft and helicopters, single engine, multi engine and jets. Should the FAA complicate the picture by designating different levels of qualifications for the various types of UAVs such that should prospective pilots be required to gain proficiency or endorsements in specific types of UAVs or require skills for all types? And who is to make that determination? As yet there are no CFIs or Certified Flight Instructors for UAVs other than those in the military and military CFIs won’t be familiar with a DJI Phantom, a Flame Wheel, Altura, any of dozens of fixed wing and home made aircraft. The skills for small and large UAVS are quite different from what the CFI has been trained to teach or evaluate. It’s one of many “chicken and the egg” scenarios involved.

The currently available Pilot’s Handbook of Aeronautical Knowledge is the original 2008 edition with 3 pages of update notations and an extra chapter added on. Adding UAS to the mix will mean modifications to at least a dozen rules yet another page of “updates”.

The process has been taking longer than anyone likes but that doesn’t make the task at hand any less daunting and complex. Throw the financial interests of Department of Defense vendors with their Global Hawks, Pumas, and dozens more to sell along with their high-dollar “consultant” fees. But the fact remains, a Global Hawk is both over priced and useless for real estate photography.

And we haven’t even mentioned large and looming issues of “detect and avoid”, public safety (ADS-B) and insurance. Where are the answers to come from and how long will it take to find them? And what are the other hidden forces involved?

And there is strong opposition being voiced by the Airline Pilots Association voiced in a petition to the FAA which states

“The Air Line Pilots Association, International (ALPA), representing the safety interests of over 51,000 professional airline pilots flying for 31 airlines in the United States and Canada, has reviewed the Request for Exemption. It is ALPA’s long‐held position that ALL aircraft in the National Airspace System (NAS), both manned and unmanned, must operate to the same high level of safety.

The airline pilots want the FAA to require a commercial level pilots license for flying UAV for hire, which includes the requirement for 250 hours flight time.

Like the old song says, “Ya know it don’t come easy!”.

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