Part 107 Waivers and Authorizations — a Primer

•September 23, 2017 • Leave a Comment

In addition to my forays into GPU compute, distributed computing, AI, and VR (my day job) I’m also a licensed drone pilot (USA).  I get a lot of questions about this from colleagues in the drone services industry since I’ve successfully obtained FAA waivers in the past, so I put together a primer for Part 107 Pilots who are frustrated with the current FAA Waiver system, with a potential solution.  We’ll talk about municipal and film permits in a later post…

Most of us Part 107 pilots have experienced this scenario: A very lucrative photography, mapping, or inspection job drops in your company’s lap to bid on. You have the equipment and fleet, hours of flying time doing the same type of work, and know the area intimately. You have references and reel/data to prove it… but the job entails flying just inside the veil of a Class Bravo SFC-10000 AGL pancake. Worse yet, it’s in a municipality that requires film permits…. and the only good launch and land site is a City Park.

You kindly provide your prospective suitor your bid, but that it will probably be at least 60 days to get the Waiver and City Special Parks Use Permit squared (you say to yourself, “that’s awfully optimistic, but hey, if they look it up on the FAA site for confirmation, that’s what the FAA says…”). Then the client goes dark: emails stop, they stop returning phone calls, and a couple weeks later you learn they just hired a kid from down the block with a Phantom 3 he bought at Best Buy to fly the job, with no heed to regulations or safety (let alone legality).

Now this is certainly frustrating, but there is a bit of prophylaxis you can apply to prevent this in the future, and there is a bonus — which I will discuss later. The first is to understand the difference between an Airspace Authorization and an Airspace Waiver.

107.41 Airspace Authorizations

An Airspace Authorization is a short-term — under 6 months — pass to fly in a small area of Class Bravo through Echo airspace, usually with severe restrictions as to altitude and radius of operations. These are the ones that are actually starting to go through quickly (if you can call 60 days “quickly”). To get on this speed-of-smell fast-track, one should look at the UAS Facility Maps available at:

https://faa.maps.arcgis.com/apps/webappviewer/index.html?id=9c2e4406710048e19806ebf6a06754ad

An example such UAS Facility Map is below, for the East side of the San Francisco bay area:

hayward_airspace

The numbers in the grid squares are guidelines: they are not hard-and-fast limits. But if you want a 60-day application turn-around, if you stay within the altitude limits in your grid squares within the radius of your Authorization application, the process is mostly automated (but still presently takes 60 days, but they hope to largely automate it to under 2 weeks eventually, as long as you stay within the limits). *[Notice we’re mixing grid squares and the radius of a circle. If you think about it a while, you can see how perversely devious this is for the FAA to do, in a bureaucratic kind of way]. You can, in the example above, request an Authorization for over 50 feet AGL along the north side of the Hayward Regional Shoreline (the grid marks 50 AGL as maximum altitude), but then your application goes into the manual examination pile — and this is where it gets interesting.

One you stray outside of the grid limits, you’re in no man’s land. Let’s say we request 100 AGL in a very tight location at Hayward Shoreline. Some physical person from the FAA will have to get to your application in the pile (weeks), and they will literally call the FSDO (local Flight Standards District Office) for their opinion, which is usually neutral — they usually say to call the Airport Manager for their opinion. So then a few weeks later the FAA calls the Airport Manager for Oakland Intl. Airport (KOAK) who then directs them to the airport’s UAS subject matter expert, who is probably on vacation. Weeks. Finally, the FAA counterpart gets the SME for KOAK on the phone or email, but what happens next is really a matter of culture. Some SME’s are militant anti-drone, and others are much more friendly (“Sure, no problem, but if they’re going to do a flight over 50 AGL, have them contact the tower via phone a day before”). Meanwhile 6 months have passed, and we haven’t even touched on the fact that Hayward Shoreline is a California State Park…

For an example of a hostile SME for an airport, just take a look at KEWR’s (Newark Liberty) UAS facility map:

kewr_airspace

Basically what they’re telling you through numbers is that there is No Way you are getting a 107.41 Authorization within a 100 kiloton-blast radius of KEWR.

