Ed O'Grady

FAA Airspace Authorization & Waiver Experiences / Notes

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46 minutes ago, Hawg97 said:

I was curious about the specific application because what the FAA appears to be granting to some individuals appears to be more of a "waiver" - i.e. Can fly in Class E airspace below 100ft AGL with a September expiry.  If, on the other hand, the approval were for a flight to occur tomorrow between 2pm and 4pm within 1200' of a certain radius, that would appear to be an authorization.  Who knows....

Silly and no safer, but it is what it is....

I see what you just described and that is what I'm getting back approved. I ask for airspace authorization for class C or D airspace, valid from April to September 2017 and I get an approval back.

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5 hours ago, Hawg97 said:

We talked, and based on my explanation to him, i was told that a waiver is the approproate request.  I just don't remember seeing any specific communication about waivers not being reviewed.

That's frustrating :( All it takes is a simple redesign of the FAA's primary page / instructions, and two separate forms, one for airspace authorizations, and one for waivers. It amazes me how slow they are to update the website. Would save SO many phone calls, emails, administrative headaches, BLEARGH.

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If you guys have already seen this, I apologize, but, this was a first for me.  I've submitted 5 airspace authorizations since the beginning of the year.  On the last one, after I spoke with the contractor, I received this email from the FAA:

Thank you for submitting an Airspace Authorization request to the Federal Aviation Administration. This email is in reference to the application submitted on 3/2/2017 in the vicinity of VBT.  Your application is being processed.

Request Number: 2017-P107-CSA-1183

Please do not reply to this email address, it is a distribution mailbox only.

Maybe (hopefully), they are in the process of updating and modifying this system to make it more user friendly and give us the ability to track the request's status.  I did submit the request on 3/2, but as usual, got no acknowledgement that I submitted it.  Since I spoke with the contractor yesterday, it only took 14 days for him to start working on it which is probably the quickest response so far...  Hopefully things will get easier...

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That request number seems to match up with the subject line I get on messages for my requests. Here is a recent subject line I got: FAA Form 7711-1 2017 WSA-465 P107 SNA Class C

I haven't figured out if it is tied specifically to my request I filed or tied to some sort of airport grid the FAA has for airspace coordinates.

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I stand corrected - this is the same numbering scheme. Below is one from October.  Steve, I assume yours is for John Wayne (SNA).  Mine is for Brunswick-Mckinnon (SSI) and the E obviously is for Class E sfc. B's appears just slightly different.

FAA Form 7711-1 2016-ESA-251-P107 SSI E

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I wonder why some pilots get acknowledgement emails, others get approvals in no time, and some get no response at all? Just growing pains? I've submitted for 3 different waivers since January and haven't heard a peep. :|

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50 minutes ago, GoneCoastal said:

I wonder why some pilots get acknowledgement emails, others get approvals in no time, and some get no response at all? Just growing pains? I've submitted for 3 different waivers since January and haven't heard a peep. :|

As I have recently discovered, if you are applying for a waiver - don't. Even if that seems like what you should be applying for.  Even if an FAA Rep told you to apply for a waiver.  Apply for an AUTHORIZATION. I resubmitted for an authorization last week. We'll see if I have better luck. 

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As has been discussed previously, a waiver is just that - a waiver of Part 107 rules.  An Airspace Authorization is precisely that, an authorization to fly in certain airspace. They are 2 entirely different things handled by 2 entirely different groups of personnel.  Airspace authorizations are handled by contractors and waivers are done by FAA employees.  It appears that for now waivers are not being released.  FAA has told me they are being processed but not released.  I don't understand why you would advise someone to NOT apply for a Waiver From Part 107, if that's what they needed, and instead apply for an Airspace Authorization. 

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4 minutes ago, Ed O'Grady said:

As has been discussed previously, a waiver is just that - a waiver of Part 107 rules.  An Airspace Authorization is precisely that, an authorization to fly in certain airspace. They are 2 entirely different things handled by 2 entirely different groups of personnel.  Airspace authorizations are handled by contractors and waivers are done by FAA employees.  It appears that for now waivers are not being released.  FAA has told me they are being processed but not released.  I don't understand why you would advise someone to NOT apply for a Waiver From Part 107, if that's what they needed, and instead apply for an Airspace Authorization. 

Wow.  Let me re-phrase:  If you need to fly commercially and legally (and I'm not suggesting anyone fly illegally) sooner rather than later, AND your issue is with airspace - file for an Airspace Authorization. If you want results similar to what was mentioned (I.e. an actual approval or response) - file for an airspace authorization. If you are looking for a waiver from certain airspace rules - so you don't have to request an authorization every time you need one, file it if you want.  Don't expect a response soon.  Or ever. Or, who knows?

