To say that Part 107 has redefined what it means to operate a drone for commercial purposes in the United States is no understatement. Professionals in various industries often identified FAA regulation as the primary reason they were hesitant to explore how UAVs could be utilized, and Part 107 removes many of the barriers that kept people away from the technology.That said, as the Small UAV Coalition and many others have specifically stated, Part 107 represent a major step forward but there is still much to be done. Part 107 means something different to various member of the Commercial UAV Advisory Board, and I wanted to find out some of their reactions to what is likely the news of the year for the industry. What are some of details associated with 107 that people aren’t talking about enough? What was their reaction to the news? How excited should the industry as a whole be about Part 107? Gregory S. WaldenAkin Gump Strauss Hauer & Feld LLPIt really depends on where you sit. If you happen to be a real estate professional and all you want to do is fly your drone above houses, then you can look at Part 107 and realize you can do everything. You don’t need anything else. If you want to do package delivery, it is permitted in Part 107, much to our surprise, but the delivery must be intrastate and within the visual line of sight, so it’s fairly narrow window of permission.The other thing that was great was that although the FAA moved the maximum 500-foot above ground level to 400-foot AGL, the rule actually permits inspections of structures well above 500 feet, depending on the height of the structure. If there’s an inspection of a structure and the inspection requires the UAV to fly over 400 feet AGL, it can fly up to 400 feet above the height of the structure, so long as it’s within a 400-foot radius of the structure. So under the rule you could have a 2,000 foot structure, and this rule permits the inspection of that structure which would go up to 2,400 feet.What has to be layered into both of these things is the class of airspace in which the UAV is flown. If you’re in uncontrolled airspace and you want to fly a drone to inspect that 2,000-foot tower, great. If that tower is sitting in class B, C, D, or E airspace you need air traffic control authorization. You can’t just say this rule allows you to inspect a structure and fly 400 feet above the height of that structure. What remains to be seen is how ATC handles these requests – the FAA has said it intends to create a web-based portal to receive authorization requests, and that it expects to have this system set up, at least for Class D and E airspace, by the time the rule is effective August 29.Lastly, we at the Small UAV Coalition pushed the FAA hard to create a waiver process for types of operation like nighttime flying and flying BVLOS that the FAA proposed to categorically prohibit. Low and behold, the FAA said yes, and so there’s a new waiver provision for Part 107, under which an operator can seek to operate at night, BVLOS, over non-participating persons, and from a moving automobile. How long will it take for the FAA to approve those waivers? What showing will the FAA require to approve a waiver? It was great the FAA adopted this waiver provision, but we will need to see how promptly and efficiently the FAA processes these waiver requests and the extent to which they’re granted. Gene RobinsonRPFlight Systems107 is everything we could hope for. Now it’s just a matter of them getting things implemented properly. What I mean by that is that their online portal and system really needs to catch up.I was probably the second person to try their review course, because I jumped right on it. It was very simple, very straightforward. I went through both of the tests they give you and after doing so, it issued a certificate. I got to the end and just said to myself, “is that it?”They have a pool of probably 300 questions, and I sent the link to all of my pilot buddies to try out the test. I got a ton of sectional questions on the test I took, and then I talked to one of my friends who took it and they didn’t have any of those questions at all. I was also struck by the fact that most of the questions on my test had nothing to do with the review I just went over. Some of the minutia they pulled out really taxed my aeronautical knowledge, but the test clearly isn’t going to be the experience for everyone. It’s all part of the knowledge base.The good thing is that now we have a start, and we’re off and running. I’m already looking to get started on waivers for nighttime flying and BVLOS. I’m going to do exigent circumstance waivers. I’ve already ditched a few of the 333s that I started for clients because 107 is going to be all they’re going to need. Lia ReichPrecisionHawkPart 107 a great first step that recognizes the value of this technology for many different commercial opportunities. That said, PrecisionHawk is working to be on the leading edge of where the rules might go. There are a couple of ways we can expand upon the rule that will allow our customers to expand their own operations. One of those opportunities is allowing the drone to fly beyond the visual line of sight of the operator. This, for example, would allow for drones to survey not just one field at a time but maybe survey an entire farm. We believe that the research we are doing under the Pathfinder program will help build a safety case to allow for enhanced commercial operations, like BVLOS, in the future. Lewis GrahamGeoCue GroupFor folks like us here at AirGon LLC who do small site precision mapping for the mining and construction industry, the biggest impact from the new Part 107 rules is the ability to fly in all uncontrolled airspace (assuming local restrictions are not in place). You can fly in any class G airspace without any approvals and without filing a notice to airmen (NOTAM). This is huge! Under the current 333 standard Certificate of Authorization (COA), you must be at least the following distances from airports, regardless of the class of airspace:
- 5 nautical miles (NM) from an airport with a control tower
- 3 NM from an airport with no tower but a published instrument flight procedure
- 2 NM from all other airports
Figure 1: Typical density of airportsUnder 107, you can operate anywhere in class G airspace (subject to the 400’ envelope previously mentioned and all other requirements) with no additional authorizations required! The vast majority of small airports in the USA are in class G uncontrolled airspace from the surface to 700 feet (where the class goes to E). Make sure you know how to read a sectional but basically any wide, faded magenta circle that does not contain a dashed circle is class G airspace from the surface to 700’. For example, our pilots are trained at Madison Executive Airport (MDQ). A quick look at the sectional shows that MDQ is class G airspace. This means that you can fly an sUAS within any proximity to MDQ. Of course you must always follow all rules of the 107, always yield right of way to manned aircraft and not interfere with airport traffic patterns.To show you how big a deal this is, consider the mine site at Charlevoix, Michigan shown in Figure 2. This site literally wraps around 3 sides of the regional airport. This would require a letter of agreement with the airport and a COA to fly under the current Section 333 rules.
