Airspace Authorization Provisions

[Dave Pitman]

Guys, every Airspace Authorization I have seen, (and I've read quite a few) contain this Language:

3. EMERGENCY/CONTINGENCY PROCEDURES - Lost Link/Lost Communications Procedures: a. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the operating area and land.

I would be interested in hearing how those of you that have read Authorizations that include this language in the Waiver would comply with the requirement that the craft return to a pre-determined location if it has lost communication AND gps lock.

Thanks.

 

[Florida Drone Supply]

Hey Dave, we will read thru our requests to see how this was addressed. I think in the past it was pretty much a canned response the was accepted. Times are changing.

 

[Moosewax]

Guys, every Airspace Authorization I have seen, (and I've read quite a few) contain this Language:

3. EMERGENCY/CONTINGENCY PROCEDURES - Lost Link/Lost Communications Procedures: a. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the operating area and land.

I would be interested in hearing how those of you that have read Authorizations that include this language in the Waiver would comply with the requirement that the craft return to a pre-determined location if it has lost communication AND gps lock.

Thanks.

Maybe I am missing something but it says "or" not "and"

"If the UAS loses communications or loses its GPS signal"

But yeah short of some sort of non-GPS navigation system there is no way to have the UAS return to home if the is no control link or GPS signal.

You could maybe comply by having the UAS autoland (most practical for VTOL) where it is if control link and gps loss occurs simultaneously.

Then maybe one would have to call their entire operating area as the "pre-determined location" lol

 

[Dave Pitman]

Maybe I am missing something but it says "or" not "and"

You are correct, it does say "or". But if we think like an attorney, I'm sure this statement would include one or the other or both. For example, the FAA would not say that if one or the other goes out you have to have a plan but if both go out, you're good with nothing, right?

"If the UAS loses communications or loses its GPS signal"
But yeah short of some sort of non-GPS navigation system there is no way to have the UAS return to home if the is no control link or GPS signal.

You could maybe comply by having the UAS autoland (most practical for VTOL) where it is if control link and gps loss occurs simultaneously.

Then maybe one would have to call their entire operating area as the "pre-determined location" lol

Agreed! That is what I am asking the community. If you have a waiver and it includes this language, how are you complying in the event of total brownout? You could set RTH to AutoLand but you cannot specify a predetermined local unless your entire AOO is the predetermined local as you say. But that is not the best choice in any instance when gps is not lost. It's kind of a conundrum.

I have not heard of anyone having to actually specify their plan in their request, but we need to be able to comply if we operate under the waiver with this stipulation.
I'm just wondering if everyone is kind of looking the other way or if anyone has actually come up with a reasonable workable strategy in order to comply.

 

[MapMaker53]

That is what I am asking the community. If you have a waiver and it includes this language, how are you complying in the event of total brownout?.....I'm just wondering if everyone is kind of looking the other way or if anyone has actually come up with a reasonable workable strategy in order to comply.

It clearly says "or" and there is no other interpretation possible. "Or" mean "or", not both. If the FAA had meant both, they would have used the word "and". The FAA just wants the drone to be able to land safely at a predetermined spot if it losses RC signal (via Home Point) OR if gps is lost (via manual flying). I'm not worried about a hypotheical attorney trying his best to interpret the word "or" differently, as I am only required to abide by the FAA's wording. The intent of the FAA wording in this case is perfectly clear, and I don't need to strategize any further. I like to keep things simple whenever I can, as life is complicated enough.

 

[Dave Pitman]

It clearly says "or" and there is no other interpretation possible. "Or" mean "or", not both. If the FAA had meant both, they would have used the word "and". The FAA just wants the drone to be able to land safely at a predetermined spot if it losses RC signal (via Home Point) OR if gps is lost (via manual flying). I'm not worried about a hypotheical attorney trying his best to interpret the word "or" differently, as I am only required to abide by the FAA's wording. The intent of the FAA wording in this case is perfectly clear, and I don't need to strategize any further. I like to keep things simple whenever I can, as life is complicated enough.

So in your interpretation you believe the FAA wants you to have a plan if one or the other happens, but in the event of both happening, which is very possible with inspections of towers for example, you are confident they don't expect you to plan for that?

Remember if both fail, then by definition one OR the other has failed is included. Clearly the FAA's intent is that something planned happens if you loose control of the uas. And they specify that that "something" is that it lands in a predetermined location.

