fly safe, compliant, and insured. - aerial technology international · 2015-04-30 · fly safe,...

Fly safe, compliant, and insured.

THE ATI AGBOT COMMERCIALIZATION PACKAGE

ATI and Skyward have teamed up to deliver a turnkey solution to get your commercial UAS operations off the ground as quickly and efficiently as possible. The Commercialization Package will provide you with everything you need to build and maintain a safe, professional, insurable, and legal UAS operation. Insurers and Regulators require that anybody flying a UAS commercially in the National Airspace (”NAS”) be able to prove the safety of their operations prior to receiving coverage or permission to fly. Signing up for the Commercialization Package will give you access to Skyward’s expert team of UAS regulatory consultants who will develop a set of operating procedures and documentation customized to your business’ needs. Upon your request, Skyward will present your operational documentation to the FAA in the form of a 333 Exemption petition and work with the regulator through approval of your commercial operations.

The partnership between ATI and Skyward has allowed us to significantly streamline the process of generating operational documents for AgBot customers. Because we are intimately familiar with the AgBot platform and the types of operations for which it will be deployed, we have been able to significantly reduce the time and cost of generating the documentation required for regulatory approval and insurance acquisition. Whether you plan use your AgBot to provide UAS services to third parties or simply as a tool to augment your existing business, building a safe and professional foundation for your operations is the first step towards maximizing the return on your UAS investment. If you would like to learn more about the Commercialization Package, please read on, or click the link below to schedule a free 45-minute assessment: skyward.io/contact

233 SW Naito Pkwy, Suite 200 | Portland, OR 97204 | [email protected]

Skyward & ATI AgBot Commercialization Package 1

http://skyward.io/contact/?sel=profserv

mailto:[email protected]

US REGULATORY OVERVIEW

The current regulatory climate in the United States strictly limits “commercial”* operations. As of April 7, 2015 there are at present only 99 companies that operate under FAA exemption, with some 800 petitions pending. However, that is by no means an exhaustive list of the companies that are currently operating in the United States, nor is it any indication of overall interest. The companies that have been chosen by the FAA for exemption have been established UAV operators in specific types of industries for which the FAA has a mandate, and they have conformed to specific operating criterion. The industries represented so far are: aerial videography, survey and mapping, precision agriculture, filmmaking, oil and gas flare stack inspection, and powerline, pipeline, or other infrastructure inspection. Current FAA regulations provide no pathway for aircraft of any type to fly within the National Airspace (“NAS”) for commercial purposes unless the aircraft has met stringent airworthiness certification requirements. A 333 exemption petition to the FAA requests that the regulator waive specific airworthiness requirements for the applicant. This is the regulatory pathway that UAS operators have been using to get approval for their commercial operations in the National Airspace (“NAS”). The 333 Exemption process is currently the most efficient and proven method for approval of commercial UAS operations. The FAA had historically required 333 holders to apply for a separate Civil COA prior to each flight. Approvals for Civil COAs can take up to 60 days, so this requirement proved to be a major hurdle for commercial UAS operators. In March 2015 the FAA announced that a “Blanket COA” would be issued in conjunction with each 333 Exemption grant. The Blanket COA carries several restrictions, including flights below 200 ft AGL and at least 5 nautical miles from an airport. Flights that do not fit the Blanket COA criteria need to be approved via the traditional Civil COA process.

On February 15, 2015 the FAA released its Notice for Proposed Rulemaking (NPRM) for public comment. The proposed rules will dramatically lower the current regulatory hurdles for legally operating in the National Airspace (NAS).

Some of the proposed rules include:

• Creating a special unmanned aircraft operator certificate

• Requiring no airworthiness certification process,

• Enabling operations under 500 ft AGL in most airspace categories.

However, for the time being, operators will have to continue to go through the Section 333 exemption process. It is anticipated that it will take 12-18 months for the final rules to be put in place, and there is no guarantee that the final rules will mirror the rules that were proposed in February. Regardless of the regulatory environment, putting processes and documentation in place is a necessary first step for standing up a safe, insurable, profitable, and sustainable UAS operation. If this is done the right way, the operation should have no problem getting through the 333 process or complying with the new rules when they are finalized. Without a thoroughly documented and professional operation, approval via either regulatory method will be unattainable, and obtaining insurance will be problematic, if not impossible. * The FAA considers any UAS operation that results in a benefit to a business to be a “commercial” operation. Included in this definition is a farmer using aerial data collected by a UAS to augment his own private farming operation.




