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FAA’s Safety Rules for Commercial Drones Are Overly Strict, Report Says

lisadoc

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https://www.wsj.com/articles/faas-s...ones-are-overly-strict-report-says-1528729200

The unusually strongly worded report released Monday urges “top-to-bottom” changes in how the Federal Aviation Administration assesses and manages risks from drones.

The report, which was requested by Congress, also criticizes the agency for extending its traditional focus on “near-zero tolerance for risk” involving airliners and applying it to cover small drones flying at low altitudes away from airports. Instead, the report concludes, the agency should peg drone safety to more-comparable hazards confronting people on the ground such as those posed by small private-plane crashes or pedestrian-vehicle accidents.

Such minimal but persistent levels of risk already are accepted by the public,according to the report. A fundamental issue is “what are we going to compare [drone] safety to?” said consultant George Ligler, who served as chairman of the committee that drafted the document.

“We do not ground airplanes because birds fly in the airspace, although we know birds can and do bring down aircraft,” the report said.

Federal Aviation Administration drone rules 'overly strict,' new report says
 

Chip

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Lisadoc, I think you should post this article in that is it possible a drone could bring down an airplane thread. The FAA is now saying pretty much what you said on that thread! I know some people think they won that hypothetical argument but they were debating the wrong thing.
 

lisadoc

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Lisadoc, I think you should post this article in that is it possible a drone could bring down an airplane thread. The FAA is now saying pretty much what you said on that thread! I know some people think they won that hypothetical argument but they were debating the wrong thing.

Thanks for the kudos but it's not really about "winning" or "losing". In the end, it is genuinely about taking a rational (risk-based) approach to a known issue, rather than an emotional, knee-jerk, or uninformed reactionary move to address the perceived problem. The FAA, as a governmental agency, is not immune to human nature and responding to public pressure (or pressure from political actors) and is known for taking an initial heavy-handed crackdown on perceived threats, before ultimately considering a science-based scheme to deal with the long-term guidance/regulation it will ultimately promulgate to control actors (such as... members of the public, airports, pilots, or airlines, etc.) on a particular subject matter.

I do not work for the FAA but I work with them closely on many subject matters, and their reaction/approach to UAS usage, though typical in its attitude, has been as over-the-top as one could imagine, mostly in response to the perception of the dangers involved by outside political actors (politicians). Even many of the FAA's own personnel realize how ridiculous and over-reaching their own agency's response has been to the risk and bemoan the overall attitude that the FAA has decided to take at this point. This report only confirms that the FAA's reaction to this issue has been extreme and the agency needs to take a step back and take a more measured, and risk-based approach to the problem.

By way of example (of the extreme nature of this reaction), even the FAA itself has been a victim of their own extreme restrictions and some serious head-shaking has gone on in dealing with the usage of drones. Recently, at one of the FAA's own facilities, they were moving a large piece of equipment across the airfield and despite the fact that the airfield itself was shut down completely during the process and it would pose zero threat to aviation, FAA personnel were unable to get permission, internal to their own agency, to fly a drone during the event in order to film the equipment moving from above. Ultimately, they were never able to secure permission from those sectors of their own agency dealing with UAS operations and missed having a valuable aerial perspective for this particular sequence. Part of the problem was the behemoth bureaucracy involved in dealing with such a large agency but mostly, it was due to the overly restrictive approach the FAA has taken to UAS flight and its perceived "threat" to our national airspace.

Personally, I don't have high hopes that the FAA will ultimately, of its own volition, take a better risk-based approach to this issue, even with this report coming out. As time moves on, additional (though extremely rare) incidents will only continue to accumulate, "demonstrating" to those dealing with UAS within the agency that their overly risk-adverse approach is justified. My belief is that they will ultimately and inevitably change their regulatory guidance when either the public at large (doubtful) or large and politically powerful corporate entities (like Amazon, Facebook, Google, media giants, and other such parties) will put such political pressure on their governmental representatives that members of Congress will enact their own regulatory framework that the FAA must abide or put tremendous pressure on the agency to modify its own regulatory structure. Until that happens, I see things only getting worse (more restrictive), not better, despite what the science (and actual data) says.
 
