UPDATES TO SECTION 333 PETITIONS – 331 FILED

Searching the Regulations.gov website is too hard, so we wanted to make it easy for you to find the latest Section 333 petitions for exemption.

We have updated our list to include the newest 214 Section 333 petitions on file, including several new Section 333 petitions Antonelli Law recently filed: iCam Copters LLC and Owlcam LLC. This brings the total number of Section 333 petitions filed with the FAA to 331.   Please note that no warranties are made to the accuracy or completeness of these petitions. For the official versions go to Regulations.gov.

If your company would like assistance filing its own Section 333 petition to fly UAS commercially, contact firm principal Jeffrey Antonelli at 312-201-8310 or fill out the contact form below and we will contact you. In addition to the iCam Copters LLC  and Owlcam LLC petitions recently filed by Antonelli Law, to see the original petition Antonelli Law filed for Nixon Engineering select it in  our previous post here

Your Name (required)

Your Email (required)

Subject

Your Message

captcha

 

 

TWO NEW FAA SECTION 333 APPROVALS ISSUED TODAY

Today, the FAA approved two  new Section 333 petitions for exemption. One exemption was issued for real estate photography and videography over non-congested areas in Tucson, Arizona using the DJI Phantom 2 Vision + (the same UAS I use as a hobbyist).  The second exemption was issued for precision agriculture crop scouting and photogrammetry using the senseFly eBee Ag UAS.

The two new exemptions approved today are as follows:

  1. Trudeau_Douglas-11138
  2. Advanced_Aviation_Solutions_LLC-11136(1)

Again, just as with previous Section 333 exemptions, the FAA continues to require that the Pilot in Command (PIC) possesses at least a private pilot certificate and a current third-class medical certificate. Interestingly, the FAA is allowing the 1.5 pound fixed-wing eBee to fly up to 70 knots.

We continue to believe that requiring a private pilot certificate (“private pilot’s license) is unnecessary as it does not provide training related to the safe operation of the UAS as documented by research studies by the FAA and Army Research Laboratory. Therefore, please contact your US Senators and Congressmen to ask them to work to eliminate the private pilot certificate requirement in Section 333 exemptions or in the upcoming NPRM for sUAS.

If you would like to speak with Antonelli Law about helping you submit your own Section 333 petition for exemption, call Principal Jeffrey Antonelli at 312-201-8310 or fill out the contact form below. Additional information about our Drone/UAS Practice Group is available by clicking here as well.

Your Name (required)

Your Email (required)

Subject

Your Message

captcha

 

 

FAA Approves Five New 333 Exemptions

Today the FAA approved five new Section 333 petitions for exemption by four companies, but continues to require a private pilot’s license for these very small UAVS, stating “Although Section 333 provides limited statutory flexibility relative to 49 USC § 44704 for the purposes of airworthiness certification, it does not provide flexibility relative to other sections of 49 USC. The FAA does not possess the authority to exempt from the statutory requirement to hold an airman certificate, as prescribed in 49 USC § 44711.”

Immediate action by Congress must be made to address this. Transportation and Infrastructure Committee Chairman Bill Shuster (R-PA) gets why a private pilots license just is not applicable to flying these UAVs. Contact your US senators and congressmen now.

Here is the letter we are sending today: Antonelli Law letter to Congress 12-14-10

The four new exemptions approved today are a follows:

  1. Clayco_Inc_11109
  2. Trimble_Navigation_Limited_11110
  3. VDOS_Global_LLC_11112
  4. Woolpert_Inc_11111
  5. Woolpert_Inc_11114

Please take a look at the hearing in progress:

Your Name (required)

Your Email (required)

Subject

Your Message

captcha

Updates to Section 333 Petitions – 117 Filed

Searching the Regulations.gov website is too hard, so we wanted to make it easy for you.

We have updated our list to include the 117 Section 333 petitions on file, including the Section 333 petition Antonelli Law filed on behalf of Nixon Engineering (more will be filed by our Drone/UAS Practice Group soon. Of the 117 Section 333 Petitions, 9 were summarily rejected with only one of those submitted by an attorney. Please note that no warranties are made to the accuracy or completeness of these petitions. For the official versions go to Regulations.gov.

If your company would like assistance filing its own Section 333 petition to fly UAS commercially, contact firm principal Jeffrey Antonelli at 312-201-8310 or fill out the contact form below and we will contact you. To see an example of the quality of our work,  select Nixon Engineering below.

