Experimental Certificate Granted UAV If MAC "Extremely Improbable"!

Larry Dighera wrote:
What distinguishes UAVs from manned
aircraft is their inability to comply with a fundamental cornerstone
of flight operations: see-and-avoid.

"See-and-avoid" is not a fundamental cornerstone of flight ops; at least
not by my definition of "fundamental". A specific counterexample appears to
be unmanned free balloons, which cannot meaningfully engage in "see-and-
avoid" yet are not limited to SUA. (At least I don't believe so.)

If you think existing aspects of Part 101 should be applied and otherwise
modified to SUA operations in the NAS I'd agree with you.

My own assertion is this: in any list of priorities that drive air
safety, regulation of UAVs is overkill and even takes time, money, and
resources away from dealing with higher probability risks.

I'm not sure I completely understand your point. You're not saying
that the FAA shouldn't regulated UAVs flown in the NAS are you?

No.

On Sun, 24 Feb 2008 22:05:16 -0000, Jim Logajan
wrote in :

Larry Dighera wrote:
What distinguishes UAVs from manned
aircraft is their inability to comply with a fundamental cornerstone
of flight operations: see-and-avoid.

"See-and-avoid" is not a fundamental cornerstone of flight ops; at least
not by my definition of "fundamental".

"See-and-avoid" is fundamental for VMC operations of aircraft.
Consider the NORDO Cub. There's nothing separating him from other
flights except his situational awareness and perhaps the
Big-sky-theory (fortune).

A specific counterexample appears to
be unmanned free balloons, which cannot meaningfully engage in "see-and-
avoid" yet are not limited to SUA. (At least I don't believe so.)

Thanks for the input. It shows you can think outside the box, but I'm
not sure paragraphs 'd' and 'e' supports your point however:


http://ecfr.gpoaccess.gov/cgi/t/text...2.0 .1.3.15.4
Title 14: Aeronautics and Space
PART 101—MOORED BALLOONS, KITES, UNMANNED ROCKETS AND UNMANNED
FREE BALLOONS
Subpart D—Unmanned Free Balloons

§ 101.33 Operating limitations.
No person may operate an unmanned free balloon—

(a) Unless otherwise authorized by ATC, below 2,000 feet above the
surface within the lateral boundaries of the surface areas of
Class B, Class C, Class D, or Class E airspace designated for an
airport;

(b) At any altitude where there are clouds or obscuring phenomena
of more than five-tenths coverage;

(c) At any altitude below 60,000 feet standard pressure altitude
where the horizontal visibility is less than five miles;

(d) During the first 1,000 feet of ascent, over a congested area
of a city, town, or settlement or an open-air assembly of persons
not associated with the operation; or

(e) In such a manner that impact of the balloon, or part thereof
including its payload, with the surface creates a hazard to
persons or property not associated with the operation.


Recall, the Dade County and Houston police departments intend to
operate the Honeywell MAV over their metropolitan areas to support
SWAT teams and issue traffic citations, so that would probably
necessitate their operation below 1,000'. And if the MAV engine quits
over a populated area, it wouldn't be able to comply with paragraph
'e' either.

If you think existing aspects of Part 101 should be applied and otherwise
modified to SUA operations in the NAS I'd agree with you.


I hadn't even considered Part 101. How would you propose to modify
Part 101?

Larry Dighera wrote:
Jim Logajan wrote:
If you think existing aspects of Part 101 should be applied and
otherwise modified to SUA operations in the NAS I'd agree with you.

I hadn't even considered Part 101. How would you propose to modify
Part 101?

Since it already includes regulations on other unmanned aircraft Part 101
seems the natural place to insert regulations on UAVs. Unfortunately I
don't have time to write up a coherent set of proposed changes to Part 101
that might satisfy both our concerns - and even if I did I don't see how it
would serve any useful purpose other than a thought exercise.

On Mon, 25 Feb 2008 04:42:36 -0000, Jim Logajan
wrote in :

Larry Dighera wrote:
Jim Logajan wrote:
If you think existing aspects of Part 101 should be applied and
otherwise modified to SUA operations in the NAS I'd agree with you.

I hadn't even considered Part 101. How would you propose to modify
Part 101?

Since it already includes regulations on other unmanned aircraft Part 101
seems the natural place to insert regulations on UAVs. Unfortunately I
don't have time to write up a coherent set of proposed changes to Part 101
that might satisfy both our concerns - and even if I did I don't see how it
would serve any useful purpose other than a thought exercise.

