UAS FAQ & FAA REGULATIONS

 

 

The information below has directly been pulled directly from the Federal Aviation Administration’s (FAA) website and the Part 107 Summary. HERE is a link to the FAA Facilities Airspace Map for current drone operation clearances. For any additional questions please reach out to our staff. We are more than happy to help advise or inform you to the safest operational standards available. Thank you!

 

+ How much weight can you fly?

Unmanned aircraft must weigh less than 55 lbs. (25 kg).

+ How far can you fly?

Visual line-of-sight (VLOS) only; the unmanned aircraft must remain within VLOS of the remote pilot in command and the person manipulating the flight controls of the small UAS. Alternatively, the unmanned aircraft must remain within VLOS of the visual observer. At all times the small unmanned aircraft must remain close enough to the remote pilot in command and the person manipulating the flight controls of the small UAS for those people to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses.

+ Can you fly over people?

Yes, as long as they are part of the operation. Small unmanned aircraft may not operate over any persons not directly participating in the operation, not under a covered structure, and not inside a covered stationary vehicle.

+ Can you operate at night?

Yes, we have a night waiver which allows operations at night. Traditionally operations are limited to daylight-only operations, or civil twilight (30 minutes before official sunrise to 30 minutes after official sunset, local time) with appropriate anti-collision lighting.

+ UNMANNED VS MANNED AIRCRAFT PRIORITY?

All unmanned aircraft must yield right of way to other aircraft.

+ ARE VISUAL OBSERVERS REQUIRED?

May use visual observer (VO) but not required unless during night operations or in special circumstances where aditional support is needed.

+ ARE FIRST PERSON VIEW CAMERAS (FPV) ALLOWED?

First-person view camera cannot satisfy “see-and-avoid” requirement but can be used as long as requirement is satisfied in other ways.

+ WHAT IS THE MAXIMUM SPEED ALLOWED?

Maximum groundspeed of 100 mph (87 knots).

+ WHAT IS THE MAXIMUM HEIGHT ALLOWED?

Maximum altitude of 400 feet above ground level (AGL) or, if higher than 400 feet AGL, remain within 400 feet of a structure.

+ WHAT IS THE MINIMUM WEATHER VISABILITY ALLOWED?

Minimum weather visibility of 3 miles from control station.

+ WHAT AIRSPACE CAN YOU OPERATE IN?

Operations in Class B, C, D and E airspace are allowed with the required ATC permission. Operations in Class G airspace are allowed without ATC permission.

+ CAN YOU FLY MULTIPLE DRONES AT THE SAME TIME?

No person may act as a remote pilot in command or VO for more than one unmanned aircraft operation at one time.

+ CAN YOU FLY FROM A MOVING VEHICLE?

No operations from a moving aircraft. No operations from a moving vehicle unless the operation is over a sparsely populated area.

+ ARE DANGEROUS OPERATIONS ALLOWED?

No careless or reckless operations.

+ CAN YOU FLY HAZADROUS MATERIALS?

No carriage of hazardous materials.

+ ARE PREFLIGHT INSPECTIONS REQUIRED?

Requires preflight inspection by the remote pilot in command.

+ ARE YOU FIT TO FLY?

A person may not operate a small unmanned aircraft if he or she knows or has reason to know of any physical or mental condition that would interfere with the safe operation of a small UAS.

+ ARE FOREIGN AIRCRAFT ALLOWED?

Foreign-registered small unmanned aircraft are allowed to operate under part 107 if they satisfy the requirements of part 375.

+ ARE EXTERNAL PAYLOADS ALLOWED?

External load operations are allowed if the object being carried by the unmanned aircraft is securely attached and does not adversely affect the flight characteristics or controllability of the aircraft.

+ IS TRANSPORTATION OF PROPERTY ALLOWED?

Transportation of property for compensation or hire allowed provided thato The aircraft, including its attached systems, payload and cargo weigh less than 55 pounds total; the flight is conducted within visual line of sight and not from a moving vehicle or aircraft; and the flight occurs wholly within the bounds of a State and does not involve transport between (1) Hawaii and another place in Hawaii through airspace outside Hawaii; (2) the District of Columbia and another place in the District of Columbia; or (3) a territory or possession of the United States and another place in the same territory or possession. Most of the restrictions discussed above are waivable if the applicant demonstrates that his or her operation can safely be conducted under the terms of a certificate of waiver.

+ CAN YOU FLY WITHOUT A REMOTE PILOT CERTIFICATE?

A person operating a small UAS must either hold a remote pilot airman certificate with a small UAS rating or be under the direct supervision of a person who does hold a remote pilot certificate (remote pilot in command).

