The transcript of the session is below but keep in mind I did not go through it to correct little things. The links and documents mentioned in this webinar can be found here.
The speakers in this webinar included the folks below.
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Thank you so much Tim I’m so glad that everyone could attend today.
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My name is steve Roade. I am the chief pilot for the airplane and the drone with the wake forest Fire Department and as Tim mentioned, I’m also a Drone Pro here with the Greensboro fizzed Oh,
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the goal today is to help answer all the questions for public safety operators, both law enforcement, fire rescue, everybody.
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And if you have a question, go down to that questions uh tab that Tim mentioned and type your question in.
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We want to try to answer as many of your questions as possible,
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during this presentation, The big goal here is to clear up misinformation that people have about public aircraft operations and operating drones in public safety.
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It’s a very new field and a lot of information is passed on and learned from one person to another or something that we heard at a seminar read in a magazine but this is the crew.
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Uh these people on this webinar from the FAA are the authorities that can help specifically answer your questions and more importantly keep us all out of trouble.
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Uh and along the way we encourage you to continue to use and utilize this new technology but flying within the rules,
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so the panel that we have today is,
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John Meehan, he’s from the national outreach program with the FAA gentleman, a scholar and a very nice person that you should reach out to or talk to.
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Also we have Kate Barber, She’s an attorney with the FAA.
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And enforcement attorney along with Heather spangler who is also another FAA attorney enforcement attorney with the FAA WHO deals with enforcement issues on a regular basis.
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You have myself north Carolina, Drone Pro uh and as I mentioned with the wake forest fire Department.
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And we have Tim kam lin, who is the drone point of contact with the Greensboro fizzed, Oh and we also have Tim Haley who kind of runs the show there and he is the man in charge.
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Our goal is a team here is to help you understand that there are lots of good people at the F. A.
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That want to help you find the right answers and utilize drones in public safety.
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Uh like I said, there’s so much rampant misinformation out there that you have to be proactive and hunt down the answers yourself.
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I personally have a website ps like Public Safety Flight https://PSflight.org where I publish regular articles and also answer questions from people in the public safety field.
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And it is always interesting when you get a question and then you research it how the facts really don’t support many of the assumptions that people have.
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So today we hope to leave you with good information so you can make good decisions uh to even make it more complex in the public safety world, there are two sets of rules that people can fly under.
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We have the certificate of waiver or authorization also known as the COA or we have part one oh seven operations and I find that a lot of public safety,
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organizations are confused by what the rules are,
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and to make it even more confusing.
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The rules for a COA flight and a Part 107 flight are not the same. And it can be very complex.
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The the I was gonna say the damage but the consequences of not flying within the rules or making assumptions.
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Is there can be an investigation of the actions above the pilot, the responsible person with the department, the department itself.
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And it’s important to know that not every investigation begins with a crash or an incident or something like that in public safety.
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We’ve all faced the what’s the political correct term.
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We’ve all faced the agitated citizen sometimes who misunderstands exactly what we’re doing,
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and all it takes is somebody who is agitated or upset for whatever reason to contact any of the FAA physio offices and that starts a complaint.
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And I’d like Tim Haley to talk for a moment about what happens when an investigation starts.
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Well steve, you know, the investigation, probably uh large percentage of people on here law enforcement. So they know how the investigation process work.
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But you know, it all starts with a somebody calling in a complaint or somebody observing the complaint and reporting to the fist, Oh, and by law we’re required to investigate every complaint we get.
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No matter if it seems like it’s just some kind of trivial uh complaint or not.
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You know, half the time the people are calling in are not aware of what the rules and regulations are. So yeah, some of the complaints we get, there’s no uh the legitimacy to them at all.
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So the first thing that’s gonna happen is when it gets assigned to a aviation safety inspector, he’s gonna make a call to the drone operator.
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And he could ask for some documentation and on this initial call, he’s just trying to find out if he needs to continue with this investigation or it’s just totally bogus because the drone operator operating with inside the law.
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So, you know, he might ask for a flight log, he’s clearly gonna ask to see a pilot certificate.
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Probably going to see if you’ve had some kind of biannual flight review or 24-month flight review.
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You might ask if you’ve got some training records. Probably gonna ask you to download the flight data from the flight profile. So you’ve got some of that information probably also gonna want to see uh that they’re the drone is registered.
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Um you know, he’s just building, he’s just looking to see if there’s any kind of issues there that he needs to investigate further.
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And then if he from that initial contact, which I want to encourage you to be as cooperative with this guy as you can because he’s got some paperwork on his desk and he’s really wanting just to get that moved along.
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So if he can determine right quick that you didn’t break any laws, he can close this case out and move on.
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Otherwise after that, you’re gonna receive what we call a letter of investigation. And that’s where we’re taking it to the next step.
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And from there, he’s gonna ask for supporting documentation to prove to him that you were operating within the rules and regulations.
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And from there, it’s the standard case that even the law enforcement guys on here know about it. From there, all the items improve get put together. And that’s when it gets forwarded on to our attorneys. And that’s when they start the investigator, the legal action of the case.
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You know, some guys uh are operating out there without a certificate and they’re thinking I don’t have an airman certificate. There’s nothing can happen to me.
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Those guys soon find out that with the lack of an Airman certificate. Then we’re looking at civil penalties.
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So you know, if you’ve got a certificate and airman certificate, then you’re probably looking at certificate, suspension.
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If you don’t have one, then you’re looking at civil penalties and that’s pretty much how we handle it right there and it’s handled at the local FSDO level.
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All right, thank you tim. And one of the things that Tim mentioned was part of the information that the pilot is going to be asked for is not only their pilot certificate, but also flight logs and data.
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And this is why it always pays to know the regulations fly within the law.
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Is because uh that telemetry, that flight log when an investigator looks at it can really throw you under the bus and show that you were not flying compliant lee.
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So there is a record that will show whether or not you’re flying within the regulations and if you’re not flying within the regulations, there are two big things that might catch you.
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One of them is uh unique for COAgencies and we’re gonna talk about that coming up, but,
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it’s important to remember that no matter who you are, the pilot in command is always responsible for the operation of the aircraft.
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Everything that’s gonna fall on the department or the responsible person, the COA or anything else,
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um, is ultimately also going to land on the shoulders of the person operating the drone, operating the controls, that’s the remote piloting command.
