Waiver Watch | Ep 19: Drone-in-a-Box & Name Change
Welcome to Waiver Watch!
Here is the agenda for this episode:
Weekly totals
Florida Power & Light Company Drone in a Box
Massachusetts Dept of Transportation Responsible Person update
Let’s get into it!
Weekly Waiver Totals
Waivers Granted
March 12-18, 2020 saw 48 waivers approved:
41 for Daylight Operations (107.29)
4 for Operations Over Human Beings (107.39(a))
All ParaZero - 3 Mavic and 1 Phantom
2 for BVLOS (107.31 & 107.33(b) and (c)(2))
1 for Daylight Operations and Operations Over Human Beings (107.29 & 107.39)
This is quite an interesting batch of waiver this week!
Florida Power & Light Company - 107W-2020-00589
Eric Schwartz and Florida Power & Light Company are the recipients of the 107.31 & 107.33(b) and (c)(2) waiver this week. One interesting note about this waiver right off the bat, it supersedes and cancels a Nextera Energy waiver. This may sound odd at first, an FP&L waiver cancelling another companies waiver? A quick investigation makes sense of this, FP&L is actually a subsidiary of Nextera Energy and Eric Schwartz likely supports UAS activities across the group.
As with most BVLOS waivers, it is difficult to ascertain exactly what activities this waiver allows. The provisions are generalized with statements like “operations are limited to the area described in the waiver application”. However, the second page does have an interesting statement:
Visual line of sight aircraft operation, is waived to allow operation of the small unmanned aircraft (sUA) beyond the direct visual line of sight of the remote pilot in command (PIC) and any visual observer (VO) who is participating in the operation.
Operations are allowed beyond the direct visual line of sight of the RPIC AND VO. However, Provision #8 states operations must utilize at least one VO and Provision #9 allows the VO to observer 2 SM of airspace around the aircraft. Here’s a graphic to help visualize our interpretation of these provisions:
Overly simplified graphic of drone visual range vs manned aircraft visual range
Since manned aircraft are much bigger, it is reasonable to expect that a human can see them at greater distances than the smaller unmanned aircraft. So the concept here is that the RPIC and VO don’t need to visually see the unmanned aircraft to still maintain separation from manned aircraft.
The RPIC must have full situational awareness of the unmanned aircraft using real-time telemetry from the GCS. The Visual Observer can then call out manned aircraft approximate location and direction of travel for the RPIC to then make a generalized evasive action from the GCS. Don’t expect the RPIC to be making precise maneuvers to “just barely avoid the manned aircraft” in this situation. An example of a maneuver might be to execute a rapid descent to a pre-determined low altitude from the GCS.
Percepto Drone in a Box with Sparrow aircraft
Percepto Drone in a Box
Lastly, the waiver doesn’t specify which aircraft this is for but we suspect it might have something to do with FP&L’s plans to use Percepto’s drone in a box solution. There is a news article here that briefly mentions it.
The Drone in a Box concept is very intriguing as it removes a lot of the need to have a person in the field supporting the data collection effort. The boxes typically handle takeoff and landing, charging or battery swapping, data download, and more. In the future, we may see these boxes positioned all over the country being flown with the push of a button from the office. There may be less of a need to have big, expensive UAS flying around replaced instead by a distributed network of smaller, inexpensive drones.
Very exciting and futuristic!
Massachusetts DOT - Aeronautics Division UAS - 107W-2020-00739
Massachusetts Dept of Transportation - Aeronautics Division UAS and Jeffrey DeCarlo received a 107.31 and 107.33(b)
The interesting thing about this waiver is we’ve already covered it in Episode 3 and this waiver simply updated the Responsible Person name. Rob Knockenhauer was the previous Responsible Person for waiver 107W-2019-03791, but it appears that he has since left the Massachusetts DOT to start his own UAS endeavor. So Jeffrey DeCarlo requested that the waiver be updated to have his name on the waiver instead of Rob’s.
It is fairly simple to update the name on a waiver, the challenge is mostly in who is the holder of the DroneZone account. As long as the DroneZone account with the original waiver can be accessed, the new Responsible Person simply logs in, creates a new application, references the previous waiver, and provides the new name and contact information.
A different kind of BVLOS
Just to recap this waiver from episode, we interpret it as a different kind of BVLOS than FP&L above. Recall this graphic:
This concept is most often called “daisy chain visual observers” and uses additional visual observers downrange to extend the RPIC’s line of sight.
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…
