Congratulations to BNSF for their recently approved FAA 107.31 waiver and 44807 exemption grant to allow Beyond Visual Line of Sight (BVLOS) UAS operations controlled by an off-site/remote pilot. While Anzen Unmanned wasn't involved in this approval, we understand the challenges BNSF went through to obtain this BVLOS approval. This is another step forward for the aviation industry.
Many people have been asking “what can I learn from this and how can I apply it to my operations?” These are important questions, and the Anzen Unmanned team analyzed the waiver and exemption in the context of other BVLOS waivers and exemptions, as well as other rulemaking and standardization efforts currently under way.
There are some key insights from the public material on what makes this FAA BVLOS approval unique, and these should be taken into account when considering how the waiver and exemption can apply to other use cases:
Off-site pilots controlling UAS nation-wide.
The American Robotics’ waiver/exemption approval last January allowed the off-site pilot to remotely control the UAS at specific controlled access farms. BNSF’s approval for remote pilots controlling the UAS is for BVLOS over their own railyards and tracks in rural/sparsely populated areas throughout the US.
Heavy reliance on cameras. Camera systems are used to:
Conduct the pre-flight inspection of the aircraft
Visually clear the take-off and landing areas
Confirm appropriate weather
Detect and then prevent flight over of people
No operations over people. Neither the Osprey and S2 aircraft has their 21.17(b) Durability & Reliability (D&R) Type Certificate (TC) yet, so BNSF used 100 D&R flight hours and prior service history to prove aircraft reliability. As of February 2021, Easy Aerial has applied for TC but Skydio has not.
Multiple layers of Detect & Avoid (DAA) safety mitigations including:
L3Harris RangeVue Pro to fuse surveillance data sources together for display and alerts. The L3Harrris data from the FAA Surveillance and Broadcast Services (SBS) Visual Augmentation System (VAS) feed includes ADS-B and data from the FAA radars. In the past, various UAS organizations have tried to gain access to the real-time FAA radar data without success; hopefully, the BNSF waiver/exemption paves the way for other UAS organizations to now gain access to the same information provided to manned aviation.
Four (4) or more EchoDyne EchoGuard radars to detect low altitude non-cooperative aircraft. The EchoGuard has an FCC Part 87 radio-navigation license, which would allow maneuvering. However, the BNSF right-of-ways constrain the operations, so the avoidance maneuvers end up going to a “safe state” altitude in response to an intruding aircraft. It is also encouraging that the FAA now allows a "safe state" altitude instead of just landing.
On-site ADS-B-in receiver to augment the higher altitude ADS-B data, which L3Harris provides under the ADS-B contract to the FAA SBS.
Typical operations are at 60’ AGL and no higher than 100’ AGL, so less likely to encounter manned aircraft.
C2 is via Wi-Fi to the railroad wireless access points that leverages BNSF network infrastructure used for positive train control. The approval also mentions LTE, but it is unclear whether this is redundant aircraft C2 or from the wireless access point to the command center.
BNSF initially requested night operations and to have the remote pilot control multiple UAS, but the FAA suggested that they amend their request to just daytime and one UAS. Undoubtedly this is part of a crawl/walk/run approach that allows the FAA to build confidence that BNSF can walk before they start running multiple UAS at night. I expect we will see BNSF running "soon" with an amended waiver/exemption approval.