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If the aircraft is found to have been operated a manner that violates the federal aviation regulations, the pilot can face a number of consequences and the monetary penalties can really add up, they can be severe.
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So, I would like to introduce John Meehan for our next slide,
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to talk about the differences between a COA and Part 107,
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and especially this very tricky subject of if a flight qualifies as a public aircraft operation, John oh, nice, Easy one.
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Thanks. Yeah. So we get this question all the time and, but before I get to that, I want to, I see a lot of we’ve got a lot of public safety folks on here, and I want.
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I really want everyone to understand that anyone who flies an aircraft and a drone as an aircraft, anyone who flies an aircraft in the national airspace system. Mhm.
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Other than the United States military is governed by title 14 of the US code and that means you, so if you’re on this, what we are, it applies to you.
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Uh So uh and public safety, if you are a qualified government entity uh which is essentially the federal government or a political subs a state or U.
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S. Territory or the District of Columbia or indian tribal nation or a political subdivision of those, you may qualify to operate as a public aircraft you meet.
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And these are defined not by you, not by me, but this is actually defined by the United States Congress in the United States code as to what is a public aircraft and it’s not what you think it is.
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So take a look at that. For example, if you’re a 401 or sorry, if you’re a 501(c)3 uh entity more than likely you are not eligible for what we call public aircraft operations by law.
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So there, so there’s some entities are able to to qualify for this.
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But then there’s also an additional limitation on what kind of missions can be flown as a public aircraft.
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And they are very limited. There’s only six or seven types of missions, law enforcement, firefighting, search and rescue, biological and geological resource management, uh aeronautical research.
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There might be another one there, but that’s in the statute that’s listed in the statute as well.
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Uh, and you’re either and part if you fly as a public aircraft, Remember I told everyone you’re, everybody on this webinar is going to be governed by title 14.
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Title 14 has different parts.
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One of the parts is called Part 107 and another one of those parts is called Part 91.
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And if you fly as a public aircraft, you’re actually flying under 14 code of federal regulations, Part 91.
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And if you’re flying under Part 107, you’re operating as a civil aircraft under Part 107. So,
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I think you, you asked me steve what’s the difference uh In my opinion, the main difference is that you can do 100% of your missions That you’re asked to do as public safety.
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You can do 100 Of those missions as a Part 107 civil operator.
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You can do only a very limited, very small amount of those missions as a public aircraft and any flight that the FAA deems was not a qualified public aircraft flight,
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Is deemed as a civil flight under Part 107.
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Does that answer your question, steve or did you want me to go further?
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Yes. And uh an important point that our audience should know is that for helicopter operations,
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like law enforcement and fire helicopter operations that could operate under a COA as a public aircraft operation, John you have mentioned many, many of them that they choose not to.
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Yeah, that’s right. And and uh when I, There’s about 350, uh I think there’s about 350 helicopter units out in the country.
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And every time I have the chance when I’m talking with their chief pilot, I always ask them, hey, you guys are qualified as public aircraft.
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Do you operate as public aircraft already operate as the civil aircraft? And they, I’ve never had one yet. Tell me that.
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Well, they all say no, we only do part 91 as a civil aircraft. And I asked them why and they said, well we do it for a number of reasons.
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Well, one reason is that it’s too complicated to no Two sets of rules For our pilots, but the 2nd 1 is that.
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In order to have the ability to do all the missions were required to do.
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We have to have Part 61 helicopter pilot certificate which is required when you fly as a civil aircraft. For example, if we want to fly the governor around, can’t do that as a public aircraft.
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They have to do it as a civil aircraft. And so the civil rules apply. So they have to have a uh a commercial helicopter pilot certificate to do that.
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And another reason they tell me they do this is uh they require any pilot applicants to to walk in the door with a f a pilot certificate.
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And they say the reason they do that is because they want everybody to start with a basic level of knowledge about the national airspace system.
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How to read a visual flight rules sectional. For example, they don’t wanna have to teach that which they would have to do as a public aircraft operator that thing.
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And John there there are some other uh quicksand areas in the whole cooperation.
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Look, I understand why lots of people went the COA route and why they feel that it is best for them.
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What I’ve actually found exactly what I mentioned before is that they haven’t asked all the right questions and they don’t understand the whole coma thing.
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Like for example uh if you are operating under a COA and you want to train new pilots to fly for your department That do not have a Part 107 certificate.
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John training flights are not approved. Public aircraft operations, are they.
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Yeah, that’s right. Uh Public aircraft, the statutes are Office of General Counsel has determined that the statutes do not allow for training flights as a public aircraft.
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So training flights and this is even mission specific training training flights.
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So you you’re going to have to have your Part 107 certificate anyway, or fly under the immediate uh guidance or you have to be flying next to a Part 107 certificated pilot who’s in a position to take control.
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Uh But yeah, so that’s a, it’s a big, big land mine out there.
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So John Charles Bun has asked a question, very question. He says, if all of your agency pilots are 107, is there still a need for a COA?
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Uh you know, that’s a decision that’s really best made by uh, the agency itself, but in John’s personal opinion, uh, I am not uh, I’m not convinced that you need the COA and,
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and you started to allude to it earlier, but uh us and the rules and policies are evolving every day and about,
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I would say 23 years ago COAs were pretty compelling and I liken this to be like a pendulum swinging back and forth.
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And in the early days, co has had a big advantage which was, you could fly at night and you could, in a life safety situation, you could operate over a person.
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Well those are gone. Now, those advantages are gone now because in april of this year, Part 107 was amended to allow for night flight without a waiver.
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Um you have to undergo the current training which includes night uh specific topics and you have to equip your drone with lighting just like you had to do with a COA.
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So that advantage is gone. So uh and then the other advantage used to be well now you can operate Uh that that advantage went away when we amended 10739 which is operations over people.
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Now you can operate over people without a waiver. But you must have what we call a category approved drone.
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And and that that’s in process.
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There is a drone category, they call it category one.
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That is that those are very small drones but you can operate today over people uh With a Category one drone under Part 107.
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So and just to be clear, John and if you’re flying under a co uh uh now uh there are, can you fly over people are their operations that are allowed?
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Well you can only fly over people uh for very very brief periods under COA in a life safety situation.
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In other words, if you don’t, somebody’s going to die, that’s pretty much the standard that’s written into the COA John that’s a great part, sorry to interrupt you.
