3. Commercial Use of UAS
3
• UAS Diversity
• Size, shape, performance, applications
• FAA Regulatory Structure
• FAA Approval for Commercial Use
• Applications For Energy Companies
14. FAA 2007 Policy Statement
• Clarifies “the FAA’s current
policy concerning operations of
unmanned aircraft[.]”
• “No person may operate a UAS
in the National Airspace System
without specific authority.”
• Civil UAS “may not be used for
compensation or hire.”
14
15. FAA Operational Authority
15
• Public Aircraft
• Certificate of Waiver or Authorization
(COA)
• Civil Aircraft
• Experimental Airworthiness Certificate
• Research and development; crew training;
market surveys
• Commercial use banned
• Model Aircraft
• AC 91-57
• 400 ft. AGL
• 55 lbs. or less
• Visual line of sight
16. Enforcement of FAA Policy
16
• FAA Enforcement
• Fines
• Warning notices
• Challenges to FAA Authority
• Pirker challenge to FAA penalty
• Texas Equusearch challenge to FAA
cease and desist letter
17. FAA Modernization Act of 2012
17
• FAA tasked with developing
a plan for “safe integration”
of UAS into the NAS
• Mandated that the FAA
issue a final rule on
integrating “small” UAS into
the NAS by August 2014
18. FAA Modernization Act of 2012
18
• Establish 6 UAS test sites
• Expand UAS use in the
Arctic
• Provide exemption for UAS
use shown to be safe
• Section 333 Exemption
20. Commercial Use of UAS in the Arctic
20
• FAA Issued Restricted Category Type Certificates
• Insitu ScanEagle X200
• AeroVironment Puma
• Based Upon Prior Acceptance by US Military
• Limited to Aerial Surveillance in Remote Artic Space
• COA – required for specific operation
• ConocoPhillips
• First commercial UAS operator using Insitu ScanEagle
• September 12, 2013
• Marine mammal and ice surveys over artic waters for environmental studies
• BP Exploration
• First commercial UAS operator over land using AeroVironment Puma
• June 8, 2014
• Inspect pipelines and infrastructure
24. FAA Approval Under Section 333
24
• Approval Before Required Rule Making
• Requirements
• Determine UAS may operate safely in the NAS
• Considerations
• Size
• Weight
• Speed
• Operational capability
• Proximity to airports and populated areas
• Visual line of sight operation
• National security
25.
26. FAA Approval Under Section 333
26
• Six Aerial Video Companies Approved For Television and
Film UAS Operations
• September 25, 2014
• Astraeus Aerial
• Aerial MOB, LLC
• HeliVideo Productions, LLC
• Pictorvision Inc
• Vortex Aerial
• Snaproll Media, LLC
27. FAA Approval Under Section 333
27
• Limitations
• Comply with proprietary flight manuals
• Operator with private pilot certificate
• Within visual line of sight
• Closed set filming area
• No more than 400 feet
• Day, VFR
• FAA notification before flight
29. Applications Under Section 333
29
• Amazon Prime Air
• Package Delivery System
• Test outdoors near lab in Seattle
“One day, seeing Amazon Prime Air will be
as normal as seeing mail trucks on the road today”
30. Other Approvals
30
• SDG&E: Special Airworthiness Certificate in
Experimental Category
• InstantEye MK2
• Approved by US Army Special Forces
• Research, development, crew training
• Limited to remote operating area
• Aerial inspections and emergency response
• Section 333 Application Pending
• Operations throughout service territory
31.
32. mofo.com
Commercial Use of
UAS in the U.S.
AUVSI Unmanned Systems
Conference
Presented by:
Bill Janicki
Morrison Foerster LLP
33. This program will also look at the types of
operations the FAA is considering for approval
and the application process for companies who
seek to use UAS for commercial purposes prior
to official rule making activities by the FAA.
Hinweis der Redaktion
Founders of 3D Robotics
Largest commercial drone manufacturer in the US
IRIS Quad copter – ready to fly, fully autonomous UAS, capable of recording high definition aerial video, controlled by an Android tablet or phone
Headquarters San Diego – Sales Berkeley – Manufacturing – TJ
Company has moved beyond hobbyists - to commercialization
Raised $30M in venture capital backing in 2013
Expected revenues of $40M in 2015.
Prototype of UAS being tested by Amazon for package delivery
Snap Roll Media sUAS
Proprietary design for film industry
Recently approved for commercial operations in the US
1 of 7 film companies approved
PD-100 Black Hornet by Norway-based Prox Dynamics
Nano drone – now has night capable UAS.
18 grams single rotor helicopter
Personal reconnaissance System – intelligence and surveillance
World’s smallest operational military UAV –
25 minute duration – 15 knot winds
Operational with British army since 2013
X-37B Orbital Test Vehicle– space drone
Mission – conduct experiments on new technologies
29 feet long – 15 feet wing span -10 feet tall– Mach 25
Boeing – launched on back of rocket and returns like a plane (2 built)
First flight launched in 2010 landed after 8 months in orbit
Second flight lasted 15 months
Landed October 17, 2014 after just under 2 years (675 days) in orbit (3rd mission)
More days on orbit in 3 missions than all of the shuttle’s 135 missions combined.
Northrop Grumman X-47B – Unmanned Combat Air Vehicle
Carrier based operations
Carrier landing 10 July 2013
Night flights April 2014
AeroVironment Puma
Hand launched – battery powered – 13 lbs.
Originally built for military surveillance operations – used in Middle East
Now being used for commercial applications in Alaska – inspecting pipelines
Yamaha RMAX
Agricultural – pesticide spraying
9 ft long; 220 lbs. loaded with fuel and pesticides
250cc two stroke gasoline engine – flammable fuel
Larger payload capability
-Extensively used in Japan for crop dusting.
