Inside Unmanned Systems

OCT-NOV 2017

Inside Unmanned Systems provides actionable business intelligence to decision-makers and influencers operating within the global UAS community. Features include analysis of key technologies, policy/regulatory developments and new product design.

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39 unmanned systems inside October/November 2017 ENGINEERING. PRACTICE. POLICY. common requests being for night operations, f lying over people and f lying BVLOS. The FA A is currently processing an av- erage of 458 applications a month and en- courages applicants to submit their appli- cation at least 90 days prior to the start of the proposed operation. While they strive to complete the review and adjudication of waivers within 90 days, the time required for the FA A to make a determination regarding waiver requests will vary based on the com- plexity of the request. The FA A is working on technology improvements to reduce waiver processing time. Waiver approvals are available on the FAA website and may be helpful in drafting a re- quest. If a waiver is disapproved, applicants can reapply. Waiver Application Problems The FA A said it receives many applications that exhibit a clear lack of understanding of Part 107. For example, some applicants seek a waiver of every single operational restriction that is subject to waiver, when the description of their proposed operation doesn't indicate they need all such waivers. In contrast, other applicants fail to realize they need additional waivers or types of permission. To address this, and other common problems cited by the FAA (see Common Problems with FA A Part 107 Waiver Requests, top right), applicants should provide a clear description of their operation including identification of possible and exist- ing risks that can affect safe operations, as well as what the applicant will do to reduce those risks to an acceptable level. D i a n a M a r i n a C o o p e r, s e n i o r v i c e p r e s i d e n t o f P o l i c y & S t r a t e g y f o r PrecisionHawk, helped prepare the appli- cation for the company 's BV LOS waiver. " The industr y needs a better understand- WHAT YOU NEED TO KNOW ABOUT WAIVER APPROVALS Approved Disapproved Disapproval Rate Flying at night 1119 2595 69.9% Flying over people 3 1655 99.8% Flying beyond visual line of sight 7 894 99.2% Operation of multiple UAS 19 182 90.5% DISAPPROVAL RATES TOP 70 % FOR MORE INFORMATION TOP 5 WAIVER REQUESTS Night Operations 0% 10% 20% 40% 50% 60% 65% 39% 21% 11% 10% 70% 30% Operations Over People Operations from a Moving Vehicle BVLOS Operations Visual Observer Source: FAA Source: FAA (Aug. 2016-Sept. 2017) FAA Air Traffi c Organization Safety Management System Manual safety_management_system_508cfi nal.pdf A high percentage of waiver applications have failed to gain FAA approval. Many applications have failed to make a strong enough safety case. Failure to identify hazards and propose risk mitigations associated with their proposed operations. Indications of a clear lack of understanding of Part 107. COMMON PROBLEMS WITH FAA PART 107 WAIVER REQUESTS Failure to address each of the waiver safety expectation guidelines found on the FAA website (Waiver Safety Explanation Guidelines) explanation_guidelines/) Failure to present the proposed operation in a manner that clearly shows the applicant is knowledgeable, and their operations are safe. 1 2 3 4

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