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But when we talk about emergency situations to fly uh you you clarify it, there has to be life has to be life safety.
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That’s right. Yeah. And and and this is this is because, you know, why why do we have the flight rules? They’re darned inconvenient for public safety, aren’t they?
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Yeah, they are. Sometimes they are, but they’re there for everyone’s safety. And remember, it’s a shared airspace we want.
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Our aviators to operate their aircraft in a safe way, that’s not going to injure persons and property on the ground as well. And a drone falling out of the sky, hitting someone with kinetic energy is going to, it’s gonna leave a mark.
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And so that’s, that’s why those rules are there, they’re not there because we like,
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you know, making things inconvenient for people, they’re there, they’re there because of safety and let me beat this dead horse yet again about a drone safety is that no drone flying today has,
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ever passed any certification test or proven to be safe.
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They are not built to any standard more than any piece of consumer electronics and they fall out of the sky every day or they fly away or they have some other malfunction.
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Um, they are not as reliable as a type certificated aircraft and those drones are coming um, there are companies in the process right now that are passing, working to pass,
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Safety certification tests and those drones will be in the category four for operations over people and I have much more latitude than any other drone out there.
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Yeah, it’s gonna be, it’s gonna be a big paradigm shift.
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I believe that when type certificated drones hit the market, uh.
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I would think a lot of government entities are gonna want to take a hard look at those John Aaron Boswell asked, isn’t a COA beneficial for flying in airspace other than g.
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You know, I would argue that now that we have LANNC and now that LANNC is available 24 hours a day, seven days a week, I would argue that not anymore, is my answer, uh,
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uh COA’s when you, when you apply for a COA, you’re gonna be asked do you want a blanket COA or a jurisdictional COA?
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And remember when you, when you fly under a co you’re flying under part 91.
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In part 91 was written for manned aircraft and there’s a lot of,
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uh essentially what you’re getting are some waivers and exemptions,
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but you’re still gonna need an airspace authorization to go fly and what you’re gonna most of you are going to get a what we call a blanket COA, that’s applicable only in Class G airspace.
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Uh and it allows you to go do your work in Class G if you want to fly in controlled airspace.
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Unfortunately, Under Part 91, that LANNC is not available to part 91 operators.
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So I would argue that in fact, you would want to have Part 107 now, because you’re going to get a LANNC authorization much faster than you would, uh you’re gonna have to apply for another co called a jurisdictional COA.
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And that’s going to have to be coordinated with every airspace air traffic facility in the area that you’re asking for approval for. And there’s going to be additional steps to do that.
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And this is probably just as good as time as ever.
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But those of you who have a COA uh pull it out, read it because I think you’re gonna find inside those COAs, there’s a significant limitation that prohibits drone operations,
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Within five nautical miles of a towered airport.
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Two nautical miles of any airport and two nautical miles of any heliport.
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So the problem jOHn is that there are heliports scattered everywhere, everywhere everywhere.
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And so, but if you have, if you have a Part 107 certificate, you can fly within five miles of an airport by just getting LANNC airspace authorization.
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So and also John when it comes to airspace authorizations, um I would be remiss if I didn’t mention that through the FAA Drone Zone, a Part 107 pilot can apply for flight in controlled airspace.
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There are waivers that are available and um we’ve never talked about this, but the the process for obtaining that waiver is similar to a COA.
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Right, you apply for the waiver, the FAA contacts, the control agency, you’re getting really a what we call it, it’s just a longer term operational airspace authorization waivers waivers have different.
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Meaning that the term waiver, the term exemption.
00:23:35.976 –> 00:23:49.396
Those are very significant words in in the FAA speak and what but you can get uh by going to Drone Zone and I’ll ask one of my colleagues to put the link up to FAA Drone Zone.
00:23:49.396 –> 00:24:00.096
Uh I forget but if you could put that up there but you would get an airspace authorization for multiple days, for example by submitting that in Drone Zone.
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And then that would go to the service center in the region that covers the airport in question and they’ll coordinate with the tower directly and get that for you.
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And you should identify yourself as public safety. And the reason you need it.
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And don’t bother don’t bother saying I need 365 days every year.
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Every day every year just because it’s not gonna be sufficient.
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And uh Andy l look uh Andy uh says he’s made a statement that if you need an authorization uh in a LANNC zero altitude location.
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The FAA has turned around our non emergency requests in two days much much faster than the old way.
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So uh I mean I mean they’re they are getting better and better about it.
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And uh and listen to you know, one of the, one of the important takeaways I think we want this audience to have is that look if you if you have a real emergency.
00:24:59.206 –> 00:25:06.606
And you can’t fully comply with Part 107 if you’re operating under Part 107 or if you can’t fully comply with 91 or your co.
00:25:06.606 –> 00:25:19.506
Uh and it’s a real emergency, make the phone call to the system’s operations support Center, It’s 24 7 and explain the situation and they will do the coordination and get you airborne.
00:25:19.506 –> 00:25:30.316
And and I’m told that before, many of my contacts tell me that it’s minutes now instead of days or hours, like it used to be, you know, 34 years ago.
00:25:30.316 –> 00:25:34.506
And again, it’s evolving every day and it gets better and better every day.
00:25:34.516 –> 00:25:47.826
And I think just one more thing I wanted to add. So One of the other advantages of Part 107 is uh You can get an airspace authorization now, 24 hours a day, seven days a week without having to call anybody.
00:25:48.306 –> 00:25:58.586
Whereas if you’re flying under a COA and you have your blanket COA and you need to get into the controlled airspace, quote, You gotta make that phone call now, that’s one extra step.
00:25:58.596 –> 00:26:03.566
Whereas with 107 and LANNC, you just do it on your phone and you’re good to go.
00:26:03.576 –> 00:26:06.926
So let me mention that the again that.
00:26:07.419 –> 00:26:12.689
Page on my website PSflight.org/ref.
00:26:12.699 –> 00:26:25.929
Has all the links that we’re talking about here. The top link in bold is the one to the FAA emergency operation request John I have found that the folks in Washington who are available 24 hours a day to call.
00:26:26.219 –> 00:26:28.969
Are extremely professional helpful.
00:26:28.969 –> 00:26:32.749
Want to make the part when I was seven emergency flight happen.
00:26:32.759 –> 00:26:38.279
Whatever the situation is, there are a lot of things that pilots and agencies can do ahead of time.
00:26:38.289 –> 00:26:41.149
If you go to that page that’s link there.
