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Airspace Authorization for Class D

brian bwin

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Just wanted to share my experience filing for, and receiving, a Certificate of Waiver/Authorization for flying in Class D airspace under Part 107 in the United States. Long post, sorry! Hope it is interesting/helpful.

Background:
Request for construction progress video and photos to be taken once per month over a period of ~10 months. Construction site is located in Class D airspace near an AFB. I don't actually know if we are getting the job or not but I went ahead and proactively filed for the COA on the same day I submitted a quote. I did this for a few reasons. 1.) These things can take up to 90 days :)eek:) according to the FAA. 2.) Gain experience for future requests. 3.) Show client I'm taking their request seriously and would be flying legally if they choose to hire me.

Timeline:
1/27/2017
Filed request for Airspace Authorization on the FAA website.
2/28/2017
Received email from FAA requesting more information and submitted response. It seems like the form was specifically related to the AFB and this step might not occur in other areas.
3/6/2017
Received Certificate of Authorization via email/PDF.

Takeaways:
  • I requested and was given permission to fly up to 105' AGL.
  • I requested only 800' laterally from the construction site but was given 1 SM. Possible 1SM is the minimum.
  • I requested for authorization until January 31, 2018 but was only given until October 31, 2017. No explanation was given.
  • Under the waiver I must call the tower one day prior to each flight and be available at all times by phone during UAS operations.
  • The COA lists other requirements such as lost-link procedure, aborting operations in emergencies, following airspace restrictions like TFRs and prohibited space, and flying only between civil sunrise/twilight. Pretty standard part 107 stuff.
  • I provided a very detailed description of proposed operations and safety mitigation procedures. Other than calling the tower my other safety items (minimum 1 visual observer used, visual communication between VO and RPIC in the event construction noise makes verbal communication impossible, flying only in wind conditions of 10MPH or less, anti-collision lighting on UAS) were not listed in the COA. It is unclear to me if that means I have to follow these (not that I wouldn't, I am very concerned about safe operation) or not. It may have been possible to get the COA without any of that information, I do not know.
  • The 30 business days it took (possibly would have been 26 without the AFB form) to get authorization is better than 90 days but still....! Clients call all the time with last minute requests and I'd hate to lose work to someone who doesn't care about going through the proper channels. I keep hearing that the airspace authorization procedure will be streamlined in the future to where you can get approval/denial within 24 hours.
Now I just need them to pull the trigger and hire me for the job! haha.

For anyone that has gone through the process:

Were you turned down initially and later approved? What steps needed to be taken to make that happen?
Did any hazard mitigation items you included in the description of operation not make it to the COA?
How long did it take?
Did you request a certain time period? Were you given it or did they shorten it?

Hope this information helps you with your business, take care and fly safe.
 

WildDoktor

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This is fantastic; thanks for writing this up! I've been curious but haven't had the need to file a COA yet, so this is great info.
 
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vtaero

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That sounds pretty good to me. I work for an executive agency and it is likely you were only authorized up until October 31st because that is the end of the fiscal year and they don't want to authorize past that at this time.

Maybe they are also wondering if some rules may change or the new faster system will come online around the fiscal year. Those are just thoughts though.

Sent from my VS995 using Tapatalk
 
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cunch

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Great write up and thanx for sharing your experience. Hopefully that customer will give you a call soon and it will lead to more work for you. Good luck!!
 
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Island Dog

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great stuff!!! Brian...thanks for sharing....we are in the same line of work, been shooting Broadcast and Business video for thirty years.....I've moved from the Philly/NY market to the ESVA....we should probably talk....I know Part 107 states giving the FAA 90 days notice.......so if I'm reading this right, it took 30 days for the initial response from the FAA? I too may need a COA in the future for commercial work and was curious how to determine a "window"? For example if I need only one day, how long on a time period do I request when considering weather and client availability to a particular site?
 

DroneDriver

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Brian,
Excellent information. Now I know what to tell someone if they want a particular job done in class D airspace "yesterday". The typical rush job!

Also worth noting: if the job that you planned for on a day(s) in the future is impacted by weather - there is a waver for this too...
When visibility and cloud clearances are below the minimums set forth in the Federal Aviation Regulations
107.51(c) and (d) Waiver
Flying Cross Aerial Productions Receive 107.51(c) and (d) Waiver - sUAS News - The Business of Drones
 

brian bwin

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I know Part 107 states giving the FAA 90 days notice.......so if I'm reading this right, it took 30 days for the initial response from the FAA? I too may need a COA in the future for commercial work and was curious how to determine a "window"? For example if I need only one day, how long on a time period do I request when considering weather and client availability to a particular site?
I requested the COA to start on 2/6/17 so I think the 90 days is less of a requirement and more of a "it might take us awhile so don't expect anything fast". It took 32 days/22 business days for the first response, then another 6/4 after I responded to that. Not terrible, but certainly not good when corporate clients come up with ideas on a whim and expect us to be able to provide service quickly.

For one-day shoots where we need a weather/client window I don't see any reason not to request an entire month to give plenty of flexibility. If we're flying below a certain height and a certain distance from the airport there's virtually no chance at all of interaction with manned aircraft so it's not like they need to fit us in around takeoffs/landings. In fact I've heard of people proactively filing for blanket 1SM COAs all over the areas where they might have work in the future (not heard of success/fail of that tactic yet). That seems a little ridiculous to me but it might be necessary since much of my county is Class D to the surface.

If you ever want to chat sometime let me know!
 

brian bwin

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...it is likely you were only authorized up until October 31st because that is the end of the fiscal year and they don't want to authorize past that at this time. Maybe they are also wondering if some rules may change or the new faster system will come online around the fiscal year...
Makes total sense, thanks for the input!
 

brian bwin

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Excellent information. Now I know what to tell someone if they want a particular job done in class D airspace "yesterday". The typical rush job!
Glad I could help, and I really do hope airspace authorizations will come down in time in the future to where we can request something with 24hrs notice and get approved/denied. I've heard the FAA has bids out for creating an airspace map/app that will show places that are essentially "instant approval" areas at certain altitudes.

Also worth noting: if the job that you planned for on a day(s) in the future is impacted by weather - there is a waver for this too...
When visibility and cloud clearances are below the minimums set forth in the Federal Aviation Regulations 107.51(c) and (d) Waiver


I get the sense that the other waiverable parts of 107 might be bit more difficult to obtain than airspace authorization (at least class D). The AskDroneU podcast went over applying for a night waiver and there was a lot of information in there about night training/visual distortions/visual observer/site requirements/and specific type of work. They were exclusively doing night real estate shoots, IIRC.
 

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