Looking for advice on applying for airspace waiver


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My local class D airport (APF) is not currently included in the LAANC system, Airmap shows it as "automated authorization coming soon".

I would like to request for a blanket waiver to fly below the altitudes defined on the LAANC grid map.

I think that is probably too general and may not be acceptable but I thought it would be the most accurate, concise  and direct way of wording the request. Do you think this has any chance, is there a more acceptable way rather than making it lengthy and word filled?

I understand that a waiver is more difficult to get than an approval so I thought I might go for approval first and then if approved, submit a request for a waiver.

 

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Rich, I suspect that KAPF has an FAA contract Tower (FCT) rather than one that is manned by FAA employees.  Seems that these towers are not in the LAANC program and it's hard to find information on what's coming next regarding these airports. But I would not assume that the Airmap tag about "coming soon" means very much.  FAA at the moment is not prone to issuing airspace waivers as you suggested.  That does not mean you shouldn't apply for it however.  The problem comes in when you are looking to transition from one grid to another and the altitudes are different.  FAA does not really want to hear that you will do this and that to mitigate risk.  You're best shot is to apply for the lowest common denominator.  If the adjoining grids show 100/200/300 AGL altitudes, then you would be best to apply for 90 AGL.  I'm not saying you can't get more than that - just saying that might make it easier.  If you get it you can always reapply for higher.   I am constantly flying in 0 AGL grids, literally under approaches to my airport and I have never been denied yet.  I typically get approval in less that 36 hours but I make it easy on them.  If I really only need 75 AGL, that's what I ask for and get.  Even though I'm smack under a few approaches, if a manned a/c was at 75 feet then he's going into the marsh and has much bigger problems.

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First of all, there is a single 150 grid.  Wonder if that's correct - I've never seen one before.  So are you asking FAA to approve the entire area in one fell swoop? I'm assuming you are excluding the 0 grids (the red no fly grids).  My guess is very little chance of approval - almost none. My previous point was that if you were looking at, let's say, 2 adjacent grids of 100 and 200 AGL max altitudes, request 75ft.  Otherwise, you would need to show clearly how you would avoid exceeding 100 ft as you transition the adjacent grid.  Start small with 2 adjacent grids as a test.  

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Well, yes, I was hopping for one blanket waiver considering if it were included in the LAANC system it would be essentially be pre determined for manual approval at altitudes much higher than I was asking for.

I will scale this way back and ask for just a small section and see how that goes, then re apply for other areas based on my priority.

I'll redo that map and post later.

Thanks again for your great advice

 

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27 minutes ago, RichP said:

Well, yes, I was hopping for one blanket waiver considering if it were included in the LAANC system it would be essentially be pre determined for manual approval at altitudes much higher than I was asking for.

I will scale this way back and ask for just a small section and see how that goes, then re apply for other areas based on my priority.

I'll redo that map and post later.

Thanks again for your great advice

 

Based on your advise, I've revised my planned request.  Here is the map, I took 200 and 300 and plan to ask for 150.  

APF Grid Waiver 1.pdf

Edited by RichP
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The reason I suggested only applying for 2 grids is as follows from FAA: "If you make a request under Part 107.41 in the Drone Zone and ask for a wide-area or long-term authorization without an associated operational waiver, you will be sent a denial notice stating that you must apply for a specific date and location that can be reasonably flown in one day. " Let's see what happens with it.

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1 hour ago, Ed O'Grady said:

The reason I suggested only applying for 2 grids is as follows from FAA: "If you make a request under Part 107.41 in the Drone Zone and ask for a wide-area or long-term authorization without an associated operational waiver, you will be sent a denial notice stating that you must apply for a specific date and location that can be reasonably flown in one day. " Let's see what happens with it.

It says to consider using the LAANC system instead.  I would much prefer using that but it's not available for KAPF.  I'll try for the shorter authorization since that should get a response faster, if I get that then I'll submit for a waiver. Also looking at the waivers granted, there has been nothing posted for 107.41 in 2018, I don't understand that.