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Chip

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Thanks for the kudos but it's not really about "winning" or "losing". In the end, it is genuinely about taking a rational (risk-based) approach to a known issue, rather than an emotional, knee-jerk, or uninformed reactionary move to address the perceived problem.

Lisadoc, good points and information. Although my original comment about people thinking they won an argument seems kind of petty when you put it that way!

My belief is that they will ultimately and inevitably change their regulatory guidance when either the public at large (doubtful) or large and politically powerful corporate entities (like Amazon, Facebook, Google, media giants, and other such parties) will put such political pressure on their governmental representatives that members of Congress will enact their own regulatory framework that the FAA must abide or put tremendous pressure on the agency to modify its own regulatory structure.

That makes sense to me. Do you have any thoughts on what the future may hold for recreational flyers who have much less or no political clout?
 

lisadoc

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Do you have any thoughts on what the future may hold for recreational flyers who have much less or no political clout?

These are just my thoughts, but I have a number of colleagues that share this view (including ones within the FAA). I believe that ultimately, the political and economic pressure of a multi-billion dollar industry (currently $20B/year {in drone sales only, not including the related services and attendant uses} - and growing at roughly 20% per year) will result in policy makers putting severe pressure on the FAA to accommodate trade and other business services related to the usage of UAS, and they'll have to open up the skies to drones and other similar automated craft. Though the major business players will be the ones to apply this pressure, both 107 pilots as well as the recreational fliers will ultimately benefit from these changes.

What you must realize is that the FAA feels they have control over the commercial drone market (since they can regulate them) but what they fear the most are the recreational fliers (which they're not allowed to really regulate), since they are not trained, licensed, or managed in any real sense and outnumber the commercial user by probably 100,000 to 1. So even though they truly fear the recreational fliers, the legal position they're currently in means that they can only dictate their control over commercial operators. The guidelines they impose on them, they hope, will spill over into the recreational world, and they sneak in as much regulation as they deem reasonable, without overtly appearing to be regulating the recreational arena.

But as the opposite comes true (industry forces them to loosen guidelines on commercial drone operation), recreational fliers will benefit by the loosening restrictions. You can't ease up on the group you can actually regulate, while simultaneously coming down harder on those you can't. It's an untenable position. So despite the fact that recreational fliers don't really have a powerful lobby for them, the major business players in the commercial arena will be the ones paving the way - like a bulldozer forging roads across the wilderness. Those roads won't only be used by commercial providers. Recreational users will inevitably utilize those same routes.
 

laurens23

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My belief is that they will ultimately and inevitably change their regulatory guidance when either the public at large (doubtful) or large and politically powerful corporate entities (like Amazon, Facebook, Google, media giants, and other such parties) will put such political pressure on their governmental representatives

I think, this is still wishful thinking.

First the obvious point missing is the rare, but inevitable incident. As you say it is a matter of managing risk and currently they are going way over the top. I fully agree here. However that does not mean there is zero risk. If there would be an incident, they will clamp down no matter what the industry wants. the industry will just move to less restrictive countries.

I do agree large corporations will put pressure. However there are two issues with this. First, while putting pressure they will also try to protect their own economic business model and try to keep competition low. I they lobby smart they will push for regulations that are an advantage for them without giving away too much space to their competition, including recreational flyers. (we see this happening with autonomous vehicles at this very moment)

I think we should look for a combination of a technological solution and public awareness.
 

DesignFlaw06

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I fear we have already reached a point where public perception will never be in our favor.

My thinking is that the strict regulations are only going to make more pilots ignorant or ignore them all together. The range of the drones and lack of understanding from law enforcement officials make the risk of being caught less likely.

I'm not saying you should ignore the FAA, but man, they've got to figure out a better solution.
 

lisadoc

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Thank you.....
This is a big report. Lots to digest.

If you don't want to read it all, at least the 11 separate recommendations to the FAA should give a good summary of its content:

1) Recommendation: The FAA should meet requests for certifications or operations approvals with an initial response of “How can we approve this?” Where the FAA employs internal boards of executives throughout the agency to provide input on decisions, final responsibility and authority and accountability for the decision should rest with the executive overseeing such boards. A time limit should be placed on responses from each member of the board, and any “No” vote should be accompanied with a clearly articulated rationale and suggestion for how that “No” vote could be made a “Yes.”

