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April 17, 2019
On April 15, ABC submitted comments on the U.S. Federal Aviation Administration’s notice of proposed rulemaking, which would amend the FAA’s 2016 final rule and allow the operation of small unmanned aircraft systems, or drones, at night and over people under certain conditions without obtaining a waiver.
ABC welcomes the FAA’s proposal to ease certain restrictions on the use of small UAS without compromising the FAA’s valid safety objections. The use of this technology has had an immensely positive impact on today’s economy, and its potential for the future is enormous.
ABC highlighted the following in its comment letter:
• Daylight-only Operations: ABC agrees with the FAA’s proposal to allow small UAS to operate at night without a waiver, as long as they are equipped with an anti-collision light that is visible for three statute miles. “Daylight-only” operations place severe limitations on the use of small UAS in the construction industry. For example, thermal imaging is a necessary tool, especially for roof inspections. Heat is absorbed during the day and at night it is released, allowing thermal imaging. Wet areas release heat slower than dry areas, showing needed repairs. Using small UAS to conduct this imaging is economical and reaches areas that could not be previously imaged or where human observation is dangerous. The UAS operator can safely perform the thermal imaging from the ground or a single location as opposed to traversing dangerous heights, especially at night, and risking an on-site injury.
• Operations Over People: ABC is pleased the proposal would allow the operation of small UAS over people who are not directly participating in the operation of the small UAS without obtaining a waiver. The current restriction is overly burdensome, particularly to those in the construction industry, where vertical structures in various stages of the construction process can more than adequately protect workers from potential UAS equipment failure. Risk can be further mitigated on a construction site by requiring all individuals working on the site to utilize and follow prescribed personal protective equipment and procedures, offering an orientation that educates workers about the UAS equipment prior to entering the work site and notifying workers of UAS operations prior to commencement of these operations while on site. Utilizing drones during the building process, including tasks at high elevations or tough-to-observe areas, can help to protect workers from potential worksite risks and injuries. In sum, this proposal will help to enhance safety on the construction site and make the building process more efficient.
ABC’s comment letter also discussed the FAA’s rules on operations over moving vehicles, the visual line-of-sight requirement and the aeronautical knowledge test.
More information on drones can be found on the FAA website.
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