FAA’s LAANC System-(Low Altitude Authorization & Notification Capability)


LAANC

Table of Contents

Quick Summary of LAANC:

“[T]he FAA is seeking to implement the Low Altitude Authorization and Notification Capability (LAANC) system. Using the LAANC system, the FAA will be able to grant near-real-time authorizations for the vast majority of operations. Implementation of the LAANC system is vital to the safety of the National Airspace System because it would (1) encourage compliance with 14 CFR 107.41 by speeding up the time to process authorization requests (2) reduce distraction of controllers working in the Tower, and (3) increase public access and capacity of the system to grant authorizations. LAANC is expected to dramatically reduce the incidence of noncompliant operations.” From the FAA’s notice in the Federal Register.

Who Benefits from LAANC?

Recreational flyers and non-recreational flyers near the 49 airports involved in the beta test. (See below which airports).

Recreational flyers who want to fly under the protections of Section 336 are required to provide prior notice of operation to “the airport operator and the airport air traffic control tower (when an air traffic facility is located at the airport) when operating within 5 miles of an airport. Recreational flyers can do this by other means but it has been a pain for recreational flyers to find reliable phone numbers and emails of airport operators and ATC towers.

Non-recreational flyers who want an authorization to fly in Class B, C, D, or E at the surface airspace can do so by using the LAANC system. 107.41 requires you to have an authorization. Many have said that a simple phone call is legally good enough. Here is my response to that statement. Regardless of whether it is legal or not, how in the world are you going to prove you have an authorization, assuming you have a verbal one, if the FAA starts asking you if you have one?  The FAA order out of D.C. told air traffic controllers to direct people to the authorization portal and NOT verbally authorize flights. Do you really think the controller who talked to you on the phone is going to have an accurate memory when asked if he authorized you contrary to the order? Furthermore, not all of the phone numbers are recorded which means FOIA does not do anyone any good. (On top of that, the phone line recordings aren’t kept for a long time and there is a good chance you will get investigated AFTER the phone recordings are destroyed). If you record your conversation on a phone, you might be getting into trouble with state wiretapping laws (see two-party wiretapping laws). In short, if you don’t want to go the authorization portal method, this is a nice alternative.

So What Cannot be Submitted via LAANC?

Complex operations cannot go through LAANC. Complex operations would be operations near the airport (in the red no-fly zone on the airport facility maps) or where a waiver is involved (e.g. flying in controlled airspace under your night waiver). If you need help obtaining these more complex airspace authorizations or waivers, contact me. :)

In the same Federal Register notice, the FAA said, “These changes include new branding of the Web site portal DroneZone and improvements to the external customer experience. It’s expected that operations that are relatively simple will go through LAANC’s automated approval process while more complex operations that require a more thorough review by FAA subject matter experts (SME) will go through the FAA’s DroneZone electronic portal.”

Am I Forced to File Via LAANC for Non-Complex Operations? 

No, you can do LAANC or the methods we are currently using, by filing for an airspace authorizations or an airspace waiver.

What Companies Are UAS Service Suppliers for LAANC?

I can’t confirm everything but here is what I have found so far.

A total of “Fourteen companies are participating in the Low Altitude Authorization and Notification Capability (LAANC) process[.]” McNeal Testimony.

 

How Many Airports Will Participate in LAANC?

The FAA is planning on having 49 airports participate.   Greg McNeal wrote in Forbes that there would be 50 but it seems  Green Bay- Austin Straubel International Airport won’t be participating.  (Compare the Forbes article to the FAA’s latest post.)

LAANC-airports

What States Have The Participating LAANC Airports? 

LAANC-states

Problems I See With This Whole Situation:

  • LAANC does NOT tell us if it fixed the problem it is attempting to alleviate. Is the drone sighting report the FAA released going to identify and take out of the total number the authorized flights?  The FAA’s Federal Register post says LAANC is attempting to make things safer while citing the inflated drone sighting numbers. That’s funny. The FAA left in a ton of crummy data in their drone sightings reports so the numbers are inflated and there is no easy way to “clean” the sightings of the 14,334 COAs already issued.  The FAA gave us some big numbers without indicating how many of these “sighting” were lawful or not. What is the logical conclusion? The FAA just cited bad data as the justification for the LAANC system. There have been COAs granted to commercial flyers for over a year and I couldn’t find any indications the FAA “cleaned” the sightings.

