Welcome to Lesson 6! In this module, you will become familiar with the current FAA regulations that govern UAS operations and the ongoing efforts to integrate their operations into the National Airspace System (NAS). On top of it are the latest rules known as PART 107. You will also explore the current recreational versus public or commercial operations of UAS, be familiar with the Certificate of Authorization (COA), Certificate of Waiver, and Airworthiness certificate and how to apply for one, and examine issues related to privacy that are of concern to both the government and industry. You will be asked to choose your application materials and organize them for your COA or Part 107 waiver application. The COA/Part 107 waiver project includes a few graded components that will be submitted in the different sections of the lesson. During this lesson, you will be engaged in discussions with fellow students on several topics related to the lesson objectives. Participation in these discussions is mandatory wherever it is requested.

Lesson Objectives

At the successful completion of this lesson, you should be able to:

• recognize the differences between standards and regulations;
• describe the rules and regulations associated with operating a UAS in the United States of America;
• interpret the FAA restrictions on operating a UAS for commercial use; and
• prepare an application for Certificate of Authorization (COA) or PART107 Certificate of Waiver.

Lesson Readings

• Sections 3.1 and 3.2 of Watts, et al., "Unmanned Aircraft Systems in Remote Sensing and Scientific Research: Classification and Considerations of Use [1]"
• Read the FAA "Literature Review on Detect, Sense, and Avoid Technology for Unmanned Aircraft Systems [2]
• Chapter 5 of textbook 1: Barnhart, et al., Introduction to Unmanned Aircraft Systems, 2nd edition

Review the following:

• Review the FAA  "Integration of Civil Unmanned Aircraft Systems (UAS) in the National Airspace System (NAS): Roadmap. [3]"
• Review the FAA "Model Aircraft Operating Standards. [4]"
• Review the FAA "Notice of proposed rulemaking (NPRM) [5]."
• Review PART 107 [6] “Operation and Certification of Small Unmanned Aircraft Systems.” 
• Review the article "What You Need to Know to Legally Operate Your Drone Under New FAA Regulation." [7]
• Review the FAA "National Policy on the Unmanned Aircraft Systems (UAS) Operational Approval. [8]"
• Review sample of  PART107 Certificate of Waiver [9].
• Review several COAs issued by the FAA. [10] 
• Review the information provided in this COA information template document [11]before completing your COA application.
• Review the samples of issued COAs that is provided to you under the "Example_COAs_from_FAA" in the Modules section.

Lesson Activities

• Participate in the "Differences between Rules and Regulations discussion forum."
• Start working on the "COA application draft."
• Submit your results for exercise 1 data processing in Pix4D.
• Continue processing the dataset for exercise 2 using Pix4D software.
• Complete the Lesson 6 Quiz.

The Federal Aviation Administration (FAA) was created in 1958 in response to a series of fatal accidents and midair collisions involving commercial aircraft. The FAA was mandated to develop plans and policies for the use of navigable airspace to ensure the safety of aircraft and the efficient use of airspace. Prescribed air traffic regulations should cover the flight of aircraft (such as safe altitudes) for navigating, protecting, and identifying aircraft; protecting individuals and property on the ground; using the navigable airspace efficiently; and preventing collision between aircraft, between aircraft and land or water vehicles, and between aircraft and airborne objects.

Since the creation of the FAA, American airspace has become one of the most regulated fields in the United States. With the introduction of UASs, the FAA has had to examine and ensure that these pilotless aircraft can operate safely and meet all the above mentioned regulations. The NAS is already congested with piloted aircraft, and adding a swarm of UAVs requires thoughtful planning. The FAA's main mandate is to ensure that UASs do not endanger current users of the NAS (including manned or other unmanned aircraft) nor compromise the safety of the people and property on the ground.

When it comes to the safe operation and integration of the UAS into the NAS, one of the main concerns that the FAA has is the lack of detect, sense, and avoid capability of the current UAS technology. The FAA did a thorough literature review to stand on what is possible and what is not along this line. The article listed in the reading assignment of this section details the FAA quest for the detect, sense, and avoid possibilities.

