Is Part 107 a good thing or a bad thing?

[Dave Armbrust]

It is a GREAT thing.

The new Part 107 regulation pretty much opens up the use of UAS to levels that can only just be imagined today. You can do almost anything as long as you remain in VLOS and within 400' of something, either the ground or a structure. The FAA has basically given us all the airspace that is not currently being used by manned aircraft.

Manned aircraft are required to remain 500' above the ground and 500' horizontally of any man made structure, unless they are landing or taking off. This unused airspace, with a 100' buffer, basically now belongs to UAS.

UAS can can even operate at a non-towered airport, but can not interfere with the operations at the airport. At a towered airport you need ATC approval and you will probably be granted it as long as what you are doing is safe and does not interfere with airport operations.

You can not fly over a person but you can fly alongside of them, you do not need to maintain a minimum distance.

The new Part 107 is far less restrictive than the 333 waivers that exist today in most cases (exception would be 333 waivers for night operation or closed sets).

Most of the few restrictions that is written into Part 107 can be waived by the FAA, if you can come up with a safe way of doing your operation. Even the VLOS can be waived, but you will need a way of insuring a similar level of safety would be provided.

What about non-commercial operators? Yes even non-commercial operators benefit under the new Part 107. It removes many of the restrictions in P.L. 112-95 imposed on model aircraft including the restrictions placed on model aircraft operating within 5 miles of an airport and operating within community based set of safety guidelines.

I do not know, it is over 600 pages, sound pretty intimidating why so many pages? It is not intimidating, the FAA received over 4,600 public comments and they considered all of them. Most of the 600 pages is explanations of why they decided what they did.

Sound pretty good so far? What does it prohibit? Careless and reckless operations, which is pretty broad, but necessary.

Where are the teeth in the new regulations? Simple, careless and reckless operations can result in loosing your remote pilot privileges.

Yes, the new Part 107 is a good thing for all of us and it makes it relatively easy to be legal with the FAA.

Is there any bad stuff in the new regulations? Yes, you have to wait till August.

 

[MacDyver]

I'm a semi law abiding (I don't trust someone who never breaks some rule or doesn't inhale) hobbyist, so very little of that matters to me, Those of us concerned about the safety of ourselves and others will make every attempt to fly safely anyway.
I do fly well below 400ft AGL, in class G airspace, well away from major traffic lanes and people, major events and infrastructure (Thats what zoom lenses are for). I will fly at night up to 200' Ft. AGL, ALWAYS within VLOS, and if I overfly homes I do so quickly at 200' Ft. AGL or more. If I'm at 400' well the whole community is obviously fair game.
Ne'er do wells will continue to do dumb and dangerous things because 107 or any other regulations doesn't matter to them anyway. Commercial Piloting regulations to me appear to be just another agency taxing your ways to make money.
The regulations as you've pointed out are so broad, vague and unenforceable it renders the whole concept meaningless. What concerns me are local and state agencies with their hodgepodge of rules made up on the fly.

 

[Cactuswest]

I'm a semi law abiding (I don't trust someone who never breaks some rule or doesn't inhale) hobbyist, so very little of that matters to me, Those of us concerned about the safety of ourselves and others will make every attempt to fly safely anyway.
I do fly well below 400ft AGL, in class G airspace, well away from major traffic lanes and people, major events and infrastructure (Thats what zoom lenses are for). I will fly at night up to 200' Ft. AGL, ALWAYS within VLOS, and if I overfly homes I do so quickly at 200' Ft. AGL or more. If I'm at 400' well the whole community is obviously fair game.
Ne'er do wells will continue to do dumb and dangerous things because 107 or any other regulations doesn't matter to them anyway. Commercial Piloting regulations to me appear to be just another agency taxing your ways to make money.
The regulations as you've pointed out are so broad, vague and unenforceable it renders the whole concept meaningless. What concerns me are local and state agencies with their hodgepodge of rules made up on the fly.

You concerns are valid, but I think the only thing that local and state agencies can legally do is regulate the takeoff and landing points because the airspace belong to the NAS and not States or cities. And they can only regulate with other local laws like noise abatement or such other edict that would indirectly preclude operating your drone.

