1. TEAM E: STANDARDS AND REGULATIONS DOCK-IN-PIECE Paul M. Calhoun Rushat Gupta Chadha Keerthana Manivannan Aishanou Osha Rait Bishwamoy Sinha Roy

2. OUTLINE Marine Mammal Protection Act – Definitions - Roy – Maritime Borders – Roy – Harassment, Permits, Impacts - Keerthana FAA Proposed Part 107 – Definitions – Rushat – Airspace - Rushat – Operational Restriction - Paul – Operator Certification - Paul – Aircraft Requirements - Paul – Loopholes - Paul – MicroUAS - Aishanou 2

3. MARINE MAMMAL PROTECTION ACT

4. DEFINITIONS What is a marine mammal? 4

5. Not Marine 5

6. Not A Mammal 6

7. Yes, A Marine Mammal 7

8. Wouldn’t Be Protected Anyway BUT WHY? 8

9. JURISDICTION Where Can This Law Be Applied? 9

10. US MARITIME BORDERS 10

11. SPECIAL MARITIME ZONE 11

12. NEW DEFINITION Harassment – Level A Has the potential to injure a marine mammal or marine mammal stock in the wild – Level B Has the potential to disturb a marine mammal or marine mammal stock in the wild by causing disruption of behavioral patterns, including, but not limited to, migration, breathing, nursing, breeding, feeding, or sheltering. 12

13. PERMITS You can get a permit to commit class B harassment (ie. Annoying a manatee) if it’s for research, or if it’s commercial/educational photography This permit lasts 1 year and can only be obtained by US citizens Requires plans, intentions, locations, and other supporting documentation 13

14. WHY DOES THIS MATTER TO US? In the absence of a permit, an autonomous vehicle operating in US waters would be required to either have the capacity to identify a mammal and avoid it so as not to commit class B harassment, or have an operator watching at all times and ready to teleoperate if a marine mammal comes close. Our system complies with MMPA by stopping the vehicle in the presence of anything large enough to be a marine mammal. 14

15. PROPOSED PART 107 OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS (14 CFR) PURSUANT TO SECTION 333 OF PUBLIC LAW 112-95, THE FAA MODERNIZATION AND REFORM ACT OF 2012

16. DEFINITIONS UAS (Unmanned Aerial System) SUAS (Small Unmanned Aerial System) – 55 lbs or less – Powered flight Micro UAS – 4.4 lbs FAA (Federal Aviation Administration) NAS (National Airspace) ATC (Air Traffic Control – usually a tower) MSL (Measured from Sea Level) AGL (Above Ground Level) 16

17. AIRSPACE Six Classes – A – B – C – D – E – G 17

18. 18

19. WHY NOW? Right now FAA has no rules – Is simply choosing not to prosecute and to use a circular that equates UAS with hobby RC planes Would have to use manned flight regulations otherwise – Manned flight airmen require a LOT of certification Almost all unnecessary given the lack of possibility of injury and property damage of small UAS. Airworthiness certification for manned vehicles takes 3-5 years – Not technically feasible 19

20. OPERATIONAL LIMITATIONS Visual line-of-sight (VLOS) only; the unmanned aircraft must remain within VLOS of the operator or visual observer. At all times the small unmanned aircraft must remain close enough to the operator for the operator to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses. – There is also a prohibition on daisy chains of visual observers. The SUAS MUST be within visual range of the operator even if the operator is not looking at the SUAS – WHY? FAA does not believe that autonomous flight is mature enough to allow drones out of sight. Cameras, binoculars, and other tools lack peripheral vision Statutory requirement of ‘see-and-avoid’ – Especially in cases of loss of positive control No requirement yet for autonomous landing, but if included on UAS, may allow for over-the-horizon flights as this mitigates loss of positive control 20