Clearly the Authorization process is pretty broken at the present time for anyone responding to bids for jobs in airspace classified other than Golf. But who flies these jobs then? 1) Folks with Section 333 Exemptions, but these are being phased out and 2) Folks with 107.41 Waivers, not Authorizations.

107.41 Airspace Waivers

Now the gentle reader may think to themselves “but I’ve read FAR stem-to-stern, and especially 107.41, in which nowhere does it say anything about a “waiver” only “ATC authorization”. It’s not a legal, nor regulatory distinction, but rather an administrative one. Under six months, tight radius, and within the UAS Facility Map grid limits? It’s an Authorization. There is no pre-flight contact to ATC required. Two years term with a 2 nautical mile radius at full-on 400 AGL near a major airport like LaGuardia? That’s a Waiver. Long-term waivers are great, but they generally come with many more restrictions than mere Authorizations such as:

  1. One or more Visual Observers required;
  2. Contacting the tower 30 minutes prior to operation (and they can veto);
  3. Contacting the tower immediately after finishing;
  4. Having two-way radio comms capability for emergencies;
  5. Forget conjoining your 107.29 nighttime waiver with your airspace waiver, unless you’re really cheeky; and
  6. You’ll have gray hair by the time they approve it (if they do approve it, and if you don’t have gray hair already).

However, the advantages of having overlapping long term waivers in your business territory are obvious:

  1. You can respond immediately to RFPs;
  2. You have a marketable piece of paper, sort of like just having your Part 107 license to begin with;
  3. You can advertise this fact to all prospective clients; and
  4. The National Air Space will be safer.

However, this does require foresight on the part of the operator. What areas am I going to likely be operating in? What ones have I been asked to operate in, in the past, that I couldn’t because of airspace classification?

Conclusion

That being said, I personally believe that having a long term Waiver, not Authorization, is the way to go. While it may take 6 months to get, if you’re in this for the long-haul I would suggest looking ahead and applying for long term Waivers in your business territories instead of reacting to client bids and applying for short term Authorizations (and then losing the jobs as you wait — to weekenders endangering the National Air Space).  Down the road I’ll write about the next layer of the onion — municipal film permits and park special use permits.

 

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Pretty Great Privacy

•March 31, 2017 • Leave a Comment

I tell you, it will be awesome.  You won’t believe how awesome it will be.

Trump just unleashed the hounds on us. “They”, our ISP’s, can now take and sell our internet access metadata. What we’ve visited, what we spent time on, what we clicked. And yet, we PAY for that access, that’s pretty galling, right? That evil ISP of yours can spy on you and find your shopping habits and your preference for light linen suits over dark suits… and forward it to God-Knows-Whom with some supersecret FISA court order, and next thing you know you’re getting spammed with subpoenas for violating the Verbal Morality Statute[1] or some other knucklehead law[2] the future (or present) congress passes regarding leisure suits or turtlenecks. Oh, the horror.

But they’ve been doing this since 2005. Unless you just discovered the Internet yesterday, your preferences have already been scraped and collected. As they say, that particular horse left the barn already in the mid 2000’s.  But wait, it gets even better (bigly, dare I say?).

More Evil

So of course Google and Yahoo and Netflix track your habits, activities, and preferences in a ginormous database via cookies and your history with interacting with those services. And some of them serve you ads “Half off a linen seersucker suit! Buy Now!” A growing number of people consider that pretty evil — and use ad-blockers, but a large majority accept this in exchange for a valuable and free (to them) service, such as Google search.

True Evil

Now if you think that’s evil, let’s explore what Google and Apple are doing *right now* as you’re reading this on your smartphone.

You smartphone is collecting data about all the Wifi networks it finds as you’re strolling and driving around with it in your pocket. This is ostensibly done so that if you want to use your phone and a free Wifi access point is available, you unlock your phone, and magically, you’re on the (faster) internet. Here’s the punchline — what’s actually evil is that unbeknownst to you, every few minutes your beloved smartphone is transmitting all that collected wifi access point data (locations, names, SSIDs, access policies) back to the mothership. Android phone? It all goes back to Google. iPhone? It all goes back to Apple.  From there, of course, it goes into another ginormous database.[3][4]

Now you might think to yourself, “well, that’s OTHER people’s information, not mine, so why do I care?” If you want to find the biggest spy — look at yourself in the mirror. That smartphone you carry is spying on everyone’s networks whether you like it or not.