2) Recommendation: The FAA should expand its perspective on a quantitative risk assessment to look more holistically at the total safety risk. Safety benefits, including those outside of aviation (e.g., the benefit of cell tower inspections without a human climbing a cell tower), should be part of the equation. UAS operations should be allowed if they decrease safety risks in society—even if they introduce new aviation safety risks—as long as they result in a net reduction in total safety risk.

3) Recommendation: Within the next 12 months, the FAA should establish and publish specific guidelines for implementing a predictable, repeatable, quantitative, risk-based process for
certifying UAS systems and aircraft and granting operations approval. These guidelines should interpret the Safety Risk Management Policy process described in Order 8040.4B (and in
accordance with International Civil Aviation Organization Doc. 9859) in the unique context of UAS. This should include the following: (1) Provide, within 18-24 months, risk-based quantitative performance standards that can serve to establish compliance with FAA rules and regulations. (2) In the interim, encourage applicants to provide quantitative probabilistic risk assessments (PRAs) to demonstrate that their operation achieves the requisite level of safety. (3) Within 18-36 months, update FAA rules to reference new performance standards with the goal of minimizing the need to grant waivers or Certificates of Authorization (COAs).

4) Recommendation: Where operational data are insufficient to credibly estimate likelihood and severity components of risk, the FAA should use a comparative risk analysis approach to compare proposed UAS operations to comparable existing or de minimis levels of risk. The FAA should research and publish applicable quantitative levels of acceptable risk in comparison to other societal activities that pose de minimis risk to people. Risk level and risk mitigation strategies should consider not only aircraft collisions but also third-party risks (e.g., to people on the ground).

5) Recommendation: Over the next 5 years, the FAA should evolve away from subjectivities present in portions of the Order 8040.4B process for UAS to a probabilistic risk analysis (PRA) process based on acceptable safety risk. In the interim, the FAA should improve the 8040.4B process to conform better with quantitative PRA practice. For the new acceptable risk process, the FAA should consider relying on the applicant to provide a PRA demonstrating the achieved level of safety, as is common in other regulatory sectors such as nuclear, dam, or drug safety.
The FAA should screen applicant PRAs by comparison to existing or de minimis levels of risk. The FAA needs to research applicable quantitative levels of acceptable risk in comparison to other societal activities in establishing a level of de minimis risk for aviation.
These acceptable levels of risk need to include risk to people on the ground and risk of collisions with a manned aircraft, particularly with regard to collision with a large commercial transport.
In evaluating applicant-generated PRA, the FAA should value the importance of risk mitigation opportunities and their potential for simplifying the analysis of risk.
In situations where the risk is low enough, the FAA should encourage applicants to obtain insurance for UAS operations in lieu of having a separate risk analysis.

6) Recommendation: The FAA should create the following two mechanisms that empower and reward safety risk management decisions that consider the broad charter of the Department of
Transportation to “serve the United States by ensuring a fast, safe, efficient, accessible and convenient transportation system that meets our vital national interests and enhances the quality of life of the American people, today and into the future”:
  • The FAA administrator should establish an incentive system that measures, promotes, and
  • rewards individuals who support balanced comparative risk assessments.
Within the next 6 months, the FAA administrator should publicly commit to ensuring timebound reviews of risk assessments so that proponents receive timely feedback.

7) Recommendation: Within 6 months, the FAA should undertake a top-to-bottom change management process aimed at moving smartly to a risk-based decision-making organization with clearly defined lines of authority, responsibility, and accountability. To that end, the FAA should establish and maintain technical training programs to ensure that agency risk decision professionals can fully comprehend the assumptions and limitations of the probabilistic risk assessment techniques appropriate to current and future UAS operations.

8) Recommendation: The FAA should identify classes of operations where the level of additional risk is expected to be so low that it is appropriate to base approval of those operations on requiring insurance in lieu of having a separate risk analysis.

9) Recommendation: The FAA should, within 6 months, collaborate with industry to define a minimum operational safety data set and develop a plan for the voluntary collection and retention of data by the operators in a central repository, following the model of the Commercial Aviation Safety Team (CAST) and the General Aviation Joint Steering Committee (GAJSC), with a goal of full implementation within 1 year. The FAA should also consult with the Drone Advisory Committee to help define the minimum operational safety data set and plan for collecting, archiving, and disseminating the data.

