Waiver Watch | Ep 14: Simultaneous Wind Turbine Inspection & Another Interesting BVLOS Waiver
Welcome to Waiver Watch!
Here is the agenda for this episode and it’s jam packed! Lot of interesting waivers and news this week:
Weekly totals
Discussion about Eileen Lockhart’s 107.35 waiver
Discussion about American Robotics 107.31 waiver
Discussion on night waiver RFI, is the bar changing slightly?
Updates on Episode 12 Mystery Waiver and Under Review Status
Let’s get into it!
Weekly Waiver Totals
Waivers Granted
February 6-12, 2020 saw 56 waivers approved with a good mix:
49 for Daylight Operations (107.29)
1 for Visual Line of Sight (107.31)
4 for Operations Over Human Beings (107.39a)
All ParaZero SafeAir
1 for Operational Limitations: Altitude (107.51b)
1 for Operation of Multiple Small Unmanned Systems (107.35)
107W-2019-06759 - Xcel Energy
This week, Eileen Lockhart and Xcel Energy were issued a waiver to 107.35 - Operation of Multiple Small Unmanned Aircraft Systems. We’re big fans of 107.35 waivers, it’s one of the concepts where drones (and other robotics to be fair) have a distinct advantage over manned aircraft. Reducing the number of human beings to operate a given number of aircraft will make operations more efficient, less costly, and provide unique ways that the aircraft be utilized.
A few features of this waiver include:
It does require a Visual Observer (Provision 8). This is pretty standard for 107.35 waivers. Depending on the level of automation, the RPIC can often times have their hands full monitoring multiple aircraft so the Visual Observer provides most of the environmental situational awareness.
Operation of up to 3 aircraft simultaneously (Provision 11)
It’s approved for 4 wind farm locations (Provision 17) so it must be related to some type of wind turbine inspection work. This makes sense from a use case standpoint, wind turbines are grouped together geographically and sometimes even close enough to have visual line of sight to multiple turbines from one location.
Great use case and looking forward to seeing the success in the news!
107W-2019-05256 - American Robotics, Inc
Vijay Somandepalli and American Robotics, Inc were issued a 107.31 waiver this past week and this one is an interesting one. American Robotics, Inc is working on a “drone in a box” concept called the Scout. It appears the primary market for them is agriculture, but it could likely be used in other use cases as well such as security or energy.
107.31 is Visual Line of Sight Aircraft but it appears this waiver is not necessarily for BVLOS operations. It has two interesting provisions:
Provision #9: The remote PIC must be physically located at the sUAS operational location and must have an unobstructed view of the airspace while the sUAS is in operation
Provision #10: The remote PIC must ensure the detect system is operational and will identify any non-participating aircraft prior to their entry into the planned operational area. For the purpose of this Waiver, the operational area is defined in provision 36;
The rest of the provisions are very similar to what we see in other BVLOS waivers.
Something is amiss with night waivers…
107Waivers has a 100% success rate on with our night waiver program. Lately, the same documents that have been approved over and over again without issue are suddenly getting RFI! We did hear recently that the FAA hired a number of new waiver reviewers, perhaps the new hires are being extra cautious and asking extra questions? Or perhaps the FAA is adjusting the bar slightly to get a night waiver based on some data or experiences they’ve had?
Clearly, there is some inconsistency too. We’ve had clients submit similar documentation in the same time frames and one person will get an RFI where the others won’t.
Here are the some of the topics that our clients have received an RFI on lately:
Night Operations Training - how is it delivered? How is it tracked? How can the Responsible Person know someone has completed training?
Sufficient lighting - if the Responsible Person doesn’t conduct a daylight site survey, how do they know there is sufficient lighting?
Persons and unmanned aircraft - what does the RPIC do if human beings or unmanned aircraft are spotted? (this is one particularly interesting because the FAA is not typically interested in unmanned aircraft to unmanned aircraft interactions)
As always, 107Waivers supports our clients to ensure they get their waiver even if an RFI is issued. We’re happy to report that all our clients that were issued RFIs were still issued waivers after we helped them provide additional information. We also continually update our documentation to ensure our future customers don’t get the same RFIs. It’s all part of our continual product improvement process and customer service!
Updates
Choctaw Nation of Oklahoma’s Mystery Waiver
Status: Still Missing in Action
Last we reported on a waiver missing from the table. If you didn’t catch that episode, you can find it here.
We made some predictions about what provisions this waiver might have. Looks like we’ll have to wait another week (or more) to see if our predictions are true or not!
“Under Review”
Status: Still Under Review
Last we discussed what the “Under Review” status means for your waiver. If you didn’t catch that episode, you can find it here.
107Waivers currently has two waivers Under Review and we estimated that once a waiver goes Under Review, you can expect a response within 5 business days. Well, one of our waivers has now been Under Review for 13 business days and the other for 11 business days.
Wrap Up
Thanks for reading this week! Leave us a comment if you have any questions or would like us to write about any specific waivers next time! If you have a waiver and would like to join us on the show to talk about it and other waivers, drop us a note! Until then…
