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My presentation for UAS - 2009

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  1. 1. We are a professional association of dedicated remote control aerial photographers. RCAPA provides operational safety guidelines, best business practices, networking and new technology information.
  2. 2. We are a professional association of dedicated remote control aerial photographers. RCAPA provides operational safety guidelines, best business practices, networking and new technology information.
  3. 3. History, purpose and affiliations• Founded 2004 • 1700 + members world wide • Consensus based best practices • Testing and continuing education • Secure private liability insurance • Produce Proposed guidelines • Member sUAS ARC
  4. 4. Global Integration issues • limited operational experience in the integration process • Current CAA policy flagrantly ignored and also un-enforced • Supine reaction from regulators only serves to exacerbate current situation. • Said lack of enforcement compels small operators not to be involved. • Lack of non-military user involvement • Lack of non-military operational understanding. • Not utilizing available information and data. • Vendor business plans and agendas keep the issue open ended. (resembles contract process, back to what they can provide) • No clear cut compliance process • Science “friction” emotion driven conclusions from manned
  5. 5. Unanswered questions impeding integration• Confines of what is safe is yet to be scientifically defined? • Were is the empirical data that proves AC 91-57 type sUAS OPS are unsafe? • If we are to be held to the same level of safety as manned aviation, what is the relative differential? (size/weight/speed how does 10-6 apply, if at all?) • Required “data” yet to be identified/quantified? • Are these arbitrary operating envelopes viable ( e.g. 400’ AGL) for empirical data gathering and business? • Can a Data-set be captured in this small of an operating envelope? • Do we fit the definition of comp and hire? 14 CFR FAR Part 1.1 and 119?
  6. 6. Do these apply? Title 14 119.1 Applicability Sec 6 (e) “...this part does not apply to—” (4) Aerial work operations, including— (i) Crop dusting, seeding, spraying, and bird chasing; (ii) Banner towing; (iii) Aerial photography or survey; (iv) Fire fighting; (v) Helicopter operations in construction or repair work (but it does apply to transportation to and from the site of operations); and (vi) Powerline or pipeline patrol; Definitions Title 14 Sec. 1.1 General definitions. Commercial operator means a person who, for compensation or hire, engages in the carriage by aircraft in air commerce of persons or property, other than as an air carrier or foreign air carrier or under the authority of Part 375 of this title. Where it is doubtful that an operation is for ``compensation or hire'', the test applied is whether the carriage by air is merely incidental to the person's other business or is, in itself, a major enterprise for profit.
  7. 7. • No “data” or safety risk analysis going in • Bins and boxes are a rehash of unacceptable RTCA work • Those with operational experience woefully underrepresented • Overall document lacks comprehensive tone • International Harmonization = Weights in kilo’s??? • Economic impact of recommendations are devastating • All will be Compounded by use of standards groups sUASARC impressions
  8. 8. • Unwarranted and heavy-handed regulation of model aviation. • Type I operations leave little in the way of viability • Operating greater than 3 NM of an airport • System certification (what does it look like???) • Manual flight control • Type II operations put small operators in direct competition with vendors (major enterprises for profit) sUASARC impressions continued...
  9. 9. • Type III operations shut out small operators • Operating greater than 10 NM sometimes 30NM from an airport • System certification • Required equipment takes most of payload • Type IIII way beyond the reach of many. • Type V LTA Lighter Than Air left out of recommendation. sUASARC impressions continued...
  10. 10. Possible consequences • Lack of empirical data gathering. • Too onerous = Lack of compliance • Regulatory apathy/denial • Law abiding operators locked out • Airspace safety suffers • No closer to a workable solution • Operators not purchasing insurance • Investment in technology will suffer
  11. 11. Affecting change •Apples to apples comparisons (ELOS) •Industry code of practice •Formula for scaleable regulations (kinetic energy???) •Defined and capture-able data set •Definable guidelines •Aircraft certification plan •Enforcement plan (comprehensive or otherwise)
  12. 12. FIN