Originally Posted by
aa777888
@MikeNYC:
I'm not going to dispute 107.37(a). It is, however, as a practical matter, difficult to be fully in compliance with this regulation when aircraft approach a UAV at speeds of 100KN or more, particularly if line of sight from the ground control station to the approaching aircraft is obstructed due to terrain, buildings, etc. There is simply not sufficient time to land the UAV, and landing the UAV is probably the only safe course of action. Typical vertical descent speeds are in the 2 to 4 meter/sec range. This puts the time to reach ground proximity in the 30 to 60 second range. You have to be able to detect an approaching aircraft from the GCS at at least 2NM or more. Experienced pilots many times have trouble detecting traffic in the pattern at this distance even when it is pointed out to them by ATC. It can't be any easier for UAV controllers and they are not in contact with ATC for traffic call-outs. This is one area where 107 is going to have to evolve and/or a technical solution brought to bear. If this guy gets hauled up on charges if he feels like fighting them he probably has a good shot at it. In the meantime I hope he files an ASRS report (FWIW).
And yet "full scale pilots" may indeed get so burdened with looking at tons of circles, whether you think it's a good idea or not. There is a huge economic force behind UAVs, they are not going to go away. However, UAV operators may get burdened with additional flight restrictions, mandatory NOTAMS, ADS-B, ATC comm's, and ground-to-air comm's requirements. Maybe even additional training requirements. BTW, I thought the Part 107 test was a joke. For a non-pilot it makes you feel like you learned something, and you did, just not nearly enough.
The FCC license issue is merely a paperwork exercise:
https://www.fcc.gov/research-reports...k-menu-block-4 I'm sure that everyone you know that uses an aviation handheld radio on the ground has applied for and received an appropriate Multicom (probably the most applicable to this problem) or whatever is appropriate under FCC Part 87 license, right? I don't know a single person who has done this. It is probably one of the most ignored, if not most unknown, regulations. Not saying you are incorrect, BTW. You've clearly got the reg's wired tight. If you want to meet the letter of the law today there is a regulatory mechanism to do it. But if UAV ground control stations are going to get comm's, maybe some changes are in order here as well. Just like they changed the rules so that you no longer need a station license for your aircraft unless flying/communicating internationally.
Was the event in question a Part 101 flight, or a Part 107 flight? I assumed 107, but that might have been a bad assumption.
Thanks for the link to the Ping transponder. It is a nice technical solution. A bit pricey, though. You can buy one for $2K. Add the cost of a handheld radio and station license onto that and I'm sure the number of "Johnny Hobbyists" will be cut down quite a bit.
Another interesting technical solution will be possible when nearly everyone is equipped with ADS-B Out in 2020: a real time TIS-B feed via internet (cellular data). This would be invaluable at the GCS. Non-real time feeds with no integrity checks are available now, of course (Flightaware, et al). Even that could be helpful today.
At any rate, my intent here was to say that we all better learn to get along. A large regional helicopter operation near me started a UAV operation about 4 years ago. They know they are going to lose business, so they are planning to lose it to themselves! The collision avoidance problem is going to get worse before it gets better, the current Part 107 is not cutting the mustard.
Hope to not have come across as snarky as I appreciate the discussion about this; it benefits us all.
We don't know if it was a 101 or a 107 flight, but the deal with 101 is that unless the flight is clearly conducted under the provisions of Part 101, by default it is a 107 flight. But you're right, we don't know.
It's nearly impossible to get an FCC Multicom license for this application, as I understand it, to be a mobile operator not in support of manned aviation. But I stand to be corrected. As you mention, though, it is an oft ignored regulation. I think the idea of ADS-B instead of voice communication will be the better long term solution, especially with the 2020 mandate. In bulk pricing and with tech improvements, the $2k transponder will drastically drop in price.
Totally agreed on the ASRS report, if he knows what that is. These airprox incidents should be tracked so as to come up with safety solutions. Appreciate the math and logic of closure rates. Perhaps the "bubble" that UAVs are given is too large?
The 107 test is indeed absurd, and it's even sillier that the US has no practical exam requirements. Many countries (even the Bahamas) require a flight exam for a commercial UAS license, and hold pilots to a higher standard. Another issue is that the FAA hasn't shown it has any teeth in enforcement.
With regard to your comment of a TIS-B feed, that certainly could be incorporated now. There are plenty of public ADS-B feeds out there (FR24/PlaneFinder/FlightAware/ADSBExchange), and it would be low bandwidth if it's only covering a 5nm ring. Some UAS (DJI M200/M210) come equipped with onboard ADS-B receivers that will display traffic on the GCS, which is great. Certainly a good start. The 2020 mandate, however, won't require ADS-B Out everywhere so many small aircraft simply will choose not to equip.