RCAPA Petitions FAA’s Peggy Gilligan for Inclusion on UAS ARC

RCAPA cites incongruities in the UAS ARC charter and what is transpiring as part of an alleged “public process”. The charter and membership roster FOIA requested by sUAS News is applicable and of concern to the small business, end-user and academic community stakeholders. This egregious oversight is yet another example of what many in the global airspace integration community view as subpar leadership and questionable administrative actions taken by the UAPO (Unmanned Aircraft Program Office.) These and other purported irregular practices have been highlighted and are not going unnoticed by elected officials. It begs the question, at what point do we as taxpayers say, enough.

The UAS ARC charter served as the foundation for our appeal to the Associate Administrator for Aviation Safety (See the attached letter dated December 29,

2012), for this stakeholder community’s inclusion on the UAS ARC, and to highlight what constitutes nothing less than wholesale disenfranchisement. Our position was solidly indemnified by the content therein and cited to support the RCAPA’s claim for inclusion in this “public” process as amended charter members.

The RCAPA will not be denigrated by accepting the role of SME as that position holds little relevance and no sway. A disheartening turn of events witnessed in the sUAS ARC where committee participants (NASA) labored on excellent and relevant products that where not even considered as part of the ARC recommendations. Worse than that and more disheartening, was the work of chartered members, cast out as they were told that the FAA would be writing standards for their stakeholders. A fate, we believe is still a very real possibility as the charter makes reference to an Advisory Circular. Possible, but unlikely that an AC would pertain to anything over 55lbs. (Other members of the sUAS ARC that were not included in this ARC have been sent copies of the FOIA and were encouraged to seek inclusion.)

All of the charter is relevant to this community, but the main points of relevance being as follows…

1. Four manned stakeholder groups have representation.

(AOPA, ALPA, NBAA, ATA. None for the unmanned community even though section 7.b states “The FAA will provide participation and support from all affected lines of business.”)

2. Two representatives from one defense contractor.

(General Atomics, Charles Sternberg and R. Scott Dann)

3. 5.b “Coordinate the resolution of any comments on related proposed rulemaking.”

(In any fair-minded persons estimation a continuation of the work from the sUAS ARC. Only confirmed as the FAA has yet to make any of that work public.)

4.  3. 8.b “The membership will be balanced in points of view, interests, and knowledge of the objectives and scope of the committee.”

(RCAPA meets all of the aforementioned criteria.)

We also assert that the lack of sector input will cause irremediable damage to manufacturers, suppliers and service providers and their ability to compete in both the domestic and foreign markets, constituting an undue and unfair economic disadvantage to this stakeholder demographic. This also serves as a glaring example of a continuing mistake made by the FAA not to include the viewpoint of persons who draw on empirical knowledge of how these systems operate and are applied for use in the NAS. Not everyone operates a Raven, Scan Eagle, Predator or Global Hawk! Unfortunately, many that will impose burdensome regulation on small business have little or no UAS experience.

The second page is the list of Congresspersons, FAA, and news outlets, et al that are in the process of being contacted on behalf of the stakeholder community.

At this point, you are probably thinking, “what can I do?” Well, here’s where the piece comes off the rails and goes interactive. It is time to get grassroots and to tell the folks that work for you, that you’re not going along with the vendor program (or tomfoolery) anymore!

Take 5 minutes, cut and paste the following into word, fill it out, sign it and send it to your local Congressperson(s).

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To Your Senator:

The Honorable (full name)
(Room #) (Name) Senate Office Building
United States Senate
Washington, DC 20510

To Your Representative:

The Honorable (full name)

(Room #) (Name) House Office Building

United States House of Representatives

Washington, DC 20515

(Today’s date)

Dear (Either Senator or Representative followed by their last name here)

Re: Unmanned Aircraft Systems Aviation Rulemaking Committee (UAS ARC)

This correspondence is in regards to the FAA’s Unmanned Aircraft Systems Aviation Rulemaking Committee, chartered June 17th 2011. The reason for contacting your office is to share with you an apparent oversight made by the FAA in not including the lone voice for the small business stakeholder community in this public process. The Remote Control Aerial Photography Association (RCAPA) advocates for the small business use of unmanned aircraft systems and needs to be included in this process.

I respectfully request that your office contact the Associate Administrator for Aviation Safety, Ms. Margaret “Peggy” Gilligan to expedite actions to correct this oversight. Thank you for your time and assistance with this important matter.