Your Name (required)

Your Email (required)

Subject

Your Message

Enter the code below.
captcha

State Farm Doubles Down on Drones – Using Airware

State Farm Insurance, one of my favorite insurance companies (they defended me from a baseless auto lawsuit when I was 19, and were my first clients in my first law firm job), recently submitted not one, but two Section 333 petitions to fly UAS in the United States.  The national insurance carrier proposes to use Aerialtronics Altura Zenith ATX8 and the Altavian Nova F6500, both using Airware’s flight control systems.

We noticed when State Farm filed its first Section 333 petition, requesting permission to test flight UAS on its own private property for experimental use, on the heels of insurer USAA doing the same. But we were surprised when State Farm filed their second Section 333 petition, seeking to enlarge their experimental use of UAS (they call it R&D) when they encounter real natural disasters:

“State Farm also seeks an exemption to permit the operation of its UAS to conduct R&D in “real world” situations during and immediately following an actual catastrophe such as hurricane, tornado, windstorm, flood, wild-fire, mudslide or similar event. State Farm’s UAS operations in this scenario would be activated in coordination with the FAA and the official in charge of on scene emergency response activities. As explained further below, such testing will occur under conditions that limit the likelihood of operations over members of the general public and ensure full coordination with any manned aircraft operations. State Farm’s use of UAS during and after actual catastrophes will educate the company on how the potential of UAS can be unlocked to assess the extent and severity of damage to insured property and enable State
Farm to continue to provide remarkable customer service to its policyholders.”

Our Drone/UAS Practice Group has been approached recently by insurers and independent claim adjusting entities wanting to know their chances of a successful 333 petition. Our basic response has been that on an individual claims basis this was not at all likely, but perhaps the FAA might allow it in the event of a natural disaster. It seems State Farm has taken the lead. Let’s hope other insurers and insurance collectives are willing to take the same chance. Its an obvious good use for UAS.

If you would like to talk with Antonelli Law’s Drone/UAS Practice Group about a Section 333 petition for your company, call firm Principal Jeffrey Antonelli at 312-201-8310, email us at jeffrey@antonelli-law.com or fill out the contact form below:

Your Name (required)

Your Email (required)

Subject

Your Message

captcha

State Farm’s first Section 333 petition: State_Farm_Mutual_Automobile_Insurance_Company_-_Exemption_Rulemaking

State Farm’s second Section 333 petition:

State_Farm_Mutual_Automobile_Insurance_Company_#2-_Exemption_Rulemaking

 

 

 

Updates to Section 333 petitons – 65 Filed So Far

Searching the Regulations.gov website is too hard, so we wanted to make it easy for you.

We have updated our list to include the 65 Section 333 petitions on file, including the Section 333 petition Antonelli Law recently filed on behalf of Nixon Engineering. Please note that no warranties are made to the accuracy or completeness of these petitions. For the official versions go to Regulations.gov.

If your company would like assistance filing its own Section 333 petition to fly UAS commercially, contact firm principal Jeffrey Antonelli at 312-201-8310 or fill out the contact form below and we will contact you. To see an example of the quality of our work,  select Nixon Engineering below.

Your Name (required)

Your Email (required)

Subject

Your Message

Enter the code below.
captcha

The Section 333 Petitions To Date

Finding all the Section 333 petitions on the Regulations.gov website is too hard, so we wanted to make it easy for you.

Pasted below are the 333 petitions filed to-date. Please note that the 333 petition we filed today on behalf of a client isn’t viewable yet until it has been assigned the official docket number. We will update as soon as it becomes available. No warranties are made to the accuracy or completeness of these petitions. For the official versions go to Regulations.gov.

If your company would like assistance filing its own Section 333 petition to the FAA to fly UAS commercially, contact firm principal Jeffrey Antonelli at 312-201-8310 or fill out the contact form below and we will contact you.

 

Your Name (required)

Your Email (required)

Subject

Your Message

Enter the code below.
captcha

Ohio UAS Conference Lessons

The Drone/UAS Practice Group at Antonelli Law exhibited last week at the Ohio UAS Conference held in Dayton, Ohio. I was personally impressed with the number of very interesting people who attended and exhibited there.