10) Recommendation: For operations approvals for which there are no standards, as operational data are collected and analyzed, the FAA should, as part of Improved Safety Risk Management,
  • Publish requirements for operational approvals with associated restrictions that can be adjusted and scaled based on industry past experience and the accumulation of related data;
  • Expand single operation approvals as experiential data accumulate and risks are assessed;
  • Permit repeated or routine operations based on the accumulation and analysis of additional data; and
  • Continuously update operational approval practices to incorporate emerging safety enhancements based on industry lessons learned until standards have been established.
11) Recommendation: In coordination with other domestic and international agencies, the FAA should pursue a planned research program in probabilistic risk analysis (PRA), including the aspect of comparative risk, so that FAA personnel can interpret or apply PRA for proposed technology innovations.
 
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lisadoc

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I think, this is still wishful thinking.

That's entirely possible. I know I'm not alone in this belief (and in fact, that's the entire basis of this report to the FAA, commissioned by Congress), so though it may be wishful thinking, at least there's a decent chance of it turning out for the better.

First the obvious point missing is the rare, but inevitable incident. As you say it is a matter of managing risk and currently they are going way over the top. I fully agree here. However that does not mean there is zero risk. If there would be an incident, they will clamp down no matter what the industry wants. the industry will just move to less restrictive countries.

Of course there's not zero risk. No one is making that claim. But, as this paper clearly points out, one needs to weigh the existing risk of UAS to commercial aviation safety against the risk of not utilizing drones or restricting them to such a degree as to make their usage ineffective. We may, for example, prevent 4 drone strikes a year if we are overly restrictive. But on the other hand, people are routinely risking their lives conducting activities that drones could easily do instead. Some examples mentioned in the report - Inspecting tall electrical/cell towers. Inspecting long stretches of railways. Watching for potential drowning victims along congested beaches. Search and rescue. Delivery of emergency supplies. Etc.

While a singular large-scale catastrophic accident involving a drone and a manned aircraft would potentially cancel all bets, there are assuredly hundreds of people whose lives could be saved each year through the development and wide-spread usage of drones. And this says nothing about the other, non-lifesaving applications that could also be instituted. People said the same thing about cars back in the Model T days, but now, they're such an intrinsic part of our daily lives, we're more than willing to overlook the 30,000 deaths each year (in the US alone) directly caused by those same vehicles. There is, like drones, a flip side of this as well, with the overall utility of vehicles and even life-saving measures (ambulances, food distribution, etc.) that more than offsets the deaths and injuries caused by vehicles... so much so that we're more than willing to accept those risks.

Let a drone save four little kids from drowning and it hits the national TV news. Let a few families be saved that are stranded during a natural disaster. Let drones deliver life-saving defibrillators to a dozen people during congested Los Angles rush-hour traffic, in record time. And even more so, let Amazon, via drone, start delivering packages right to doorsteps across the nation in under an hour. Or Domino's start delivering your pizza within a few minutes, and we'll soon see how poor of a public image drones have in short order.

I think we should look for a combination of a technological solution and public awareness.

I also think that as the technology develops in autonomous drones (like your car example), the risk goes even lower and acceptance goes higher. Ultimately, the technological safety features will likely diminish the risk to such low levels that all players will have to admit that the minimized risk is far outweighed by their tremendous positive usage and productivity.

Even the advances in automation and technological sensors in consumer-level quad-copters in the last 5 years alone makes drone usage all the more practical and less of a hazard. Imagine if today the skies were filled with equivalent numbers of Phantom 1s and 2s, instead of all the actual numbers of Mavics, P4s, Inspires, etc. The risks would certainly be far different, as millions of P1s and P2s suffer uncontrolled flyaways, crashes, drops from the sky, etc. Instead, we now have safety RTH, obstacle avoidance, geo-fencing, GPS and acoustic sensor positioning, and so on. Five years from now, I doubt you'll be comfortable flying an original Mavic Pro, as the drone tech will surpass the existing tech to such a degree (with capabilities like integrated 3-D environmental mapping, smart predictive AI flight behavior, TCAS incorporation, and a myriad of other features that are only currently a gleam in the eye of some engineer at DJI or Autel) that you'll wonder why anyone ever flew those unsophisticated Mavics so long ago, .
 