How Does LAANC Relate to Unmanned Traffic Management (“UTM”) System?

LAANC is the Low Altitude part of the UTM. “UTM is how airspace will be managed to enable multiple UAS operations conducted beyond visual line-of-sight (BVLOS), where air traffic services are not provided.”

“Concurrently, the FAA and NASA have developed a joint UTM Research Plan to document research objectives and map out the development of UTM. NASA is conducting research at UAS test sites to further explore UTM capabilities that will accommodate rulemaking as it expands opportunities for UAS integration. The FAA expects that UTM capabilities will be implemented incrementally over the next several years.”

Resources:

FAA’s Concept of Operations for LAANC from February 2017 for “INFORMATION ONLY PURPOSES”

Keep in mind this was for only informational purposes. Things might have been changed.

1 Introduction

The Federal Aviation Administration (FAA) is responsible for implementing notification
and authorization (N&A) processes specific to operation of small unmanned aircraft
systems. See Pub. L. 112-95 § 336(a) (5) and 14 CFR § 107.41. From an Air Traffic
Control (ATC) and Air Traffic Management (ATM) perspective, notification of
unmanned aviation activity enables the Air Navigation Service Provider (ANSP) to
provide safe and efficient flight services to all aircraft in the NAS. From a regulatory and
safety perspective, notification of unmanned aviation operations provides a means of
traceability to (1) inform other NAS users, if needed, of unmanned aviation activity in the
vicinity of the airspace in which they are operating; (2) ensure operators are complying
and conforming to regulatory standards; and (3) identify and hold accountable those who
are responsible during accident/incident investigations.

1.1 Background

The FAA is in the process of determining its approach and business plan to integrate
model aircraft, UAS, and sUAS into the NAS. As part of that approach, the FAA is
dedicated to ensuring safety requirements are met for integration of unmanned aviation
into the NAS, where unmanned aircraft are able to operate safely in the same airspace
with manned aircraft. The FAA must ensure that integrated UAS operations meet
appropriate performance standards and access requirements. The FAA seeks to reduce
barriers to access and equitable access to airspace. The FAA’s challenge is to foster
equitable access for all users and providers while ensuring critical ATC technical and
safety requirements are met for NAS operations. In addition, the FAA seeks to foster a
competitive environment for providers of UAS and related services. As the FAA and
industry move toward integration of all types of UAS into the NAS, the FAA
promulgated 14 CFR part 107, which governs non-hobbyist operations of small UAS.
Part 107 contains a regulation that requires receipt of an authorization from the FAA
prior to operating in Class B, C, D, or the surface areas of Class E airspace. In addition,
Congress specified “model aircraft” may not endanger of the safety of the NAS, but are
otherwise exempt from aviation regulations as long as such aircraft are flown strictly for
hobby or recreational use, are operated in accordance with a community-based set of
safety guidelines, weigh no more than 55 pounds, are operated in a manner that does not
interfere with and gives way to manned aircraft, and, when flown within 5 miles of an
airport, the operator of the aircraft provides notification to the airport operator and the
airport ATC tower with prior notice of the operation. Pursuant to this framework, the
FAA requires model aircraft operators provide airport operators and the airport air traffic
control tower (when the air traffic facility is located at the airport) with prior notice of the
operation.

1.2 Problem Statement

The FAA has developed a UAS implementation plan that outlines the long term planning
for UAS integration. There is a limited strategy for identifying and inserting
technological capabilities into existing FAA systems that would enable safe sUAS
operations in accordance with established FAA rules as cited above. The current process
for meeting authorization and notification requirements of existing rules is manually
intensive and therefore costly. In addition, the time to approve authorization in this
manual state is inefficient, preventing some time critical commercial and public
operations (e.g. news, emergency response).