Well, you could provide a paper for this NTSB UAV meeting:


NTSB TO HOLD SAFETY FORUM ABOUT UNMANNED AIRCRAFT
http://www.ntsb.gov/Pressrel/2008/080303.html
(http://www.avweb.com/eletter/archive...ll.html#197303)
The growing use of unmanned aircraft systems (UAS) in the National
Airspace System is raising a number of safety concerns, and the
NTSB said this week it will address them all in a three-day forum,
April 29 to May 1, in Washington, D.C. The forum will provide an
opportunity for the board and interested parties to discuss
issues such as regulatory standards, perspectives of current UAS
operators, certification and airworthiness, perspectives of
current users of the National Airspace System (that would be all
of us), and future UAS applications. The forum is a result of the
safety board's investigation into the crash of a Predator B
unmanned aircraft near Nogales, Ariz., in April 2006. "The Nogales
accident* surfaced a number of important questions that need to be
addressed if UAS's are to operate safely in the National Air
Space," said board member Kitty Higgins, who will chair the forum.
The Board's investigation of the Nogales accident resulted in 22
safety recommendations to address deficiencies associated with the
civilian use of unmanned aircraft. "We are very interested in the
military's experience with UAS's, training of pilots, maintenance
of the aircraft, communication with Air Traffic Control and
oversight of UAS operations by public-use agencies and other
operators," Higgins said.

Or we could each write one or the group could contribute their
thoughts for a group submission.




http://www.ntsb.gov/Pressrel/2008/080303.html
FOR IMMEDIATE RELEASE: March 3 , 2008 SB-08-07

NTSB TO HOLD SAFETY FORUM ON UNMANNED AIRCRAFT SYSTEMS
--------------------------------------------------------------------------------

Washington, D.C. - The National Transportation Safety Board will hold
a three-day forum on the safety of unmanned aircraft systems (UAS).
The forum will be convened April 29 to May 1 in the NTSB Board Room
and Conference Center in Washington. The forum will provide an
opportunity for the Board and interested parties to understand the
safety implications presented by the growing use of UAS in the
National Airspace System.

Issues addressed will include:

- Regulatory standards,
- Integration with the National Airspace System,
- Perspectives of current UAS operators,
- Design, certification and airworthiness,
- Human factors,
- Future UAS applications and perspectives of current
users of the National Airspace System.

The forum is a result of the Safety Board's investigation into a
Predator B unmanned aircraft that crashed near Nogales, Arizona, in
April 2006. The Board's October 2007 meeting on this accident
resulted in 22 safety recommendations to address deficiencies
associated with the civilian use of unmanned aircraft.

"The Nogales accident surfaced a number of important questions that
need to be addressed if UAS's are to operate safely in the National
Air Space," said Board Member Kitty Higgins, who will chair the forum.
"We are very interested in the military's experience with UAS's,
training of pilots, maintenance of the aircraft, communication with
Air Traffic Control and oversight of UAS operations by public use
agencies and other operators."

The forum will include representatives from the military, industry,
the FAA, and government agencies involved in UAS operations.
Interested members of the aviation community and general public are
encouraged to attend. A forum agenda will be announced by press
release in mid-April.

Representatives from the UAS industry are invited to set up display
booths and unmanned aircraft vehicle scale models that demonstrate
unmanned aircraft systems and technologies. Display space is limited
and will be allocated on a first-come, first served basis.

Organizations interested in setting up a display should contact Mr.
Daniel Bartlett at the NTSB at with their
specific requirements no later than March 28, 2008. Requests for
display space after this date cannot be accommodated.

A live and archived webcast of the forum will be available on the
Board's web site at www.ntsb.gov.

NTSB Public Affairs: Peter Knudson (202) 314-6100







* http://www.ntsb.gov/ntsb/brief.asp?e...09X00531&key=1
NTSB Identification: CHI06MA121.
The docket is stored in the Docket Management System (DMS). Please
contact Records Management Division
14 CFR Public Use
Accident occurred Tuesday, April 25, 2006 in Nogales, AZ
Probable Cause Approval Date: 10/31/2007
Aircraft: General Atomics Predator B, registration: None
Injuries: 1 Uninjured.
The unmanned aircraft (UA), a Predator B, collided with the terrain
following a loss of engine power while patrolling the southern U.S.
border on a Customs and Border Protection (CPB) mission.

The UA's takeoff was delayed due to the inability to establish a
communication link between the UA and Pilot Payload Operator (PPO)-1
console during initial power-up. After troubleshooting the problem, an
avionics technician switched the main processor cards between PPO-1
and PPO-2. Personnel who were maintaining the unmanned aircraft system
(UAS) stated there were very few spare parts purchased with the UAS,
which is why they switched the main processor cards instead of
replacing the card in PPO-1. The link was subsequently established,
and the flight was initiated.