00:26:41.159 –> 00:26:52.929
Um you will see the request form and what I do is I have printed out that request form I filled in all the information on it that I’m going to need. That isn’t variable.
00:26:53.119 –> 00:27:00.399
And so I have that readily at hand if I need to submit it to the DC Office and and put a copy with dispatch.
00:27:00.409 –> 00:27:05.769
Absolutely. If you have you know maybe you got a phone issue have dispatched to make the call for you.
00:27:05.779 –> 00:27:08.439
Right? So there’s lots of ways.
00:27:08.449 –> 00:27:19.959
But yeah that’s a good idea. I haven’t haven’t pre filled out as much as possible cause they want to know what’s your phone number in case they got a call you maybe they’ve got a you know an in bound airliner that’s got an emergency. Maybe they’re gonna they’re gonna tell you get out of the way.
00:27:19.969 –> 00:27:30.619
Right so you can have a lot of that stuff already pre filled out uh luis Martinez made a comment that I don’t disagree with as a as a man pilot.
00:27:30.629 –> 00:27:38.099
He says uh he’s talking about COA agencies having to issue NOTAMS for flight operations.
00:27:38.109 –> 00:27:43.139
And he says it’s it’s getting ridiculous because um all these notices are being.
00:27:43.519 –> 00:27:51.239
Issue that serve no real useful purpose and it’s just saying you know we may or may not fly and,
00:27:51.249 –> 00:28:00.439
I have found that the issuance of NOTAMS, it’s another one of those just painful COA administrative things that can set you up to failure.
00:28:00.449 –> 00:28:09.739
You know it’s one thing to also have to submit records of your flights and everything else but as a COAgency and maintaining your public aircraft.
00:28:10.019 –> 00:28:11.839
Um Oh my gosh! The.
00:28:12.344 –> 00:28:23.434
The record keeping for maintaining a public aircraft operation is extensive and if you’re not doing it now and you’re not complaining about all the record keeping, your having to do for your drone.
00:28:23.444 –> 00:28:27.244
Um you’re not doing it right on that link page.
00:28:27.254 –> 00:28:41.464
Dan kelly who has been posting links here. Um he’s probably going to post links to AC 91-91 maintaining public aircraft if you have a drone and you want to comply with the regulations, that document will blow your mind.
00:28:42.044 –> 00:28:49.454
I think another, another factor that folks need to consider is the reporting requirements.
00:28:49.454 –> 00:29:01.554
I don’t, I don’t know we just touched on that but the Notam is just one of them but you have to report every malfunction that happens with your drone when you fly under a COA and under Part 107, you only have to report.
00:29:02.044 –> 00:29:09.964
Those crashes that meet the threshold stated basically $500 or more worth of damage or serious injury to a person.
00:29:09.974 –> 00:29:17.474
Whereas in a COA there’s a a big list of things that are reportable to the FAA
00:29:17.484 –> 00:29:32.164
And and while I’ve got the microphone, I know I’m talking a lot here, but there’s also a separate NTSB reporting requirements. If you have a true fly away, for example, the Either 107 or 91, you have to make that report.
00:29:32.644 –> 00:29:42.284
But yeah, if you, if you like, if you like keeping lots of records and you like writing reports and you like filing notices, then maybe the co is good for you.
00:29:42.294 –> 00:29:46.264
If you don’t like doing that, then maybe the part seven is good for you.
00:29:46.644 –> 00:29:50.964
Here’s another gotcha, John is if you are operating in a state,
00:29:51.344 –> 00:30:04.654
where the government agencies have very open record laws or freedom of Information act requests, um all that information on flights personnel, all that can be discovered.
00:30:04.654 –> 00:30:11.114
I can be requested by anybody and certainly it would be discoverable in the case of any sort of civil lawsuit.
00:30:11.114 –> 00:30:20.154
So more records to hang you with John we’re talking about CO is still and so christian Dick asks a question.
00:30:20.164 –> 00:30:25.864
Um, Isn’t a COA required to obtain a tactical beyond visual line of sight waiver?
00:30:26.644 –> 00:30:29.954
Yes It is. You have to be a COA holder to get that.
00:30:29.964 –> 00:30:34.964
Uh and that’s their issuing those under part 91. Um.
00:30:36.722 –> 00:30:48.052
And I looked at it, I looked at one of those the other night uh and I saw that in the same uh document where they said you could go Tactical beyond visual line of sight.
00:30:48.052 –> 00:30:55.342
The document also said that oh by the way you can’t fly within five nautical miles of the towered airport and you can’t fly within two miles of a heliport.
00:30:55.722 –> 00:30:59.632
So I would argue that uh.
00:31:00.522 –> 00:31:11.492
That while Tactical beyond visual line of sight is certainly an option, you could get the same temporary emergency approval by calling the SOSC
00:31:11.502 –> 00:31:16.742
Absolutely explaining the situation and they can give it to you right there. And so.
00:31:17.222 –> 00:31:28.872
Absolutely. And and another thing John this is kind of a one of these evolving topics right now, but under a COA it requires you to have a visual observer to fly at night.
00:31:28.882 –> 00:31:37.442
Under most correct. Right, yep. That’s typically a standard clause for part 91 coz Required Under 10729.
00:31:37.722 –> 00:31:47.432
So discussions that I’ve been having recently is whether or not a tactical beyond visual line of sight waiver would eliminate the need to have a visual observer at night.
00:31:49.479 –> 00:31:57.499
I think there are apples and oranges, you are required in your COA to have a visual observer at night period full stop.
00:31:58.179 –> 00:32:10.599
So there goes the problem with the COA at night period full stop with the visual observer is a tactical beyond visual line of sight waiver is for the pilot, the pilot might not have line of sight,
00:32:10.979 –> 00:32:19.289
but under a COA, if you’re flying at night you have to have a visual observer that is able to maintain sight of that aircraft.
00:32:19.679 –> 00:32:27.849
Um it can significantly limit your operations and expose you to more questions in case of a problem.
00:32:27.859 –> 00:32:33.099
Who wants to tackle airworthiness with drones and COAs?
00:32:35.079 –> 00:32:41.479
I know John I’ve been picking on you a lot but uh well I’ll start it and then if anybody else wants to jump in.
00:32:41.479 –> 00:32:46.719
So you know, if you, if you look at what does airworthiness mean?