Drone regulation was inevitable and you can choose to embrace it or ignore it at your own risks. For hobbyist I don't see much of problem. For commercial operator, clients will demand certification or it will become a promotional line on the biz card. So there is no reason to fight it. Besides, I don't think the requirements for non pilots are very demanding in getting a license and very easy for FAA licensed pilots.

One thing we can all do is self regulating ourselves, hobbyist and not, to make drone flying as safe as possible and reject the hot dogs out there who give everyone of us a bad name.

 

[FASTFJR]

Lets face it, most of us here and on other forums always try to fly within the rules / laws. The ones who don't could care less about any rules and laws

 

[RaptorMan]

It is a GREAT thing.

The new Part 107 regulation pretty much opens up the use of UAS to levels that can only just be imagined today. You can do almost anything as long as you remain in VLOS and within 400' of something, either the ground or a structure. The FAA has basically given us all the airspace that is not currently being used by manned aircraft.

Manned aircraft are required to remain 500' above the ground and 500' horizontally of any man made structure, unless they are landing or taking off. This unused airspace, with a 100' buffer, basically now belongs to UAS.

UAS can can even operate at a non-towered airport, but can not interfere with the operations at the airport. At a towered airport you need ATC approval and you will probably be granted it as long as what you are doing is safe and does not interfere with airport operations.

You can not fly over a person but you can fly alongside of them, you do not need to maintain a minimum distance.

The new Part 107 is far less restrictive than the 333 waivers that exist today in most cases (exception would be 333 waivers for night operation or closed sets).

Most of the few restrictions that is written into Part 107 can be waived by the FAA, if you can come up with a safe way of doing your operation. Even the VLOS can be waived, but you will need a way of insuring a similar level of safety would be provided.

What about non-commercial operators? Yes even non-commercial operators benefit under the new Part 107. It removes many of the restrictions in P.L. 112-95 imposed on model aircraft including the restrictions placed on model aircraft operating within 5 miles of an airport and operating within community based set of safety guidelines.

I do not know, it is over 600 pages, sound pretty intimidating why so many pages? It is not intimidating, the FAA received over 4,600 public comments and they considered all of them. Most of the 600 pages is explanations of why they decided what they did.

Sound pretty good so far? What does it prohibit? Careless and reckless operations, which is pretty broad, but necessary.

Where are the teeth in the new regulations? Simple, careless and reckless operations can result in loosing your remote pilot privileges.

Yes, the new Part 107 is a good thing for all of us and it makes it relatively easy to be legal with the FAA.

Is there any bad stuff in the new regulations? Yes, you have to wait till August.

Dave, it sounds promising and if a seasoned pilot such as yourself can get on board that's very comforting.

I'm 100% certain that this is not the last of it and that there will be revisions and additions going forward. I've mentioned numerous times before about flying a camera drone over a stadium sporting event and although it does not appear this is legal now by anyone I am confident that within 5 years, 8 at the most, it will be commonplace. I think in order for that to happen there will need to be a system in place to certify pilots to perform such missions and other missions like bridge inspections where active traffic is present.

So, things are looking up and I'd argue what we have now is more of a road map for future additions.

The one thing I'm not 100% certain of though you appear comfortable is the fact the helicopters can and do occupy the same airspace as drones -- how is that provided for in the new rules?


Brian

 

[RaptorMan]

Just so its clear I'm not opposed to a legal framework for commercial drone work so long as the process isn't overly burdensome or require a full on pilots license -- I hope I've been clear on this before now. I have not yet read the full text but what I've gleaned appears to be more-or-less in line with what I'd want and expected. And, as it now appears there IS a kind of tiered arrangement with remote pilots being permitted to do most things but not permitted to do other things like fly over people on a movie set. That is fully as I'd expect and sounds reasonable to me.

And, as mentioned before, I fully expect the rules to be updated numerous times over the next decade with a lot of change over the next 5 years and lessor change after that.


