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COA Considerations for 333 flyers

Discussion in 'Flight Regulations' started by MIke Magee, Feb 20, 2016.

  1. MIke Magee

    MIke Magee Active Member

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    I snagged this post from Tom in an unrelated thread that I found very interesting.

    Last week I visited the BOS FSDO (most of my area) and spoke with the UAS guy. He was uncharacteristically friendly and interested in hearing from 333 guys periodically. He was somewhat aware that local towers and operators can no longer ink letters of understanding for addendum's to the blanket COA that we use.

    MOST of us are impacted by this situation.

    I really appreciate Tom's post and I hope he and any others using COA's will chime in here and offer suggestions about approach and wording with these requests, as well as experience with turn around times and denial/approval rates.

     
  2. MIke Magee

    MIke Magee Active Member

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    My questions for people using COA's (eg. in a class D area like my situation).
    • How much of a time window do you normally get to accommodate weather & shoot cancellations? Can you get a week window for instance?
    • Are there any terms/approaches that are more effective in obtaining approval?
     
  3. MIke Magee

    MIke Magee Active Member

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  4. Brad Meier

    Brad Meier Active Member
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    Mike,

    Its typical government where there are too many hands involved and no one is communicating. The COAs can run around 60 days but if you're denied it'll probably come within a few weeks. I was even told by one lady dealing with COAs that 60 days is 60 work days. Ha, I think they are just making it up as they go. I can't remember any production I've been involved with that knows any sort of details that would be required to file for a COA - 60 days out.

    As for dates, if you notice on the COA application there is no where on the form where it asks for a specific date of operation. Once approved you'll still have to deal with the local ATC facility on the specifics such as dates, times, communications. And then theres also the standard POA and NOTAMs of course.

    Now this is only my experience and it can vary depending on each local facilities interpretation of the process.
     
  5. Tom Hirschmann

    Tom Hirschmann New Member

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    Thanks for starting a new thread Mike, I would also like to learn from the experience that others have had. The COA process, just like everything else FAA related, seems to be in a constant state of flux as they figure it out.

    And Brad is right about the time line, I believe that there is an initial review process for all COA applications before a more thorough review. At least they don't make us wait for 60-90 days before denying a request. Also agree with Brad that there few productions we have worked for that have their details sorted out 60 days in advance and then don't make any changes to the location schedule. Frustrating but at least we have a legal option for the time being while the FAA sorts out the details.
     
  6. MIke Magee

    MIke Magee Active Member

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    Would anyone have an approved COA that they would care to share? Perhaps a POA as well. Once we get going, I'll share what we use.

    tx,m
     
  7. Shaun Stanton

    Shaun Stanton Active Member

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    I find that it depends on the jurisdiction. Oddly enough I have a lot of freedom of movement in Albuquerque Class C. But I get a shit load of flack to operate in Santa Fe. KABQ is big picture and gets us through the process fast. But KSAF is a contract tower that has to go through their company's safety manager. Even if the the flight barely touches their stupid class D ring. But in Taos NM I can fly 1.5NM off the end of a runway at the Taos gorge bridge without issues. So it all depends on who owns the airport or ATC. I am finding that the FAA AFS-80 guys just yield to the airspace owner.
     
  8. MIke Magee

    MIke Magee Active Member

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    SO I'm working on a COA for the local class D (KBVY) and have been interacting via email with a very helpful gent from the "UAS Tactical Operations Section, AJV-115 COA Section Processing". These guys appear to preprocess the COA requests before forwarding them to "ATC Facility Coordination" for ATO and ATC blessing.

    I plan to have Sporty's VHF radio fro the VO to monitor local tower communications, checked the box that I'd have one to listen (receive) and that I'd have 2 cell phones available for immediate bi-directional conversation. His response was:

    How have other folks addressed this 91.129 for flights within class D? I's like to know how to respond here. These handhelds are LOS generally and would be useless 2 miles out best case.

    All opinions appreciated.

    Thanks.
     
  9. Gary Haynes

    Gary Haynes Administrator
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    Mike if the radio you got from Sporty's is a typical handheld (TX/RX) then simply answer the question as Yes. Splitting hairs your cellphone is also a two way radio. Good example of TMI. Simple yes/no responses without elaboration confusing the issue is sometimes the best governmental answer :)
     
  10. MIke Magee

    MIke Magee Active Member

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    Thanks Gary. Learning that less is more with the FAA.