COMPANY ANALYSIS

The FAA stated in early 2014 that they would begin fast-tracking commercial UAV use through this “Section 333” exemption process. Specifically, they prioritized the fields of filmmaking, powerline and flare stack inspection, and precision agriculture. The FAA chose those areas for statutory reasons to fulfill their mandate of aviation safety. These domains and use cases, as opposed to package delivery, easily qualify under the FMRA 2012 statutory requirement that use of UAV in the national airspace be safe based on their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight. In addition, the FAA requires exemption petitioners to justify their petition in terms of the public good. Thus, the companies that have been granted exemptions have shown that their operation of a UAV is safer (thus benefiting the public good) than an equivalent operation conducted through manned aviation. Aerial filmmaking with a 10 lb UAV over the actors is much safer than hovering a several thousand pound helicopter full of aviation fuel over a set; and hazardous infrastructure inspection with UAVs, for example, provides a clear financial and safety gain over using a human on a scaffold or a rope.

Companies more interested in operating UAVs for package delivery in urban environments have so far not been able to make a similar safety case in the United States, though other countries, notably the United Kingdom, has published regulatory guidelines for operating UAVs within London and other congested areas. Rural areas, on the other hand, are inherently low-risk locations for operations, both because by definition there are fewer people and valuable properties on the ground, but also because rural areas are typically well away from airports or airways and are thus unlikely to interfere with manned aviation. Thus, precision agriculture operations are also good candidates for exemptions. And, in fact, there have been multiple exemptions granted for precision agriculture companies. In brief, companies able to demonstrate a clear enhancement of safety, reduction in risk, public benefit, and operations conducted well away from urban environments, are more likely to be rapidly approved by the FAA. Urban operations, however, are not out of the question; they will simply require more risk mitigations and deeper dialogue with the FAA on operational constraints and requirements.

FAA REQUIREMENTS

The FAA has revealed a considerable amount of information on what they consider to be a basic set of qualifications for operating UAVs. Among these are:

1. Private pilot license (Sport Pilot License OK) The NPRM has proposed new license termed an unmanned aircraft certificate with a small UAS rating.

2. Second or third-class medical certificate The NPRM has proposed self-certification.

3. Direct visual line of sight

4. Restricted area of operations

5. Human in the loop

6. Less than 55 lbs

7. Less than 100 mph

In addition, the FAA requires that companies maintain flight records and maintenance records as well as possess a General Operating Manual or similar, a Flight Manual, and a Maintenance Manual for their operations and aircraft. Companies must also fly within pre-determined and well-defined areas, and the FAA requires that any excursion outside the area of operations be reported to the FAA. Finally, all commercial UAVs must be registered with the FAA and receive an N-number. Failure to demonstrably maintain the conditions of the exemption invalidate the exemption, and reporting requirements are in place. These standards are well in keeping with the existing standards of aviation that the FAA maintains. And as we anticipated, many of these requirements were outlined in proposed small UAS rule released on February 15th, 2015.




INSURANCE ENVIRONMENT

Lack of FAA approval in the US is not proving to be a barrier to insurance, as there are at least seven insurance carriers active in the UAS space in the US. However, operators can expect the investment in a Section 333 to pay dividends on the insurance premium when they get their approval, as the insurance carriers consider these companies to be “pre-screened” risks. Of critical importance is the professionalism of the UAS operation. Has a Standard Operating Procedure been developed? Are the pilots trained and experienced? Is a spotter employed for all flights? Is a safe distance always maintained from persons and property? All these factors can play into insurability and pricing, regardless of whether or not the company has received permission to operate from the FAA. Most commercial insurance policies exclude aviation exposure, and the industry currently classifies UAS exposure as aviation

exposure. As such, UAS operators are required to secure coverage from an insurance company that can offer an aviation-specific policy. For operators, aviation insurance falls into two basic categories: legal liability and physical damage (hull). Operators should consider liability insurance as a minimum, as it could save the business from a catastrophic lawsuit, and most customers will require it. Liability insurance covers the cost to repair property the operator might damage and injury to persons. Additional coverage may include personal injury (invasion of privacy), non-owned (crashing someone else’s drone), war perils including malicious damage, medical expenses, and premises liability. Hull damage policies cover physical damage to the UAS itself. Essentially, this covers the cost to repair, or the total loss of either the platform, payload, and ground equipment.

SKYWARD APPLICABILITY

The Skyward system was developed to help UAS operators stand up and maintain safe, compliant, and insured UAS programs. Following written guidelines to fill out an application may seem like a simple proposition, however, as you can see from the information above, building the safe UAS program behind that application is not. Whether a customer is building an entire UAS program from scratch or simply looking for the right training program, we can help get them in the air as quickly as possible. The procedures, tools, and documentation we develop for our customers will not only meet the needs of regulators and insurers; they will serve as the foundation of a professional, efficient, and safe UAS operation.