00:32:46.719 –> 00:32:58.599
And I think one of our attorneys the other day had a great description and feel free to jump in if I mistake this. But essentially airworthy, this means that it conforms to the type certificate and it’s in a safe condition for flight.
00:32:59.179 –> 00:33:03.889
Now, drones that people are using today do not yet.
00:33:04.279 –> 00:33:09.289
And I emphasize the word yet they don’t have an airworthiness certificate,
00:33:09.879 –> 00:33:20.699
and what we do under Part 107 as we recognize this Uh and under the part 91 causes that that that’s a determination that is really,
00:33:21.379 –> 00:33:29.489
left to the remote pilot in command and in the case of a co it’s also uh under the,
00:33:29.979 –> 00:33:37.349
responsible persons responsibility and it’s also the agency’s responsibility because they have given the F.
00:33:37.349 –> 00:33:45.799
A. A statement that we deem this to be airworthy, and the airworthy regulations are in part.
00:33:47.029 –> 00:33:53.519
21 23 and I believe 43 but Tim or one of those other folks can correct me if I’m wrong there.
00:33:53.519 –> 00:34:05.849
But so ah and remember that you as the pilot in command are ultimately responsible for everything that happens or fails to happen with that flight.
00:34:05.859 –> 00:34:20.839
If you’re flying in a Part 107, there’s a one of the, 107 regulations uh says the pilot in command is the final authority. So no matter what the chief says, if it’s if you can’t do it will conform with the regulations, you’re on the hook.
00:34:21.229 –> 00:34:29.339
Uh part 91. It’s 91 3 also. So you’re you’re still responsible as the remote pilot in command for that.
00:34:29.349 –> 00:34:38.699
But airworthy, you know, it’s an endless debate essentially what we want is these aircraft to be in a condition, safe conditions for flight.
00:34:38.699 –> 00:34:45.499
Which means you’ve you’ve done a pre flight right? You’ve looked at it, you’ve done the manufacturer’s maintenance.
00:34:46.029 –> 00:34:54.569
Uh If a blade’s been broken, in fact, if you’re under a COA and you broke a blade, you’re supposed to report that to the FAA That’s in your COA.
00:34:54.579 –> 00:35:04.719
And you gotta so you gotta have maintenance logs and maintenance records and, well, speaking of propellers John under public aircraft maintenance
00:35:04.719 –> 00:35:13.629
AC 91-91 you also need to keep track of The time and operation for each of those parts to, I mean it’s an endless administration 91-91.
00:35:13.639 –> 00:35:16.889
It’s an advisory circular. So it’s recommended practice.
00:35:16.889 –> 00:35:29.749
But ultimately right, why why is this important? Well, if something bad happens and the FAA shows up on your doorstep, you’re you’re going to have to justify your actions, right? And how you’re gonna do that, You’re gonna have to, you’re gonna be asked to show documentation. That’s all.
00:35:30.329 –> 00:35:44.149
Well, the propeller issue has been a problem in drone accidents, both in the United States and the UK, where the UK has issued guidance that propellers should not be used more than five hours.
00:35:44.529 –> 00:35:59.349
Uh, And the only way, you know how long you’ve used it is by tracking it. So, um, maybe some of that’s coming, jennifer ask a question, John if a department decides they no longer want their co what is the process for terminating it?
00:36:00.642 –> 00:36:13.962
Ah I believe that in the COA is uh an email address but you can go to caps and you can cancel your COA and caps I believe. And you can also send an email so you want your COA canceled.
00:36:14.342 –> 00:36:21.452
All right. Uh Matthew you can also let it expire. Remember they they have a they don’t have an unlimited life.
00:36:22.042 –> 00:36:27.592
Matthew asks he works for a police department in a town that does not have LANNC. I love this question.
00:36:27.602 –> 00:36:35.662
And it’s in controlled airspace. What will it take to get LANNC in my community? We’ve been trying to years to get LANNC at my local airport.
00:36:36.042 –> 00:36:49.992
Um John this sounds like something that we’ve talked about just a few minutes ago about going to FAA Drone Zone and applying for an extended uh Yeah that sounds like what we would call a wide area authorization request.
00:36:50.002 –> 00:36:57.472
Uh And it depends on who controls that airspace. If it’s U. S. Military at D. O. D. Controlled airspace, they have to agree.
00:36:57.482 –> 00:37:03.202
Uh And not all airports that is a joint airport where they control it.
00:37:03.212 –> 00:37:06.102
Uh So not all of those facilities are on there.
00:37:06.112 –> 00:37:13.662
Um If you have an emergency, don’t let that stop you. Right go make the phone call to the SOSC
00:37:13.672 –> 00:37:18.162
Tell them you’ve got an emergency, it’s inside the zero grid of such and such an airport.
00:37:18.942 –> 00:37:29.552
There’s no excuse not to make that call right there. Uh There’s no excuse and it and it takes seconds and and I would bet that if they got enough of those phone calls things might change.
00:37:29.552 –> 00:37:38.892
But the, I think we want the audience to understand that we’re incorporating more and more airports every day into the LANNC system.
00:37:38.902 –> 00:37:52.252
Uh, there’s a process they have to go through the federal contract. Towers were being are being added as well, so there’s different layers. And D. O. D. Has a bunch of airports that they control.
00:37:52.442 –> 00:37:55.792
I think the Navy seems to be more amenable than the Army.
00:37:56.500 –> 00:38:06.740
You know we don’t control that. Right? So so uh they’re working through that uh And again right this is every day is a new day and every day is an evolution everyday.
00:38:06.740 –> 00:38:11.910
It does get better. I think everybody would Say it’s a lot better than it was 2 3 years ago.
00:38:12.400 –> 00:38:19.120
Um There’s no magic switch. But remember if if you’re in that situation I would go to Drone Zone,
00:38:19.600 –> 00:38:27.520
uh and make the request tell them tell them early on that your public safety in here and put some why you need to be able to get in there,
00:38:28.200 –> 00:38:29.920
and then uh.
00:38:30.900 –> 00:38:32.720
If until you get that.
00:38:33.900 –> 00:38:41.860
Approval that long term approval don’t let the fact that it’s an emergency inside controlled airspace stop you from doing your mission.
00:38:41.870 –> 00:38:54.700
Make the phone call to the SOSC And the FAA will get you they’ll they’ll work those phones they’ll get with the controlling air airport or air air traffic facility and they’ll get you in.
