It is quite amazing the mindset of the FAA when it comes to UAV operations. There is something desperately wrong here. I fully understand the need for air safety. And have absolutely no problems with that of course. But what i fail to see the logic is the more or less total BAN on amateur UAV development. Or should I say High Altitude UAV development. I guess if you stay below 400 feet you are Ok. But this is the part i do not understand.

I can launch, and do all the time already totally legally by the way with the blessings of the FAA. Balloons that carry payloads up to 6 pounds each, and up to 12 pounds if multiple payloads. And use balloons that are anywhere from only a pound or two to balloons that weigh hundreds of pounds even!

I can do this, and as I stated already do legally.

But to do a UAV at altitudes we do with the balloons up to 120,000 feet we can not do. Of course above 60,000 is un controlled airspace. And you should be able to do anything you want. But you need to travel through 0 to 60,000 first.

But the part the FAA has NOT given us an explanation to is this. two examples,

Example 1

We fly our 4 pound experimental payload via a balloon, It rises at a speed of anywhere between 500 to 1500 feet per minute, exatly how fast the rise not too controllable, all depends on the lift placed in the balloon. The flight path is totally determined by the winds aloft. Whatever way the wind is blowing is the direction the balloon will go we have absolutely no control over this. The balloon reaches max altitude, and either pops or is terminated, (depends on the type of the balloon) and the payload starts to come down via a parachute. again totally un controllable, where it falls is totally dependent of fall rate and the winds aloft again. eventually landing wherever it lands,,

This is ABSOLUTELY LEGAL

Example 2

Using the EXACT same guidelines as the example for payload weight , weight densities, etc, it falls easily into the legal definition of the above balloon flight in every way. But with one change, After seperation from the balloon we are able to steer the payload. Be it a standard payload with a parafoil type of parachute where we can steer it to directions we want. Or taking it one step further a true UAV glider where it still meets all the spec's needed to be legal,, but now is in the shape of the airplane glider. So again it's steerable!

Example is absolutely ILLEGAL and FORBIDDEN!!!

WTF?

Ok we are thinking of safety,, which would you rather have,

1- a 4 pound box falling via a parachute to wherever it falls no matter where it is..and they do! we have had them land on tollways,, we have had them lane between taxi ways at OHARE international airport, we had them land at Nuke plants where they called out the bomb squads to check it out. But this is all fine and OK and no one has a problem with BUT........

2- take a 4 pound glider, and as it's coming down if it looks like it might be going somewhae not safe,, an airport, or major approach or departure lane,, or ny other not too safe situatiion so you deciode to steer it so it does NOT go there. Sounds great huh? But IN THE FAA'S EYES THIS IS TOTTALLY ILLEGAL. C

Can anyone at all see any logic in this?

Maybe I see we haul the glider up to 100 K drop it, fly it wherever we wish until it gets to 60 K then let go of the controls, and let it go wherever it does, then once it's below 400 feet then control it again and land it he he he

Drop me a note with a copy of what you reply to this please. send it to,

nss@mwt.net

The total logic just escapes me.

Joe

Views: 133

Comment by Tom Yochum on May 13, 2009 at 2:49pm
Logic is banned at the FAA.
Comment by Shawn Jones on May 13, 2009 at 3:36pm
I agree with you totally Joe, I don't see the logic either. Your example is exactly what I want to do, however until I can find a way to do it legally, I guess my project is on hold. Too bad I guess. I took my test and received my amateur radio license, not necessarily for this project alone, but it was one of the motivating factors. Maybe one day.
Comment by NSS on May 13, 2009 at 4:02pm
Evening Shawn,

Joe here WB9SBD founder and mission director of Near Space Sciences, i am one of the three people that started all this Amateur radio based ballooning experiments, Over 20 years ago now.

What's your call and where are you located?
Comment by Garry Qualls on May 13, 2009 at 7:19pm
I think the primary distinction between your two examples is the predictability of your vehicle's behavior to a pilot operating in the NAS who has seen it and is trying to avoid it. Both the balloon and the parachute can be expected to move only vertically relative to their surrounding air mass and making a decision to climb, descend, or turn to avoid them will have predictable outcomes for any pilot.

As it has been explained to me, within the National Airspace System, as it is managed by the FAA, safety is a product of the responsibility of each pilot to see and avoid threats. The primary stumbling block for UAVs to operate regularly within this safety regime is their inability to "sense and avoid" other aircraft. A lot of people have been focused on this issue for a lot of years, so there is a lot of literature to read out there. I think that the responsibility for air safety will always be placed directly on the heads of individual pilots as long as there are piloted aircraft, so the ball will always be in the UAV's court to prove they are at least as aware, predictable, and safe as a good human pilot.
Comment by bGatti on May 13, 2009 at 9:04pm
The FAA doesn't require pilots to be awake when they fly passengers.
They rely on pilots to self-report when they haven't slept for 24 hours before pushing back from the terminal and banning the use of ipods for 10 minutes.