    -m
     
  11. Shaun Stanton

    Shaun Stanton Active Member

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    Yup, I have been told to not use my two way handheld other than monitoring traffic. Both C and D airspace that I operate in want me to use my Cell as a primary and radio secondary. They have been getting pissed at other companies stepping on manned airplanes and would rather be on the phone with them. That is her in NM, it maybe different in other airspace.
     
  12. Gary Haynes

    Gary Haynes Administrator
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    Up here in South Dakota we don't use an AC radio nor them fancy cell phones. We use good ol' american made cotton kite twine and a couple of Campbells soup cans 'tween us and the tower. Only issue is when an 18 wheeler snags the line. Man those soup cans sure can fly fast!!
     
    Shaun Stanton and Steve Maller like this.
  13. MIke Magee

    MIke Magee Active Member

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    Maybe we'll buy some soup cans.

    BTW, the blanket COA just got bumped up to 400'. I heard it was on the way.

    https://www.faa.gov/news/updates/?newsId=85264

     
  14. Shaun Stanton

    Shaun Stanton Active Member

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    Its great. Ironically prior to this I was only 400 feet inside class C airspace under my specific COA.
     
  15. Howard Dapp

    Howard Dapp Active Member

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  16. Shaun Stanton

    Shaun Stanton Active Member

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    What I have done is put a COA for a certain area. Then what I found out is that COA is good for a couple of years. Once its in the system you have a point of contact to request a amendment to get a different location. That usually can be hashed out in a week and a half. If you have get a new one from scratch that takes a bit more time. Hopefully, now that the FAA has approved 400 feet for the blanket COA that will have significantly reduce the number of requests. I have managed to get one as early as 3 weeks.
     
  17. MIke Magee

    MIke Magee Active Member

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    I've got two in for general areas like Shaun, both using the online system in your url. I'm hoping this will give me the flexibility to hand most of my work, but still waiting. They have been in the atc coordination phase for almost 4 weeks now. I've heard that they will tend to reject the COA apps quickly, so I'm hoping the time is a good sign.
     
  18. Howard Dapp

    Howard Dapp Active Member

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    Good info thanks guys!
     
  19. MIke Magee

    MIke Magee Active Member

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    I recently printed out the 5/2016 blanket COA that grants 400' to all valid 333 exemptions to put in my flight manual that I carry on gigs.
    (http://www.faa.gov/uas/legislative_...dia/Section-333-Blanket-400-COA-Effective.pdf)

    And, I took a few minutes to actually read it.

    Sure, I call up heliports, and make the proper notifications while under the 333, just like most of us.

    But am I the only one that:
    • Has never filed operations summaries on a monthly basis ( C: Reporting Requirements)
    • Has never called n a D-NOTAM to 877.4.US.NTMS between 24-72 hours preflight?
    Just Wondering if I'm the only one slacking off here.

    BTW: D-NOTAM:
    NOTAM (D)
    NOTAM (D) information
    is advisory in nature and is not restric-tive.
    The “D” pertains to the kind of dissemination method used by the
    FAA; in this case it would be a “wide” dissemination

    A NOTAM (D)
    advertises changes to the NAS that would clause a pilot to rearrange
    or reconsider the flight. They pertain to enroute navigation aids, civil
    public use landing areas listed in the Airport/Facility Directory (AFD)
    and aeronautical data that are related to Instrument Flight Rules (IFR)
    operations. They are disseminated to all navigational facilities within
    the NAS, and all public use airports, seaplane bases and heliports
    listed in the Airport/Facility Directory.​
    Example NOTAM(D) Situations:
    „
    • NAVAID outages and restrictions
    • Airport closures and commissioning
    • Runway restrictions
    • Communications
    • Changes in ATC service
    • (AND I GUESS, Drone activity)
     
  20. Shaun Stanton

    Shaun Stanton Active Member

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    If I am flying under my 333 I file every time. I was told the rationale for this was more for the controllers. It lets the appropriate ATC know that there is drone activity in the area. In reality, unless its close to an airport its like big woopde fcking doo. Its a requirement, so I figure might as well. Its not too hard to file one. I find that they prefer the radial/DME to a NAVAID and also proximity to the closest airports. In my case some times that's 50 miles. Usually if its over 20 miles the NOTAM guy does not even bother noting it.


    In your example for D NOTAMS, they involve anything notable to a flight. L NOTAMS I think are appropriate as they alert pilots on approach to be mindful of their altitudes.

    The funny thing is, I file no NOTAM's when operating under 336. I just call tower and say hey I am flying 3 miles south of you. They are like whatever, thanks for the heads up.
     

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