00:38:54.710 –> 00:39:08.130
They we we want public safety to be able to do their mission right now if you’re if it’s not an emergency then they’re going to say no well let me give our our viewers to pro tips.
00:39:08.140 –> 00:39:13.850
One is become very familiar with the FAA emergency operation request.
00:39:13.860 –> 00:39:26.430
And the folks in DC I encourage everyone to look up the information through the links that we’ve given you and uh maybe dan again can post that link in the chat section and give the folks in D.
00:39:26.430 –> 00:39:38.100
C. A proactive call and just um ask him every question you have before it’s an actual emergency so that you learn what they’re expecting from you and what they can do.
00:39:38.110 –> 00:39:44.420
And it never hurts to ask your Drone Pro before you do that, Ask your Drone Pro.
00:39:45.005 –> 00:39:49.045
Yeah I’ll raise my hand. I can absolutely help with that.
00:39:49.055 –> 00:40:01.225
The second pro tip that I have is I think it’s a mistake when you’re operating in any area that has controlled airspace that you haven’t reached out proactively to the control tower.
00:40:01.605 –> 00:40:06.875
And explained uh you know not demanded that I demand to fly in the air space.
00:40:06.885 –> 00:40:15.145
But I find that many approvals are about relationships going there and talking to them about what you’re doing.
00:40:15.155 –> 00:40:26.095
Um and like for example here in the Raleigh, North Carolina area there I can fly in almost all of the airspace at the airport.
00:40:26.105 –> 00:40:30.825
But I am aware of what the approach and departure corridors are,
00:40:31.105 –> 00:40:42.775
and that’s just off limits because the aircraft are so low in those two corridors, narrow corridors that there’s no way I would either ask them to fly there or get permission to fly there.
00:40:42.785 –> 00:40:49.305
So let me just let me just say something though that the I think that’s a great idea off hours.
00:40:49.315 –> 00:40:58.625
But one of the things the FAA does not want public safety doing is they do not want you calling the tower trying to get an airspace authorization. That is correct.
00:40:58.705 –> 00:41:01.515
So uh kind of two separate things right.
00:41:01.525 –> 00:41:07.085
If you if you can get your LANNC authorization, go do it. If you can’t do that. It’s an emergency.
00:41:07.095 –> 00:41:11.125
Make the phone call to the SOSC The SOSC Will have the conversation.
00:41:11.505 –> 00:41:23.325
But I think that is a good idea to uh in when it’s not busy for the tower folks uh go get a tour of the facility, have the conversation, so don’t call the tower.
00:41:23.705 –> 00:41:33.695
Don’t call the tower for a wwaiver. You should make friends with your tower so that when your waiver request comes through the channels, they go, oh, that’s Bob.
00:41:33.705 –> 00:41:35.725
Yeah, he’s a good guy done.
00:41:38.470 –> 00:41:47.290
Okay, Davis Powers says when I passed my part, 107 tests, I agreed to stick with the rules if I have to follow a suspect.
00:41:47.670 –> 00:41:55.490
Um but he goes to an area where I might go beyond visual line of sight or over 400 ft, what do I do?
00:41:55.870 –> 00:41:57.810
All the SOSC
00:41:58.320 –> 00:42:11.120
And if you can’t do it have your dispatch to it and if none of those were you have to land, I mean you you you got to listen to you know you got to comply with the rules or not.
00:42:11.130 –> 00:42:14.470
There could be ultralight flying through no radio right?
00:42:14.470 –> 00:42:24.950
Could be a helicopter hems how do you know you don’t know these these drones are you know, we would all love to be able to let everybody go autonomous beyond visual line of sight.
00:42:24.950 –> 00:42:31.590
But the reality is that the current state of technology with drones is not there yet? It’s not.
00:42:31.600 –> 00:42:39.580
And so Davis, I’m an unguided missiles. Davis says that you know what do I do? He took an oath to preserve life, I get it.
00:42:39.590 –> 00:42:49.600
Um but life in the air like you know, these are built to no known standard. They are built to no standard, greater than a toy.
00:42:49.610 –> 00:42:53.500
They operate on unregulated radio spectrum.
00:42:53.510 –> 00:42:58.060
Um They are not safe to fly outside of the rules.
00:42:58.070 –> 00:43:09.620
They will be, they are not right now we are quickly getting towards the end of the webinar and we haven’t yet heard from our great attorneys.
00:43:09.630 –> 00:43:24.590
So Heather and Kate, can you give us some words of wisdom about if pilots should fly within the rules, what you look for when an enforcement action comes to your desk and what advice you have for our public safety pilots?
00:43:25.912 –> 00:43:29.932
Yeah I can start steve um you know I think,
00:43:30.512 –> 00:43:44.132
to make it as short as I can because I’m sure I could talk forever about advice I might give to a public safety but I think one of the most important things is if you are operating under Part 107,
00:43:44.512 –> 00:43:54.972
um you need to read part one of second um so you need to know what it says, what the rules are and it’s really probably one of the more,
00:43:54.982 –> 00:43:59.532
the easier regulations we have for the FAA to read through and understand,
00:43:59.912 –> 00:44:04.232
and if you’re operating under a COA, you know you need to read your COA.
00:44:04.812 –> 00:44:13.032
Ultimately it’s the remote piloting command responsibility whether it’s Part 107 or your operating under a COA to follow the rules.
00:44:13.412 –> 00:44:20.922
Um So it’s really difficult I would think for you to follow the rules if you’ve never actually read what the COA says.
00:44:20.932 –> 00:44:23.852
Um So and you’re required under the code.
00:44:23.862 –> 00:44:31.072
Have read it, understand it and to have it with you. So I think for me those are that’s really important.
00:44:31.072 –> 00:44:45.882
And we touched on this a little bit earlier but just to remind you know everybody that it’s really ultimately you as the pilot whether Part 107 or a COA that’s going to face the consequences if you violate the regulations.
00:44:45.882 –> 00:44:59.022
And Tim talked about it a little bit earlier but you could be facing you know suspension or revocation of your remote pilot certificate or if you don’t have one you could be facing a civil penalty that’s assessed per violation.
00:44:59.022 –> 00:45:04.802
So it can get up to five or $6000 that you’re facing if you don’t follow the rules.
