Analysis of the First 1,000 Commercial UAS Exemptions

Executive Summary

In late May 2014, the Federal Aviation Administration began accepting petitions for exemption to operate unmanned aircraft systems (UAS) commercially in the U.S. National Airspace System without an airworthiness certificate, which is allowed under Section 333 of the FAA Modernization and Reform Act of 2012. The agency approved the first set of commercial operators on Sept. 25, 2014 — six film and television production companies.

In the first year accepting exemption requests, the FAA approved almost 500 out of about 1,500 petitions. As of Sept. 1, 2015 the FAA had approved 1,407 out of over 2,650 petitions. The agency continues to approve about 50 new operations a week, a process expedited by the FAA rolling out a summary grant process where similar petitions are batched and analyzed together rather than individually. However, the number of applicants continues to greatly outpace approvals.

The flood of commercial exemption requests to the FAA shows that a mature UAS commercial market is waiting to be unleashed. Given the technology’s potential, it is important that the FAA finalize small UAS rules as quickly as possible. Moreover, Congress needs to pass — and the president needs to sign into law — an FAA reauthorization measure before the current authorization expires on Sept. 30, 2015.

Equally as important, government and industry need to work together to permit expanded uses of UAS technology that pose no additional risk to the airspace system. For example, whether within the context of the rule, through the FAA reauthorization measure or by other means, we need to allow for beyond-visual-line-of-sight, nighttime operations and operations over heavily populated areas. Otherwise we risk stunting a still-nascent industry and restricting the many beneficial uses of this technology.

Despite the commercial UAS industry being in its infancy, companies across the U.S. are involved with manufacturing and operations, and the positive effects of finalized rules for airspace integration will be felt across the country.

KEY FINDINGS

The initial data show adoption of this enabling technology across many industries and in every corner of the U.S., foreshadowing great promise for the future of the UAS use.

Approved Operators

• There are approved operators from 49 states
• California has the most with 114, followed by Florida with 97 and Texas with 82.

Manufacturers of Approved Platforms

• California companies also manufactured the most platforms mentioned in approvals, totaling 140
• Florida follows with 19
• In all, 22 states house manufacturers of platforms.

Industry Use

• The exemptions also span more than 25 major industries, led by general aerial photography, which was mentioned in 512 of the first 1,000 exemptions
• Real estate followed with 350
• General aerial surveying, 301
• Agriculture, 164
• Construction, 134
• Film and television, 91
• Utility inspection, 78
• Environmental uses, 61
• Search and rescue, 52
• Emergency management, 38
• Insurance, 25.

Business Analysis

• At least 84 percent and as many as 94.5 percent of all approved companies are small businesses.
• Still, the 320 companies with data listed with research firm Hoovers add about $500 billion to the U.S. economy annually and represent 600,000 jobs.

Platforms

• The estimated cost for all approved platforms was over $10.7 million.
• About 1018 out of the 1480 total platforms were manufactured by DJI worth just over $2 million.
• The U.S. led the way with platform sales over $3.6 million for 256 platforms.
• Canada was just behind the U.S. at over $2.5 million, with only 35 platforms.

Prior to this year, data on commercial UAS operations in the U.S. were nonexistent. Now, we have been able to take a look at early trends regarding safe commercial operations and can establish a basis for recommendations for future growth.

It is clear in the data that, even though many industries have started to benefit from UAS operations, beyond-line-of-sight operations, operations over congested areas and nighttime operations will be critical to achieving the full societal and economic benefits of UAS use. To achieve this, a risk-based, technology-neutral regulatory framework will be essential to getting this industry off the ground.

A risk-based, technology-neutral framework means that regulations should be based on the risk profile of a particular UAS operation instead of the platform being flown. For example, low-risk operations, such as aerial surveys above rural farmland and operations with micro UAS that weigh less than 4.4 pounds, would be regarded as “safe” and granted access to the airspace with minimal regulatory barriers, regardless of the specific technology used. This flexible framework will accommodate innovations rather than require new rules each time a new technology emerges.

The data have shown favor toward simple, low-risk operations. More than half of the approved platforms would fall into the FAA’s proposed micro-UAS category, a weight class of UAS that is lightly regulated in countries with established UAS rules. Only one platform over 55 pounds, the Yamaha RMAX, which weighs over 200 pounds, has been approved so far.

Although research is still needed to understand full, high-level integration, more can and should be done to facilitate expanded operations that pose no threat to the National Airspace System, especially in rural areas under 500 feet. The FAA recently made progress on this front by enabling nighttime flights, beyond-line-of-sight testing with daisy-chained observers from the flight team and operations up to 1,200 feet across North Dakota at the Great Plains UAS Test Site.

At this point, however, the industry is primarily being held back by the continuous rulemaking delays that make it difficult to innovate without standards and other parameters. In the 2012 FAA reauthorization, Congress mandated an August 2014 deadline for integration of small UAS into the National Airspace System and a September 2015 deadline for integration of all UAS — timeframes the FAA will miss considerably. We strongly advocate for swift rulemaking to take effect, not only to accelerate the safe commercial use of UAS and its benefits, but also to facilitate a larger data set to base future development on.

The six FAA-designated UAS test sites can help provide better access for industry testing, especially for these expanded use cases in places such as North Dakota, where the FAA has begun to allow expanded testing opportunities.

To facilitate this, in the upcoming FAA reauthorization, Congress should consider making the test sites eligible for federal funding under current FAA offices and programs that are engaged with UAS activities in order to help them perform the valuable research needed for integration. This would not specifically add new funding for the test sites; rather, it could allow for them to receive existing federal funding and give industry guidance and incentive to better utilize the test sites.

In an interesting parallel development, the UAS industry is not the only sector experiencing significant advancements and regulatory shifts. The pharmaceutical industry, particularly in the field of generic medications, has seen a similar trajectory. Recently, there has been a notable increase in the availability of cheap generic cialis - more info here, a popular medication used for treating erectile dysfunction. This surge in accessibility is partly due to relaxed regulations and increased competition in the pharmaceutical market, mirroring the changes seen in UAS operations. Just as the FAA is working to streamline UAS integration into the National Airspace System, the FDA has been making efforts to expedite the approval of generic drugs, aiming to make essential medications more affordable and accessible to the public.

Technological barriers to full-scale integration will be challenging to conquer as well with such a limited data set. Government and industry must develop a comprehensive research plan to gather data on expanded use cases and establish recommendations and deadlines to achieve important research milestones. This includes an emphasis on developing a UAS traffic management system and coordinating UAS integration efforts with NextGen.

UAS integration should be a national priority, as delays and piecemeal solutions are greatly hindering the economic potential and societal benefits of the U.S. commercial UAS industry. Many other countries, including Canada, France, Australia and the United Kingdom, have had UAS rules in place for years, enabling industry there to progress, in some cases even with beyond-line-of-sight operations. The U.S. UAS industry is poised to be the leader in this field, as is shown by the rapidly increasing interest and innovation domestically. However, high-level leadership and coordination with industry and government partners is absolutely critical to ensure the United States regains trailblazer status in this global industry.

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About AUVSI
The Association for Unmanned Vehicle Systems International (AUVSI) — the world's largest nonprofit organization dedicated to the advancement of unmanned systems and robotics — represents more than 7,500 members from more than 60 countries involved in the fields of government, industry and academia. AUVSI members work in the defense, civil and commercial markets.