FAA Webinar: How to Apply for a UAV Waiver

Overview
In this webinar, speaker Kevin Morris provides an in depth perspective on how the FAA processes UAS related waivers. Starting with the definition taken verbatim from the slides in the video, a waiver is an official document issued by the FAA which authorizes certain operations of aircraft outside the limitations of a regulation. If you are applying for a waiver you must prove to the FAA that your mission can demonstrate an equivalent level of safety of the waived operation. If this is something that ythat interests you, click on the video below, and check out my annotations.

Although this video focuses on operational waivers, it is important to know the difference between an operational waiver and airspace authorization. Taken directly from the video slides are the following definitions.

• Operational Waiver-the authorized method in which you will operate your UAS while deviating from a regulation

• Authorization- permission to fly in a specified segment of airspace while still following all of the rules. This can be obtained through sources such as FAA Dronezone and LAANC. 

Shown in Figure 1 is a chart taken from the FAA website that serves to link an example scenario to the appropriate waiver that you should look into.

Figure 1: FAA Operations that Require Waivers

Waiver Policy Requirements (107.2)
 This is pretty much an outline that the FAA provides to help you write your waiver. As stated in the video, a complete description of your proposed operation must be submitted to the FAA in as much detail as possible. In addition, the FAA needs justification that demonstrates that you will fly the UAS safely while deviating the rule. Perhaps the most important words in the those two sentences are complete and justification. If you fail to communicate to the FAA how you model those words in a proposed UAS flight, your waiver will likely be rejected. If the waiver is not rejected, the FAA may prescribe further limitations on your waived operation.

Waiver Process
After determining the mission that you want to get a waiver for, Go to DroneZone and visit some of the links in the tan box similar to the screenshot shown in Figure 2. Provided that you have read the pertinent information as well as consulting other sources such as this blog, Click (on) “Create Part 107 Waiver/Authorization” and fill in the required information on the website. The FAA will then review the request and if you have provided a holistic, detailed, and data supportive evidence the FAA may give you an approved waiver in approximately 30 days. Nevertheless, the burden is on you to prove to the FAA that you will be able to the sUAS in a way that doesn't sacrifice any safety risks that are a result of the waiver in the first place.

Figure 2: FAA Dronezone Screenshot

If  the FAA requires more details of your operation, they will issue a Request for Further Information (RFI). In the video, Morris emphasizes that if you receive an RFI, respond to it as quickly as possible otherwise the FAA will table it and move on to other applications. In this case, you could prolong the waiver process significantly. If the waiver is denied, the FAA will send you feedback which can help you get an approval. In other words, the FAA will try to work for you even though it isn’t necessarily their responsibility to.

Waiver Tips

• Submit the waiver 90 days prior to the proposed operation to be sure that there is time
• Note the time window of your waiver
• Be sure to read all of the instructions
• Utilize the guidance links in Dronezone! 

Waiver Safety Explanation Guidelines (WSEG)
This resource is mentioned in nearly every waiver related webinar so make sure you take advantage of this resource. Although it does not guarantee that following it will get your waiver approved, the (WSEG) has important questions that will be identical to the waiver itself. Furthermore it has important instructions that need to be read in their entirety to ensure that your providing the correct data the FAA requires   Click here to be directed to the WSRG.

Navigating the Waiver Application: DroneZone
If you have created and loged into your DroneZone account and have followed along with the video, pay close attention to 17:00-25:00. In my opinion, there is no better way to learn about this process other than viewing it from the video. Nevertheless, there is a skeleton of this process listed below:

Know what you are requesting

• Operational Waiver? (focused on in the video)
• Airspace Authorization?
• Airspace Waiver?

 Acknowledgment

• Who is the responsible party?
• Individual
• Organization
• If an organization has 10 remote pilots, that want to fly at night and a waiver is approved to do so, there is no need to submit 10 waivers. 

Anticipate if you will need more than one waiver per regulation.Although the FAA does not typically issue more than one waiver, the scope of the mission will make that determination.

Waiver Application

• Select Regulation that you want to be used
• Operational Parameters
• Exhibiting Waivers

Details About UAS

• This is required for most waivers, there are some instincases where this is not required
• If you upload attachments, bookmark them so that the waiver team can process the information faster

Confirmation

• Dronezone Account will tell you when application is reviewed
• Make sure that waiver is 100% Complete! 

