Today the FAA released additional details about the new FAA UAS Integration Pilot Program initiated by President Trump and DOT Secretary Elain Chao. This program is described as providing an opportunity for package delivery, flights beyond visual line of sight, and other vanguard operations in partnership with participating state, local, and tribal governments. What follows are a few details and clarifications we learned today via an FAA webinar about what governmental entities can qualify as a governmental “Lead Applicant” and important details regarding the mechanics and requirements of the entire application process.
First, I re-emphasize that the Notice of Intent email must be filed within 20 days of the publication in the Federal Register of the Pilot Program. This email notice of intent need not be elaborate, but if this deadline is missed the opportunity is gone.
Second, the following points and clarifications may be of interest to you:
- “Lead Applicant” includes entities such as public universities, law enforcement agencies/police departments, as well as local governments and States themselves.
- A private industry stakeholder can partner with multiple potential lead applications, even if though separate applications.
- Emphasis appears to be in the 200- 400 feet AGL altitudes, although exceptions might be made. Updates regarding this may appear at the FAA.GOV/UAS website.
- The pilot program operations will include existing regulatory approvals such as Part 107 waivers. It was explained that the Presidential memorandum does not change or add to the FAA regulatory structure/authorizations.
Third, all timelines and submission formats are available to view at www.faaco.faa.gov.
Pay particular attention to the document called the “SIR”. Submissions must go through an online portal, and access to the Pilot Program online portal will be provided once a proper submission has been entered through 9-AWA-UASIPP@FAA.GOV. The response from FAA will include information for both the online portal and an FAA Facebook page.
The full application process (available to view at https://www.faa.gov/uas/programs_partnerships/uas_integration_pilot_program/splash/ includes submission of relevant proposals including:
- CONOPS (Concept of Operations – the how and why your operations and volume of airspace will be conducted safely)
- A proposal of public benefit (how your proposed acceptance into the pilot program will push the envelope and benefit the industry and/or society)
- Economic benefit analysis
- Proposed plan of local community outreach and relations
- Privacy policy
- Description of the team members’ relevant history and how their skills, expertise, and proposed operations will push the envelope of UAS, safely
The goal is to become operational within 270 days from the date of publication in the Federal Register.
Antonelli Law can help you with these applications including but not limited to CONOPSs, privacy policies, Memorandum of Understanding, Part 107 waivers, etc. Our experience extends over a decade in the unmanned operations industry.
The Federal Register Notice for the UAS Integration Pilot Program is unpublished. It is scheduled to be published on 11/08/2017. Once it is published it will be available on this page (https://www.federalregister.gov/documents/2017/11/08/2017-24126/unmanned-aircraft-systems-integration-pilot-program-establishment-of-program-and-request-for) in an official form. Until then, you can download the unpublished PDF version at on this page (https://s3.amazonaws.com/public-inspection.federalregister.gov/2017-24126.pdf). Good luck and remember to begin the process within 20 days.
BY JEFFREY ANTONELLI, ANTONELLI LAW LTD., antonelli-law.com