On the Other Side of the Looking Glass

In my location, we have at least 10 Wifi access points, all sqwuaking SSIDs. So everytime someone drives by, Google and/or Apple is getting an update as to my network status! To be clear — I’m not running a bitcoin boilerplate widows-and-orphans-cold-calling scheme from the basement or anything nefarious like that, but this certainly gives me “the skeeves”. What to do? There IS actually a way, that you, as a Wifi access point owner or administrator, can prevent this from happening.

Turn if off by adding to your Wifi access point SSID the suffix “_nomap”[5]. Good luck Googling that! (They don’t have a “sponsored link” highlighting this fact.) I think this is backwards — there should be an opt-IN called “_mapme”, instead of the other way around.

And if you’re concerned about ISP’s spying on you, you can always use a VPN like HideMyAss or a service like Tor (if you’re REALLY paranoid).  However, even with a VPN Google will still always have your number and history when you visit their site.

[1] https://www.youtube.com/watch?v=5rVQGT01Kzg

[2] http://www.jdsupra.com/legalnews/the-drone-privacy-and-transparency-act-42426/

[3] https://www.theregister.co.uk/2011/04/22/google_android_privacy_concerns/

[4] https://www.theregister.co.uk/2016/09/12/turn_off_location_services_go_ahead_says_google_well_still_track_you/

[5] http://www.ghacks.net/2014/10/29/add-_nomap-to-your-routers-ssid-to-have-it-ignored-by-google-and-mozilla/

Article about the challenges of 360 cinematography

•March 2, 2017 • Leave a Comment

Here’s a very informative article about the production, workflow/postproduction challenges of creating compelling 360 VR content.  I can confirm much of what they have observed:

http://www.lauschsicht.com/our-guide-to-360-degree-filmmaking/

 

Pametar –Services Rate Maps By Geolocation

•February 23, 2017 • Leave a Comment

A friend of mine, Nathaniel Brown, started a beta website that’s sort of like what Glassdoor does with salaries — but with a twist.  It collects anonymous (or named, optionally) info about charges for photography, video, etc by geolocation. I suggested he add drone services too, so what this now is, is a site where you can see by geolocation, what people are charging for various services (including drone stuff, information about which has been changing rapidly and thinly available).  This is sorely needed as there currently is very little transparency about what are customary charges for photgraphy, VR, and drone services — which vary wildly by location.  Shooting an aerial of a wedding in Pocatello, Idaho will be very different than a drone flight in congested airspace like NYC which requires film permits, FAA waivers/authorizations and the like.

It’s called “Pametar” because it’s “RateMap” spelled backwards…

Hit it here if you want to sign up for the Beta: http://bit.ly/2lAPnUJ

 

Toptal — Interesting Business Model

•February 3, 2017 • Leave a Comment

As I was scrolling around YCombinator’s Hacker News (an indulgence I’ll admit I probably spend too much time doing) I came across a freelancer site called Toptal.  Since I’m both a programmer, manager, and executive, and I have a bit of free time on my hands the notion of freelancing again was giving me “the itch”.  I was intrigued by Toptal because they are very exclusive and it appears that their signal to noise ratio is very impressive compared to other sites like Upwork or Hired where it’s essentially a free-for-all, with the usual freemium add-ins that constantly tempt you to melt your credit card.  I’ll try joining the toptal software programmers network since there seems to be a lot of good firms looking for solid skills in the latest technologies like machine learning, virtual reality, and front-end development.

Part 2 of GemVR’s showreel for Q4 2016

•January 2, 2017 • Leave a Comment

As promised.  Enjoy.

Part 2 of GemVR’s showreel for Q4 2016

Part 1 of GemVR’s showreel for Q4 2016

•December 27, 2016 • Leave a Comment

Hope you enjoy! Part 1 of 2.  Part 2 will be the 360/3D.