Figure 2: Mine site in Charlevoix, MIA look at the sectional chart for Charlevoix (Figure 3) reveals that this airport is class G airspace. This means this mine site can be flown under part 107 with no additional paperwork or permissions. I think you can see that this is a game changer with respect to sUAS flying ability in the USA.
Figure 3: Sectional of Charlevoix airportAgain, be very careful in assuring you know how to read sectional charts! Airports encircled by faded magenta that incorporate a dashed magenta line are in Class E airspace within the dashed line area (see Figure 4). You cannot fly in any class other than G without explicit permission from Air Traffic Control (the COA process seems to be disappearing).
Figure 4: Class E extends to the ground within the dashed magenta lineOf course, being a good neighbor in our sUAS industry is going to be key to our overall future success. I would always attempt to cooperate with an airport if I were flying in close proximity! Maria RiggioExelon CorpSeveral of us from Exelon (members of respective business units within the Exelon Corporation) sat on the call as FAA spoke of Part 107, eager to hear how it was going to propel us beyond our current ability to use drones. For Exelon Generation-Wind, it does wonders for how we can inspect wind turbines and blades. That will benefit us immensely. There was some disillusion that the BVLOS-elephant-in-the-air continued to evade us. That’s definitely something our utility business units are immensely interested in. We know there are internal work-a-rounds with the alignment to UAV Test sites; the team at Airware has been good about keeping us apprised of those opportunities as we continue working with them. But it would have been most beneficial for our utilities to be able to fully employ BVLOS (although we have yet to have deliberately requested this permission from the FAA) —storm restoration, downed lines, areas that are not accessible by foot or vehicle, protected species and other environmental considerations...these are all things that will really demonstrate more benefit to the customer, a safer work environment for employees, and prove additional value to the company. Maybe we, as commercial drone users still aren’t quite ready for BVLOS. Nonetheless, progress is progress and we’re more than happy to see it moving in the right direction.Additionally, Part 107 is risk-based so it allows for increased opportunities to assess our infrastructure aligned with our commitment to public safety. For example, the ability to more readily use UAS to assess damage after storms, in support of more efficient restoration strategies (restoring power to customers quicker, including critical customers such as hospitals and nursing homes).One genuine concern with Part 107 for Exelon utilities is the potential absence of hurdles for those not committed to Part 107 compliance. The risks that may be created accordingly (and the corresponding public perception) may hinder ongoing, compliant uses. Iain AllenBarrick GoldFrom Barrick’s perspective, this is great news. We already have a 333 for our Nevada mines and the surrounding ranches, so it is not going to have an immediate impact on how and when we use drones at those mines, but the longer term implications are huge. I am expecting an explosion of innovation in the domestic (US) drone industry now that the uncertainty has been removed. We should quickly have cheaper, better airframes. More important will be new developments in sensor payloads. LiDAR, thermal and hyperspectral are developing and I anticipate more, better, cheaper sensors in the near future. And Barrick is ready and willing to use them, so bring it on!I will also be interested to see how the drone-as-a-service market develops. Currently we own and operate our own drones, but with the anticipated explosion in innovation, it may make more sense for companies like Barrick to contract this out, leaving 3rd parties who are focused on the technology to ensure they are using the latest technology. Another option we are exploring is relatively short term leases, again to ensure our technology is relatively current. How will Part 107 impact the way you approach your business? Continue the conversation on Twitter (#uavroundtable) or in the comments section below.