00:45:04.812 –> 00:45:13.832
So, um, if I can stress anything, it’s read through this guidance, we’ve provided, you read your COA, read Part 107 and really try to understand what the rules are.
00:45:14.812 –> 00:45:26.122
So Heather you mentioned, read the COA and that’s an important point that all pilots under the COA are required to have a copy of it with them at all times, so they should have it readily at hand to read.
00:45:29.567 –> 00:45:32.587
Kate, do you have any words of wisdom from the enforcement side?
00:45:35.567 –> 00:45:42.077
Well I would echo everything that Heather just stated and you know, just to.
00:45:42.767 –> 00:45:51.737
I understand that you know use your best judgment, know the rules and follow them because they are in the best interests of safety,
00:45:51.747 –> 00:46:02.087
and above all, if you have any questions reach out to people that have the answers, whether it be myself or Heather or anybody on this webinar,
00:46:02.167 –> 00:46:10.877
everybody is pretty passionate and willing to help you get to the solution or um answer any questions that you have and.
00:46:11.767 –> 00:46:12.787
To you know.
00:46:13.667 –> 00:46:16.577
And if you have an emergency call, the SOSC
00:46:16.587 –> 00:46:24.937
That the FAA is always willing to work with you and we’re just here to help you and to educate you and make sure that everything is done,
00:46:24.947 –> 00:46:33.077
you know to the best and the safest possible link and we want to make sure that these resources with the drones are used,
00:46:33.267 –> 00:46:38.137
um the safest way for public service and that they can help you,
00:46:38.147 –> 00:46:51.337
and we want to make sure that you are educated and feel confident in your abilities and um again, if you have any questions just reach out to us, pretty sure that covers just about everything or at least John covered at all.
00:46:51.347 –> 00:47:02.087
So well Kate, I think you would agree with this that the worst thing that you can do is assume that you understand what all the regulations are, the slide that we have up in front of us is a good example of that,
00:47:02.467 –> 00:47:09.687
When we talk about flying both with a COA or Part 107, here is an assumption that a lot of pilots just don’t understand.
00:47:10.067 –> 00:47:15.697
Um, if you are flying during the day to maintain the visual line of sight, there are a number of,
00:47:15.707 –> 00:47:25.387
factors that you have to be able to see and determine visually by looking at it, not with the telemetry from your controller and you can look under uh,
00:47:25.767 –> 00:47:28.787
Uh, CFR 107.31.
00:47:29.864 –> 00:47:43.184
To see what those are. So Robert Zarracina in Minnesota went out with his co pilot and tested to see exactly what the distances were in order to comply with visual line of sight,
00:47:43.564 –> 00:47:48.084
and what we found what he found was rather surprising that.
00:47:48.464 –> 00:48:03.464
In order to maintain the drone within the regulations during the day, if you did not look down and you did not look away, you could fly as far as about 1200 ft from the pilot to be able to maintain those criteria.
00:48:03.474 –> 00:48:17.874
If you looked away it was almost impossible to spot the drone again or find it even with a visual observer And you had to fly the drone back towards the pilot uh even as close as only 600 ft from the pilot.
00:48:17.884 –> 00:48:27.974
And this chart that we have in front of us shows the altitude that you were flying at and the distance from you that you would have to be able to maintain the visual line of sight requirements.
00:48:28.294 –> 00:48:42.144
This orange area in the center of this flight recapture Is if it was distanced from you and you look down and you look back, you have to fly the drone back, you can probably capture it between 500 and 900 ft away from you.
00:48:42.154 –> 00:48:46.314
Just being able to see the darkness guy is not going to cover you.
00:48:46.314 –> 00:48:52.484
And as we’ve said, if there’s an accident or an injury or an incident or complaint even,
00:48:52.764 –> 00:49:01.664
and your flight logs telemetry are requested either voluntarily or as Heather has mentioned with a subpoena,
00:49:01.674 –> 00:49:13.684
um you know this, your flight telemetry might show that you were outside of these ranges and to make it even more alarming if we look at the next slide at night.
00:49:14.436 –> 00:49:24.156
Night flight and visual line of sight flight uh, is actually going to be a webinar that we’re planning for next month to talk about this in depth.
00:49:24.166 –> 00:49:29.466
But one of the assumptions I hear all the time from people is I have strobe lights on my drone.
00:49:29.476 –> 00:49:33.656
I can see them for three miles. I can fly far away at night.
00:49:33.936 –> 00:49:42.256
The reality is no, the strobe lights on the drones are not for you, they are for separation from manned aircraft.
00:49:42.266 –> 00:49:47.156
They are actually not part of the requirement that you have to maintain visual line of sight.
00:49:47.536 –> 00:49:55.446
So when your drone gets even a little bit far away from you at night in the dark, you cannot maintain visual line of sight.
00:49:55.446 –> 00:50:04.656
That would be noncompliant flight in the testing, real world testing using a Mavic and a Phantom and Matrice.
00:50:05.036 –> 00:50:15.126
The drone couldn’t be no further than about 100 ft from the pilot at night in order to maintain compliant visual line of sight.
00:50:15.136 –> 00:50:25.556
This is where a bunch of you right now are going to say that can’t be true. We’ve been flying like that for years. We’ve been flying at night at distances and stuff.
00:50:26.136 –> 00:50:35.646
Well, this is an opportunity. We’re just trying to help give you information because as ken, welch asked here in the question to answer box because is there any good news?
00:50:36.036 –> 00:50:41.136
Well ken, if you’re looking for good news, you should probably go to,
00:50:41.146 –> 00:50:46.186
um, manufacturers marketing seminar, what we’re trying to give everyone,
00:50:46.196 –> 00:50:56.556
is the facts so that they can fly safe and not have to face any civil penalties or actually there have been pilots the last Super Bowl,
00:50:56.736 –> 00:51:06.126
that facing criminal penalties for some of their operations just because your public safety doesn’t give you a waiver for doing things that are dangerous.
00:51:06.136 –> 00:51:10.436
Steve this John here can I jump in a little pilot? So I think there is good news.
00:51:10.446 –> 00:51:23.746
The good news is that uh the regulations are evolving to enable your operations uh as we get more data and we and we get more real uh information.
00:51:23.746 –> 00:51:32.716
So and you can see that in the modifications that were done to Part 107 to allow for operations over people and for night. So it’s that’s positive.