21. OPERATIONAL LIMITATIONS Small unmanned aircraft may not operate over any persons not directly involved in the operation. – Micro UAS not subject to this restriction – “the operator must ensure that all persons directly involved in the small unmanned aircraft operation receive a briefing that includes operating conditions, emergency procedures, contingency procedures, roles and responsibilities, and potential hazards” Daylight-only operations (official sunrise to official sunset, local time). – Also includes a weather restriction that there must be high visibility – Low light visual sensors being considered as a mitigation that allows for night time flying Must yield right-of-way to other aircraft, manned or unmanned. May use visual observer (VO) but not required. – FAA regulation allows VOs to be under the ‘command’ of operators, along with any other ‘flight crew’ 21

22. OPERATIONAL LIMITATIONS Maximum airspeed of 100 mph (87 knots). – Micro restricted to 34 mph Maximum altitude of 500 feet above ground level. – Micro restricted to 400 feet Minimum weather visibility of 3 miles from control station. – Micro restricted to 1500 feet from operator No operations are allowed in Class A (18,000 feet & above) airspace. Operations in Class B, C, D and E airspace are allowed with the required ATC permission. – Micro restricted from entering any but Class G airspace Operations in Class G airspace are allowed without ATC permission 22

23. REMEMBER! Class A and E airspace is measured from sea level! 23

24. You can’t climb Denali with your Drone 24

25. OPERATIONAL LIMITATIONS No person may act as an operator or VO for more than one unmanned aircraft operation at one time. Preflight inspection by the operator. A person may not operate a small unmanned aircraft if he or she knows or has reason to know of any physical or mental condition that would interfere with the safeoperation of a small UAS. – No drunk pilots – No blind visual observers – No putting drugs on the drone Possibility of including relaxed rules for SUAS with advanced risk mitigation systems 25

26. OPERATOR CERTIFICATION AND RESPONSIBILITIES Pass an initial aeronautical knowledge test at an FAA-approved knowledge testing center. – Knowledge test includes: regulations, NAS classifications, how to maneuver to avoid collision, how to deal with adverse weather in various locations, calculating payload, emergency responses, decision making, crew management, airport and radio communication procedure including terminology, drug and alcohol effects on flying – Have to speak English to get certified, but if disabled can get a restricted cert Be vetted by the Transportation Security Administration. – Certs take 6-8 weeks to process – TSA charges for vetting – Current TSA requirements mean only citizens can operate the SUAS Obtain an unmanned aircraft operator certificate with a small UAS rating (like existing pilot airman certificates, never expires). – Total cost will be around $300 to certify – You can’t use UAS flight time to satisfy other certs’ flight time 26

27. OPERATOR CERTIFICATION AND RESPONSIBILITIES Pass a recurrent aeronautical knowledge test every 24 months. – Less material than initial test – Former UAS pilots from the armed forces take this instead of initial knowledge test Be at least 17 years old. – This being a commercial license, causes some small issue as it licenses minors to be a commercial entity – Thinking of lowering the age to 15 anyway Make available to the FAA, upon request, the small UAS for inspection or testing, and any associated documents/records required to be kept under the proposed rule. 27

28. OPERATOR CERTIFICATION AND RESPONSIBILITIES Report an accident to the FAA within 10 days of any operation that results in injury or property damage. Conduct a preflight inspection, to include specific aircraft and control station systems checks, to ensure the small UAS is safe for operation. – This is intended to help mitigate the possibility of loss of positive control – UAS required to have enough power for full planned flight + five minutes of emergency time Operators not allowed to operate out of land or air vehicles, – Allowed to do so out of boats or jetskis – FAA open to hearing reasons why it may be beneficial to operate out of a moving vehicle Operators would have to keep up with NOTAMs (Notice to Airmen), which provide temporary flight restrictions – ex. When the Pope goes by 28

29. AIRCRAFT REQUIREMENTS Aircraft Registration required (same requirements that apply to all other aircraft). – Since this replaces the hobbyist registration with a blanket use registration, it’s likely all registrations will have to go through the Flight Standards District Office – Anticipated $5 registration fee – Aircraft can only be registered to citizens, permanent residents, and US Corporations / Governmental Entities SUAS cannot be an ‘Air Carrier’ – Air Carriers carry people or property as part of commercial activity – Operators are allowed to move their own property on their SUAS Cannot exceed the 55 lb limit – External loads may require an additional certification Cannot fly over international borders – Current treaties are highly restrictive and the US is negotiating them 29