More automation is needed to support the growing demands for safe and efficient sUAS
operations in the NAS. The FAA has limited resources to respond to the need for
automation development to support sUAS. At the same time, industry has shown an
interest and capability to provide sUAS services as a critical element of future UAS
Traffic Management (UTM).

A critical element associated with such automation will be information sharing among the
various entities responsible for sUAS operations. However, currently there are no
conventions or standards for exchanging information between FAA and external entities
about sUAS operations. Given the many FAA systems that comprise the NAS and
associated support capabilities, conventions for the secure, safe, and orderly exchange of
sUAS-related information are needed to enable sUAS operations to scale safely and
quickly enough to meet the anticipated rapid growth in demand expected.

1.3 Purpose and Scope

The development of a fully functioning and streamlined, user friendly N&A capability is
complex and subject to a variety of inputs and coordination points across the UAS
community. This document will give stakeholders and leadership the necessary
contextual information to understand and provide input on the FAA’s Low Altitude
Authorization and Notification Capability (LAANC) development, demonstrations, and
fielding.

The LAANC demonstration effort is constrained by the following resources and
regulations:

– Policy: This project will leverage sending information to 3rd party systems,
allowing them to provide authorizations, and submit operational information back
to the FAA. This poses a number of policy and legal issues that will need to be
addressed along the way.
– Financial: The FAA will not be providing capital resources for the purchase or
acquisition of software programs or systems, or in conducting demonstrations of
proposed solutions. Existing systems in use at this time are expected to be adapted
to work according to requirements identified in the N&A effort outlined herein.

2 Current Operations & Shortfalls

Currently there is no means of automated authorization or notification between UAS
operators and ATC. This is because the FAA’s and ANSP’s notification information
needs with respect to UAS operations depend on a number of factors, including the type
of UAS operation being conducted, where it is conducted, what services (if any) are
required, what the UAS capabilities are, and more. Identifying and implementing
notification requirements appropriate to specific UAS operations would allow the FAA,
safety organizations, and regulators to process and access flight data in accordance with
their organizational needs and responsibilities.

Specific information requirements about a UAS operation may vary commensurate with
the risk of the operation. For example, ATC and/or the FAA may require more
information about the proposed UAS activity and more explicit procedures and
automated support for the delivery and handling of that information as the risk of the
operation increases. The basic information needs, though, should generally be consistent
across operations.

Non-hobbyist operators of sUAS must comply with 14 CFR part 107 (“Small Unmanned
Aircraft Systems”). The following general criteria illustrates the use cases1 for
identifying whether a given low altitude operation requires notification only or request
for ATC authorization.
a. To be considered a model aircraft operator, the operator must notify an Airport under
Public Law 112-95 § 336(a)(5):

 When the UAS is flown within five miles of an airport: the operator of the
model aircraft provides the airport operator and the airport air traffic control
tower (when an air traffic facility is located at the airport) with prior notice of
the operation.
 Model aircraft operators flying from a permanent location within five miles of
an airport: the operator can establish a mutually agreed upon operating
procedure with the airport operator and the airport air traffic control tower
(when an air traffic facility is located at the airport).

b. For all sUAS operations under 14 CFR Part 107:

 No person may operate a small unmanned aircraft in Class B, Class C, or
Class D airspace or within the lateral boundaries of the surface area of Class E
airspace designated for an airport unless that person has prior authorization
from Air Traffic Control (ATC). Please refer to Appendix A to Attachment 1
for a description of airspace types.

Note: There is no requirement for authorization in Class G airspace, however notification
is required within five miles of an airport regardless of the airspace class in which the
airport resides.

2.1 Operational Shortfalls

The new FAA UAS rules introduced in 2016 address the requirements for operators of
sUAS. Recently, the FAA developed an initial set of requirements for both notification
and authorization, based on the premise that authorization be automated to the greatest
extent practicable. Those operational requirements were delivered under separate cover
and provided as information to stakeholders. The current operational shortfalls are
1 Specific scenarios for the above use cases can be found in Attachment 1 to this CONOPs. The scenarios
identified to date are not exhaustive, but instead are the first scenarios prioritized to be addressed with the
LAANC system. The FAA will continue to work with industry to identify additional scenarios and use
cases that will be addressed by LAANC as part of ongoing collaboration with industry.
inefficient processes for obtaining authorization or notifying ATC of operations, the
timeline required to obtain authorizations from FAA, and the growing backlog associated
with current processes.