Common Mistakes

• People fail to read the instructions
• People don’t filly address the Waiver Safety explanation Guidelines question
• People don’t provide a method with sufficient detail describing how risk is mitigated

Conclusion

When applying for a waiver, it is essential that you know how to navigate DroneZone and that you select the appropriate regulation that you want an exemption from. Therefore, having an understanding of general FAA regulations are essential to the success of your waiver application. In addition, you need to keep in mind that since the FAA cannot physically be present to see the operation, you must communicate your safety procedures in a way that is complete and justified. In other words, if you have an argument that your operation is safe, you not only need to provide multiple sources of data proving that, but you must validate your sources with a thorough explanation. 

FAA Webinar: How to Legally Fly Beyond Line of Sight

Overview
The Operation of Beyond Visual Line of Sight (BVLOS) is one of a family of waivers available under Part 107. As discussed in other waiver webinars, the FAA expects the language for the BVLOS to written in a certain format. In this webinar series, Kevin Morris provides tips and resources on how to increase your likelihood of obtaining a BVLOS waiver. As always, the video to this webinar can be accessed below and you can see my annotations of the video the further down you scroll.

Starting with 107.31, the remote pilot in command must maintain visual line of sight with the sUA at all times. This also applies to the control operator and the visual observers. The FAA expects that the mentioned crew can be able to determine the following items while maintaining visual line of sight.

• Aircraft Location
• Attitude, altitude, and direction of flight
• Note any other traffic in airspace
• Ensure the sUA does not endanger anybody or their property

Risks to Operating BVLOS
Perhaps the biggest concern to the FAA is making sure a waiver applicant will be able to demonstrate how they are going to use the see and avoid technique despite being beyond line of sight. Other topics of concern include but are not limited to:

• GPS signal
• Equipment reliability
• Proving that the operator knows that they will not be flying over people or vehicles
• Frequency interference
• Transmission range
• Is everything FCC approved?
• Cloud Clearance Requirements

Equipment Reliability
As mentioned in other waiver application videos, the FAA wants to know if there are life limited parts, a maintenance program to address the life limited parts, and a description of the components that make up the sUA. Furthermore this can include items such as:

• Software
• Command and control links
• Maximum distance sUA can fly without loosing signal
• Failure rate of systems

Waiver Safety Explanation Guidelines
This topic is a recurring theme in every waiver related FAA webinar that I have seen. Therefore referencing the waiver safety explanation guidelines is something that I think every applicant must do in order to have a chance at getting FAA approval. Because the FAA is highly concerned with the safe operation of a sUAS, applicants need to have detailed risk mitigation and must address circumstances that can occur in the event of an emergency. Taken directly from the video, there are 7 key items of concern which are listed below:

• Continuously knowing the position, altitude, attitude and movement of the aircraft
• Avoiding other aircraft/flying over people
• Ensuring the sUA will be seen ad a distance of at least 3 statute miles
• How will the RPIC be alerted if there is a malfunction
• Does the operating crew knows the capabilities/limitations/process of sUA?
• Weather/Cloud Coverage
• Description of Transmitters/Control Links

Important Considerations
An understanding of the latency rate and how it can affect the operations of the sUA can greatly improve your chances of obtaining an FAA approved waiver. In addition, the FAA wants to know your thought process pertaining to how you will address a lost connection and how the sUA crew will know where the sUA is.As mentioned in the video, the FAA is interested in knowing what the crew will do when the mission does not go as planned because in theory, an applicant has a reputation in completing successful missions. Nevertheless, this assumption is checked by the FAA to ensure that they can trust the applicant’s ability to safely operate a waived mission.

Transmissions and Receivers
Aside from proving to the FAA that the crew will know that the sUA will correctly navigate through it’s intended area of operation, the FAA also wants details on the ranges of the transmitters and receivers. Shown in Figure 1 is a diagram taken from Researchgate.

Figure 1: Retrieved from Researchgate

Other Applicable Rules
To emphasize that although you are applying for BVLOS this does not mean that your exempt from other Part 107 operations. In fact it would be wise to address the operations listed below:

• 107.19-RPIC responsibilities
• 107.23-Hazardous operation
• 107.37-Right-of-way
• 107.39- Operations Over People

If trying to address 107.39, the FAA wants to know what program are you using to get flight traffic data on and how close to rel time is it. In addition, the FAA wants to know about what you used to determine who you are flying over (which relates to 107.39). Since the FAA likely doesn't live in your operating area, they need to know details about the population. Furthermore, you need to ensure that the sUAS can be seen from other people from a minimum of 3 statute miles as mentioned in other FAA webinars.