(BTW) kudos to the first DIYer who can get a pilot on record as believing than the operation of an ipod has a snowballs chance in hell of crashing their airplane...

While it may seem unrelated - I think it proves that the FAA is arbitrary and whimsical.
Comment by Magellan on May 13, 2009 at 9:39pm
This is apparently legal in New Zealand. Take a look at http://gpsboomerang.com/.
Comment by NSS on May 14, 2009 at 6:17am
Gary States,
"I think the primary distinction between your two examples is the predictability of your vehicle's behavior to a pilot operating in the NAS who has seen it and is trying to avoid it. Both the balloon and the parachute can be expected to move only vertically relative to their surrounding air mass and making a decision to climb, descend, or turn to avoid them will have predictable outcomes for any pilot."

What I see wrong with this thought, in the beginning of these flights we tried having chase planes to be in the areas once they come back down to aid in recovery efforts. We know at all times as well as the FAA and the area ARTCC knows EXACTLY where this thing is (well withinn the limits of the GPS so what 20 feet?) Anyway, the key here is the ability to see and avoid the payload. as gary states If that is the rule then this is even more messed up that i though.

Because going up we have followed visually both from the chase planes or to even someone on the ground with their bare eyes, we have watched the balloon and payload go all the way to 120,000 feet! The balloon gets HUGE the smallest one we use gets like 40 feet in diameter,, But once it pops, IT'S GONE

we have never ever seen one post balloon pop. NEVER. We know exactly where it is, the FAA and the local ARTCC knows also EXACTLY where it is, We have had chase planes withinn 200 feet of where it was passing through and did not see it. The boxes and chute are just too small. and moving way too fast vertically to see it.

Or for that matter it is falling soo fast that at say 40,000 feet it is still falling close to 10000 feet a minute, How high above the horizon will it be when seen from a pilot by the time they get near it, At least with the UAV it is NOT dropping like a rock and staying at a certain altitude.

but as stated we have tried ohh at least 20 times to have the chase plane watch for the payloads when they come back in and yet to have seen one. We have seen them from the ground the last 2000 feet or so as they land, So it's not that they can NOT be seen, it's just something about being in the plane and seeing them.

But as stated in our flights both the FAA know it's happening, and the local ARTCC knows at all times where it is,

So still confused
Comment by Tom Yochum on May 14, 2009 at 8:29am
Perhaps you have already thought of this, but could you have the payload drop via parachute until it hit 400' and then transition to horizontal, controlled flight? Obviously, you would have to release the parachute and have some pretty nifty control logic to pull out of a dive, but it could be done.
Comment by NSS on May 14, 2009 at 9:43am
and above 60K too is un controlled.. so release at 120K controlled, deploy small chute at 60K, OR,, hmmm, stop controlling and have trim set to either fly on in the desired direction or for circles till it's below 400 then take over he he he,,
Comment by DJS on May 14, 2009 at 11:32am
I've been through this in detailed conversations with the FAA on many occasions before. Though it seems to not make sense - it is very logical from their point of view. Their concern here is not one of sense(see)-and-avoid but rather concern for the relative sophistication (or lack thereof) of the autonomy.

The logic associated with the 'A' part of a UAV is still the largest concern for the FAA.
If you have a 4lb brick being dropped by a balloon, either with or without a parachute, it may be dangerous, but it's path is somewhat known --- down, and relatively quickly.
On the other hand - if you have a glider or an airplane with a capability of reaching much further, you need be concerned about all aspects of the autonomy.
• What if any mission limits exist?
• What does the vehicle do if a limit is exceeded?
• Can the limits be updated in flight?
• How does the UAV protect those software imbedded limits from inadvertent memory loss issues?
• What system limitations exist to prevent a fly-away event?
• What flight termination capabilities does the air vehicle have should something go very wrong?
• ...the list goes on and on...

The FAA's Safety Checklist questionnaire for UAVs seeking certification is more than 10-pages of single-spaced, extremely detailed questions. The questions are far more about the logic trees and system back-ups in the event of a fly-away event than they are about the mass-characteristics of the brick that might come in contact with another aircraft.
It is the Autonomy of the UAV that is the biggest concern.

One can argue about the balloon paradox if one wants. The bottom line though is that the requirement to permit balloon flights was seen as an necessity even before the FAA began to actively legislate airspace as they do now -- so the requirement to permit balloon flights was essentially "Grandfathered" in. When you talk to the FAA and point to the balloon example and say "But you allow us to do this!", they are hearing you say "Then - should you allow us to do this?"

I'm sure that the time will come when there will be more open use of autonomous systems within the NAS - but it will definitely be baby-steps between now and then.

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