+ HOW TO ACQUIRE A REMOTE PILOT CERTIFICATE?

To qualify for a remote pilot certificate, a person must: demonstrate aeronautical knowledge by either: passing an initial aeronautical knowledge test at an FAA-approved knowledge testing center; or hold a part 61 pilot certificate other than student pilot, complete a flight review within the previous 24 months, and complete a small UAS online training course provided by the FAA. Be vetted by the Transportation Security Administration. Be at least 16 years old. Part 61 pilot certificate holders may obtain a temporary remote pilot certificate immediately upon submission of their application for a permanent certificate. Other applicants will obtain a temporary remote pilot certificate upon successful completion of TSA security vetting. The FAA anticipates that it will be able to issue a temporary remote pilot certificate within 10 business days after receiving a completed remote pilot certificate application.

+ HOW CAN FOREIGN PILOTS OPERATE LEGALLY?

Until international standards are developed, foreign certificated UAS pilots will be required to obtain an FAA issued remote pilot certificate with a small UAS rating.

+ WHAT ARE THE REMOTE PILOTS RESPONSIBILITIES?

A remote pilot in command must: make available to the FAA, upon request, the small UAS for inspection or testing, and any associated documents/records required to be kept under the rule. Report to the FAA within 10 days of any operation that results in at least serious injury, loss of consciousness, or property damage of at least $500. Conduct a preflight inspection, to include specific aircraft and control station systems checks, to ensure the small UAS is in a condition for safe operation. Ensure that the small unmanned aircraft complies with the existing registration requirements specified in § 91.203(a)(2). A remote pilot in command may deviate from the requirements of this rule in response to an in-flight emergency.

+ IS AN AIRCRAFT AIRWORTHINESS CERTIFICATION REQUIRED?

FAA airworthiness certification is not required. However, the remote pilot in command must conduct a preflight check of the small UAS to ensure that it is in a condition for safe operation.

+ DOES PART 107 APPLY TO MODEL AIRCRAFT?

Part 107 does not apply to model aircraft that satisfy all of the criteria specified in section 336 of Public Law 112-95. The rule codifies the FAA’s enforcement authority in part 101 by prohibiting model aircraft operators from endangering the safety of the NAS.

 
 

IATSE LOCAL 600 UAS

 

 

IATSE Local 600 is a national local covering all of the United States and Puerto Rico. The IATSE has been very active in organizing production across the United States and Canada for decades. Now, virtually every production on major networks, cable channels and streaming services as well as a growing number of shows on smaller outlets such as the History Channel are union.

Following is a brief guide for UAS crews “working union” on signatory productions. All information below is directly sourced from the IATSE Local 600. For any additional questions please reach out to our staff. We are more than happy to help advise or inform you to the safest operational standards available. Thank you!

 

+ The “Panavision” Model

The most flexible way for a technology company to do work under the IATSE contract is what we call the “Panavision” or “Technocrane” model. Producers are accustomed to working this way with a variety of vendors. Under the “Panavision” model, the vendor company rents their equipment to the production as well as selling them pre production/wrap services, production support that is not be work covered by IATSE contract, transportation for the equipment, etc. They also require that the production work only with their approved Local 600 member crew/technicians. The producer fulfills their obligation to hire union members by hiring these technicians as production hires on union time cards while they are on the production. The rates for the L600 crew must be at contract minimum or better. Contracts set floors, not ceilings. When back at the shop, the crew may work for the vendor company under any terms they may choose. Because the vendor company itself is not a signatory to any union contract, the union has no authority over the vendor’s in-shop relationships. Union rates have to do with labor only. Equipment or “kit” rentals are between the crew member or company and the production. Equipment or “kit” rentals are not part of our contracts. Ultimately, because UAS work is all over union scale, the impact of this is more about form, how quotes are written, than any actual impediment to competitive bidding. How much of an over scale amount for on-production labor goes on the union timecard vs. being added to equipment rental and other services being paid directly to the company are between the company and the technician. While on the production’s union time card, the production is paying union health and retirement benefit contributions, as well as workman’s compensation insurance and all applicable employment taxes on behalf of the union member.

+ Aviation Insurance

How aviation liability coverage is handled is currently all over the map. It is a tradition in the industry (for example camera cars, cranes and traditional aircraft) that the company who rents the equipment to the production is in a secondary position to the production’s primary insurance. The logic behind this is that the production is ultimately in charge of operations, scheduling, logistics and storage. Due to the nature of production, a photographic crew will seldom meet the regulatory thresholds of being a true subcontractor. Now, some the large studios are pushing against 60 years of established industry practice by asking for all liability to be carried by the UAS aerial operator. This matter is currently a topic of discussion between the studios and Local 600. It is the Local’s recommendation that the aerial operator ask to be in a secondary position. If the production refuses, the final decision is up to the aerial operator.

