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Old 10-08-2019, 11:51 AM
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rhklenke
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The FAA has been granting permission for "public entities" to fly UAS in the NAS for over a decade under a process called Certificate of Authorization (CoA). I have worked within the CoA process since soon after its inception and up until recently, I have maintained CoAs for our research work as a public university.

The CoA approval process call for the FAA ATO to give final approval of the CoA based on the location of the activity in the NAS. In my involvement with CoAs, across several different organizations and different locations, the altitude limit is set at the top of the Class G airspace - i.e., the point where Class E airspace starts. This is either 1200' or 700' AGL, depending on where the location is. Universally, Class E airspace starts at 1200'. The 700' Class E airspace is a transition area which typically surrounds airports that are uncontrolled, but have a certain amount of traffic and/or have instrument approaches.

In my involvement in the CoA process, I have not seen a CoA approved for altitudes above the bottom of Class E airspace. I believe that it is (and has been) possible to request a CoA for higher altitudes, but I have not actually seen it done, or approved. Unfortunately, I'm not surprised that ATO is planning on putting the limit in Class G airspace at 700' or 1200', that's what they've been doing for over a decade.

Within Controlled airspace, (Class E to the surface, Classes B, C, and D) the FAA ATO already did an assessment of how high they could routinely allow UAS flights. That data is shown in the FAA's UAS Facility Maps (see link on https://www.faa.gov/uas/commercial_o...facility_maps/). I'm also not surprised that ATO is holding club fields in controlled airspace to the altitudes on the Facility Maps. They've already done the analysis on how high they should allow, so why would they do something different?

I'm fully in agreement that this sucks and doesn't take into consideration the safety record of MODEL AIRPLANES vs. drones.

I think what Joel is alluding to is creation of a "third" category between "recreational UAS flyer" and "commercial UAS flyer" - i.e., a licensed "model aircraft pilot" for those who want to go higher and/or faster than allowed under Section 349 or FAR Part 107. I hope he is right, and I wouldn't hesitate in doing what it might take to obtain such a license. I *teach* classes on commercial drone flying under Part 107, and its not rocket science (although certain parts are confusing to lay people off the streets with no aviation background or affinity). I'd be more than willing to teach fellow jet guys about airspace, regulations, etc. for free as necessary to pass such a test.

Bob

Last edited by rhklenke; 10-08-2019 at 11:54 AM.