The document discusses the evolving regulatory landscape for unmanned aerial vehicles (UAVs) in the U.S., emphasizing the need for the FAA to establish a comprehensive framework for their integration into the national airspace system. It highlights current exemptions under Section 333 of the FAA Modernization and Reform Act, which allows for case-by-case approvals for commercial operations while forecasting significant growth in the UAV market. The research aims to assess public awareness and compliance concerning UAV operations and their implications for airspace safety and efficiency.

1. Unmanned Aerial Vehicles: FAA and Regulatory Compliance
Tilak Ramaprakash
8/7/2015

2. • Submitted to the Faculty of Purdue University, in Partial Fulfillment of the Requirements for the MS in
Aviation and Aerospace Management Degree

3. Introduction
• The Unmanned Aerial Vehicle (UAV), also known as a drone, has been referred to in many ways as several
acronyms have come into play over the years to describe them: Unmanned Aircraft (UA), Remotely Operated
Aircraft (ROA), Remotely Piloted Vehicle (RPV), Unmanned Aerial System or Unmanned Aircraft System
(UAS), Remotely Piloted Aircraft (RPA), and Remotely Piloted Aircraft Systems (RPAS).
• Much has been speculated on the subject of regulating the burgeoning UAV sector. Unmanned Aircraft
Systems continue to be the most dynamic growth sector within the aviation industry. Till date, the UAV industry
has grown largely as a result of supporting defense organizations. This is reflected in the type of systems that
have been developed. However, operations in civil airspace have had different priorities. As the Federal
Aviation Administration (FAA) has been addressing the issues of implementing a regulatory system that will
govern this new industry, technological advances continue to rapidly grow. Commercial uses of UAVs include
law enforcement, aerial photography, property surveying, search and rescue missions, scientific research,
mapping, and more. Drones are also being planning for daily use such as pizza delivery.

4. Current Exemptions
• Under current law, any aircraft operation in the national airspace requires a certificated and registered aircraft,
a licensed pilot, and operational approval. Section 333 of the FAA Modernization and Reform Act of 2012
(FMRA) grants the Secretary of Transportation the authority to determine whether an airworthiness certificate is
required for a UAS to operate safely in the National Airspace System (NAS) (FAA, n.d.).
• This authority is currently being used to issue case-by-case authorization for certain unmanned aircraft to
perform commercial operations prior to the finalization of the Small UAS Rule, which will be the primary
method for authorizing small UAS operations once it is complete. Expected implementation for this target has
been September, 2015. However, at the time of this writing, it appears unlikely that this timeframe will be met.
• Until the complete regulatory structure has been implemented, the Section 333 Exemption process provides
operators who wish to pursue safe and legal entry into the NAS a competitive advantage in the UAS
marketplace, thus discouraging illegal operations and improving safety. It is anticipated that this activity will
result in significant economic benefits, and the FAAAdministrator has identified this as a high priority project to
address demand for civil operation of UAS for commercial purposes.

5. • To currently operate a UAV, unless flown only for hobby or recreational purposes, a Section 333 exemption
must be granted by the FAA to fly a UAS for commercial, i.e. business, purposes.
• As of this writing, the FAA has granted 1,111 exemptions for commercial operators (FAA, n.d.). Among the
current uses are motion picture production, aerial photography, agriculture use and power line, bridge, and
railroad inspection. An updated list on which entities have been granted exemptions can be viewed on the FAA
web site.

6. Growth
• World Unmanned Aerial Vehicle Systems annual sector study forecasts the U.S. and international Unmanned
Aircraft markets. The Teal Group creates a market profile along with a forecast for military and civil markets for both
the U.S. and outside the U.S. The study forecasts significant spending growth. Total procurement and R&D is
expected to increase from $5.2 billion to $11.6 billion annually over the next decade. The Teal Group’s ten year
forecast estimates total UAS spending worldwide at $89.5 Billion (FAA, n.d).
•
• Once able to operate on an open scale, the FAA estimates roughly 7,500 commercial small UAS will be operating at
the end of five years. This forecast is dependent on the regulatory structure finally adopted, and the technology as well
as cost structure of this evolving industry.
•
• The FAA has predicted that 30,000 drones could be flying in U.S. skies in less than twenty years (Jenkins, 2014).
Once the new regulations are in place, the scopes of the challenges that lie ahead for the FAA will be tremendous.
There will be many major challenges as well as underlying issues for the regulatory agency to monitor. As can be
understood by these numbers, the scope and challenges that lie ahead for governance of this rapidly growing industry
are immense.