Our process begins with a free assessment, in which we learn about the customer’s business goals, the stage of their UAS operations, and their technical and operational acumen. We work with the customer to determine their individual needs in order to stand up their operation. We then provide the customer with an outline of the requirements and a price quote. Skyward will work with the customer to build and document their operation. While Skyward provides a customized solution for each individual operator, our collaboration with ATI has enabled us to standardize much of the process, significantly reducing the time to approval and cost to our customers.

REGULATORY SERVICES

As noted above, regulators and insurers require UAS operators to build and maintain procedures and documentation in order to remain in compliance with their approvals and their insurance policies. We work directly with regulators and have developed a deep understanding of the nuances of the requirements. Based on your plan of operations, we will help you determine which requirements you will need to follow and how to best demonstrate compliance. Our services include:

• Writing and submitting regulatory applications (Section 333 Exemption letter, COA, SFOC, et al)

• Regulatory analysis and consulting • General Operating Manual • UAV Operating System Limitations • Operation Checklists (pre and post-flight) • Flight Training Manuals • UAV Operations Manual

• Safety Management System • Risk Assessment • Training Certificates • Proof of insurance • Landowner permission • UAS engineering characterization, equipment

testing, and feasibility studies • Aircraft registration




DIGITAL SYSTEM OF RECORD

Skyward is uniquely positioned to provide the operational controls and audit process the FAA requires, with an online system that replaces manual recordkeeping for the requirements noted above. Skyward offers its Professional Services customers a free subscription to the Skyward Software, which is a private online system that allows our customers to upload, store, and update their operational, regulatory, and insurance information. Customers can use the system to manage their operations, as well as to present data to regulators and insurers upon request.

FLEET AND OPERATIONS MANAGEMENT

As businesses grow, so does operational complexity. With Skyward you can track and manage pilot credentials, certifications, and training. You can also track air vehicle maintenance and incidents. Skyward notifies users of safety alerts for registered vehicles and changes in regulatory or insurance requirements that may impact operations. Managing flight operations efficiently, in compliance with regulatory requirements, can be difficult. Skyward provides the tools to ensure a safe and compliant operation. Tools include scheduling and dispatching of qualified pilots and vehicles, procedure checklists, maps, and flight tracking and logging.

TRAINING

Training is one of the most important components to standing up a safe UAS operation. Whether a customer plans to file for regulatory approval or not, a certain level of UAS training and airspace knowledge will be required by Skyward and by the insurance companies. Skyward has teamed up with UAS-specific training partners to provide the appropriate level of training to our customers.

The FAA has indicated that 333 exemption requests will only be approved if the pilot in command holds or plans to acquire a Private Pilot License (PPL). The FAA recently made clear that various less time-intensive and less expensive forms of PPLs will be accepted, including Sport Pilot LIcenses. The NPRM proposes to lower this threshold to a UAS operator certificate. Skyward maintains a list of training programs that can help our customers satisfy the appropriate requirements as quickly as possible.




INSURANCE

After completing the initial assessment, Skyward refers customers to its insurance partners. Because we work closely with UAS-specific insurers and they know that Skyward builds safe and compliant operations for its customers, our customers will have access to the most favorable policies and prices available.

PACKAGES AND PRICING

Our customers come from all corners of the industry, and vary from startups to mature professional operations. Some of them have already applied for 333 exemptions, and some have not. This diversity results in a wide range of requests for our services. As such, it is difficult to provide firm price estimates prior to conducting an assessment with the potential customer. Pricing varies based on complexity of use case, uniqueness of the UAS platform, and the size/complexity of the organization. However, through our partnership with ATI, we have been able to greatly reduce our pricing for customers applying to the FAA with the ATI AgBot. We are familiar with the UAS, the customers’ proposed uses, and the type of operation that needs to be built around them. We offer an initial 45-minute assessment call for free in order to learn more about the customers’ background and goals, after which we provide an estimate and a scope of work. Most of our customers ask us to help stand up their operations and then assist with the regulatory application process.

NEXT STEPS

Please use the following link to schedule a free assessment with Skyward’s Professional Services team. Alternatively, feel free to email us at [email protected] with any questions.




http://skyward.io/contact?sel=profserv


fly safe, compliant, and insured. - aerial technology international · 2015-04-30 · fly safe,...

Documents