The FAA has established a process for commercial sUAS operators, operating under 14
CFR Part 107 to request a waiver of operation or authorization. A manual form has been
created that allows operators to enter data into the FAA’s system. The data is forwarded
to a review directorate in FAA. The FAA quotes, “The FAA will strive to complete
review and adjudication of waivers and airspace authorizations within 90 days; however,
the time required for the FAA to make a determination regarding waiver/airspace
authorization requests will vary based on the complexity of the request.” Because the
FAA’s current process depends on a manual review of every request, the time to
complete the request is lengthy and costly. Because the review is manual, there is already
a backlog in completing the review of requested waivers and authorizations.
Since late 2015, the FAA has registered more than 500,000 hobbyist sUAS operators,
with that number expected to grow significantly. The number of sUAS flights is
expected to increase dramatically as the new rules expand to enable new types of
operations and are further clarified regarding where and how sUAS flights can be
conducted. Operators will be seeking ways to fly safely while complying with the
governing rules. Processes and electronic systems supporting these rules and associated
sUAS operations are needed now.

2.2 Technology Gap

Technologically, UAS operators and the FAA need a streamlined, efficient, solution to
enable notification and authorization. At this time, the primary ways in which UAS
operators and ATC communicate for the purpose of notification and authorization is
through submission of a web form on the FAA website, which then uses other forms of
communication to process the data. The FAA is seeking to close the gap of manual versus
automated data transfer and authorizations by defining and establishing a technological
solution that will allow for data exchange between operators and ATC. A demonstration
of an initial solution is envisioned as the first step in closing this technology gap.

3 Guiding Principles

3.1 LAANC

Low Altitude Authorization and Notification Capability (LAANC) is the broad term for
an enterprise capability to automate to the maximum extent possible the ability for FAA
to grant authorization to CFR Part 107 operators under 14 CFR 107.41 and to allow for
model aircraft operators to notify ATC of planned operations within 5 miles of an airport
as described at Pub. L. 112-95 § 336. LAANC major elements include the FAAs
provision of authenticated map data for use in determining authorization, the use of third
part providers (TPP) to provide services to operators, and the ability for multiple TPP to
provide services. Generally, LAANC should encourage participation of operators in
creating an environment of inclusiveness and ease of use.

3.2 Notification

Notifications resulting from model aircraft operators under Pub. L. 112-95 § 336 are the
result of data sent from UAS operators to ATC to provide situational awareness about
operation events planned in a particular airspace. Notifications are those transactions sent
one way from UAS operator to ATC.

3.3 Request for Authorization

A request for authorization will contain data from a small UAS operator to a third party
provider (TPP) providing key parameters about an operation. The FAA may approve or
deny such requests in accordance with 14 CFR 107.41.

3.4 Authorization

Authorizations are the result of data sent from the TPP and by extension ATC, to an
operator regarding a specific request received asking permission to operate in a particular
airspace, operating under CFR Part 107 rules.

3.5 Remote Pilot Operator & UAS Operations in Airspace

The term “PIC” is specific to the person who is ultimately responsible for the operation
and safety during flight. The term “FAA” refers to the agency, or an unspecified entity
within the agency, as well as the ANSP. The term “ANSP” is a specific individual who
manages flight traffic on behalf of the FAA.

3.6 Use cases and scenarios

Scenarios for the existing use cases identified to date do not represent an exhaustive list
of notification and authorization challenges that will be addressed by implementation of
LAANC system or initial demonstrations. The urgent need for an initial LAANC solution
to enable time sensitive operations and expedite the authorization process has required
prioritization of scenarios that will guide stakeholders in development of an initial
demonstration event. The FAA will focus efforts to establish requirements for the
LAANC system using the scenarios referenced in Attachment 1. Through workshops and
continued collaboration with industry, the FAA will solicit and develop additional use
case scenarios to be prioritized as the LAANC demonstration and implementation effort
progresses.