For example, one terrific conversation I had was with a gentleman who had worked on the Global Hawk, and who also reacquainted me with the work scientists were doing on dark matter and string theory.  I was also impressed with the large number of active and retired military personnel who attended, which is fitting given that Dayton is a true center of aerospace industry and research, and a prime location given that Wright-Patterson Air Force Base is located there.

But I also met people who were on the leading edge of the civilian development of commercial drones (sUAS), like Dr. Andrew Shepherd, Director of the Unmanned Aerial Systems program at Sinclair Community College, which recently announced an affiliation with Ohio State for UAS data analytics and geospatial precision agriculture programs. The companies that are now broadening from purely Department of Defense contracting into the commercial market, and the startups that are beginning as commercial UAS providers from the outset, will both need workers with specialized training.

Excellent academic foundations with true partnerships and a path to industry jobs should benefit  American workers. As was made abundantly clear at the Illinois Aerial Precision Ag Show this summer, big data is expected to overshadow the aircraft production in UAS. Programs tailored to educate American students now will help employers fill those data analyst jobs without having to resort to offshoring or expensive and unpatriotic over-reliance (my opinion) on HB-1 and other visa hiring programs.

Folks from the insurance world were present too, and assured me that numerous carriers were willing to underwrite UAS operators. That’s a crucial piece of the business case puzzle, because for all the media talk of Amazon and Google getting into the UAS game, it will more likely be the thousands of small and mid size players and wanna be players that will actually make this thing an industry.  Getting into the high risk high reward UAS market without adequate insurance coverage is a non-starter.

As for the Drone/UAS Practice Group at Antonelli Law, we are looking forward to helping more clients with their FAA Section 333 petitions for exemption to fly commercial UAS. We published a newsletter recently about Section 333 which is available here, and are  looking forward to helping shape the UAS industry response to the forthcoming FAA sUAS NPRM.

If you would like to contact the Drone/UAS Practice Group please call Jeffrey Antonelli at 312-201-8310 or fill out the following contact form and we will contact you promptly.

Your Name (required)

Your Email (required)

Subject

Your Message

Enter the code below.
captcha

Is U Class Airspace for UAS the Answer?

We met University of Michigan’s Ella Atkins, Associate Professor of Aerospace Engineering, at the AUVSI conference back in May 2014. She gave us her article on UAS safety to read, and was very engaging.

Recently as I was working to ready our firm to exhibit at the Ohio UAS Conference in Dayton August 26-28, I came across Professor Atkin’s article on my desk, Atkins, E. M., “Autonomy as an Enabler of Economically Viable, Beyond-Line-of-Sight, Low-Altitude UAS Applications with Acceptable Risk,” AUVSI North American Conference, Orange County Convention Center, Orlando, FL, May 2014,and thought I would share the paper with those who have an interest in UAS and aviation in general.

Following is an abstract of Professor Atkin’s article. For the full paper, please email Professor Atkins directly at ematkins@umich.edu

Abstract

This paper describes a practical vision for low-altitude UAS operations based on a Class G airspace subdivision that will support safe near-term UAS deployment without impact to existing manned aircraft operations. An agriculture reference mission is defined as a case study for which low-altitude UAS offer the landowner tangible benefit without introducing unacceptable risk. A Class U airspace designation is proposed for surface to 500 feet above ground level below existing Class G airspace. Reasonable operational requirements for Class U are shown to significantly depend on overflown property ownership and type. A candidate sub classification of Class U airspace based on property ownership
(private or public) and type (rural, suburban, and urban) is proposed along with candidate requirements for the vehicle, its safety features, and its operator(s). Autonomous geofencing is proposed as a means to ensure low-altitude UAS do not exit their designated Class U operating area. A certified geofencing capability can ensure safe flight in rural areas without the need to wait for system-wide detect-and-avoid so long as manned aircraft remain clear of the occupied Class U region. A deterministic and simple geofencing (or electronic leashing) algorithm is presented. Geofencing represents autonomy in that it guarantees operating boundaries are respected even if operator inputs must be overridden. Such algorithms are available today and can ultimately be safety-certified to provide the backbone autonomy necessary to ensure UAS will not leave their designated operating area despite flight operations beyond line of sight. The paper concludes with a discussion of additional technologies needed to achieve adequate safety and privacy management for suburban and urban operations.

For information on Professor Atkins’ work on UAS, visit http://www.engin.umich.edu/college/about/news/stories/2012/march/flying-robots

 

An Antonelli Law blog on UAS/Drone Law