7. • Saddled with the current expected industry growth, the FAA has several areas where public compliance and
cooperation are imperative. One of the areas of great concern is Airspace Integration. The safe and efficient
integration of UAS into the national airspace system has the potential for broad benefits for virtually all of the
public sector.
• The FAA must implement the new, integrated structure in a systematic order for it to be effective. And just
the same, operators must adhere to the rules in order for the regulator to grow the integrated NAS system.
• The intent of this research is to determine the commercial and public awareness of the importance and
necessity of participation in assisting the FAA in the ongoing development and integration of UAVs into the
current airspace system.

8. Hypothesis
• Regulatory compliance and cooperation will be imperative in order for Unmanned Aerial Vehicles to become
a significant component of the national airspace system.

9. Airspace Integration
• The current national airspace system has evolved to support safe operation and equitable access to a diverse
range of users. The architecture of the NAS has evolved primarily to support manned operations. Therefore,
when considering unmanned aircraft, there are several issues related to the ability of UAVs to integrate with the
current users of the NAS (Weibel & Hansman, 2006).
• The FAA is working on how to integrate the unmanned aircraft systems (UAS) into the national airspace
system and solidify regulations to permit commercial operation of small UAS. It is likely that small businesses
will conduct the majority of commercial operations.
• Over the last century, the number of aircraft operating at any given time has grown substantially. The traffic is
normally concentrated around populated areas and on flight paths into and out of major airports and along
popular routes. Areas of heavy activity are subject to air traffic control procedures. It may be that some
proportion of drone traffic will one day be substituted for existing piloted traffic. However, to date, drone traffic
has mostly been additional to piloted traffic. It has also been almost entirely outside controlled airspace, because
(with few exceptions) remotely-piloted flights inside controlled airspace are still prohibited.

10. • However, several factors suggest the likelihood of increasing congestion in previously non-busy airspace. For
example, most hobbyist uses of small drones will be by people who live in densely-populated areas. Drone
transport for industrial and commercial purposes will be to a large extent in urban areas. Surveillance activities
will cluster around such locations as ground-traffic routes, tourism locations, sports and entertainment events,
and gathering-points of celebrities and notorieties (Clarke, 2014).
• The UAS community does not yet have a set of standardized design specifications for basic UAS design that
ensures safe and reliable operation in typical civilian service applications. Ultimately, the pace of integration
will be determined by the ability of industry, the user community, and the FAA to overcome technical,
regulatory, and operational challenges.
•

11. • Unmanned aerial vehicles pose an increased risk in comparison to other air traffic. An unmanned flying
system consists of the drone itself, the ground station and the communication technology. There are therefore
three possible sources of error. Current contention reflects that the safe integration of civilian drone traffic into
the available airspace is fraught with uncertainty and a steep learning curve for all involved (Wilde Beuger
Solmecke, 2014).
•
• The purpose of this research is guided by the need for this new commercial sector to understand the severity
of operating UAVs in an integrated airspace system with manned aircraft. This research will determine from
sample data how the public will view the transition.

12. Methodology
• As this is a relatively new area of study with little prior research data available upon which to base this
project, new methods will be used from the start. Although few studies are available, they are not current to
date. Since a regulatory structure has not yet been set in place for UAVs, there are limited ways to collect data
regarding means to test the hypothesis. For this reason, there will be no scope of validating any prior research
done in this field.
• Data collection methods will be both by questionnaires and interviews. As time will be limited to one
semester, the majority of data collected will be through surveys that will be sent via post or internet to those
participants actively involved with the national airspace system, such as air traffic controllers and pilots, as well
as those who are not directly involved with the NAS.
• Interviews will be used for participants of the study who are both current and planned operators of UAV’s.
The questionnaires will involve closed-ended questions, while the interviews will be open-ended and more
detailed.