Edited by RichP
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20 hours ago, RichP said:

It says to consider using the LAANC system instead.  I would much prefer using that but it's not available for KAPF.  I'll try for the shorter authorization since that should get a response faster, if I get that then I'll submit for a waiver. Also looking at the waivers granted, there has been nothing posted for 107.41 in 2018, I don't understand that.

Why not just apply for the authorization and forget the waiver. The authorization is more likely to be approved and a whole lot sooner than a waiver would be. You get the same thing almost; an authorization allows you to operate in the airspace as long as you adhere to the existing regulations whereas a waiver grants you the ability to ignore a written regulation provided that you prove to the FAA you can do it in a safe manner to their satisfaction. I know locally that wide area authorizations are being approved without any problems. Waiver, are another story.

For a wide area authorization you are going to have to follow the altitude restrictions on the UAS Facilities map for your airspace. If you want to deviate from those restrictions you are going to need a waiver. If, on the other hand, you just want to fly and the altitudes for each grid are not a problem then by all means, save yourself the grief and apply for airspace authorization.

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@R Martin, at least in my area, that's not completely correct.  Now, for a moment, let's make certain that semantics are not getting in the way.  I use Skyward as the pathway to LAANC and made about 40 requests in the last 60 days.  In every case, "manual authorization" was required because I was requesting to fly higher than the grids indicated.  All requests, by coincidence, were in 0 AGL grids AND all requests were in locations approx 1.7 to 1.8 miles from 2 different runways, AND all were directly under the approach to those runways.  Now, a few of these requests "timed out".  That is, FAA did not respond to Skyward within 24 hours of the operation so about 5 of these requests were cancelled.  None were denied and all others were approved.  In terms of timing, just this morning I received another authorization for one of those areas that was only submitted at 2:58 pm local time yesterday.  The FAA facility responsible for my area is Jacksonville ARTCC and maybe I'm just lucky to have them but I really couldn't ask for more, given the FAA guidelines.  But the key is that in a 0 AGL grid, I ask for 75 feet and I get it.  300 feet would get rejected I'm sure given the approach to these runways. 

Edited by Ed O'Grady
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My main area is not served by LAANC. I'm still under an FCT in Class D airspace so I'm still filing the old school way. By the time LAANC is added to this airport, I'll be involved in the construction of a new campus in (woot) uncontrolled airspace and I won't have to worry about any stinkin' authorization.

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Well I applied for an authorization for a small area and asked for an altitude far below the grid number. I’m thinking that if it doesn’t get approved it would be for reasons other than altitude. The only thing I thought of afterwards was I could have added that I would monitor ATC while flying however my guess is that most requests don’t include that capability unless they are in a more sensitive area. So, time will tell. 

I appreciate the advice from all the experienced pilots, it’s been very helpful. 

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  • 3 weeks later...
On 9/25/2018 at 10:31 AM, Ed O'Grady said:

The reason I suggested only applying for 2 grids is as follows from FAA: "If you make a request under Part 107.41 in the Drone Zone and ask for a wide-area or long-term authorization without an associated operational waiver, you will be sent a denial notice stating that you must apply for a specific date and location that can be reasonably flown in one day. " Let's see what happens with it.

Thanks very much for your help Ed, my waiver was approved today! I’m sure if not for your experience and guidance, I would not have been successful on my first try.

 

Thanks again 

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On 9/25/2018 at 7:10 AM, RichP said:

That great, thanks!

So what I did was to take the KAPF facility map grid and color coded it as I've seen in approved waivers.

I put all

0 grids as NFZ,

100, 150 = 75'

200  = 150'

300, 400 =200'

Do you think that is okay or is that too many zones?

 

APF Grid Waiver.pdf

Instead of making this more complicated than necessary, just ask for a wide-area authorization for KAPF's airspace. That has been the trend lately after LAANC went live. The FAA will require you to adhere to the altitude restrictions of the UAS Facilities map they have on the Cloud. You will not be able to fly in any of the zero altitude grids without additional authorization. You will not be able to exceed the posted grid altitude for any reason unless authorized to do so (ie. you will not be able to add the 400' bubble to a tower height). The grid altitude is the absolute limit without additional authorization.

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