30. AIRCRAFT REQUIREMENTS Doesn’t apply to anything owned by the government, which continue to be regulated by 91.113(b) – Always requires a waiver because there’s a see-and-avoid stipulation. – GOV can claim civil use and be under 107 if they want This saves some paperwork but adds the restrictions of Part 107. Registration of SUAS must be done every 3 years – Keeps records current 30

31. AIRCRAFT REQUIREMENTS Aircraft markings required (same requirements that apply to all other aircraft). If aircraft is too small to display markings in standard size, then the aircraft simply needs to display markings in the largest practicable manner. – Painted on or otherwise made permanent – No ornamentation – Contrast in color with background – Placed in a location visible from the ground – Be legible – 12 inches high – Two thirds as wide as high – Solid lines that are one sixth as wide as high – Spaced out at least one fourth of character width 31

32. HOW CAN I GET OUT OF THIS? Try to get your UAS classified as a model aircraft – The aircraft is flown strictly for hobby or recreational use; – The aircraft is operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization; – The aircraft is limited to not more than 55 pounds unless otherwise certified through a design, construction, inspection, flight test, and operational safety program administered by a community-based organization; – The aircraft is operated in a manner that does not interfere with and gives way to any manned aircraft; and – When flown within 5 miles of an airport, the operator of the aircraft provides the airport operator and the airport air traffic control tower (when an air traffic facility is located at the airport) with prior notice of the operation. 32

33. HOW CAN I GET OUT OF THIS? Get an Exemption – Exemptions available for non-recreational or highly advanced systems – If we aren’t all exempt, nobody is! – Possibility of including relaxed rules for UAS with advanced risk mitigation systems The sort of thing an MRSD group could put together pretty easily 33

34. MICRO UAS FAA considering adding a Micro UAS rating. Canada currently does this 34

35. COMPARISON OF CANADIAN RULES GOVERNING MICRO UAS CLASS WITH PROVISIONS OF PROPOSED PART 107 AND MICRO UAS SUB- CLASSIFICATION PROVISIONCANADASMALL UAS NPRM MICRO UAS SUB- CLASSIFICATION Definition of Small UASUp to 4.4 lbs (2 kg)Up to 55 lbs (24 kg)Up to 4.4 lbs (2 kg) Maximum Altitude Above Ground 300 feet500 feet400 feet Airspace LimitationsOnly within Class G airspaceAllowed within Class E in areas not designated for an airport. Otherwise, need ATC permission. Only within Class G airspace Allowed within Class B, C and D with ATC permission. Allowed in Class G with no ATC permission 35

36. PROVISIONCANADASMALL UAS NPRM MICRO UAS SUB- CLASSIFICATION Distance from people and structures 100 feet laterally from any building, structure, vehicle, vessel or animal not associated with the operation and 100 feet from any person. Simply prohibits UAS operations over any person not involved in the operations (unless under a covered structure) Flying over any person is permitted Ability to extend operational area NoYes, from a waterborne vehicle No Autonomous operationsNoYesNo Aeronautical knowledge required Yes; ground schoolYes; applicant would take knowledge test Yes; applicant would self-certify First person view permitted NoYes, provided operator is visually capable of seeing the small UAS No Operator training required Yes, ground schoolNo Visual observer training required YesNo 36

37. PROVISIONCANADASMALL UAS NPRM MICRO UAS SUB- CLASSIFICATION Operator certificate required NoYes (must pass basic UAS aeronautical test) Yes (no knowledge test required) Preflight safety assessment Yes Operate in a congested area NoYes Liability insuranceYes, $100,000 CANNo Daylight operations only Yes Aircraft must be made out of frangible materials No Yes 37

38. DOCKING... Questions? 38