To clarify further - If you need some other type of approval - seek a WAIVER. Because that's the only choice your given. And, as Ed mentioned they aren't being released.  I've been told they aren't even being processed.  Ed is probably more accurate since he's actually had a verbal conversation with someone at the FAA.  It's just more ambiguity.

Maybe I made a mistake believing the comment was about "airspace" since that's the topic of this forum and the comment mentioned pilots getting "quick approvals".  There haven't been "quick approvals" - if they are waivers - since January 23.  

Its great that there are experts on here about the finer points of the hazy rules and processes, but I really hope you are hearing things from the FAA that indicates there will actually be a system put in place to do what it's purported to do - not just to meet a date given to them by Congress. 

Anyway, thanks for pointing out the need for further clarification. 

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I'm not hearing anything new about the upcoming "instant approval" system.  It was supposed to arrive in summer of '17 but I am now hearing sometime 2018.  I just wish we could get our hands on the grid mapping that has already been done.  Here's an example of the mapping done at KMCO

grid.thumb.jpg.cc9d5f790846a797522cb98723039388.jpg

If we had access to the map for our given areas, we would know up front what we could or could not get approval for.  That would make everyone's life easier. For that matter, since we studied for, passed, and have stated that we will abide by the Part 107 certificate regulations, why shouldn't Part 107 certificate holders simply be allowed to fly and abide by the grid map?  I guess that's out of the question!

I noticed something last night on FAA site that may have been there but I just never noticed before.  Under "beyond the basics" I saw "Standard special provisions for part 107 waivers (coming soon)".  When I applied for a waiver from Daylight operations, I reviewed many approvals and tried to address each and every provision but I still got denied.  They all seemed to be the same, but it looks like they are going to issue something to cover all that.  Patience is a virtue!

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As luck would have it, today I finally heard back on my daylight operations waiver for class G. They need some more information, and quite frankly, I'm not sure how to respond. Any suggestions?

From their email:

       

Quote

 

For a waiver from section 107.29 - Daylight Operations:

 

•  Applicant must provide a method by which the remote pilot will be able to continuously

    know and determine the position, altitude, attitude, and movement of their small

    unmanned aircraft (sUA).

What information is provided on the Phantom 4 Pro’s integrated software display, and how will the remote PIC use the information to meet the Performance Based Standard (PBS)? If the remote PIC is relying on the integrated software display to meet the PBS, how will the PIC meet the PBS in the event of an integrated software failure?

 

 

Obviously, the software and controls tell us the pertinent information. But how in the world do I respond to the question about an integrated software failure??

 

 

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6 minutes ago, GoneCoastal said:

As luck would have it, today I finally heard back on my daylight operations waiver for class G. They need some more information, and quite frankly, I'm not sure how to respond. Any suggestions?

From their email:

       

 

Obviously, the software and controls tell us the pertinent information. But how in the world do I respond to the question about an integrated software failure??

 "If the remote PIC is relying on the integrated software display to meet the PBS, how will the PIC meet the PBS in the event of an integrated software failure?" Only an engineer or DJI can answer that.

 

That gobledygook was never asked in my night waiver. Sorry, looks like you got a very anal dude...

 "If the remote PIC is relying on the integrated software display to meet the PBS, how will the PIC meet the PBS in the event of an integrated software failure?" first, they should define "integrated software failure". Only an engineer or DJI can answer that, other than "Reverting to visual clues and manually piloting the UAS to an immediate emergency landing and utilizing a well trained VO or two? 

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"Or hitting the self destruct button"..Stop it, you're killing me :D

You are right sounds like a newbee trying to impress her/his boss with how many words can be strung together and still sound smart! Is not ALL software, since Pong, integrated with some other piece of code??

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1 hour ago, GoneCoastal said:

As luck would have it, today I finally heard back on my daylight operations waiver for class G. They need some more information, and quite frankly, I'm not sure how to respond. Any suggestions?

From their email:

Obviously, the software and controls tell us the pertinent information. But how in the world do I respond to the question about an integrated software failure??

Can you also provide the text you submitted that describes your operations? This will help us avoid duplicating info you may have already included. If you didn't keep a copy, ask them via email to provide it, shouldn't take em long. I agree with others, the term "integrated software failure" is ridiculous - taken at face value, that would imply DJI or other manufacturers deliberately embed failures into their software. However you now have to address this since they brought it up. I would try and find a good contact at DJI to see if they can provide some data or information around this topic. If you get anything, would be awesome if you could share it here.

As for the question "What information is provided on the Phantom 4 Pro’s integrated software display", I would grab a screen shot of the display while the drone is in flight during the day in unrestricted airspace and provide that photo in reply back.

Back to the other question on integrated software failure, it could be as simple as stating you would immediately land the system by either piloting the craft back home yourself or utilizing the return to home feature. Or maybe you need to explain the craft would hover in GPS mode until the software was force killed, then restarted. In this event, you would need to know what happens in advance if you force kill the DJI go app mid flight...

