FAA COA Process for UAS Proves to be Elusive for ERM

Explosives Risk Managers LLC (ERM) submitted its first Certificate of Waiver Authorization (COA) for civilian operation of unmanned aircraft systems (UAS) to Federal Aviation Administration (FAA) today.  COA approval from the FAA is necessary to operate UAS commercially under a Section 333 exemption from FAA rules.  Currently, it is impossible to strictly comply with FAA rules while operating UAS commercially.

In cooperation with Terra Dinamica LLC, ERM was invited to operate UAS in a Vermont quarry operation in support of their blasting operations as soon as FAA approves their exemption request.  ERM and Terra Dinamica will provide enhanced blast area security, video of the shot and post-blast inspection.  The UAS will also be used to measure rock volumes and inspect hard to reach places.

But before flying a mission under a Section 333 exemption, exemption holders must receive a COA from FAA for civilian use of UAS.  ERM has been closely following the COA process used by FAA and it has changed significantly three times in the last month.

A month ago, the process for obtaining a COA involved completing a complex 22-page form.  We were thinking we needed to hire a pilot just to complete the forms.  FAA warned that it could take up to two months for a COA to be approved.  We were pleased to see the form greatly simplified a few weeks later.  It was now called the FAA UAS Civil COA Request.  Just some basic information, some maps and an email to 9-AJV-115-UASOrganization@faa.gov.  Hey, we can do this.

All the while, the information posted on the FAA website regarding the Section 333 exemption process made it clear that a person could apply for a COA after they filed their petition and their aircraft registration.  As it did on February 28, 2015.  We have applied for registration of our aircraft, but that’s another story.

So on February 27th, we completed the FAA UAS Civil COA Request, downloaded maps and marked them up and submitted our COA request as instructed.  Surprisingly, we received an auto-reply instructing us that “FAA is no longer accepting soft copy applications for commercial operations. You may still apply for a civil COA at https://oeaaa.faa.gov/oeaaa/external/uas.”  We were told to register, which we did, and then set about to complete the on-line process.

We could not get past the first page or so, getting that “you have not completed the information properly” warning.  Then we noticed that it required an approved exemption number and aircraft registration to complete the process.  We sent an email to FAA asking them to clarify the discrepancy.

So in all, we’ve spent about 16 person-hours chasing the COA rabbit and have not gotten anywhere.  We hope that it does not take two months to receive a COA after a person receives an exemption and that our aircraft registration goes smoothly.

We understand FAA’s need to follow a process and applaud their sensible NPRM, but its frustrating to stay grounded and wade through the morass of bureaucracy when so many other persons are flying UAS commercially outside FAA’s rules.

Hopefully FAA will level the playing field soon for those of us willing to comply.


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