Brian

 

[licensed pilot]

I'm a semi law abiding (I don't trust someone who never breaks some rule or doesn't inhale) hobbyist, so very little of that matters to me, Those of us concerned about the safety of ourselves and others will make every attempt to fly safely anyway.
I do fly well below 400ft AGL, in class G airspace, well away from major traffic lanes and people, major events and infrastructure (Thats what zoom lenses are for). I will fly at night up to 200' Ft. AGL, ALWAYS within VLOS, and if I overfly homes I do so quickly at 200' Ft. AGL or more. If I'm at 400' well the whole community is obviously fair game.
Ne'er do wells will continue to do dumb and dangerous things because 107 or any other regulations doesn't matter to them anyway. Commercial Piloting regulations to me appear to be just another agency taxing your ways to make money.
The regulations as you've pointed out are so broad, vague and unenforceable it renders the whole concept meaningless. What concerns me are local and state agencies with their hodgepodge of rules made up on the fly.

"(I don't trust someone who never breaks some rule or doesn't inhale) I will fly at night up to 200' Ft. AGL, ALWAYS within VLOS, and if I overfly homes I do so quickly at 200' Ft. AGL or more. If I'm at 400' well the whole community is obviously fair game."

Exactly the type of attitude the causes rest of us to be saddled with rules. Thanks. (just please don't inhale while flying)

 

[Dave Armbrust]

Dave, it sounds promising and if a seasoned pilot such as yourself can get on board that's very comforting.

I'm 100% certain that this is not the last of it and that there will be revisions and additions going forward. I've mentioned numerous times before about flying a camera drone over a stadium sporting event and although it does not appear this is legal now by anyone I am confident that within 5 years, 8 at the most, it will be commonplace. I think in order for that to happen there will need to be a system in place to certify pilots to perform such missions and other missions like bridge inspections where active traffic is present.

So, things are looking up and I'd argue what we have now is more of a road map for future additions.

The one thing I'm not 100% certain of though you appear comfortable is the fact the helicopters can and do occupy the same airspace as drones -- how is that provided for in the new rules?


Brian

Brian, you are 100% correct. This is only the beginning and as the industry figures out how to do more safely the FAA will change the regulations.

The new regulations do allow you to fly over people if they are inside a vehicle or structure that would protect them from a UAS striking their vehicle. Therefore the bridge inspection you mention will be allowed as long as you are not flying over pedestrians and the operation is not careless or reckless.

These new regulations eliminate the need for a 333 waiver for most operators. If you already have a 333 waiver you can continue to operate under it till its expiration, or you can operate under part 107. If you have a standard waiver, or have requested one, the new rules are more permissive that the 333 waiver and there would be no reason to continue to operate under the 333 waiver.

Regarding helicopters a UAS must give way to any manned aircraft. This is the reason we must remain in VLOS at all time. Also an airplane can operate below 500' if it is landing or taking off. We can not interfer with airport operations.

 

[RaptorMan]

Brian, you are 100% correct. This is only the beginning and as the industry figures out how to do more safely the FAA will change the regulations.

The new regulations do allow you to fly over people if they are inside a vehicle or structure that would protect them from a UAS striking their vehicle. Therefore the bridge inspection you mention will be allowed as long as you are not flying over pedestrians and the operation is not careless or reckless.

These new regulations eliminate the need for a 333 waiver for most operators. If you already have a 333 waiver you can continue to operate under it till its expiration, or you can operate under part 107. If you have a standard waiver, or have requested one, the new rules are more permissive that the 333 waiver and there would be no reason to continue to operate under the 333 waiver.

Regarding helicopters a UAS must give way to any manned aircraft. This is the reason we must remain in VLOS at all time. Also an airplane can operate below 500' if it is landing or taking off. We can not interfer with airport operations.

Dave, again thanks for your feedback...

I appreciate that planes are below 500' on takeoff and landing and that a drone pilot must give way to a manned AC and that should also include balloons and parachuters..

Thanks for the distinction on flying over vehicles for bridge inspection, though I'm not sure how someone riding a motorcycle, bicycle or walking would be protected if a drone were to crash while inspecting a bridge. My sense is this would or should require more than a basic remote pilot certificate.