13. • As the number of active commercial operators under the exemption is limited, the survey will involve more
operators that plan on starting operations once the FAA has begun the process of implementing the new
regulatory structure and integration of the airspace has begun.
• Content in both the questionnaires and interviews will encompass the scope of challenges that the FAA faces
and the level of participants’ understanding towards regulatory compliance.
• Selection procedures for participants in the study will be through snowball sampling. As the UAV
communities, both current and planned, are extremely limited, this method would be most favorable for
recruiting the maximum amount of participants in the limited time allotted. It would be possible to use
respondent-driven sampling (RDS) if desired, but that would be decided at a later stage if weighting is warranted
with the number and type of participants available.

14. • Data will be analyzed in accordance with the participants’ roles, or future role, in the national airspace system.
Roles of the research study participants will include air traffic controllers, pilots, and both current and future
commercial drone business owners and operators.
• Results of the data will be tested against the hypothesis, “Regulatory compliance and cooperation will be
imperative in order for Unmanned Aerial Vehicles to become a significant component of the national airspace
system.”

15. Implications and Limitations
• Limitations encountered during the research may include the time period allotted for the entire research project. One
semester will encompass the entire research process of collecting data, analyzing, and publishing. In this process,
collection of data may be the most time-consuming.
• The basic timeline for this study will be:
• September – Identify and describe the variables, locate samples, collect data
• October – Pilot test hypothesis, analyze data
• November – Conclusions regarding hypothesis
• December – Publish findings
• Since this is new research that will not be building upon any past pilot studies, there will be provisions in place for
possibilities when steps of the study do not progress as planned. A potential limitation may be the selection of an
insufficient number of qualified participants in the given allotment of time. An ample number of questionnaires will be
distributed. In the unlikely event that there are an insufficient number of respondents to the survey, then there will still
be enough interviewee data to test the hypothesis.

16. Resources
• Resources needed for the collection of data are basic and of current technology which is readily available.
These include questionnaires to be distributed via U.S. mail and internet. Interviews will be done in person
with participants from at least two major metropolitan areas. The latter may be increased if time permits.

17. References
• Bennet, W. (2014). Civilian drones, privacy, and the federal-state balance. Brookings Institution. September, 2014. p.1-22.
•
• Carr, E. (n.d.). Unmanned aerial vehicles: Examining the safety, security, privacy, and regulatory issues of integration into U.S. airspace.
National Center for Policy Analysis. Retrieved from: http://www.ncpa.org/pdfs/sp-Drones-long-paper.pdf
•
• Cavoukian, A. (2012). Privacy and drones: Unmanned Aerial Vehicles. Information and Privacy Commission. Ontario, Canada. Retrieved
from: https://www.ipc.on.ca/images/Resources/pbd-drones.pdf
•
• Clarke, R. (2014). Drones’ challenges to public safety. Unmanned Aerial Systems Conference. 17 February 2014, Adelaide.
• FAA. (n.d.). Unmanned Aerial Systems. Retrieved from: http://www.faa.gov/uas/
• Jenkins, B. (2014). Watching the watchmen: Drone privacy and the need for oversight. Kentucky Law Journal. Fall, 2013, Vol.102 (1),
p.161-182.
•
• Weibel, R. & Hansman, R. (2006). Safety considerations for operation of unmanned aerial vehicles in the national airspace system. MIT
International Center for Air Transportation. Report No. ICAT-2005-1
•
• Wilde Beuger Solmecke (18 February 2014). Civilian drones and the legal issues surrounding their use. Retrieved from: https://www.wbs-
law.de/internetrecht/civilian-drones-legal-issues-surrounding-use-50459/