3.7 Collaboration between Industry and FAA

It is expected that the FAA will work with industry partners to establish the LAANC, and
conduct a successful proposed solution demonstration, with an understanding that no
decisions have been reached on the implementation of LAANC services.

3.8 Collaboration within Industry (Industry to Industry cooperation)

It is expected that industry stakeholders will collaborate with each other as well as the
FAA, through and within workshops, demonstration(s), data exchange partnerships, and
in the overall development of the LAANC nationwide solution.

4 Assumptions

Following are assumptions associated with LAANC. The assumptions include key
integration assumptions as well as those specifically applicable to the sUAS operations
described in this document:

1) Information on airspace class designations and airport locations will not be
provided via Application Programming Interface (APIs) associated with N&A
functions or web services. Due to the static nature of such data and public
availability, Third Party Providers (TPPs) are expected to obtain this information
outside of the N&A processes.

2) N&A APIs will be limited to the smallest function practicable (e.g., via “micro
web services”) to ensure scalability and flexibility. (I.e. one API per functional
requirement instead of one API that spans multiple functional requirements).

3) N&A APIs will be versioned to accommodate additional phased capability as that
capability is introduced.

4) Future LAANC capability will be provided through the FAA’s system wide
information management (SWIM). Interfaces to SWIM and exchange methods
will be established for operational connection in future efforts.

5) Operator’s registration numbers may be used as unique identifiers if required to
amend submitted approvals. For sUAS operators under 14 CFR part 107, unique
certification numbers will be used.

6) Responsibilities and requirements that are deemed to fall outside FAA’s scope
(operator side) are the responsibility of the operator and TPP. The FAA will not
assign responsibility to one or the other. In order to avoid undue dependency on
TPPs, these responsibilities are expected to be established by mutual agreement
between the parties.

7) All Hobbyist operators must comply with Part 101.41: (e) When flown within 5
miles of an airport, the operator of the aircraft provides the airport operator and
the airport air traffic control tower (when an air traffic facility is located at the
airport) with prior notice of the operation. This differs from Part 107 (see item 6)
in that the Part 101 requirement is based on a prescribed distance from an airport
rather than a particular airspace designation.

8) 14 CFR Part 107 operators must comply with Part § 107.41: Operation in certain
airspace. No person may operate a small unmanned aircraft in Class B, Class C,
or Class D airspace or within the lateral boundaries of the surface area of Class E
airspace designated for an airport unless that person has prior authorization from
Air Traffic Control (ATC).

9) LAANC will service the well informed/well intended operator and will actively
encourage participation in the FAA’s goal of ensuring safe NAS operations for all
aircraft types.

5 Implementation Alternative

A set of operational requirements for notification and authorization was delivered in 2Q
FY16. The FAA investigated several alternatives to achieving the requirements and in 4Q
FY16 issued a request for information (RFI) to industry to gain an understanding of the
state of industry with regard to this capability. Based on the results of that RFI, the FAA
is currently pursuing an alternative where the FAA provides for data exchange with
TPPs. In this alternative the FAA provides authenticated map data and TPPs provide
resulting authorization and notification data to the FAA via an API. All vendors provide
format of data in accordance with FAA needs. Any business model for fee collection
from operators is developed by individual TPPs. The FAA will retain a separate web
interface for authorization requests and notifications.

6 Description of Key Services

Automated notification is essential to facilitate sUAS operator submission of all required
flight information, retrieval of that information by ATC facilities and/or FAA, and
provision of feedback from ATC to the UAS operator if necessary. Operators submit
their notifications through a TPP interface or through the FAA’s web portal for
notification/authorization. Based on the Operator’s planned operating type, the
operating area, and altitude indicated by the UAS operator, the TPP indicates to the
operator whether ATC authorization is required (i.e., the operation, or portions of the
operation, will be in controlled airspace), whether they may operate without authorization
(i.e., the entire operation will be in uncontrolled airspace), or whether they will be
operating within 5 miles of an airport.