Lastly, the VLOS stipulation is one that is going to be amended down the road as that will inhibit such things as SAR and surveillance work. But, looking down the road to when SAR drones are permitted beyond VLOS it is likely to require additional pilot certificates as well as drones with additional sensors/tech and a certification process for them. Again, looking ahead perhaps 5-8 years I think we'll see SAR drones operating for hours at a time and well beyond visual range of the operator/pilot.


Brian

 

[Dave Armbrust]

Just so its clear I'm not opposed to a legal framework for commercial drone work so long as the process isn't overly burdensome or require a full on pilots license -- I hope I've been clear on this before now. I have not yet read the full text but what I've gleaned appears to be more-or-less in line with what I'd want and expected. And, as it now appears there IS a kind of tiered arrangement with remote pilots being permitted to do most things but not permitted to do other things like fly over people on a movie set. That is fully as I'd expect and sounds reasonable to me.

And, as mentioned before, I fully expect the rules to be updated numerous times over the next decade with a lot of change over the next 5 years and lessor change after that.


Brian

Brian, you now have two choices and you get to chose which one you want to do.

For hobby or recreational use you can operate under the protection of P.L. 112-95 which say that the FAA can not place additional restrictions on model aircraft. The restrictions in P.L. 112-95 are actually more restrictive than Part 107, but if you are a member of AMA, flying more than 5 miles from any airport and just having fun and no one is profiting from your efforts you do not need the less restrictive Part 107 and you can just ignore the new regulations.

If you prefer to operate under the less restrictive Part 107 regulations, you may do so by taking a written test and process your own 8710 application. After being vetted by the TSA you will be issued a remote pilot certificate. Total cost about $150 for the written test every two years. The testing center will need to check your id and certify that it was you that took and passed the test.

The need to visit the FSDO, a DPE or an CFI is only for pilots that have a current pilot certificate, other than student. You need to present government issued photo identification, your pilot certificate, your current flight review and the certificate that you have taken the online course.

There is no tiered arrangement. You can obtain a part 107 waiver to fly over people in a closed movie set, but you have to have far more safety precautions than required in Part 107. These 107 waivers would be considered on a per case basis after a careful review by the FAA. If your safety procedures are adequate then the 107 waiver may be issued.

 

[Dave Armbrust]

Dave, again thanks for your feedback...

I appreciate that planes are below 500' on takeoff and landing and that a drone pilot must give way to a manned AC and that should also include balloons and parachuters..

Thanks for the distinction on flying over vehicles for bridge inspection, though I'm not sure how someone riding a motorcycle, bicycle or walking would be protected if a drone were to crash while inspecting a bridge. My sense is this would or should require more than a basic remote pilot certificate.

Lastly, the VLOS stipulation is one that is going to be amended down the road as that will inhibit such things as SAR and surveillance work. But, looking down the road to when SAR drones are permitted beyond VLOS it is likely to require additional pilot certificates as well as drones with additional sensors/tech and a certification process for them. Again, looking ahead perhaps 5-8 years I think we'll see SAR drones operating for hours at a time and well beyond visual range of the operator/pilot.


Brian

Brian, you are asking good questions and I am happy to answer them to the best of my ability.

I did say pedestrian and should have included motorcycles and bicycles as well. If they are present you may not fly over them while doing a bridge inspection. They must be in a vehicle or structure that protects them in order to fly over them.

I think you could ask for and be granted a part 107 VLOS waiver for a SAR mission if you were operating within TFR for the SAR and in a unpopulated area. If reasonable precautions were taken to ensure there were no manned aircraft (TFR) and that you were not likely to injure persons or damage property (unpopulated area).

The FAA has already acknowledge that VLOS and operation over people can be waived on a case by case basis. It the industry comes up with ways to do this safely there may be a change in the 107 to accomidate this technology.

Things like more than four motor and reduced weight may be ways that the industry reduces risks for these type of operations. The technology is advancing quickly and we are able to do more with smaller and smaller drones. With smaller drones we have lower risks. How small must a drone be to allow them to fly over people? These are the type of question that need to be figured out, and we are not there yet.