+ Studio Vendor Agreements

Some large studios have recently been sending “preferred vendor agreements” to pre-qualify UAS operators. These may contain a questionnaire asking if the aerial operator has an issue with the studio requiring all crew to be direct employees of the aerial operator. An aerial operator declaring that they have no issue with this requirement does not preclude the crew’s union membership or the aerial operator asking the production to place their crew on union timecards. Membership in Local 600 is a relationship between the individual crew member and the Local, not a relationship between the aerial operator and the Local.

+ Local 600 Members on Non-Union Productions

Local 600 members may work on non-union productions as they may choose. Local 600 has no rules requiring members to decline non-union work.

+ Union Timecard vs. Invoice

Aerial operators should ask union productions to put their UAS crews on union timecards. If the production refuses to pay the UAS crew on union timecards, the aerial operator may make alternative arrangements including non-union timecards or invoicing. Local 600 considers productions who refuse to pay UAS crews union timecards to be in violation of our contracts. When this happens it is a matter between Local 600 and the producer and it does not involve the aerial operator or individual crew members.

+ Local 600 UAS Staffing and Contract Rate Guidance

There are often questions about rules and how Local 600 works. Ultimately, we can modify most standing rules as might be required to do the work. The following is a general guide to traditional work rules and some of the accommodations to the rules that have been brought up as being useful for doing UAS work under union contracts.

+ Local 600 UAS Work Rules

To provide flexibility, we are considering that the Pilot position may be staffed by either a Director of Photography or Camera Operator.

  1. Under Local 600 agreements, every shooting unit must have a Director of Photography. It is the production’s responsibility to see that this requirement is met.

  2. When putting a UAS crew on a full working production unit, the production will already have a principle Director of Photography. In these circumstances both the Pilot and the Camera Operator could work in the Camera Operator classification under the production’s Director of Photography.

  3. When the UAS crew is working as a “splinter” or independent unit without otherwise having a Director of Photography supplied by the production, either the Pilot or Camera Operator must be a Director of Photography.

  4. Under Local 600 rules, a Director of Photography may also work as a Camera Operator at the Camera Operator rate or above.

  5. It is not unusual for one Director of Photography to do specialized work under another Director of Photography.

  6. Every UAS unit must have a Camera Assistant (or Technician).

  7. Under Local 600 agreements, every manned camera (not locked-off) must have at least one Camera Assistant assigned to that camera. It is the production’s responsibility to see that this requirement is being met.

  8. “Being assigned to that camera” does not mean that the Camera Assistant cannot also be working with the UAS and related systems.

  9. The 1st Camera Assistant may be assisted by a 2nd Camera Assistant as required.

  10. Having a 2nd Camera Assistant is not mandatory.

  11. A 2nd Camera Assistant is not necessarily assigned to one particular camera and may be performing other technical and support duties.

  12. It is a tradition within the camera department that the 2nd Camera Assistant calls out distances during the shot when the 1st Assistant is unable to judge distances from their perspective. This is a factor as defining the Visual Observer as being a 2nd Camera Assistant.

  13. A 1st Camera Assistant operates camera focus and zoom.

  14. Directors of Photography and Camera Operators may not work primarily in the capacity of Camera Assistants.

  15. As a practical matter, the camera department is a hierarchical organization where a higher paid category may assist a lesser paid category in getting the work done.

  16. When working with highly specialized equipment, it is not unusual for the Director of Photography or Camera Operator to supervise and work closely with Camera Assistants to prepare the equipment and address technical issues that may arise.

  17. As UAS work begins, there is concern for there being an adequate number of experienced Local 600 members in each category to properly staff the crews. Local 600 members needing to work out-of-category to ensure that UAS crews are properly staffed should inform their regional Local 600 office.

+ Rules Regarding Contract Rates

  1. Contract rates for all classifications are minimums. Local 600 agreements do not prohibit the negotiation of better rates, terms, or conditions for any job category.

  2. Over scale “flat rates” are permitted as long as actual hours are submitted on a union time card and that the “flat rate” remains higher than the total for actual hours at contract rates. In this sense, “flat rates” are more accurately termed “minimum guarantees”. There is no such thing as “unpaid time” on a union timecard.

  3. Rates are not discounted for prep and wrap. However, arrangements such as scale for prep and wrap and over-scale for working days are permissible under contract.

+ Work Types

A member who regularly works theatrical projects may also work under sports contracts. Contact the Local for sports rules that may be region specific.