If ATC authorization is not required, and the operation is one in which the operator
would provide notification to an airport operator and airport air traffic control tower
(when an air traffic facility is located at the airport), the TPP forwards the notification to
the FAA, where the information is available for distribution to other appropriate airspace
users, and is stored for traceability and data analysis purposes. If ATC authorization is
required, the TPP uses FAA authoritative facility map information (UAS Facility Map;
UASFM) and approved FAA business rules to automatically determine whether a flight
can be authorized and forwards the authorization information to the FAA through an API.
Automatic authorizations are provided to the operator. The FAA internally makes that
information available to ATC at the affected airport(s). If such automatic authorization is
not possible, the operation will be denied the opportunity for reconsideration. If a
reconsideration is requested (e.g., a different altitude or time), the request is forwarded to
the appropriate ATC authorities that provide feedback electronically via the TPP to the
UAS operator. If the operation has been authorized, either by the TPP using authoritative
maps or by appropriate ATC entity, the UAS operator may operate within the parameters
authorized by the action. If the operation has been denied, the UAS operator may review
the reasons for denial and modify the proposed authorization request accordingly (e.g.,
choose a different start time, different operating area), and resubmit the request for
authorization.

Lead times for submitting a notification depend on whether ATC authorization is
required. For instance, if only notification is required, the UAS operator may submit the
notification shortly before commencing the operation. ATC may impose time restrictions
on the pre-notification process to ensure no hazards exist in the timeframe in which the
operation occurs. However, if ATC authorization is required for the operation, the UAS
operator is required to submit the request for authorization in accordance with the
directions ATC provides for the specific airspace. The minimum lead times for
submittal, as well as lead times for providing ATC feedback will be determined and
specified by the FAA.

The FAA anticipates the current process of manual direct coordination with FAA, which
could take 90 days to complete. That process is envisioned to remain in place as LAANC
is introduced and after LAANC is fully operational, and future demand on the manual
process is likely to decrease as a result.

6.1 Distribution of Notification Info to Other Airspace Users

As previously mentioned, all unmanned aviation flight information—regardless of
whether flights require ATC authorization—are submitted to the FAA via an interface
with the TPP.

Information dissemination could be facilitated by the same notification mechanism used
for ATC submission, or by other means. Regardless of how this is done, all NAS airspace
users must have access to information about planned and active UAS operating areas
relevant to them. Disseminating UAS activity to other airspace users ensures safety of
flight as UAS present additional safety concerns due to the ranges of UAS physical, flight
performance, and operational characteristics that vary significantly from manned aircraft.
This information could be disseminated via TPPs, where those TPPs share information
with each other, or could be done through FAA central distribution of collected
information. In either case, the data would be sanitized to remove proprietary, personal,
or secure information. Sanitized information would provide sufficient data to act and
avoid by other sUAS or manned aircraft in the area.

Users of the NAS vary considerably. In this context, NAS users include sUAS operators,
model aircraft operators, as well as general aviation (GA) airspace users and commercial
carriers. NAS users are required to review published notification information for relevant
UAS activity along their intended routes of flight. For this information to be accurate and
timely, UAS operators are responsible for adhering to regulations and following proper
N&A procedures. This includes ensuring that information accurately reflects their
proposed operation, and that operations do not occur outside of the parameters of their
notification.

Follow-on development work associated with the notification concept would include a
more accurate determination of the circumstances in which dissemination of information
to other airspace users about UAS operating areas is required. The FAA is responsible for
determining the process and mechanisms for routing, storing, and managing notification
information, and for distributing the most current information to other airspace users.

6.2 Use of Third Party Providers

The FAA is pursuing the provision of LAANC services using private TPPs to provide
services specific to sUAS operations. Such services would be accomplished through an
exchange of information between the FAA and the third party, whereby the third party
would be the primary interface to the operator. The third party would use authoritative
map information and business rules provided by the FAA to authorize sUAS operations
in an area, at a particular time, under a set of conditions. The following paragraphs
outline the operational requirements of the overall system.