The flight was being flown from a ground control station (GCS), which
contained two nearly identical control consoles: PPO-1 and PPO-2.
Normally, a certified pilot controls the UA from PPO-1, and the camera
payload operator (typically a U.S. Border Patrol agent) controls the
camera, which is mounted on the UA, from PPO-2. Although the aircraft
control levers (flaps, condition lever, throttle, and speed lever) on
PPO-1 and PPO-2 appear identical, they may have different functions
depending on which console controls the UA. When PPO-1 controls the
UA, movement the condition lever to the forward position opens the
fuel valve to the engine; movement to the middle position closes the
fuel valve to the engine, which shuts down the engine; and movement to
the aft position causes the propeller to feather. When the UA is
controlled by PPO-1, the condition lever at the PPO-2 console controls
the camera's iris setting. Moving the lever forward increases the iris
opening, moving the lever to the middle position locks the camera's
iris setting, and moving the lever aft decreases the opening.
Typically, the lever is set in the middle position.

Console lockup checklist procedures indicate that, before switching
operational control between the two consoles, the pilot must match the
control positions on PPO?2 to those on PPO-1 by moving the PPO-2
condition lever from the middle position to the forward position,
which keeps the engine operating. The pilot stated in a postaccident
interview that, during the flight, PPO-1 locked up, so he switched
control of the UA to PPO-2. In doing so, he did not use the checklist
and failed to match the position of the controls on PPO-2 to how they
were set on PPO-1. This resulted in the condition lever being in the
fuel cutoff position when the switch to PPO-2 was made, and the fuel
supply to the engine was shut off.

With no engine power, the UA began to descend. The pilot realized that
the UA was not maintaining altitude but did not immediately identify
that the condition lever was in the fuel cutoff position. The pilot
and avionics technician decided to shut down the entire system and
send the UA into its lost-link profile, which is a predetermined
autonomous flightpath, until they could figure out what the problem
was. After the system was shut down, the UA descended below line of
sight (LOS), and communications could not be reestablished. The UA
began to fly its lost-link profile as it descended to impact with the
terrain.

When the UA lost engine power, it began to operate on battery power.
On battery power, the UA began to shed electrical equipment to
conserve electrical power. In doing so, electrical power to the
transponder was shut down. This resulted in air traffic control not
being able to detect a Mode C transponder return for the UA as it
descended below the bottom of the temporary flight restricted
airspace. The primary radar return was also lost when the UA descended
below the LOS in the mountainous area.

The investigation revealed a series of computer lockups had occurred
since the CBP UAS began operating. Nine lockups occurred in a 3-month
period before the accident, including 2 on the day of the accident
before takeoff and another on April 19, 2006, 6 days before the
accident. Troubleshooting before and after the accident did not
determine the cause of the lockups. Neither the CBP nor its
contractors had a documented maintenance program that ensured that
maintenance tasks were performed correctly and that comprehensive
root-cause analyses and corrective action procedures were required
when failures, such as console lockups, occurred repeatedly.

Review of the CBP's training records showed that the accident pilot
had recently transitioned from flying the Predator A to flying the
Predator B and had only 27 hours of Predator B flight time. According
to the CBP, the pilot was given verbal approval to fly its Predator B
with the caveat that the pilot's instructor would be present in the
GCS when the pilot was flying. This verbal approval was not standard
practice for the CBP. The instructor pilot was in another building on
the airport and did not enter the GCS until after it was shut down and
the UA entered the lost-link procedure.

The investigation also revealed that the CBP was providing a minimal
amount of operational oversight for the UAS program at the time of the
accident.



The National Transportation Safety Board determines the probable
cause(s) of this accident as follows:

The pilot's failure to use checklist procedures when switching
operational control from PPO-1 to PPO-2, which resulted in the fuel
valve inadvertently being shut off and the subsequent total loss of
engine power, and lack of a flight instructor in the GCS, as required
by the CBP's approval to allow the pilot to fly the Predator B.
Factors associated with the accident were repeated and unresolved
console lockups, inadequate maintenance procedures performed by the
manufacturer, and the operator's inadequate surveillance of the UAS
program.

Full narrative available
NTSB Identification: CHI06MA121.
The docket is stored in the Docket Management System (DMS). Please contact Records Management Division
14 CFR Public Use
Accident occurred Tuesday, April 25, 2006 in Nogales, AZ
Probable Cause Approval Date: 10/31/2007
Aircraft: General Atomics Predator B, registration: None
Injuries: 1 Uninjured.
The unmanned aircraft (UA), a Predator B, collided with the terrain following a loss of engine power while patrolling the southern U.S. border on a Customs and Border Protection (CPB) mission.

