Part 107 Waivers and the Integration Pilot Program: Buying the Stairway to Heaven

All that glitters is not always gold, all is quiet across the Part 107 regulatory front, but if you listen carefully you will begin to hear the halls of Congress rumble with excitement as Federal Aviation Administration’s Reauthorization Bill is only 2 months away.

Insiders agree that this time around the FAA reauthorization has legs and is not showing any signs of being delayed. All the other times before the expiration was due on the FAA reauthorization it was determined it would be delayed, is no word good word? President Trump kept the legislative members here in Washington DC this summer to work when traditionally they would be on summer recess. Many last-minute entries into this bill has been made silently without much mention from the media or from the hobbyist community. Many agree that the 336 sector of the industry has lost leadership clout and wisdom while getting involved with the FAA and the UAS Industry through the years.

On the Hill, the FAA might have redemption for Taylor, 336, remote & ID because the forecasted size and growth in this bill has the potential to change how UAS are operated forever. Sadly, it was the industry leadership from foreign manufacturers and our own US Silicon Valley experts selling apps to solve problems that didn’t exist that helped to inflate numbers that did not make their billion dollar forecasts. These people first claimed to represent hobbyists and drones for good interests, but as government dictates the industry cannot move on with operations until these vehicles are thus regulated.  The hardest part is that through the years these vehicles poured into our country unregulated and much like guns a recall would not be very successful. Remote & ID will continue to sap the legs from the drone industry because we cannot get a consensus from manufacturers, regulators and operators.

Companies with special needs for UAS flights for airspace integration, testing and operations will have two choices ahead. The first is doing special interest work with a lobbyist and someone who knows federal regulations and submitting waivers. The FAA is publically stating that they are slowing down waiver operations in favor of the IPP. If you are not one of the members of IPP then you should work with a lobbyist who can get your company in front of those who can make waivers happen as a matter of economics and expedience of the law which you are receiving the waiver for your operations.  

If you didn’t make the IPP group, and spending $10,000-50,000 for a lobbyist is not in the budget not all is lost. We have had testing centers, military bases, and demonstrations all at the expensive of the manufacturer which contributed to their own failures. The IPP will be a difficult, expensive and competitive road for most, so maybe you dodged a bullet? If you have the cash to survive then continue to read this article.

How to Buy the Stairway? Interpreted through Stairway

As Led Zepplin says in Stairway to Heaven:

There’s a lady who’s sure
All that glitters is gold
And she’s buying a stairway to heaven

The “lady” are the numerous UAS companies maneuvering for market domination through a regulatory road block securing a way that they will collect a tax from a user each time they access their technology. Or they want to dominate just one portion of a market in which they sell many units to the degree of essentially changing daily activities of everyday people with automated technology.

When she gets there she knows
If the stores are all closed
With a word she can get what she came for

These same companies also use effective lobbying tactics with the FAA and Congress to gain superiority over drone regulations and from the place of expertise give them comforting wisdom. She knows when she gets to DC to hire a lobbyist to round up the troops to move forward legislation. They have for the most part made the waters murky for integration, by not being able to agree on regulation as they each backstab to gain more leverage to some great tax receivable (pie) in the sky for themselves or clients.

If there’s a bustle in your hedgerow
Don’t be alarmed now
It’s just a spring clean for the May queen

It won’t be a spring clean, but the September discussions of the reauthorization will certainly contain the spring clean for 336 hobbyists. Their exact future is undetermined at this time; they may have to comply by law or they may have to join a community based organization and follow their rules which hardly anyone does, enforcement could be determined by local law enforcement. I believe that State and local Law enforcement will be picking up the slack in FAA enforcement issues because the FAA is out tasked with support to go after every violator.

Yes, there are two paths you can go by
But in the long run
There’s still time to change the road you’re on

I believe this to be true and that those companies and entities accepted into IPP should also level the playing field by hiring a lobbyist to help with getting you in front of the right people. By laying eyes on well-developed plans the FAA can use this information and considers your company of value. Those with no experience who apply and just want the waiver will have difficulty in receiving experimental operational waivers for Part 107. If you didn’t make it into the IPP why not have Falcon Foundation UAS LLC contact your representatives for a meeting? We will discuss and find the particulars that make your business unique and compelling for science through successful and key economic contributing factors in commerce that are demonstrated safety through the valid applied research and safety points of A,B,C,..

The piper’s calling you to join him

The Piper(‘s) are the Falcon Foundation LLC and you should join them as they have secured waivers for clients in the hard to obtain experimental categories that will take technical expertise and lobby work to achieve results such as BVLOS, SWARM, and Flights Over People. We are a no frills get it done business with results to prove our experience and expertise. Why pay a high dollar law firm? You are only paying for their extremely expensive office space downtown and luxury living with your hard-earned dollars. Do you want to earn a waiver? Learn from us and come to Capitol Hill with our team and receive ROI on your calculated efforts for your specific UAS integration.

Rob Thompson 

Co-Founder | Aviation Policy & Regulations 

Falcon Foundation UAS L.L.C.

Maryland | District of Columbia | Virginia 


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