The operational requirements call for an automated ATC N&A system or service that
would eliminate the need for operators to call ATC directly or make requests via the
FAA’s webpage, and would limit overall operator interaction with ATC. This requires the
system/service to incorporate the following information:

 Real-time information on airspace status (e.g., Controlled Airspace, Special Activity
Airspace)
 Available projected information on airspace status (e.g., Controlled Airspace, Special
Activity Airspace)
 UAS Facility Maps (UASFM) that indicate “pre-approved fly zones” and “areas that
require further ATC coordination”

– For each airport, ATC (in collaboration with the airport operator) would develop
UASFM.
– Within each grid on the map, ATC would identify maximum altitudes at which
flight is permitted without further coordination.
– Airspace at or below the maximum altitudes would be “pre-approved fly zones”
and airspace above the maximum altitudes would be “that require further ATC
coordination.”

 Other “areas that require further ATC coordination” designated outside of airportspecific
maps (e.g., areas in which sUAS operations are prohibited under 14 CFR
99.7 and/or Pub. L. 114-190 § 2209)

The operator may use the TPP’s system to determine the viability of his/her proposed
flight operation as a planning function. Based on the operator’s input for proposed
operating area, altitude, date, start time, and duration, the “Planner Tool” would
determine whether each proposed flight operation would be within one or more of the
following:

(a) Five miles of an airport, or within Class B, C, D, or Class E surface area;
(b) Any airport-specific “areas that require further ATC coordination”;
(c) Special Activity Airspace where operations are prohibited; and
(d) A “no-fly zone” (outside of airport-specific maps).

If a proposed model aircraft flight operation is outside five miles of an airport, then ATC
notification is not required. Similarly, if a proposed sUAS flight operation will occur only
in Class G airspace, then 14 CFR part 107 does not require ATC authorization. If ATC
notification and/or authorization is not required, the operator (or designee) may
nonetheless voluntarily submit their proposed flight information through the TPP
interface. If no airspace restrictions exist, the system will provide confirmation to the
operator that the flight information has been received.

If the operation requires ATC notification or authorization, the operator (or designee)
must submit their proposed flight information via the system’s Flight Information
Submittal Tool. If the operation is within an airport-specific “area that requires further
ATC coordination” and outside of Special Activity Airspace where operations are
prohibited (in the vicinity of the airport), the system will automatically deliver
acknowledgement or authorization regarding the operation. Conversely, if the operator
(or designee) submits their proposed flight information, and the operation is within an
airport-specific “area that requires further coordination” or within Special Activity
Airspace where operations are prohibited (in the vicinity of the airport), the system will
automatically deliver a message denying the operation. Small UAS operators who operate
in accordance with part 107 will have the opportunity to further discuss their request to
operate in controlled airspace with ATC.

7 Overarching Roles & Architecture

There are five major roles defined for the concept; Operator, Third Party Provider, FAA
Processor, FAA ATC, and FAA Map Provider. The high level interaction among the
roles is described in section 7.6.

7.1 UAS Operator

Operators are people or organizations that are external to the FAA and that must follow
the rules outlined in 14 CFR part 107, Pub. L. 114-190 § 336, or a certificate of
authorization the FAA has issued to them under Pub. L. 114-190 § 333. .
Operators will submit required UAS operations information to a third party either via an
operator interface or possibly in bulk (for multiple planned Part 107 flights). Information
requirements are being developed at this time.

 

OperatorType of RequestThird Party ResponseFAA Response
Operators providing notification pursuant to Pub. L. 112-95 Section 336NotificationAcknowledgeNone
Part 107 sUAS OperatorAuto Authorization  “Fly without Further Coordination”AuthorizedAcknowledge and provide authorization message
Part 107 sUAS OperatorAuto ResponseNot-AuthorizedNone: state “Further Coordination Required”
Part 107 sUAS OperatorAuto ResponseNot-AuthorizedNone; Clarify the request involves “Special Activity Airspace”
Part 107 sUAS OperatorManual Authorization “No-Fly Zone” DiscussionAcknowledged and Sent to FAASecondary Contact (Direct Contact with Operator)
Operators providing