The UA's takeoff was delayed due to the inability to establish a communication link between the UA and Pilot Payload Operator (PPO)-1 console during initial power-up. After troubleshooting the problem, an avionics technician switched the main processor cards between PPO-1 and PPO-2. Personnel who were maintaining the unmanned aircraft system (UAS) stated there were very few spare parts purchased with the UAS, which is why they switched the main processor cards instead of replacing the card in PPO-1. The link was subsequently established, and the flight was initiated.

The flight was being flown from a ground control station (GCS), which contained two nearly identical control consoles: PPO-1 and PPO-2. Normally, a certified pilot controls the UA from PPO-1, and the camera payload operator (typically a U.S. Border Patrol agent) controls the camera, which is mounted on the UA, from PPO-2. Although the aircraft control levers (flaps, condition lever, throttle, and speed lever) on PPO-1 and PPO-2 appear identical, they may have different functions depending on which console controls the UA. When PPO-1 controls the UA, movement the condition lever to the forward position opens the fuel valve to the engine; movement to the middle position closes the fuel valve to the engine, which shuts down the engine; and movement to the aft position causes the propeller to feather. When the UA is controlled by PPO-1, the condition lever at the PPO-2 console controls the camera's iris setting. Moving the lever forward increases the iris opening, moving the lever to
the middle position locks the camera's iris setting, and moving the lever aft decreases the opening. Typically, the lever is set in the middle position.

Console lockup checklist procedures indicate that, before switching operational control between the two consoles, the pilot must match the control positions on PPO?2 to those on PPO-1 by moving the PPO-2 condition lever from the middle position to the forward position, which keeps the engine operating. The pilot stated in a postaccident interview that, during the flight, PPO-1 locked up, so he switched control of the UA to PPO-2. In doing so, he did not use the checklist and failed to match the position of the controls on PPO-2 to how they were set on PPO-1. This resulted in the condition lever being in the fuel cutoff position when the switch to PPO-2 was made, and the fuel supply to the engine was shut off.

With no engine power, the UA began to descend. The pilot realized that the UA was not maintaining altitude but did not immediately identify that the condition lever was in the fuel cutoff position. The pilot and avionics technician decided to shut down the entire system and send the UA into its lost-link profile, which is a predetermined autonomous flightpath, until they could figure out what the problem was. After the system was shut down, the UA descended below line of sight (LOS), and communications could not be reestablished. The UA began to fly its lost-link profile as it descended to impact with the terrain.

When the UA lost engine power, it began to operate on battery power. On battery power, the UA began to shed electrical equipment to conserve electrical power. In doing so, electrical power to the transponder was shut down. This resulted in air traffic control not being able to detect a Mode C transponder return for the UA as it descended below the bottom of the temporary flight restricted airspace. The primary radar return was also lost when the UA descended below the LOS in the mountainous area.

The investigation revealed a series of computer lockups had occurred since the CBP UAS began operating. Nine lockups occurred in a 3-month period before the accident, including 2 on the day of the accident before takeoff and another on April 19, 2006, 6 days before the accident. Troubleshooting before and after the accident did not determine the cause of the lockups. Neither the CBP nor its contractors had a documented maintenance program that ensured that maintenance tasks were performed correctly and that comprehensive root-cause analyses and corrective action procedures were required when failures, such as console lockups, occurred repeatedly.

Review of the CBP's training records showed that the accident pilot had recently transitioned from flying the Predator A to flying the Predator B and had only 27 hours of Predator B flight time. According to the CBP, the pilot was given verbal approval to fly its Predator B with the caveat that the pilot's instructor would be present in the GCS when the pilot was flying. This verbal approval was not standard practice for the CBP. The instructor pilot was in another building on the airport and did not enter the GCS until after it was shut down and the UA entered the lost-link procedure.

The investigation also revealed that the CBP was providing a minimal amount of operational oversight for the UAS program at the time of the accident.

The National Transportation Safety Board determines the probable cause(s) of this accident as follows:

The pilot's failure to use checklist procedures when switching operational control from PPO-1 to PPO-2, which resulted in the fuel valve inadvertently being shut off and the subsequent total loss of engine power, and lack of a flight instructor in the GCS, as required by the CBP's approval to allow the pilot to fly the Predator B. Factors associated with the accident were repeated and unresolved console lockups, inadequate maintenance procedures performed by the manufacturer, and the operator's inadequate surveillance of the UAS program.

Full narrative available
http://www.ntsb.gov/ntsb/GenPDF.asp?...06MA121&rpt=fa
http://www.ntsb.gov/ntsb/GenPDF.asp?...06MA121&rpt=fi