Questions to Ask the Crew

• Do they understand what your doing?
• Do they understand the limitations?
• Do they know GPS liability in respect to tall structures?
• What happens when GPS goes out?
• How do you accomplish a safe let down of the sUAS if GPS is lost?
• How do you ensure clouds are consistent with the duration of UAS flight?
• Is there an FCC Grant or licence?
• Does the system operate with an acceptable bit error rate?

Conclusion
Although BVLOS is a very complex, high risk UAS operation that requires significant research, mission planning and checks and balances, it is not an impossible waiver to get. Three tips taken directly from the FAA video include knowing the airspace, having a process on how you will remain in compliance with other parts of 107, and ensuring that the RPIC will have control of the sUA at all times. In recent news, Uber Eats has been testing sUAS and has delivered food BVLOS and is rummored to be in the final stages of becoming an air carrier. Althought this will be under part 135 rules, Uber has a system that meets the FAA's BVLOS expectations. To learn more about that click the video below.

FAA Webinar: How to Legally Fly Over 400 Feet

Overview
If flying under Part 107, 400 feet AGL is the maximum threshold that you can reach with your sUAS. However, if you are flying within a 400 foot radius of a structure, you can fly 400 feet above the structure’s uppermost limit. Remember: Airspace can change! For example, if you are operating a sUAS 400 feet over the height of the structure in the red box shown in Figure 1, you will have switched from uncontrolled airspace to class Bravo airspace which requires a whole different method operating procedures.

Figure 1: UAS Operation Consideration

Webinar Description                                             
The following video is a Webinar that you should consider watching if you are interested in obtaining a waiver for an sUAS flight above 400 feet AGL. Similar to other Webinars, I created an outline of key takeaways to improve my understanding of the procedures that need to be in place for a successful sUAS operation. Click on the video to view the Webinar, and scroll down to view my takeaways.

In the first section of the video, the FAA introduces broad questions that need to be considered throughout  the session. These include directly addressing:

• How will you avoid other aircraft? 
• Will you have to communicate with Air Traffic Control? 
• How do you account for varying wind and weather conditions?  

Next, a very solid understanding of airspace is critical for the the success of a waiver. Understanding of airspace includes but is not limited to knowing:

• Common routes aircraft operate at
• Aircraft operation frequency
• Military activity
• Aerial applicator activity
• Helicopter activity
• Ensuring that the operation will not fly over people  
• Turbulence generated from wind farms
• Weather Conditions
• Who will be contacted to coordinate the UAS operation

In addition to the list above, you are going to need to know what aircraft you are sharing the airspace with and effectively demonstrate how you will be able to detect the other air traffic. If your operation requires visual observers, how do they communicate with you to ensure that the sUAS operation can effectively detect and yield to other aircraft? As repeated several times in the video, the FAA wants to know what your doing and how you're doing it.

Furthermore, an in depth understanding of who is controlling the airspace that you are in is vital to the success of obtaining an approved waiver by the FAA. This may involve direct communication with an Air Traffic Control Facility (ATC). Taken directly from the slides in the video, some questions that you should be prepared to answer in detail include but are not limited to:

• Which ATC facility is controlling the airspace?
• What type coordination will be needed?
• How will you prove that other aircraft will be separated from the sUA?

Waiver Safety Explanation Guidelines
As mentioned in several of the other FAA webinars, using the Waiver Safety Explanation Guidelines will aid you in writing process for the waiver. Remember, simply answering  the questions in this outline as well as the Waiver Safety Explanation Guidelines might not be enough to obtain a waiver. However, there are five key points taken from the video that are very important to address at minimum.

• Avoiding non participating aircraft/structures
• Ensuring the sUA will be seen at a distance of at least 3 statute miles
• Accurately determining the sUA altitude, attitude, and direction of flight
• Describe the area of operations
• Air Traffic Control communications

When flying at a higher altitude, the sUA will become alot more difficult to see. Therefore you must consider 107.31 and be able to determine if the sUAS is above, below, or on a collision course with another aircraft.