I hope others chime in.

 

[MapMaker53]

Yes. They only use the word "or". If you feel the FAA should address both happening at the same time - which I'm guessing is extremely rare or the FAA would have addressed that, you should make that suggestion to them. But at the current time, the waiver language only addresses one OR the other situation occurring. That's all we need to accommodate.

 

[Dave Pitman]

If both fail, then one of them have failed too. As far as them intending not to include both should they fail, I think that is a bit naive tbh. I doubt they have any statistics whatsoever in order to determine that loss of both it is so rare as to have no need to address it. That just doesn't sound like the FAA at all.

I actually hope you are correct though, and the FAA has no concern that both control signal and gps lock can be lost at the same time. I just find that hard to believe. To be able to address this is difficult and I'm sure none of us wants to go there. That does not mean that we might need to though.

 

[Moosewax]

If both fail, then one of them have failed too. As far as them intending not to include both should they fail, I think that is a bit naive tbh. I doubt they have any statistics whatsoever in order to determine that loss of both it is so rare as to have no need to address it. That just doesn't sound like the FAA at all.

I actually hope you are correct though, and the FAA has no concern that both control signal and gps lock can be lost at the same time. I just find that hard to believe. To be able to address this is difficult and I'm sure none of us wants to go there. That does not mean that we might need to though.

So for 1, the FAA does not ask us to have a plan written for such a scenario in a COA for now, so getting all elaborate and writing one in, while commendable, is above and beyond what is asked for.

2) no one is saying don't have a plan for it.

3) your options are limited based on airframe and technical knowledge.

4) (I am getting cheeky here) maybe an idea is to model your plan after what a manned aircraft would be expected to do in a similar scenario. So basically if a manned aircraft loses the ability to be controlled and loses it's navigation capabilities, what is the plan? I think it might involve sticking your head between your legs and kissing your sweet butt goodbye. But definitely initiating crash procedures would be a start. Buckle in, warn your passengers etc.

Anyways such a scenario does not bring easy answers too mind. I would think something like assessing why you may have lost control link and attempting to regain link would be your best bet.
- maybe by getting closer to the aircraft, boosting your signal strength, reseting your controller, etc.

- also have a contingency plan for how to respond to the crash. Having fire suppression gear, first aid kit, rendering aid at the crash site, calling first responders etc.

Take lots of photos at a crash, treat it like a crime scene, and do not touch anything except to prevent a fire etc.

 

[MapMaker53]

If both fail, then one of them have failed too. As far as them intending not to include both should they fail, I think that is a bit naive tbh.

Not naive at all. I'm not saying both COULDN'T happen, just that it is very unlikely. I have yet to hear it proved that it has happened to anyone. Again, not saying it COULDN'T happen. Just saying (and I will continue to repeat this) that the FAA uses the word "OR" which does not mean it is a case where BOTH rc control and gps are lost at the same time. It just is not a concern of the FAA when issuing a waiver as reflected in the language used.

The only contingency plan I can think of that could address the above duel failure situation would be for the drone to initiate auto land if that duel failure was detected -- but that would rule out being able to establish a predetermined emergency return location and would also require manufacturers to issue a firmware update that will allow such a detection to initiate the same critical battery auto land response. It would also likely cause the aircraft to land in tree canopies, lakes, roofs, school yards, highways, etc. My feeling is the FAA probably looked at this relatively unlikely scenario and saw no good solution to rectify it with current technology, so they avoided using "and" in the wording so operators could realistically abide by the waiver. So if the "both" scenario happens to occur, the best course of action would be to immediately report it to ATC and continue to try to regain rc control with the drone as described by Moosewax above.

 

[Dave Pitman]

Thanks for the discussion. That's why I brought it up.

A point I would like to add is that just because something is very unlikely is by no means a reason to dismiss that the FAA requires something. For example, except for the immediate approach and departure ends of a runway and perhaps rotor wing ops in certain areas, there is almost 0% chance that operating a suas under 400agl would interfere with manned aviation. Yet in controlled airspace...well, you know.

The Airspace authorization provisions are so that we don't interfere with manned aircraft. The FAA wants to ensure if we loose a craft, it will not just randomly fly around somewhere. No matter how unlikely. I don't think the FAA could care less how difficult it is for us to accomplish that and that doesn't enter into their equation.

 

[MapMaker53]

I'm done. Goodnight, folks.