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1 hour ago, GoneCoastal said:

   

 

Obviously, the software and controls tell us the pertinent information. But how in the world do I respond to the question about an integrated software failure??

 

 

All of that information is provided via the DJI Go app on your tablet as you fly. In the event that the tablet fails and you lose you positional data, then that would be cause to execute a RTH function and call it a night. I think that is what they are looking for. You can always call the local FSDO and ask them too. The Fort Worth FSDO was extremely helpful to me when I was going through the process.

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To me, the failure that they are asking about sounds more like a departure from controlled flight - a complete software failure. Perhaps a fair question but one for which we can not provide an answer.  Dual controllers and receivers with dual control links? Let me back the Predator out of the garage because the ones we fly just don't have that.

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20 minutes ago, Ed O'Grady said:

To me, the failure that they are asking about sounds more like a departure from controlled flight - a complete software failure. Perhaps a fair question but one for which we can not provide an answer.  Dual controllers and receivers with dual control links? Let me back the Predator out of the garage because the ones we fly just don't have that.

Precisely! It feels like a loaded question.Total software failure sounds like an inevitable crash.

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I got another approval for airspace authorization Class D airspace at KSLI. This one had an interesting section in it that actually makes sense.

Quote

3. COORDINATION PROCEDURES:
a. The PIC must meet with the Operations Officer/Tower Chief once face to face, prior to operations in order to talk about concerns/procedures. ###-###-####
b. The PIC must call Base Ops 24 hours prior to operation in order to allow Base Ops to develop a NOTAM. ###-###-####
c. The PIC must contact the tower directly using a cell phone from the operations site prior to the start and upon completion of operations at ###-###-####. The PIC will provide a good cell phone contact number during this phone call.

This is an army airfield tower. I'm looking for suggestions on what to expect and what I should plan for when meeting face to face. Anyone do this yet? I plan on wearing dress shirt/tie, is this overkill? Am I over thinking this? =)

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I really think you can ditch the shirt and tie! "Business casual" would be my choice for sure.  I'm going to assume that those unusual requirements are simply because it's an Army airfield and I'm guessing that the contractor checked with them before granting your request.  I agree Steve that they do make a lot of sense.  Congrats!

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15 hours ago, Steve Bennett said:

I got another approval for airspace authorization Class D airspace at KSLI. This one had an interesting section in it that actually makes sense.

This is an army airfield tower. I'm looking for suggestions on what to expect and what I should plan for when meeting face to face. Anyone do this yet? I plan on wearing dress shirt/tie, is this overkill? Am I over thinking this? =)

Nice shirt; tie optional but it can't hurt. We did something similar with our local airport. They basically want to know if you have your stuff together. Take a copy of your operating procedures and make sure you have a section covering the normal stuff you would need for filing for a certificate of waiver such as a lost link sections, a detailed account of your flight profile that you are planning to fly (times, specific northing and easting, altitude, and duration if possible dependent upon weather of course). I provided a cell number (we are required to notify the tower 15 minutes prior to takeoff and upon termination of flight ops). Radio protocols should be used on the tower calls via cell as well...they appreciate you speaking their language and not wasting their time and it makes you look professional as well. Offer to file your own NOTAMs via ENII 24-48 hours beforehand if that is possible (reduces their paperwork).

Look them in the eye, smile, listen to their concerns, answer their questions, don't slouch and eat your vegetables....(the latter is purely tongue in cheek and in no way guarantees a positive outcome...but it shouldn't hurt either)

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Woohoo! Despite the FAA throwing me a curve ball, I was just approved for night ops in class G. Sorry, Steve I know you asked for details on my application, but I don't have any of it. And as much as I'd like to reach out to the FAA and request my application be sent to me, Ill just count my blessings and be happy it was approved :) 

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On 3/31/2017 at 7:41 AM, GoneCoastal said:

Woohoo! Despite the FAA throwing me a curve ball, I was just approved for night ops in class G. Sorry, Steve I know you asked for details on my application, but I don't have any of it. And as much as I'd like to reach out to the FAA and request my application be sent to me, Ill just count my blessings and be happy it was approved :) 

I felt the same way about asking for more stuff (application), didn't want to be a pest. However, my night COA, and all others, did state "1. A copy of the application made for this certificate shall be attached and become a part hereof.
2. This certificate shall be presented for inspection upon the request of any authorized representative of the
Federal Aviation Administration, or of any State or municipal official charged with the duty of enforcing local laws
or regulations." so you are pretty much required to have it with you, application and all. Seems like this was an oversight with IT when they designed the portal, probably to be fixed next version, after we have pestered them with multiple emails requesting applications.

 

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