Experimental Certificate Granted UAV If MAC "Extremely Improbable"!

On Sun, 24 Feb 2008 15:02:40 -0500, "John T"
wrote in
:

"Larry Dighera" wrote in message


But it seems the police want to fly them over
the heads of urban dwellers. What is the safeguard against this UAV
hitting someone in the event of an engine or guidance or control
failure or fuel exhaustion? I am unable to imagine a safeguard
against that sort of scenario.

Larry, you're not asking reasonable questions.

I don't agree. You are aware that the Honeywell MAV is solely
dependent on the continuous operation of its ducted fan for support,
right?

To demonstrate, let's change just a couple words and see how you would respond:

"What is the safeguard against a GA plane hitting someone in the event of an
engine or guidance or control failure or fuel exhaustion?"

FAA regulations mandate that human piloted aircraft must remain 1,000'
feet above congested areas, and within gliding distance of a landing
site. This UAV doesn't glide, and the police department intends to
fly it at low level. We're talking about two different classes
(apples/oranges) of vehicles; comparing them doesn't seem valid to me.

I'll point to the recent crash in Sanford, FL and two crashes in Leesburg,
VA in the last several years as quick and ready evidence not flattering to
GA. The NTSB database has many more.

I'm not familiar with those. If you're going to cite them as
supporting your assertion, perhaps you'll be kind enough to relate
their specifics, or provide links. Thank you.

But personally, I don't believe it's valid to compare UAVs with the
majority of current aircraft operating in the NAS, because it doesn't
seem UAV operations are being held to the same standards, nor do they
have the same capabilities or potential consequences to their
operators. Further, the FAA doesn't even permit model aircraft to
operate like the police departments intend to use UAVs:


http://rgl.faa.gov/Regulatory_and_Gu...High light=91
3 0 OPERATING STANDARDS.
a. Select an operating site that is of sufficient distance from
populated areas. The selected site should be away from noise
sensitive areas such as parks, schools, hospitals, churches, etc.

We're not talking about automated systems here. Humans are at the controls
of the UAVs and the planes.

Will those humans operating UAVs hold airmen certificates? Will those
humans be exposed to losing their lives if their piloting causes a MAC
or crash? It's a lot different that manned aircraft.

John, I know you're a bright guy if you're making a living as an
independent consultant, but for some reason it seems like you aren't
truly appreciating the issue. Did you read any of the information in
my original article in this thread? Or is it me? Is there something
I'm overlooking?

I'll grant it's harder for the UAV pilot to avoid ground structures due to
limited field of vision,

It is my understanding, that currently the FAA requires a ground
observer or a chase plane, in addition to the person controlling the
UAV, so the UAV pilot doesn't have to have complete situational
awareness; but the team does, of course.

but the size and speed of the UAVs also make the risk they present much
lower than that of our GA planes.

That depends on the particular UAV under discussion. The Honeywell
MAV does not glide, so it can't comply with:


http://ecfr.gpoaccess.gov/cgi/t/text...1.3.10&idno=14
CFE Title 14: Aeronautics and Space
PART 91—GENERAL OPERATING AND FLIGHT RULES
§ 91.119 Minimum safe altitudes: General.
Except when necessary for takeoff or landing, no person may
operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an
emergency landing without undue hazard to persons or property on
the surface.

(b) Over congested areas. Over any congested area of a city, town,
or settlement, or over any open air assembly of persons, an
altitude of 1,000 feet above the highest obstacle within a
horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above
the surface, except over open water or sparsely populated areas.
In those cases, the aircraft may not be operated closer than 500
feet to any person, vessel, vehicle, or structure.


So my question is, why should a UAV, that lacks a human occupant who
is exposed to harm in the event of a mishap (unlike UAV operators who
are not aboard the UAV obviously), and lacks the capabilities to
comply with current FARs, be permitted to violate current FARs?

It doesn't make any sense to me, but I'll bet it has everything to do
with potential corporate profit. If true, that not a good reason to
increase the risk to the public, IMNSHO.

"Larry Dighera" wrote in message


...and within gliding distance of a landing site.

Which regulation are you quoting here?

I can think of many metro areas (not to mention wilderness) where 1000' will
not put you anywhere near a suitable landing site but, of course, *any* site
receiving an aircraft becomes a landing site.

--
John T
http://sage1solutions.com/blogs/TknoFlyer
http://sage1solutions.com/products
NEW! FlyteBalance v2.0 (W&B); FlyteLog v2.0 (Logbook)
____________________

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.

Andrew Sarangan wrote:
When a human pilot is on board, there is a strong incentive for not
crashing. Unless the pilot is suicidal, we can expect the pilot to do
everything humanly possible to avoid crashing. That same incentive
does not exist in UAVs. The worst thing that can happen to a UAV crash
pilot is that he may lose his job, not his life. No matter how
conscientious the UAV pilot may be, there is a huge difference between
paying for your mistakes with your life vs facing disciplinary action.

There are a class of unmanned operations covered by Part 101, "MOORED
BALLOONS, KITES, UNMANNED ROCKETS AND UNMANNED FREE BALLOONS" wherein it
has always been the case that the instinct for self-preservation was never
a motivation for safe operation of those craft. Yet none of them are
outright banned so I don't see why Part 101 can't be modified to include
UAVs.