-Approved by Australia’a commercial aviation authority
Utilized by UC Davis to spray vineyards in Oakville, CA – to test efficiency and safety
Operated under COA – must be operated in uncontrolled airspace, at less than 50 feet in 3 defined operating area.
Cyphy Works - Boston area start up – PARC Drone
Recently received a second round of funding of $7M
Designed to hover at around 1000 feet and act as surveillance outpost or communications relay
Ultrathin “microfilament” cable that keeps its drones tethered to power and communications systems, rather than requiring on-board fuel and wireless signals.
Able to stay airborne around the clock
FAA authority for operations
Public -Public entities Military, Customs and Border Protection, Law Enforcement.
FAA approval through application for Certificate of Waiver or Authorization (COA)
UAS – FAA Airworthiness Certification or DOD Airworthiness Statement – with
limitations on operations.
545 active public use COAs at the end of 2013
Civil – FAA Experimental Airworthiness Certificate for research & development, training
Commercial Use prohibited
Model – UAS used as a hobby or for recreational purposes
No approval required
Voluntary guidelines in AC 91-57
Below 400 feet; UAS less than 55lbs (AMA)
Visual Line of sight
Commercial operators
FAA would fine
send cease and desist warning letters
Pirker – first FAA fine of commercial UAS operator
“careless and reckless operation” of an aircraft–
overturned by NTSB judge
model UAS was not aircraft – no enforceable FAA rule to enforce for model aircraft
Texas Equusearch – received email from FAA inspector warning them to cease and desist
using UAS for search and rescue operations.
Equusearch challenged FAA’s authority to issue such an order in Federal CT.
Judged dismissed case – email was not official FAA order representing the agency’s
final conclusion – so not challengeable in court.
Judge noted the absence of any identified legal consequences flowing from the
challenged email.
FAA Modernization and Reform Act 0f 2012
6 test ranges – integrate both public and civil UAS into NAS
Arctic – approve UAS for both public and civil use
Section 333 exemption – before UAS rule making is complete
6 test sites became operational in 2014
University of Alaska at Fairbanks
COA – wildlife surveys (second) caribou, reindeer, musk ox, and bear
Aeryon Scout sUAS from multiple locations – second - Collect safety data
State of Nevada
COA – third – Desert Rock Airport– develop standards for operations around airports
Insitu ScanEagle
New York Griffiss International Airport
COA – Precision Hawk Lancaster – agricultural research operations
North Dakota Department of Commerce - COA – first approval
Draganflyer X4ES sUAS – agricultural research – soil quality, crop status
Texas A&M University
COA – AAAI RS-16 – 85 lbs. - restoration of the ocean and ocean wetlands along the Padre Island National Seashore
Virginia Tech University
COA – Smart Road Flyer – research in vehicle and highway systems - agriculture operations
Insitu ScanEagle X200 – next
AeroVironment Puma – next
ConocoPhillips –
Marine mammal and ice survey necessary to meet environmental and safety rules before drilling on the sea floor
Crash on second test flight due to engine failure – aborted into the water
BP Exploration –AeroVironment Puma – mapping and geographic information systems, check pipelines and infrastructure
Insitu ScanEagle X200 – catapult launched
First used for military operations – airworthiness release by military
– being flown over artic waters for environmental studies
18 ½ hours on 1.5 gallons of fuel; 44lbs
day VFR; over water; 98 knots
Beyond line of sight operations
BP Exploration
AeroVironment Puma – hand launched – battery powered
First used in military operations – airworthiness release
Inspect pipelines and infrastructure
Beyond line of sight operations –
31/2 hours of endurance
13.5 lbs.
$250,000?
Requests supported by:
Motion Picture and Television Operations Manual
Flight Operations and Procedures Manual
7th company – Flying – Cam, approved October 10, 2014 (first approval for foreign company) for scripted, closed-set filming; proprietary design – one rotor and two motors
8th company – Cine Drones – denied exemption because request did not comply with requirements of 14 CFR 11.18
Motion Picture – Film: Sep 25, 2014 – FAA approved six aerial photo and video production companies to use drones for the film and television industry.
UAS flight manuals with detailed safety procedures and standard operating procedures
No more than 400 feet ALG, 50 knots, weight more than 55 lbs.
30 minutes duration or 25% of remaining battery power (lack of flammable fuel)
Drone operators certified (private pilot certificate 200 cycles, 25 hours total time)
FAA notification before each mission – request for NOTAM
Registered with N-number
Only on closed sets
No night flights
Inspect aircraft before flight and operate according to manufacturer’s manual
UAS aircraft record: document maintenance, functional test flights, alterations, time in service
“Amazon Prime Air.” – application for exemption to test drones near its lab in Seattle to test new system to deliver packages.
Outdoors, on Amazon property. Current tests are indoors or in other countries.
FAA has rejected a number of applications for failing to comply with the statutory requirements of 14 CFR 11.81 and requests applicant provide additional information.
InstantEye MK2
One Pound quad copter made by Physical Sciences Inc. for the military
Miniature, high performance aerial robotic.
Launched and recovered using the palm of your hand– weighs less than a pound
30 minute duration
Robust design – all weather, day or night – up 30 mph winds – recover after collisions
Deployed with troops in Afghanistan
Began with Military application -
Approved for military use – Airworthiness Release Certificate by US Army Special Operations Command
VDOS Global Section 333 application
Aeryon Skyranger – perform flare stack inspection for Shell Oil Company in the Gulf of Mexico
Company believes they are next in line for approval.
Application states commercial pilot license
Used by US and Canadian military; Univ of Alaska Fairbanks (research COA)