The FAA acknowledges that these final part 107 rules are not final. They did not want to wait until the technology improves to the point where they could have a more refined versions of the regulations. They wanted to allow the lowest risk operations now, and consider higher risk operations on a case by case basis. They decided that delaying part 107 until these refinements can be made would have a detrimental effect on the industry.

Over 4,600 people commented on the proposed rules and what we got was the combined wisdom of those comments.

 

[RaptorMan]

Brian, you are asking good questions and I am happy to answer them to the best of my ability.

I did say pedestrian and should have included motorcycles and bicycles as well. If they are present you may not fly over them while doing a bridge inspection. They must be in a vehicle or structure that protects them in order to fly over them.

I think you could ask for and be granted a part 107 VLOS waiver for a SAR mission if you were operating within TFR for the SAR and in a unpopulated area. If reasonable precautions were taken to ensure there were no manned aircraft (TFR) and that you were not likely to injure persons or damage property (unpopulated area).

The FAA has already acknowledge that VLOS and operation over people can be waived on a case by case basis. It the industry comes up with ways to do this safely there may be a change in the 107 to accomidate this technology.

Things like more than four motor and reduced weight may be ways that the industry reduces risks for these type of operations. The technology is advancing quickly and we are able to do more with smaller and smaller drones. With smaller drones we have lower risks. How small must a drone be to allow them to fly over people? These are the type of question that need to be figured out, and we are not there yet.

The FAA acknowledges that these final part 107 rules are not final. They did not want to wait until the technology improves to the point where they could have a more refined versions of the regulations. They wanted to allow the lowest risk operations now, and consider higher risk operations on a case by case basis. They decided that delaying part 107 until these refinements can be made would have a detrimental effect on the industry.

Over 4,600 people commented on the proposed rules and what we got was the combined wisdom of those comments.

Yeah, Dave, I think for the beyond VLOS missions, other than the exceptions which might be granted under 107, it's likely that a drone would need additional equipment to permit this on a more routine basis. I've mentioned this before but will repeat that a drone with transponder that reports: alt, heading, horizontal velocity, vertical velocity, AC type and serial number (tail number), and perhaps also report the flight/mission plan number. And, it would be a good idea as well to have collision avoidance sensors such as radar. In fact, if I were to spec a drone for such missions I'd want:

1. A transponder as mentioned above that reports as above.
2. Radar altimeter
3. Collision avoidance and navigation radar
4. Pilot fixed look forward camera with HD video and/or FLIR
5. Main camera package with stabilized platform for still, video and/or FLIR
6. Collision avoidance lights

Just over a year ago we had the two scumbags that escaped from the Clinton Correctional Facility in Dannemora NY and if they had a half dozen such drones they might have caught them the second night. We will see police work being done by drones like this in the future, but it will take time to roll out drones with the equipment needed to do this. But, when such drones are available the FAA will need to adjust the rules to permit such drones to operate.

I don't believe any current transponders report that level of detail, but I think this is an area where progress can and will be made. I also think that when such transponders are available that cockpit instrumentation could/should be augmented to permit pilots to see this information for AC in there vicinity. So, in addition to any info a pilot might learn during flight planning/filing he/she should be apprised of any new information when they are approaching the area in question.

In summary, I think were going to see a greater integration of data into the air traffic control system and that much of it will be automated. So, as a pilot enters an area in which a drone or other AC is operating he should be informed of this if his flight is likely to come within some specified distance either horizontally or vertically. I'm not saying we should eliminate the air traffic controllers (humans), but augment that with automated data from ATC including drone operations.


Brian

 

[MacDyver]

"(I don't trust someone who never breaks some rule or doesn't inhale) I will fly at night up to 200' Ft. AGL, ALWAYS within VLOS, and if I overfly homes I do so quickly at 200' Ft. AGL or more. If I'm at 400' well the whole community is obviously fair game."