In this section, you will explore the current regulations that govern UAS operations and the efforts underway to integrate their operations into the National Airspace System (NAS). The status of UAS regulations can be considered in relation to two different eras. The first one preceded the provisions of the FAA Modernization and Reform Act of 2012 (P.L. 112-95), and the second is what we are currently dealing with after the 2012 provision. During both eras, the FAA regulations on operating a UAS in NAS were very strict and in fact prohibited civilians from flying UASs until Part 107 went into effect on August 29, 2016. In 2008, The Aviation Safety Unmanned Aircraft Program Office (UAPO) of the FAA issued the Interim Operational Approval Guidance 08-01. “Interim Operational Approval Guidance, Unmanned Aircraft Systems Operations in the U. S. National Airspace System” provided guidance to help determine if unmanned aircraft systems (UAS) should be allowed to conduct flight operations in the U. S. national airspace system (NAS). On July 30, 2013, the FAA issued a national policy (N 8900.227) for reviewing and evaluating the safety and interoperability of proposed Unmanned Aircraft Systems (UAS) flight operations conducted within the United States (U.S.) National Airspace System (NAS) under the subject “Unmanned Aircraft Systems (UAS) Operational Approval.” The new national policy defined in details the methods of the UAS operational approval through the issuance of either a COA for public aircraft operations or a Special Airworthiness Certificate for civil operations. All guidelines and regulations are jointly developed by the following entities within the FAA:

• the Unmanned Aircraft Program Office (UAPO), FAA Aircraft Certification Service (AIR-160)
• the Production and Airworthiness Division, FAA Aircraft Certification Service (AIR-200)
• the Flight Technologies and Procedures Division, FAA Flight Standards Service (AFS-400)
• the FAA Air Traffic Organization’s Office of System Operations and Safety, (AJR-3)

Originally, the Certificate of Authorization, or COA, was limited to public agencies and no commercial agency was granted a COA. Even for public agencies, COA cannot be guaranteed, and COAs may take different lengths of time or have some restrictions built in, according to the FAA document N 8900.227, which states “because of the uniqueness of various UAS flight operations, each application must be evaluated on its own technical merits, including operational risk management (ORM) planning. Each application may require unique authorizations or limitations directly related to the specific needs or capabilities of the UAS and/or the proposed specific mission and operating location.”. However, during 2015, the FAA started issuing grants exemption for commercial entities to fly UAS for commercial use under strict limitations.  The FAA based such grant exemption on section 333 of the FAA Modernization and Reform Act of 2012. [12]  An exemption according to section 333, allows commercial companies to fly UAS, after they apply for COA, of course, for commercial use. Even with the heavy restrictions that surrounded these exemptions, the move was welcomed by companies who are planning to use UAS for various commercial tasks, and it was considered to be the baby step that they were waiting for.

The previous surprising move by the FAA was followed by three unprecedented moves.

As you may have noticed from the materials you reviewed in the previous section, no one is allowed to fly a UAS without prior approval from the FAA. Any UAS operation in the United States has to occur in one of two ways. Either the UAS belongs to a public agency (i.e., governmental) and then requires a COA or operates under Part 107 rules, or it belongs to to a civilian entity and therefore requires adherence to Part 107 rules and perhaps a special airworthiness certificate or a waiver. For manned aircraft, the FAA requires several basic steps to obtain an airworthiness certificate in either the Standard or Special class. The FAA may issue an applicant an airworthiness certificate when:

• the registered owner or operator/agent registers the aircraft,
• the applicant submits an application through the dedicated portal, and
• the FAA determines the aircraft is eligible and in a condition for safe operation.

The process for a UAS is different for the time being, as it is approached through either a COA or a special airworthiness certificate, as was discussed above. For UAS, the FAA may consider an airwortiness letter like the following:

"To Whom It May Concern:

The eBee small Unmanned Aircraft System has been inspected and reviewed on behalf of XY organization  by qualified individuals and a determination has been made based on testing data and evaluation data provided by the manufacturer that the aircraft is serviceable and airworthy for the intended use as advertised by the manufacturer, subject to the warrantees and representations offered by said manufacturer.

Sincerely,

John Doe, System Engineer, XY organization"

Just to reiterate, the process of requesting a UAS operation within the territorial airspace of the United States (the airspace above the contiguous United States, Alaska, Hawaii, U.S. territories, and U.S. territorial waters) differentiates depending whether the applicant is a public agency or a civilian entity. The methods of operational approval are the issuance of either a COA for public aircraft operations or for civilian operators is either to operate under PART 107 for UAS that weighs less than 55 lbs or operators need to apply for an exemption under the Special Authority for Certain Unmanned Systems (49 U.S.C. §44807) [13]. Special Airworthiness Certificate [14] is needed for civil operations under certain conditions. The FAA on its website allowed civil users to apply for a COA, it is not needed anymore, through a dedicated portal. This Form shows the web application interface [15]. The form is provided to show the actual interface for the COA application and the required materials and all applicants have to provide the required submissions through the portal. To apply for a COA, go to the FAA UAS Civil COA Portal [16]. You will need to create an account on the FAA website before you proceed with your application. Anyhow, if you are planning to apply for a COA, be prepared to provide the following materials and information through the portal and/or when the FAA ask you later if needed:

Sample Certificate of Authorization Application

This link provides a sample of COA application provided by the FAA on their website Sample COA application form from the FAA website [17]. 

