This short essay will analyze a hypothetical situation where a Boeing-Insitu ScanEagle and a General Atomics Predator B modified by the National Aeronautics and Space Administration (NASA) known as the Ikhana, are to be used for oceanic environmental studies by a private commercial entity. The 40lb DoD Group 3 ScanEagle (Insitu, 2017) will be flown via line-of-sight (LOS) control to a range of approximately 200NM. The Group 5 Ikhana maximum takeoff weight is 10,500lbs (General Atomics, 2014) and will be flown with SATCOM beyond-line-of-sight (BLOS) datalinks to approximately 1000NM from the coast. Crew complement, qualifications, and training need to be determined for sustained operations.
Crew Member Quantity and Qualities
Since the ScanEagle weighs less than 55lbs, and will not be used for recreational or hobby purposes, its use will be in accordance with Title 14 Code of Federal Regulations Part 107, Operation and Certification of Small Unmanned Aircraft Systems (Federal Aviation Administration, 2016). A key provision of Part 107 is the Certificate of Authorization/Waiver (COA) process, which will be required to fly beyond visual range, above 400ft, and during hours of darkness if required. The operator bears the burden of demonstrating acceptable risk mitigation strategies in the COA application, one of which should be full compliance with pilot certification requirements. For the ScanEagle, pilots will need to posses a remote pilot certificate with sUAS endorsement. These are obtained by demonstrating acceptable aeronautical knowledge, defined in Paragraph 107.63, and allow Part 61 certificate holders to use an expedited process. The author recommends hiring an initial cadre of pilots that hold a Part 61 and Remote Pilot certificates, and have prior ScanEagle experience, who can train additional employees.
MQ-9 operations will require a longer, specialized approval process, as there is not sufficient regulations in place for National Airspace System (NAS) integration. Since the MQ-9 is well over 55lbs, standing regulations require airworthiness certificates and registration, certificated pilots, and an concept of operations that complies with Federal Aviation Regulations (FARs)(FAA, 2017). Requesting relief from federal regulations typically requires legislative approval, however in Section 333 of the FAA Modernization and Reform Act of 2012 Congress delegated authority to waive some FAR requirements specifically related to UAS to the Secretary of Transportation. While the ocean survey company could potentially ask for pilot certification requirements to be waived, it is recommended to hire instrument rated commercial pilots, reducing the amount of requested exemptions and hopefully, the approval timeline. For all “333 exemptions,” the company will need to specify exactly which FARs they need waived, and document an alternative process that will ensure an equivalent level of safety. After approval, which can take roughly 12 months, the company will need to ensure certified pilots are at the controls, and trained on the specific COA restrictions. In military and border patrol operations, the MQ-9 has a dedicated pilot and sensor operator. Since the FAA does not mandate UAS crew compliment, the company will need to show that survey operations can be safely performed by only a pilot, for example with automated payloads and post-flight analysis, or add a sensor operator. Additional information on the data collection and analysis process will be required to make a final determination.
Hiring Replacements
For basic ScanEagle pilot recruitment, the company can accept applicants with no prior aviation experience, train them, and perhaps pay for Remote Pilot certificates. Part 107 allows non-certified pilots to be at the controls of the UAS, provided they are directly supervised by a certificate holder that has immediate access to the flight controls. Objective pilot candidates should posses Part 61 and 107 certificates, and have prior UAS experience. A “chief ScanEagle pilot” position is also recommended, with the extra requirement for a commercial pilot certificate. This individual will develop best practices for the ocean surveys that will.
MQ-9 pilots will need to meet all of the currency requirements of regular instrument rated commercial pilots, until the 333 exemption process is replaced with a FAR for large UAS. This will require the company to budget and schedule for aircraft rental and currency flights. As a means of reducing that burden, the 333 exemption could be modified, requesting additional relief by allowing non-certificated pilots to conduct the ocean survey mission after completing an organic training program. Given the size of the MQ-9, and the fact that it will need to transit controlled airspace to/from the mission area, waiver of pilot certification requirements is unlikely.
Conclusion
This short essay has investigated the certification, qualification, and training processes that will be required to comply with FARs in conducting a proposed UAS ocean survey mission. Developing a ScanEagle pilot team was found to be relatively easy thanks to the recent activation of 14 CFR Part 107. MQ-9 Ikhana operations are still subject to traditional FARs unless granted a 333 Exemption and COA, which requires significant documentation, lead time, and currency resources.
References
Federal Aviation Administration. (2017). Unmanned Aircraft Systems: Section 333. Retrieved from https://www.faa.gov/uas/beyond_the_basics/section_333/
General Atomics - Aeronautical Systems Incorporated. (2014). Predator B RPA Product Data Card. Retrieved from http://www.ga-asi.com/predator-b
Insitu. (2017). ScanEagle Product Data Card. Retrieved from https://insitu.com/images/uploads/pdfs/ScanEagle_SubFolder_Digital_DU032817.pdf
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