Exactly the type of attitude the causes rest of us to be saddled with rules. Thanks. (just please don't inhale while flying)

Stuck on stupid, either you have difficulty reading or understanding either way this is generally why I ignore you

 

[licensed pilot]

Stuck on stupid, either you have difficulty reading or understanding either way this is generally why I ignore you

 

[Dave Armbrust]

Yeah, Dave, I think for the beyond VLOS missions, other than the exceptions which might be granted under 107, it's likely that a drone would need additional equipment to permit this on a more routine basis. I've mentioned this before but will repeat that a drone with transponder that reports: alt, heading, horizontal velocity, vertical velocity, AC type and serial number (tail number), and perhaps also report the flight/mission plan number. And, it would be a good idea as well to have collision avoidance sensors such as radar. In fact, if I were to spec a drone for such missions I'd want:

1. A transponder as mentioned above that reports as above.
2. Radar altimeter
3. Collision avoidance and navigation radar
4. Pilot fixed look forward camera with HD video and/or FLIR
5. Main camera package with stabilized platform for still, video and/or FLIR
6. Collision avoidance lights

Just over a year ago we had the two scumbags that escaped from the Clinton Correctional Facility in Dannemora NY and if they had a half dozen such drones they might have caught them the second night. We will see police work being done by drones like this in the future, but it will take time to roll out drones with the equipment needed to do this. But, when such drones are available the FAA will need to adjust the rules to permit such drones to operate.

I don't believe any current transponders report that level of detail, but I think this is an area where progress can and will be made. I also think that when such transponders are available that cockpit instrumentation could/should be augmented to permit pilots to see this information for AC in there vicinity. So, in addition to any info a pilot might learn during flight planning/filing he/she should be apprised of any new information when they are approaching the area in question.

In summary, I think were going to see a greater integration of data into the air traffic control system and that much of it will be automated. So, as a pilot enters an area in which a drone or other AC is operating he should be informed of this if his flight is likely to come within some specified distance either horizontally or vertically. I'm not saying we should eliminate the air traffic controllers (humans), but augment that with automated data from ATC including drone operations.


Brian

While the FAA may find that this would be adequate to grant an 107 waiver, they may find less equipment may be satisfactory. It depends on where you want to operate. If it is near an airport they would probably not approve it. If it is in a remote area, where the only risk is lost of the UA you may find that much less equipment than what you suggest would be acceptable.

The FAA is not expecting zero risk, but are likely to approve some risk as long as we have taken reasonable precautions to reduce the risk especially if we are using proven technology.

They will likely approve 107 waivers for beyond VLOS in low risk area before allowing this type of operations in higher risk areas.

There are agriculture uses, SAR, ski resorts, power line patrol, survey work and many more uses in nonpopulated areas where the industry can put beyond VLOS operations to use with very little risk to the public. Let's perfect the technology there, in remote areas, before we risk persons or property other than the UAS.

 

[Brett W]

Hey guys,
This is my first reply at all so excuse me. I am a 4,000 hour HEMS pilot and have been chief pilot of a 4 a/c part 135 operation for 2 years. I also own my own company with 2 arms. One a simple DJI UAS type operation. The other is a very complex maritime/SAR commercial operation. We have been exploring and pushing the FAA over some of these issues because we violate all of the set standard (10ft x 9ft, 110+kt vne, 275lbs, and 40nm range @ 2hours aloft) however we have launched specialty in the maritime industry. The only reason we are even applying with the FAA is because we will initially register them with the FAA thigh they will be operating internationally over water. I will be happy to keep you guys informed of our progress.

 

[SixtyMike]

Hey guys,
This is my first reply at all so excuse me. I am a 4,000 hour HEMS pilot and have been chief pilot of a 4 a/c part 135 operation for 2 years. I also own my own company with 2 arms. One a simple DJI UAS type operation. The other is a very complex maritime/SAR commercial operation. We have been exploring and pushing the FAA over some of these issues because we violate all of the set standard (10ft x 9ft, 110+kt vne, 275lbs, and 40nm range @ 2hours aloft) however we have launched specialty in the maritime industry. The only reason we are even applying with the FAA is because we will initially register them with the FAA thigh they will be operating internationally over water. I will be happy to keep you guys informed of our progress.

Sounds interesting. Keep us informed.
Another rotor head here,
60M