Eno’s Aviation Working Group has been meeting regularly to discuss ways to integrate unmanned aircraft systems (UAS) into the national air space. Determining how these devices are integrated is a critical imperative facing the industry and the federal government. It will define how aviation advances in the coming decade. While the 2018 5-year FAA reauthorization addressed some of these issues, it mostly lays the groundwork for future rulemaking.

One of the critical rulemakings is Remote ID, which would standardize the transmission of UAS identification information to other parties. This rulemaking is moving slowly through the regulatory process. In the meantime, UASs large and small are proliferating under a set of rigid standards to ensure safety. Remote ID will allow for more flexible rules, but in order to operate a UAS outside of those rules, (for example, one that that is heavier than allowed or beyond visual line of sight) operators, manufacturers, and testers must ask for an exemption or waiver from existing rules. Or, of course, they may certify unmanned aircraft much in the same way as manned aircraft.

The focus of the Working Group’s upcoming white paper is how that waiver and exemption process – and certification in general – is working and how it can be improved. To inform that research, from now until October 18, 2019, Eno is conducting a survey of operators asking them details of their experience applying for waivers under Part 107 and exemptions under the old Sections 333 or new 44807. The survey focuses on how the waiver/exemption process impacts the bottom line of a UAS business, the quality of communication between the FAA and applicant, and how special provisions at the end of the process impact a company’s business model.

Eno’s Aviation Work Group will include the survey’s findings in a broad set of recommendations to the Congress and Department of Transportation.