On Sun, 24 Feb 2008 17:03:51 -0500, "John T"
wrote in
:

"Larry Dighera" wrote in message


...and within gliding distance of a landing site.

Which regulation are you quoting here?


http://ecfr.gpoaccess.gov/cgi/t/text...1.3.10&idno=14
CFE Title 14: Aeronautics and Space
PART 91—GENERAL OPERATING AND FLIGHT RULES
§ 91.119 Minimum safe altitudes: General.
Except when necessary for takeoff or landing, no person may
operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an
emergency landing without undue hazard to persons or property on
the surface.

(b) Over congested areas. Over any congested area of a city, town,
or settlement, or over any open air assembly of persons, an
altitude of 1,000 feet above the highest obstacle within a
horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above
the surface, except over open water or sparsely populated areas.
In those cases, the aircraft may not be operated closer than 500
feet to any person, vessel, vehicle, or structure.



I can think of many metro areas (not to mention wilderness) where 1000' will
not put you anywhere near a suitable landing site but, of course, *any* site
receiving an aircraft becomes a landing site.

"Larry Dighera" wrote in message


"Larry Dighera" wrote in message


...and within gliding distance of a landing site.

Which regulation are you quoting here?

http://ecfr.gpoaccess.gov/cgi/t/text...1.3.10&idno=14
CFE Title 14: Aeronautics and Space
PART 91-GENERAL OPERATING AND FLIGHT RULES
§ 91.119 Minimum safe altitudes: General.

Your entire quote was: "Human piloted aircraft must remain 1,000' feet above
congested areas, and within gliding distance of a landing site."

Your justification for that was a description of minimum altitudes, not a
restriction to be withing gliding distance of a landing site.

Is there another reg stipulating such a restriction?

--
John T
http://sage1solutions.com/blogs/TknoFlyer
http://sage1solutions.com/products
NEW! FlyteBalance v2.0 (W&B); FlyteLog v2.0 (Logbook)
____________________

"Larry Dighera" wrote in message


FAA regulations mandate that human piloted aircraft must remain 1,000'
feet above congested areas, and within gliding distance of a landing
site. This UAV doesn't glide, and the police department intends to
fly it at low level. We're talking about two different classes
(apples/oranges) of vehicles; comparing them doesn't seem valid to me.

Larry, you're either more obtuse than I give you credit for or you're just
trying to fan the flames of some arbitrary argument in an effort to pump a
modicum of on-topic discussion into this forum.

I'll trust for the moment it's the latter, but I still have to ask: Do
helicopters not qualify for GA status? Do they glide? Do their flight
characteristics differ substantially from this UAV?

See the other sub-thread regarding your claim of a requirement to be within
gliding distance of a landing site. I have yet to see the evidence of
anything but a restriction on altitudes.

--
John T
http://sage1solutions.com/blogs/TknoFlyer
http://sage1solutions.com/products
NEW! FlyteBalance v2.0 (W&B); FlyteLog v2.0 (Logbook)
____________________

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?

On Sun, 24 Feb 2008 18:11:05 -0500, "John T"
wrote in
:

"Larry Dighera" wrote in message


"Larry Dighera" wrote in message


...and within gliding distance of a landing site.

Which regulation are you quoting here?

http://ecfr.gpoaccess.gov/cgi/t/text...1.3.10&idno=14
CFE Title 14: Aeronautics and Space
PART 91-GENERAL OPERATING AND FLIGHT RULES
§ 91.119 Minimum safe altitudes: General.

Your entire quote was: "Human piloted aircraft must remain 1,000' feet above
congested areas, and within gliding distance of a landing site."

Your justification for that was a description of minimum altitudes, not a
restriction to be withing gliding distance of a landing site.


Well, when I fly low over Los Angeles, I take gliding distance into
consideration, but you've managed to find a nit. If that is the only
one you found, is it safe to assume you agreed with the remainder of
my follow up article?

Is there another reg stipulating such a restriction?

I'm not sure.

On Sun, 24 Feb 2008 18:22:11 -0500, "John T"
wrote in
:

"Larry Dighera" wrote in message


FAA regulations mandate that human piloted aircraft must remain 1,000'
feet above congested areas, and within gliding distance of a landing
site. This UAV doesn't glide, and the police department intends to
fly it at low level. We're talking about two different classes
(apples/oranges) of vehicles; comparing them doesn't seem valid to me.

Larry, you're either more obtuse than I give you credit for or you're just
trying to fan the flames of some arbitrary argument in an effort to pump a
modicum of on-topic discussion into this forum.


Well, it does seem that we are talking past each other. I assure you,
I'm sincere in my discussion of this subject for its own value. I'm
genuinely concerned that UAVs may become a hazard if there is not
input from all NAS stakeholders into the FAA's rulemaking.

I'll trust for the moment it's the latter, but I still have to ask: Do
helicopters not qualify for GA status? Do they glide? Do their flight
characteristics differ substantially from this UAV?


Helicopters are capable of controlled flight (autorotation) in the
event of a power failure. The Honeywell MAV also flies in the event
its power plant fails: like a piano. :-)