While aircraft capable of flight without an onboard pilot have been around for decades, the concept of unpiloted aircraft has garnered significant attention in recent years. That’s not surprising. Government and civilian operation of “unmanned” aircraft is a publicly known fact that continues to gain steam. As of 2008, the United States Air Force (USAF) operated 5,331 unmanned aerial vehicles (UAVs); double the number of its piloted aircraft. In 2012, the Air Force trained more drone pilots than jet pilots; an unprecedented occurrence. Such explosive growth is not limited to the military either. Civilian operation of remotely piloted aircraft continues to expand into new areas of utilization.
As humanless flying machines become more and more prevalent, their presence and operational capabilities continue to spark numerous questions and debates. A fair percentage of these questions appear to come from the recreational, radio-controlled aircraft (RCA) community. That’s understandable. After all, publicly known pilotless drones patrolling the nation’s skies will get public attention and comment, which invariably leads to new government regulations. While regulatory oversight is absolutely necessary for multi-ton machines overflying populated locales, such regulations probably won’t prove advantageous at the RCA level. To protect the hobby from unnecessary government burden, one essential step is to determine the characteristics that separate recreational RCAs from commercial & government UAVs.
That’s easier said than done. In many instances, the line separating RCAs and UAVs is essentially nonexistent. The two aircraft types share several common characteristics, causing black and white definitions to blur into gray. As the government has yet to define clear-cut differences between the two aircraft types, many operators are left guessing as to what (if any) regulations they need to follow. Although Congress has given the FAA until September 30, 2015 to assimilate UAVs into the nation’s airspace system, that still means operators are left to fend for themselves in the interim.
Defining the Boundaries
In an attempt to assist operators of pilotless aircraft, I’ve spent some time sifting through the mass of materials, procedures, and precedents available that might help shed some light on the issue. Throughout this document, you’ll see standards (or the closest thing currently available) to help guide you in your operations. Please bear in mind that much of the included material is for guidance only. Just a portion of the information is currently subject to federal law or regulation. Additionally, the parameters below will likely be significantly altered or redefined in the coming years. However, this compilation still offers us a bit to go on for the present.
Before we get too specific, let’s consider some generally agreed-upon definitions of the two aircraft categories. Later on, we’ll delve a bit deeper into specifics of several other aspects.
Unmanned Aerial Vehicle: According to Wikipedia, a UAV, or drone, is controlled either autonomously or by remote control of a pilot. While remote piloting was the norm for many years, autonomous control has since become the standard method of operation. DIY Drones echoes this definition; claiming that UAVs have the capacity for autonomous flight and navigation. The Academy of Model Aeronautics (AMA) adds that drones are “computer-controlled for nearly their entire flight.” Apparently, as long as the autonomous system is in place and capable of functioning, the aircraft remains a UAV, regardless of whether or not the autonomous system is in use.
Radio-Controlled Aircraft: By contrast, RCA (as the name implies) are controlled with a handheld radio transmitter, which communicates with a receiver aboard the aircraft. The receiver directs the aircraft’s servos to move the control surfaces based on pilot input.
Based on the above definitions, one could argue that failure or removal of autonomous system components would effectively relegate a UAV to RCA status. Going about it the other way, Chris Anderson of DIY Drones states, “A[n] RC plane becomes a UAV with the addition of an autopilot.” AMA’s definition is predicated on the amount of autonomous flight. Per their website, AMA claims that an RC flier “manually controls the aircraft via R/C for nearly the entire flight.” Even if an autopilot is installed and occasionally used, AMA maintains that an RC remains an RC. Regardless of whose definition is most accurate, everyone seems to agree that to be a drone, an unmanned aircraft must be equipped for autonomous flight.
RCA: Nearly everyone seems to agree that R/C aircraft are operated for recreational purposes only. AMA’s Chris Burns claims the organization’s safety code “does not allow our members to fly for commercial purposes…” The FAA’s website states that model aircraft fliers don’t need any sort of FAA approval, but stipulates that such RC flights “are not for business purposes.”
Drone: In contrast to RCA, one of the generally agreed-upon requirements for UAVs is that these aircraft are mission-oriented, transport a payload, or otherwise perform some sort of practical function. While such pursuits have historically been for military purposes, commercial and non-military governmental UAV application continues to expand into new sectors. Some current drone uses include firefighting, aerial surveillance, police duties, homeland security, mapping/photography, wildlife & livestock monitoring, traffic reporting, and surveying for mineral deposits & fossil fuels. With time, it’s anyone’s guess as to how widespread drone usage will become.
Aircraft (System) Certification
RCA: Currently, unoccupied aircraft that are flown strictly for recreational purposes aren’t subject to FAA certification or oversight – provided they comply with certain operating conditions (discussed later). This could very well change in the future, but at present, RC hobbyists have done a commendable job of self-policing their activities.
Recreational UAVs: Despite the fact that many hobby aircraft are equipped for extended-duration autonomous flight (as discussed above), in the eyes of the U.S. government, these vehicles are viewed as a type of RCA. Such aircraft are not subject to FAA certification, provided they abide with the operating conditions specified for RCA.
Commercial RCAs: All recreational, unpiloted aircraft are prohibited from engaging in any type of commercial activity. To be eligible for commercial operations, the system(s) must meet the equipment and certification requirements of actual drones (specifics to follow).
Government Drones: To operate in the national airspace system (NAS), government UAVs must obtain a Certificate of Authorization (COA) or Waiver. One of the eligibility requirements for a COA is the sponsorship of a public (meaning government) entity.
Government RCA: This aircraft category technically doesn’t exist. Any unmanned government aircraft are actually UAVs, regardless of whether or not they’re being operated autonomously at any given time. Years ago, remotely piloted drones might have been considered RCAs before the development of reliable autonomous systems.
Commercial UAVs: To operate drones for business purposes, civilian (non-government) organizations must obtain a Special Airworthiness Certificate – Experimental Category prior to conducting commercial flights in the NAS. The certificate applies not just to the aircraft, but to the entire unmanned aircraft system (UAS); including the ground control station, control link/specialized datalink, and any additional support equipment. The certification process usually takes 60-90 days and requires the drone to obtain an FAA registration (“N”) number. At present, the FAA is only issuing commercial UAV certificates for research & development purposes.