00:51:32.726 –> 00:51:35.966
I think the other good news is we’ve got the SOSC
00:51:35.976 –> 00:51:48.866
Is available to you 24 7. I mean that’s huge. And then uh you know on this this whole three statute miles night flight and visual line of sight. And and I think Heather and Kate both reemphasizes.
00:51:49.536 –> 00:51:59.656
You gotta go back and read the regulations and you’ll see that each one of those you know you’ve got 127.117 dot 217.3.
00:51:59.666 –> 00:52:01.356
You know all the way down.
00:52:02.136 –> 00:52:09.846
Each one of those covers a different thing. And the visual line of sight regulation that says visual line of sight.
00:52:10.816 –> 00:52:22.756
It defines what the FAA means by that. It doesn’t mean what you and I may think initially like, oh yeah, I see that speck of something out there, that’s not what that’s not what the FAA definition of visual line of sight is.
00:52:22.766 –> 00:52:29.156
And if you have a situation where we’re coming to investigate, guess what’s definition we’re going to apply.
00:52:29.166 –> 00:52:36.256
It’s the one that’s in the regulation, right? And and that visual line of sight criteria applies.
00:52:36.256 –> 00:52:42.326
You’ll if you read it very carefully, you’ll see that this applies in day, night, good weather, bad weather.
00:52:42.326 –> 00:52:54.826
It it doesn’t say like, you know, oh, and at night you can know, it says you’ve got to see it well enough with vision unaided, except for eyeglasses, essentially at all times during the flight,
00:52:55.416 –> 00:53:02.336
well enough well enough well enough to know its location, altitude, attitude, direction of flight.
00:53:02.716 –> 00:53:10.106
Uh the surrounding airspace, you’re not hazard to people and property on the ground and in the air.
00:53:10.106 –> 00:53:24.036
And if I’ve gone back and looked at the net proposed rulemaking, when all of this started happening. And one of the issues that the FAA. Was very concerned about is operating at night over people when you can’t see those people.
00:53:24.416 –> 00:53:27.136
And that means they’ve got to be pretty close to you. So.
00:53:28.209 –> 00:53:36.499
I know I piled on there. But uh I think there is good news, I think we really want you all to understand that. Part 107.29.
00:53:36.509 –> 00:53:42.909
I call it really the more of the prerequisites to fly at night, They’re not the approvals to fly at night.
00:53:42.909 –> 00:53:53.379
It’s the prerequisites. There is one blurb in there about if during the flight you can dim it for safety reasons But they’re pretty much a prerequisite there.
00:53:53.379 –> 00:53:58.069
Right. That 107.31 is visual line of sight. That’s the criteria for what?
00:53:58.079 –> 00:54:02.829
So so seeing the speck of light three miles out is not gonna work.
00:54:03.409 –> 00:54:08.299
And John I think the best news that we have from this webinar,
00:54:08.309 –> 00:54:20.419
uh is that what we’re giving everybody is straight hard reality facts that they can use to operate confidently in all these situations,
00:54:20.509 –> 00:54:23.149
to avoid any complications from flight.
00:54:23.149 –> 00:54:26.149
So we we want you we all want you,
00:54:26.159 –> 00:54:39.729
all the FAA folks that are on this webinar, all the brainpower that went into putting this together for them to share their information with you uh is here because we all want to help you.
00:54:40.209 –> 00:54:48.769
Um And Tim I know that we’ve got we’ve posted these links in The Chat box as we’ve gone along.
00:54:49.059 –> 00:54:53.429
If we can advance to slide 18, put that on the screen.
00:54:53.809 –> 00:54:57.429
Uh I have a question and answer that,
00:54:57.809 –> 00:55:09.569
in from the uh the webinar here chris says what happens when we’re in controlled airspace and we have crime or crash scenes that we have to investigate.
00:55:09.579 –> 00:55:23.419
And then Jeff says well he answers the question himself. He says, well, we get waivers regularly in zero airspace for crime and crash, so it is possible become familiar with the folks in DC
00:55:23.459 –> 00:55:25.329
Learn what that procedure is.
00:55:25.958 –> 00:55:38.878
For our law enforcement folks. Um This is who you can contact for more information, firstname.lastname@example.org or contact the UAS team.
00:55:39.358 –> 00:55:41.158
I don’t know what the number is.
00:55:41.168 –> 00:55:54.118
8844 fly my you a uh so whatever that turns out to be uh and as we said um everybody here always wants people to fly safe to excel.
00:55:54.128 –> 00:56:08.878
And I personally recognize that many drone pilots out there are new aviators and so I encourage you all to find an aviation mentor that uh has studied aviation familiar with it.
00:56:09.158 –> 00:56:16.988
Um It might be a man pilot, It might be an air traffic controller. I have many friends where controllers who teach me something new every day.
00:56:16.998 –> 00:56:23.988
I’ve been a manned pilot since 1988. I’m always learning and I encourage you to find a mentor.
00:56:23.998 –> 00:56:27.738
My contact information will be here in just a moment. You can always go there.
00:56:27.738 –> 00:56:39.138
It is you can always reach out to me directly uh in North Carolina, Don’t hesitate to reach out to Tim Camelin in uh there’s his contact information, he’s at the Greensboro FSDO.
00:56:39.138 –> 00:56:43.578
Oh and he’s a drone point of contact, Tim Haley and Dan Kelly.
00:56:44.258 –> 00:56:51.598
Our exceptional members of the Greensboro FSDO who are responsible not just for drones but for all sorts of education.
00:56:51.608 –> 00:56:59.368
Um And they are great context to ask for more information gentlemen and ladies and pilots.
00:56:59.758 –> 00:57:03.378
Um we are out of time.
00:57:03.858 –> 00:57:17.668
Um but you never assume never trust anything you heard on the grapevine without double checking it yourself and as I said a good pilot is always learning. Thank you very much.
00:57:22.958 –> 00:57:26.828
Thanks steve. That was pretty informative. There was a lot of information there.
00:57:26.838 –> 00:57:37.978
We also have a lot of links that we’re putting into the chat also. We’ll probably download all the Q. And a session and some of the questions that we did not get to. We’ll try to get back to them in the next week.
00:57:38.358 –> 00:57:43.628
So I appreciate everybody turning out. It looks like we had about 165 there at one time.
00:57:43.638 –> 00:57:53.468
So thank you for your interest and I’ve seen as far as well as Texas attending today so appreciate everybody attending today and we’ll wrap this up.