As the commenting deadline of April 15th draws near, we have collated some of the most interesting and practical suggestions that might greatly interest you.
So, what are some of the main highlights of the 2019 NPRM? The main purpose of the NPRM is captured quite well in this summary prepared by the FAA:
The FAA proposes to amend its rules applicable to the operation of small unmanned aircraft systems (UAS). This rulemaking would allow operations of small unmanned aircraft over people in certain conditions and operations of small UAS at night without obtaining a waiver. It would also require remote pilots in command to present their remote pilot in command certificate as well as identification to certain Federal, State, or local officials, upon request, and proposes to amend the knowledge testing requirements in the rules that apply to small UAS operations to require training every 24 calendar months. This proposal would be the next phase in integrating small UAS using a risk-based approach. These amendments would allow expanded small UAS operations and reduce the knowledge testing burden on remote pilots in command certificate holders.
Key points of the NPRM
It was heartening to note that more than 80% of the comments were positive and supportive of the FAA’s NPRM. Folks who expressed support include Part 107 pilots, public safety officials, and students.
So, what was the most recurrent them that people commented on? Not surprisingly, it was anti-collision lighting. Many people are confused by the lack of specifications in the NPRM.
The FAA defines anti-collision lighting as, “Any flashing or stroboscopic device that is of sufficient intensity so as to be visible for at least 3 statute miles”.
Further, the NPRM also invites comments on the following specific points-
An enthusiastic commentator has recommended the following –
One commentator suggested the use of position lighting in addition to anti-collision light.
Citing increased risk to manned aircraft, the National Agricultural Aviation Association, which represents 1,900 members, is not very supportive of FAA’s NPRM. They have made several exciting suggestions in their comment – a practical one being contacting “NVG (Night Vision Goggles) manufacturers to determine what the proper lighting specifications should be for UAVs.” According to the NAAA, only a specific type of LED light can be seen through Night Vision Goggles.
That seems possible. For a drone to fall under category 2, the NPRM states that:
“The unmanned aircraft would not have exposed rotating parts that could lacerate human skin.”
A parachute safety system can meet this criterion if it (1) completely envelops the propellers or, (2) Cuts off the motor, reduces the speed of descent (thus staying within the specified injury threshold)
The Alaska-based, Indemnis received approval for their safety parachutes just before the NPRM was released. An alternative to prop guards and parachute safety systems, is, of course, prop cages.
The use of bladeless propellers alone does not suffice. You also need to meet the injury threshold.
DJI’s Geo V2.0 already places greater restrictions on drone pilots. Click HERE to learn more this refined geo-fencing system.
Click Here to read the comment.
Click Here to read the comment.
Some hobby pilots are worried that the FAA’s NPRM affects them as well. In fact, these hobby pilots have used the same template to voice their dissent. Some excerpts from this letter -
“I urge the agency to take into consideration the existing safety guidelines for modelers and account for the fact that model aircraft and commercial drones are not the same the FAA cannot and should not take a one-size-fits-all approach to regulations.”
“Hobbyists who fly model aircraft do not need to be included in new rules for drone operators because we already follow our own proven set of safety guidelines, often at remote fixed flying site locations.”
Whether or not hobby pilots pose any risk to airspace is undoubtedly open to debate. However, this new NPRM affects Part 107 pilots only. Throughout the document, the FAA has used the term “remote pilot” to mean “a person authorized to conduct operations under Part 107”.
Click HERE to comment on FAA’s NPRM. Commenting deadline is April 15th.
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