Respectfully,

(Your name)

(Make your mark here)

(Your address)

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You might also want to leverage Twitter, Facebook and LinkedIN

Here is a copy and paste tweet.

HEY FAA UAS in the NAS today the RCAPA way suasnews.com/2012/01/11217/… #FAA#AUVSI #sUASnews #UAV #UAS

Join the Facebook page here https://www.facebook.com/groups/317984811558233/ and add support

Finally LinkedIN http://www.linkedin.com/groups/RCAPA-4230773

Over the next several months, there will be follow up conversations with members of Congress. Ensuing actions and information will be posted and reported on as the information becomes available and or is deemed warranted. Your support will be an indispensable part of righting this regulatory wrong.

As always, to be continued….

The RCAPA letter to the FAA in full

RE: UASARC December 29, 2011

Dear Ms. Gilligan

This correspondence is being submitted to highlight and attempt to correct the apparent oversight in not including UAS small business or end user stakeholders on the UASARC. The Remote Control Aerial Photography Association (RCAPA) was a primary force for the small business owner and UAS operator on the 2008 sUAS ARC (Order 1110.150). Our input was solicited then and a reasonable expectation existed that RCAPA would be a part of any future sUAS regulatory effort. However, RCAPA was completely unaware of the convening of this new ARC or its charter until it was made public in a FOIA request made by the sUAS News in November 2011. Upon even a cursory inspection, this ARC iteration lacks the semblance of a “fair balance” of participation, as there is absolutely no representation from the small business and services stakeholders; a disconcerting prospect when one considers that no less than four stakeholder groups represent the manned aviation community, and one large defense contractor (General Atomics) has two representatives on this same ARC. It is immediately obvious that the largest demographic of sUAS end users has gone totally unrepresented. This is in spite of section 8.b of the new charter that specifically states, “The membership will be balanced in points of view, interests, interests and knowledge and scope of the committee.” All sections of the charter are relevant and are of concern to the small business and services stakeholder community.

Furthermore, the work in this ARC dovetails with and is a continuance of the work and recommendations made in the 2008 sUAS ARC (Sec 5.b). It was the consensus of the participants of that ARC that many significant issues were not fully addressed or concluded in that effort. We assert that the items outlined and contained in the “Committee Procedures” (Jun 17, 2011), pertain to those issues, recommendations and the ensuing rulemaking as well as Global
harmonization issues and a host of other objectives and goals relevant to the UAS business and end user stakeholders. We speak from experience as full members of the aforementioned sUAS ARC, and other Global efforts as the lone voice for the small business and end user stakeholder community. We are at the forefront and abreast of the issues and goals stated in the aforementioned charter.

We the RCAPA, therefore formally request inclusion as a an amended chartered member on this UAS ARC citing the Federal Advisory Committee Act (5 U.S.C. Appendix 2), and on the grounds that the lack of small business empirical knowledge base and expertise will have a negative impact on the safety of the National Airspace System (NAS). The RCAPA also asserts that the lack of sector input will cause irremediable damage to manufacturers, suppliers and service
providers and their ability to compete in both the domestic and foreign markets, constituting an undue and unfair economic disadvantage to this stakeholder demographic.

We eagerly await your reply.

Sincerely,

Rick Connolly, President
Patrick Egan, Director

CC:

The following Honorable members of the United States Congress

Rick Berg
Judy Biggert
Barbara Boxer
Henry Cuellar
Chip Cravaack
Donna Edwards
Dianne Feinstein
Chuck Fleischmann
Gabrielle Giffords
Raul M. Grijalva
Wally Herger
Randy Hultgren
Duncan Hunter
Darrel Issa
Jon Kyl
Daniel Lipinski
Ben Ray Lujan
Doris Matsui
Senator John McCain
Michael T. McCaul
Howard P. “Buck” McKenon
Randy Neugebauer
Ed Pastor
Benjamin Quayle,
Scott Rigell
Dana Rohrabacher
John Sarbanes
Lamar S. Smith
Frederica Wilson
SBA Ombudsman
White House Office of Science and Technology Policy

FAA
Acting Administrator
Leslie H. Smith
Richard Prosek

News outlets

Editors of the sUAS News
MSNBC
News Corp.
Science Editor, PBS News Hour
Drudge Report
Danger Room, Wired Magazine
Other interested parties

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