notification pursuant

to Pub. L. 112-96

§ 336

Notification “No-Fly”AcknowledgeProvide statement to

operator that the

operation could

interfere with other

operations in the

NAS and/or at an

airport

7.2 Third Party Provider

Third Party providers (TPPs) will provide Notification and Authorization communication
services on behalf of the FAA. TPPs are expected to be private entities, such as
corporations. They provide the primary interface to the operator via system application
software that is likely to include mobile applications. Each TPP will use only FAA
sources such as authorized UASFM, Special Use Airspace (SUA), TFRs, NOTAMs, data
to automatically provide, where feasible, confirmations of notification and authorizations
to UAS operators. Each TPP will obtain Environmental Systems Research Institute
(ESRI) based Geographic Information Systems (GIS) map data
(www.uas.faa.opendata.arcgis.com) from a designated repository, managed by the FAA
aeronautical information service organization (AJV-5) , and will maintain current map
data in accordance with FAA-provided notification of new map data availability.
The TPP will manage communications and messaging with the operator and with the
FAA. As an example, the TPP will provide standard messages to the operator based on
the determination made (e.g. “operation is authorized”). The TPPs will manage and store
all the records of authorization and notification requests in protected areas based on
SORN (Systems of Records Notices) requirements. The TPP will send authorization and
notification records (and or mapped data) to the FAA for display to ATC. Finally, the
TPP will manage Part 107 operator secondary requests for authorization once automatic
denial has been provided.

The level of governance for TPPs has not been determined. All interfaces to the FAA
where a TPP is exchanging information with the FAA will be tested, proven, controlled
and securely managed. There is currently no plan by the FAA to “authorize” or certify a
provider. However, a mechanism might be developed whereby the services provided by
a TPP will be monitored for performance and to collect metrics (e.g. numbers and types
of authorizations processed and associated error rates).

7.3 Air Navigation Service Provider (ANSP)/FAA Processor

In the operating concept, the FAA will provide a standard gateway for processing
messages between third party providers and FAA end users (e.g. ATC or Service
Centers). The FAA will also provide processing services to display information to meet
the FAA users’ needs. The gateway serves as a routing function for display and storage.

7.4 FAA ATC

In the operating concept, air traffic control personnel at a facility (or at a centralized
location) will have an ability to see authorizations, notifications, and waivers as
processed by a third party provider and sent to ATC.2 TPP will not be able to process
waivers, but will have an ability to allow the operator to enter the waiver information for
FAA review. Processing of authorizations may be accomplished at a centralized location
or at individual facilities. If processing of authorizations occurs at a centralized location
(e.g., FAA regional service centers), ATC personnel at affected facilities will have
situational awareness of the authorizations and notifications and will be provided with an
ability to override requested operational actions. ATC personnel will have the ability to
review all actions (Authorizations, Notifications, Waivers) affecting their respective
airspace and will have the ability to reject, accept, acknowledge, or perform additional
review. The method(s) of providing authorization, notification, and waiver information
to ATC personnel has not been determined. Early implementation may be accomplished
by email, or internet access if internet access is available. Operational procedures
detailing the interaction of ATC with the authorization and notification system have not
been determined.

7.5 FAA Map Provider and Special Instructions

In the operating concept, the FAA will provide the UASFM data to be used in
determining authorization and notification. Map data will be made available through
automation. The FAA mapping organization will provide map data on a periodic basis,
initially on a 56 day update cycle, using ESRI standard formats and functionality, with a
long term goal of providing real-time updates. The mapping organization will also
collect available information on other airspace limitations imposed by existing
NOTAMS, TFRs or regulation.

 

Jonathan Rupprecht

Mr. Rupprecht is an aviation attorney who focuses on drones. Read more about his background as a commercial pilot, flight instructor, Embry-Riddle Aeronautical University grad, and legal author. He has had media appearances on Forbes, Newsweek, Politico, NPR, Marketwatch, The Independent, Motherboard, and other sources. Feel free to send Jonathan a message here.

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