- Following the requirements in the Small UAS rule (Part 107)
- Following the rules in your Section 333 grant of
exemption
- Obtain an airworthiness certificate for the aircraft
(FAA, n.d.)
I won’t go into the
methods in which a person must navigate each of those procedures but I do want
to highlight the difference between the requirements to operate a UAS for
business purposes and the requirements necessary for operating a manned
aircraft in a commercial manner.
Two factors basically
render a flight (manned) commercial: carriage of passengers (or cargo) and
compensation (Wieand, 2016). There are a
multitude of Federal Aviation Regulations (FARs) that govern how individuals
will operate aircraft in commercial operations.
Typically they are broken down into specific “Parts” (91, 121, 135). In a very simplified manner, the pilot must
have a commercial pilot license at a minimum and most often have a charter
certificate (air carrier certificate) in order to operate for income. Essentially, while it’s reasonable to assume
you’ll be careful flying yourself around, the FAA considers Part 135 rules necessary
to ensure that people in the business of providing air transportation will
exercise special care to ensure passenger safety (Wieand, 2016). The cost to obtain a commercial pilot license
can be quite expensive and the time it takes to obtain the skillset is a
tremendous commitment and investment. It
starts out with a private pilot license that costs about $8,000 dollars, then
you get your instrument rating, so that you can fly into clouds, and that’s
another five or six grand (Greene, 2014).
Most pilots report spending close to $100,000 in order to get all of the
required licenses necessary to operate an aircraft for air transport. At the very minimum (i.e. banner carrying
Cessna), a pilot will spend close to $20,000 and a minimum of 6 months in order
to have the right certifications. Not to
mention, they must maintain a medical certificate.
The purpose of this
entire discussion is simply to point out that the commercial manned pilot has a
tremendous amount of time and money invested in their tradecraft. They are highly motivated to operate within
the rules and regulations of the FAA.
There are plenty of examples of folks who haven’t, and the FAA is never
afraid to take action and remove certificates for bad decisions. Now, as we compare that to the UAS industry,
the difference is tremendous. Someone
who has a couple thousand dollars invested in the licenses, certificates, and
requirements listed above doesn’t have the same motivation to ensure they are
following the proper procedures. The
risk versus reward can be easily skewed.
Say for instance a business is willing to pay you $5,000 to conduct UAS
photography over an area that you know is a Temporary Flight Restriction
(TFR). Your total investment is only a
few thousand dollars at most so your reward is far greater than the risk.
UAS don’t have passengers
so the stance that the regulation keeps passenger safe becomes mute. However, UAS do fall from the sky when not
operated correctly and I don’t care if it is 20 pounds, or 2,000 pounds, an
object falling from the sky can cause irreparable damage and death.
FAA
(n.d.). Unmanned Aircraft Systems (UAS) Frequently Asked Questions. Retrieved from https://www.faa.gov/uas/faqs/
Greene,
L. (2014, November 21). So You Want to Be a Pilot: What It Costs And How Much
You’ll Make. Billfold. Retrieved from https://www.thebillfold.com/2014/11/so-you-want-to-be-a-pilot-what-it-costs-and-how-much-youll-make/
Wieand,
J. (2016, February). The Rules of the Game; Business
Jet Traveller. Retrieved from https://www.bjtonline.com/business-jet-news/the-rules-of-the-game
Christopher,
ReplyDeleteYou’ve identified an interesting and important topic to blog and would be a great debate topic. The road to becoming a commercial (manned) pilot is very expensive and requires a lot of ground training and flight hours; not to mention all the evaluations both written and practical “hands on”. Once one becomes an aviator that is often quoted as “a license to learn”. It takes hours of continuing education, self-study, and flight hours to become fully competent.
Part 107 is a great start to integrating UAS operators/pilots into the National Airspace System (NAS). It is imperative that all operators fly their platform IAW all rules, waivers, or certificates to ensure safety and comply with the FAA. As UAS become more sophisticated and further integrated into the NAS, the FAA will most likely require specific levels of training and UAS pilots may have to be appropriately licensed; it would not be surprising if UAS pilots had to get medical certificates in the future. Effectively communicating with Air Traffic Control (ATC) is an art within itself and requires many flight hours to just be “OK” at the task. As manned and unmanned aircraft integrate and begin to fly instrument approaches into airports with parallel runways, the unmanned pilot must be trained to the same levels of competency as their manned counterparts. Great Read.
Paul