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 1We 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 LEGALExample 2Using 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. CCan 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 heDrop me a note with a copy of what you reply to this please. send it to,nss@mwt.netThe total logic just escapes me.Joe
Also it must be taken into account that the FAA listens to whoever is the loudest/richest/most powerful (e.g. Obama's user fee proposal). For UAV systems to gain better acceptance it needs to be a much larger industry.
For more insight into the process that produced the new rules, you can listen to Episode #84 of the All Things That Fly podcast, titled "RC and the Man". It's at the bottom of this page. There is a link there to download the mp3 file directly and you can also subscribe to it using itunes, etc.
That is an awesome video, and yes explains everything i wish this all to be. But what it fails to address is small UAV's UAV's that weigh so little and are so small density wise that they themselves the FAA already claim they are airworthy as is. as a dead meat but not if you control it.
Does seem to be a bit of a paradox, but DJS appears to have eloquently described the FAA's rationale.
I wonder, though, if there's the unwritten thinking of - if the craft can be steered, it "could" be a threat, so we want to avoid the chance. Of course, that completely ignores the fact that those with malicious intent aren't likely to care what the FAA rules are...
On the "sense-and-avoid" issue; I just happened across this Proteus test video, and thought it might be of interest. Enjoy!
Thing is and this is why it's all messed up, we fly a BOX that weighs 4 pounds, and it comes down via a parachute. be it a chute like this
or this
There is ABSOLUTELY NOTHING ILLEGAL in either one of these chutes.
The illegal part is fly this LEGAL system ,
the exact same system, but be able to steer where it's going, even tho it's the exact same system but by adding the ability to steer it makes it now Illegal,
The ONLY thing I can even remotely think of because it was not too long ago when an amateur could do these and do them legally. Because our group did fly some test vehicles for NASA and also did a flight for some guys that eventually went to work for Rutan on the X prize. we flew a scale RC model of a prototype. And it was simple no problems thing to do,
What's Changed? The ONLY thing I can think of is 911.
Be it a 4 pound box or a 4 pount airplane the striking difference risk is absolutely the same. as well as damage, if anything the damage will be far less because the overall densitity is far less on the UAV than the typical balloon payload.
Great explanation by DJS. This is not difficult to understand if you can adopt perspective of the FAA and try to empathize with their mission.
The FAA directives that are more puzzling to me relate to the shutdown of anyone conducting commercial operations (e.g. aerial photography) without a COA. It would seem that there is more risk to other aircraft from amateur operators rather than professional operators.
They all of the above concerns are also in far 101 on the free balloons side too, every one of the rules,
And directly from them the reason the weight and densities are stated as they are with the balloon systems is with those numbers there is little or none damage possible even with a direct hit. Thats why they specift max weight and DENSITY!
witht he spec's tTHEY want they know even if a direct hit was to occour nothing would happen.
OK take this one step further
The UAV is soo crazy restrictive, You know I can fly a 5000 pount payload balloon with almost no problem whatso ever, a simple waiver and it's done, been there done that several times for balloons that exceed the 101 regs, tales no time at all. it just amazes me I can fly a 100 pound balloon with little paperwork yet I cant fly a 4 pound UAV
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.
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,,
Comments
I wonder, though, if there's the unwritten thinking of - if the craft can be steered, it "could" be a threat, so we want to avoid the chance. Of course, that completely ignores the fact that those with malicious intent aren't likely to care what the FAA rules are...
On the "sense-and-avoid" issue; I just happened across this Proteus test video, and thought it might be of interest. Enjoy!
or this
There is ABSOLUTELY NOTHING ILLEGAL in either one of these chutes.The illegal part is fly this LEGAL system ,
the exact same system, but be able to steer where it's going, even tho it's the exact same system but by adding the ability to steer it makes it now Illegal,
how messed up is that?
What's Changed? The ONLY thing I can think of is 911.
Be it a 4 pound box or a 4 pount airplane the striking difference risk is absolutely the same. as well as damage, if anything the damage will be far less because the overall densitity is far less on the UAV than the typical balloon payload.
The FAA directives that are more puzzling to me relate to the shutdown of anyone conducting commercial operations (e.g. aerial photography) without a COA. It would seem that there is more risk to other aircraft from amateur operators rather than professional operators.
And directly from them the reason the weight and densities are stated as they are with the balloon systems is with those numbers there is little or none damage possible even with a direct hit. Thats why they specift max weight and DENSITY!
witht he spec's tTHEY want they know even if a direct hit was to occour nothing would happen.
OK take this one step further
The UAV is soo crazy restrictive, You know I can fly a 5000 pount payload balloon with almost no problem whatso ever, a simple waiver and it's done, been there done that several times for balloons that exceed the 101 regs, tales no time at all. it just amazes me I can fly a 100 pound balloon with little paperwork yet I cant fly a 4 pound UAV
just messed up
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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