The SFAR Part 107 Shades of Things to Come…

Patrick Egan

Many of you who have had to back off from the day-to-day UAS airspace integration grind, should find the following update of interest. This type of piece is a hard one to write as it lacks definitive answers for the multitude of relevant and deserving questions. I know…just what a community that is longing for definition wants to hear. Don’t think it’s because I don’t want to share or am under some sort of request not to speak. Typically, there’s little more to share then tidbits, rumors and innuendo and not because the FAA is taciturn. It’s just symptomatic of a process that basically consists of running ideas up the flagpole to management, and from what I have been able to gather, the old guard just can’t seem to cozy up to anything unmanned (however small) in their airspace. I’m not really sure exactly who “they” are, and what entitles them to arbitrarily lock us out of “our” airspace. And here in lies the parking spot for the safety argument. Sure, any fair-minded person can understand the argument for an acceptable level of safety, and many of us do want to take a good neighbor approach toward airspace integration. But I think the “do no harm” maxim may be little more than wishful thinking when one takes into consideration some of the other safety issues in the NAS.

As I’m sure many of you have already deduced… The foundation or baseline of what we will more than likely see going out to comment should be loosely based on the sUAS ARC recommendations. Those recommendations, that many of you have probably read, will have gotten a good going over by the Safety Risk Management Panel (SRMP.) Some are of the opinion that the panel in question lacks the necessary small UAS experience and application acumen to effectively do the job. Unfortunately for us, the FAA is satisfied with the level of experience on said panel.  Nothing earth shattering here either, as that condition has been and continues to be one of the only consistencies in this entire process.

The list pertains primarily to the Type 1 and possibly Type 2 (or A&B) depending how they cut it up. The restrictions on larger craft should put those operations beyond the reach of most.

Highlights from the latest iteration are shaping up to look like this:

VLOS = 400’ AGL out to 1500’ laterally.

Small UAS handbook

Manufacturers operations and maintenance manuals

Operations only allowed 5 miles from charted airports. The other bins or “types” will find themselves flying further away.

Written permission from airport manager for operations closer than 5 miles (I suppose that there’ll still be no operating in Class B)

Ground School

Pilot certification (Pilot’s license)

Observer certification

Class 2 medicals for both the pilot and observer

Electronic position and altitude reporting (Self certification okay here.)

No autonomous aids (but not here.)

Aircraft certification, PIC (Pilot in Command) will declare

Some sort of automated web-tool to be developed for registration

Data collection/capture (TBD)

SFAR standards still to be developed by ASTM and other standards groups (another story all together)

And for the nonaffiliated RC hobbyists, you will basically be at the mercy of the ATO as they will be writing the regulations for you.

* This list is meant to demonstrate the tone of SFAR as we’ve not had the privilege of laying eyes on the chiseled granite.

A brief admonitory about the NPRM process…

At one time in the history of our great country, the NPRM process might have meant something in where the democratic process included the public that the government was formed to represent. With the risk of sounding somewhat cynical, those days are over! The FAA or other Federal regulating body is under no obligation (let alone law) to change anything based on comments made during the notice. So, for all intensive purposes the process has devolved into little more than a feigned affair.

To be continued…

Some useful links

http://regs.dot.gov/rulemakings/201009/FAA.htm – 17

https://www.suasnews.com/2010/08/1194/patrick-egan-arc-roundup/

5 thoughts on “The SFAR Part 107 Shades of Things to Come…

  1. Possibility of sUAS specific pilot’s license, or standard VFR full-scale fixed wing?

    Thanks for the article Patrick.

  2. Do you know what type of pilots license the holder should have? What about a private’s pilot license?

    As regarding the aircraft certification, if I understand this right, manufacturers of rc helis, multicopters, etc, will have to provide some sort of unrealistic certification to prove that their aircrafts are good to go in the eyes of the FAA, is this so or I am completely off path? If it is so, then poor of them!

    “With the risk of sounding somewhat cynical, those days are over!”

    No, you don’t, this is a fact, anything “federal” is out of control. I recommend you to read “Diaprax and the End of the Ages, Vol I”, by Dean Gotcher. He is a christian author, but diaprax which is the topic in question, applies so much to goverment these days that you will be amazed how decisions are made by this doctrine.

    Anyways, keep us posted. Thanks for your efforts!

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