At the same time as we posted the FAA ARC inclusion saga the following was on its way to our Federal representation (House and Senate), SBA Ombudsman, White House Office of Science and Technology Policy and other news outlets as promised.
Re: UAS ARC (unmanned Aircraft Systems Aviation Rulemaking Committee)
January 10, 2012
Dear Representative …
This correspondence is in regards to the FAA’s UAS ARC chartered June 17th 2011. The Remote Control Aerial Photography Association (RCAPA) advocates for the small business use of unmanned aircraft system. We are a group with membership in all 50 states. The reason for our contacting your office is to share this apparent oversight made by the FAA by not including the lone voice for the small business stakeholder community in this public process. The charter of this Aviation Rulemaking Committee indicates a continuation of work from the sUAS ARC (Order 1110.150).
In our letter addressed to the Associate Administrator for Aviation Safety, Margaret Gilligan (enclosed and CC’d to the Congressman) the RCAPA Board has appealed for inclusion in this stakeholder process to balance the points of view and interests. Sec. 7b. of the UAS ARC Charter Organization and Administration states, “The FAA will provide participation and support from all affected lines of business.” We contend that our exclusion from the
process 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.
Our association has been an active part of the Global Airspace Integration process for 7 plus years and possesses a wellrounded understanding of the majority of the items listed for consideration in the aforementioned charter. Therefore, we assert that a lack of participation from our association could have negative and detrimental effects on the overall safety of the NAS (National Airspace System.)
We are requesting 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.
Rick Connolly, President
Patrick Egan, Director
Several other organizations and groups representing the NAS stakeholder community were alerted and encourage to follow suit in an effort to insure their members voices and concerns are also heard, and that includes the manned aviation groups, as well. This should not come as a surprise as RCAPA has always held an inclusive vision and advocated for the level playing field prescribed by law, encouraging all to exercise the rights afforded them with the trappings of a due process “fairness” window dressing thing. After all, they’ll be the same disheartened group paying the tax liability that supports whatever diktat finally emerges.
More good old fashion FAA schadenfreude.
The NPRM has been pushed back again to “spring”, April or May of 2012, looking like 2013 before we see the SFAR (I still call it this as the “S” is for special). Again, all best case here as there have been whispers of another hitch in the funding giddy up. The last one threw folks into such a nosedive as travel was canceled and talk of furloughs ran rampant through the Independence Ave office, moral was lower than a snakes belly. We can only guess what will happen to the timeline if those poor folks have to endure another couple of skint weeks.
The stakeholder impression of the campaign…
The outpouring of feedback has been overwhelmingly positive and supportive as the narrative makes it’s way through the Global community. The more prevalent comments suggest that the content of the inclusion letter demonstrates far too much restraint for what many see as an unmitigated travesty. In all actuality, I was taken aback by the sardonic European view of the Unmanned Program Office (UAPO) leadership. The general consensus can be surmised, and as was espoused to the author almost unanimously, is that the UAPO is ostensibly an ineffectual group with a questionable grasp on the Global airspace integration big picture. So much so, that the majority of the present Global dis-harmonization can be attributed to their lack of accomplishment. A notion that was prevalent at the UAS 2011 symposium in Paris. However, at the time I had written that off as the other CAA rep’s immediate reaction to being snubbed by the FAA no show??
The ICAO meetings should prove interesting, to say the least.