Lighting Considerations
In the daytime, the light on the sUA will become more difficult to see. Although you might be able to see the lights on the sUA, how will you insure that other aircraft will be able to see the sUA? Remember, other aircraft must be able to see you from at least 3 statute miles. In certain cases such as restricted airspace, or TFRs, you might be able to argue that other aircraft do not have to see the sUA.
Nevertheless, make sure the manufacture of the lights that you have for your sUA guarantees that the lights can be seen 3 statute miles or more. Shown in Figure 2 is the UAV micromax light. Although it appears to be operating in a day time condition, testing needs to be done to confirm that it can be seen from someone 3 statute miles away. 

Figure 2: UAV Micromax Light

Expectations for the Remote Pilot In Command
Taken directly from the slides in the FAA video, the Remote Pilot in Command must always know the following when operating the sUA especially in an altitude higher than 400 feet:

• Geographic location 
• Altitude AGL
• Attitude
• Direction of flight
• Visual line of sight

In applications that have failed, many request altitude that goes beyond visual line of sight. This can be corrected by submitting an extensive beyond visual line of sight waiver which is talked about in another blog post. Lastly, the FAA wants to know what kind of communications equipment that will be used during the proposed mission. More specifically are questions that one should highly consider answering in regards to communication equipment:

• Is it authorized?
• Is it reliable? 
• Is s there a backup system?
• Who will answer the call when your the RPIC? 
• How will ATC contact someone if there is no phone signal? 

Conclusion
In order to successfully obtain an airspace waiver, it is vital that the UAS crew effectively describes how and why a proposed mission will account for airspace, visual line of sight, and risk assessments throughout the entire operation of the sUAS. If you are someone who is planning to get this type of waiver for the first time, I highly recommend that your team practices the communications, emergency procedures, and crew resource management in a lower altitude that way you can better analyze and set up expectations for a higher altitude operation. For more resources that better help you plan your mission and obtain a waiver visit https://www.faa.gov/uas/commercial_operators/part_107_waivers/.

FAA Webinar: Operations Over People

Overview                                                                                                                                                   If you are someone that is interested in flying a sUAS over people, use the following as an outline to help you understand what considerations need to be made. In an effort to improve my knowledge of the administrative requirements for waivers, I figured I’d share my takeaways from an FAA webinar that addresses 107.39- Operations over people. To view the video in its entirety, click on it below.                                                                     

Understand 107.39 and 107.23
In the first part, an understanding of Part 107.39 is reviewed. Key takeaways include: 

• Crew members directly participating in the sUAS mission. 
• Defining directly participating  crew members in the context of a sUAS 
• Defining crew crew members that are not included in a sUAS mission 

According to AC 107-2, Crew members directly participating in a sUAS mission are defined having involvement necessary for the safe operation of the sUAS. These include 

• The remote Pilot In Command (PIC)
• The Visual Observers (VOs)
• The Sensor Operator
• Anyone safety related official. For example this can be a police officer closing off a road so that you can fly a sUAS over it without any traffic interference

On the other hand, crew members do not include 

• Public that is made aware of sUAS presence but not apart the operation
• Newscasters/Reporters
• Actors 

Next, Operating over people is defined as the action of a sUA passing over any part of a person:

This Includes people not directly participating in the operation. The parameters defining the word "over" are depicted as an imaginary cylinder that extends from a person up to the UAS as shown in Figure 1. If the diameter of the cylinder changes and you fly over a part of it, you will have flown

over the person.                                                                                                                                                                                                                                              . 107.23a which defines Hazardous operations of a UAS is explained to show that although you might be conducting a flight near people, you must not fly in a way that can endanger someones life. Therefore it is important to know:

• How to control the flight direction of the sUA at all times
• The ground speed of the sUA
• The wind
• Altitude

After having an understanding of how both 107.29 and 107.39 interact interact with each other, An overview of how waivers may be issued from the FAA was introduced emphasizing that applicants for a waiver

• Must have a complete description of the operation that they want to complete
• Provide a detailed description of how the operation will be conducted safely                                                                                                 

Inventory the sUAS

Since there are several risks associated with operating over people, providing a detailed inventory of your sUA and a description of the components that are on board the sUA will help the FAA better understand the level of consequences that a sUA could have if an incident flying over people were to occur. Given the fact that humans have the potential to interfere with the aircraft, the FAA is highly concerned about how people beneath the unmanned aircraft will remain safe. Therefore they want to know that you are aware of the extent injury your sUA can potentially inflect on someone. Specific items that an applicant must look into include but are not limited to:

• Make up of the sUA blades
• Material of the aircraft
• RPM on the aircraft blades
• Weight of the Aircraft
• Operation Altitude
• Velocity of Aircraft
• Life Limited Components 

At the very minimum, the FAA wants to know that in the event an emergency were to occur, that an applicant has detailed contingency plans in place  ideal for the specific missions that the sUA will engage in. For information about how to further adjust your mission to ensure that key safety requirements are met. Visit the Waiver Operation Safety Guidelines from the FAA website. More importantly, it is emphasized in the video that the Waiver Operation Safety Guidelines are a starting point and a complete analysis of a proposed flight is expected in the waiver application.

Mitigate the Risk . 

There are 4 main topics that the waiver operation safety guidelines want to explain. These are taken directly from 11:41 of the FAA video. 

1. When the sUA impacts a human, the sUA the sUA will not cause a serious injury or worse
2. Data addresses not only blunt trauma injuries, but also laceration injuries
3. Operating conditions, limitations or procedures that must be followed to ensure safe operations
4.  Qualifications of the Pilot in Command or the person manipulating the controls 

Shown in Figure 2 is the Safety Risk Matrix posted by the FAA. It is best practice to do everything possible to stay in the green. 

Figure 2: Safety Risk Matrix taken from the FAA Video

Questions to Consider 

• How do you know what injury level a sUA can inflict upon a person? 
• How was testing data performed?
• When was testing data performed?
• Alternatively to testing data, how can you ensure that a sUA will not hit a human? 
• What other safety related features will also reduce  risk?  
• Are there are limitations of safety features?
• How do safety related features work? 
• Do you have a maintenance program?
• Do you have a procedure to correct older components?
• How do you track software updates?
• Is the Remote Pilot in Command aware of the safety measures in place?
• Is the Remote Pilot in Command experienced in using emergency equipment? 
• What is the estimated time of the operation?  

Conclusion
As stated in the video, flying over people is not an easy waiver to get. However, according to recent UAS initiatives, there are proposed rules that will allow certain sUAS to fly over people without having to obtain a waiver. Furthermore, obtaining a waiver may become easier depending if the installation of a Parachute could be applicable to your UAS. Nevertheless, a thorough analysis of focusing on the safety of the people the sUAS flys over is key to the success of getting the FAA to grant approval to your waiver.

The State of Drones in Big Business

UAS is rapidly becoming a central part of our economy. Because of this, businesses of every size are seizing to opportunity to embrace UAS technology assuming that there is a need for it. To further your understand of UAS in the business arena, I encourage you to read a white paper put together by Skyward- a UAS consulting company related to Verizon.  To access a free version of its white paper, click on the image below.

A key takeaway that I want to focus on in this white paper is the bar graph depicting the challenges companies have faced while using UAVs shown in Figure 1. As no surprise for me, nearly half of the companies surveyed have trouble staying up to date with UAV laws and regulations followed by ensuring the correct performance of procedural duties otherwise known as crew resource management. Thankfully, my education at Purdue University has not only taught me to excel at tackling the first two issues head on, but I am confident in my ability to provide solutions to the latter issues as well. In fact, most of the solutions are demonstrated throughout this blog so keep an eye out for more posts regarding these topics.

Figure 1: Challenges in UAS Among Medium and Large Scale Companies

Drone Pilot Field Kit

Another tool that you can use to improve your credibility as a UAS Pilot is the Drone Pilot Field Kit that has been created by DRONEU. Although it resembles a cluster historic, vague, and debatable topics that can cause people to ponder over for hours, I believe the insight, the interpretations and the data provided it this work prepares people for what lies ahead in the rapidly changing UAS industry. Click on the Image to download a free version of this 695 page masterpiece. 

UAS Saving Lives In Africa

Quoted as "radical technology" speaker Keller Rinaudo argues that small developing economies in Africa can out innovate wealthy economies and legacy infrastructure. In the video below is an explanation of how UAVs are being used to serve over 1,000 medical facilities, 4 different countries and over 10 million people. Although UAS regulations in the United States are significantly different then Africa, Zipline has been able to master a system that some of the largest companies in the world have not been able to figure out yet. More importantly they are making the process self sufficient to the locals that they serve. Click on the video to learn more about this fascinating Application of UAS technology. 

How UAS is Saving Lives In Africa