Certificate of Authorization Application Components

Make sure that your COA application provide the FAA with the following components:

- Applicant Contact Information:

• 333 Exemption number if any
• name, address, phone, and email

- Purpose of the operation and the requested exemption, if any

- Aircraft System

• description
  • picture
  • airframe
    • dimensions
  • power source
    • electric, internal combustion, etc.
  • weight (gross takeoff weight)
  • avionics
  • performance
    • endurance
    • range
    • speed
    • operating altitude
    • turing radius
    • climb/decent rates
• Airworthiness statement and documentation
• Communications
• pilot/operator to aircraft
• pilot/operator to observers
• communication within the airspace
  • air traffic control procedures and frequencies
  • local airspace frequencies
• video/data
  • FCC approved frequencies
  • ranges
• operational communications range
• backup communication
  • radios
  • cell phones/landlines

- Ground Control Station

• description
  • picture
  • capabilities
  • setup and operations
• frequency management
• FCC approved equipment
• range

- ConOps, Emergency Procedures, and Risk Mitigation

• identify, control, and document potential hazards (examples)
  • human factors
  • machine
  • media
  • management
  • mission
• assess the risks (examples)
  • weather induced flight cancelation or termination
  • lost communication
  • loss of payload
  • aircraft fire
• analyze risk control measures (examples)
  • mishap notification
  • access and contact procedures to fire and rescue
  • programmed procedure for lost links
• make control decisions
• implementation of risk controls
• review and improvement process

- Flight Operations Area and Time

• COA Location
  • boundary points (or center point if circular) recorded in coordinates
• Time of Day
• Launch and Recovery Points
  • launch and recovery points recorded in coordinates
• Lost Link/Rally Points
  • lost link/rally points recorded in coordinates
• Description of airspace class(es) (A, C, D, E, or G) for proposed operations and surrounding area

• Map and/or aeronautical chart depicting the flight operations in relation to ground references and airspace
  • VFR Chart
  • Aerial image (i.e. Google Earth/Maps)
    • Show COA area with boundaries clearly marked.
    • Show planned launch, recovery, and rally points.
• FAA coordination and concept of operations plan (Flight Standards District Office, Air Traffic Control Tower, etc.)
• Planned nominal flight operations in proposed airspace
• Altitude (minimum and maximum)
• Security for crew

- Launch and Recovery Procedures

• Primary/planned launch and recovery location(s)
• Launch and recovery checklists and procedures
• Takeoff and Landing or Fixed Wing launch and recovery methods
  • Launch (examples)
    • Hand-held
    • Rail
    • Catapult
    • Support vehicles/equipment
    • Weather limits
  • Recovery (examples)
    • Net
    • Grass
    • Weather limits
    • Landing speed

- Lost Communications Procedure

• Return to Base (RTB) procedures
• Lost communication between pilot and Air Traffic Controllers
• Lost communication between pilot and observers

- Lost Link Mission Procedures

• Internal navigation systems failure
• Control systems failure
• 5%">Low/lost battery
• Length of time to identify lost link
• Procedure to re-establish link
• Procedure if link is not re-established
• Platform actions if link is lost
• Notification procedures in the event of lost link

- Operator (Pilot) and Visual Observers

• Crew qualifications
  • Pilot certifications
  • Aircraft currency
  • Required currency of medicals
  • Platform training and currency
• Crew resource management (CRM) approach
• Communications and coordination for operations
• Provision for UAS operations (single platform at a time)

In this section, you are expected to develop and submit the required materials for the COA or Part of 107 waiver application for the platform you selected in the activities of Lesson 1. It is helpful to review previously submitted COA or Part 107 waiver applications available on the FAA website before populating your own documentation, so you can become familiar with the format, required materials, and depth of information. The following is a brief list about the materials you may need in order to complete the COA or Part 107 waiver application for your platform:

1. Aircraft system
2. Communications
3. Ground Control station
4. Emergency procedures
5. Flight operations area
6. Launch and recovery
7. Lost communications
8. Lost link mission
9. Operator and visual observers

Make sure to incorporate risk mitigation strategies and address the integration of automation and autonomy in your system in the various sections as appropriate. More details on the information required for a COA or Part 107 waiver application can be found in the template provided. The link to the FAA site provided above also provides plenty of examples on COA and Part 107 waiver applications.

Summary

Congratulations! You've finished Lesson 6, Aviation Regulatory and Certificate of Authorization Process (COA). I hope you digested the materials very well, as they are essential to understanding the circumstances of operating any UAS in the U.S. The exercise of developing your own COA or Part 107 waiver application will enable you to manage a UAS operation, as it has provided you with crucial knowledge about logistics and safety concerns regarding UAS operations. The exercise not only had provided you with FAA rules and regulations, but has also given the necessary technical knowledge about different sub-systems of the UAS.

Final Tasks