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Chip

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...they will push for regulations that are an advantage for them without giving away too much space to their competition, including recreational flyers. (we see this happening with autonomous vehicles at this very moment)
I think we should look for a combination of a technological solution and public awareness.

Can you clarify what kind of regs you mean? I was thinking that autonomous commercial drones might pave the way for removal of VLOS requirement on recreational flyers.
 

Chip

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... FAA should pursue a planned research program in probabilistic risk analysis (PRA), including the aspect of comparative risk, so that FAA personnel can interpret or apply PRA for proposed technology innovations.

Can you break this one down a little? Who is qualified to do this type of PRA and how is comparative risk quantified or considered in the equation?
 

laurens23

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First off I think we are on the same side. I'm just playing the devils advocate here.
Of course there's not zero risk. No one is making that claim. But, as this paper clearly points out, one needs to weigh the existing risk of UAS to commercial aviation safety against the risk of not utilizing drones or restricting them to such a degree as to make their usage ineffective.
The issue with those comparisons is that drones are a risk to innocent bystanders. The feeling that "no place is safe" and "anyone can be watching you at any time" are a big negative impact. everyone knows and accepts the risks when they drive a car or walk along the street. But a stealthy drone that can be anywhere is hard to accept.

I agree that once we see more positive news (rescue service, delivery service, police, locating missing persons) the opinion of the public will slowly change to acceptance.
I also think that as the technology develops in autonomous drones (like your car example),
I do not like this move. It is like making race-car drivers passengers in their own cars. I do think that there is a big market for autonomy in the commercial side of things.
Five years from now, I doubt you'll be comfortable flying an original Mavic Pro,....
(with capabilities like integrated 3-D environmental mapping, smart predictive AI flight behavior, TCAS incorporation, and a myriad of other features that are only currently a gleam in the eye of some engineer at DJI or Autel).
I think you are overestimating the development. 5 years is ~2 generations of products. With DJI swatting at anything that is getting close, and regulations changing every day, it's hard to see any major developments that soon.
Can you clarify what kind of regs you mean? I was thinking that autonomous commercial drones might pave the way for removal of VLOS requirement on recreational flyers.
First off I think there is a big difference between goals for commercial and private use:

Commercial want autonomous flights. mapping, agriculture, surveying, inspections, patrolling, delivery, are all examples where a pre-determined flight path will be an excelent solution.

Private want to be in control. photo, video, racing all require the operator to be in control, take of at a whim and be able to steer or position the drone as the moment dictates.

In short, autonomous flight means pre-defined flight-path which is fine for commercial use and this will likely be their area of focus for developments. However this is not interesting for most private use (taking pictures/video or racing). This means that a push from the commercial side to autonomous drones does not benefit the recreational user and we might even end up with regulations aimed at autonomous drones that hinder the use of regular consumer drones.

Secondly, big commercial companies will have no problem paying $5000+ for a delivery drone with a lot of safety features (transponder, extra motors, redundancy). This might than spill over into private regulations pushing the already significant $1000 consumer drones out of reach of most people's budget, basically killing the market.

Third there is the lobbying. It will start with exclusive testing rights for companies in certain areas (like the autonomous cars get permission to test in certain cities) Then a commercial company will develop a drone with a patented safety device X and try to get regulations that only allow drones with X to fly cornering the market.

All this will also result in ever increasing bureaucracy, keeping newcomers away from the market.

Finally I think regulations all aim for an unregulated class for "toys", and strict regulations aimed more at commercial operations for anything bigger. I predict this will force the consumer market into very capable mini, but still toy-drones (mix between Mavic air and Tello). This will leave the real hobbyist in a difficult position. The hobbyist wants more than the "toys" but does not want to end up in the regulations of the commercial drones.
 

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I have to say, I might be wrong,but I think this Amazon Drone Delivery thing is a bit of a red herring and is rather more of a "look at us, we're at the bleeding edge of technology" marketing exercise. I don't see it developing successfully into anything significant in the medium term at least.

Piloted deliveries of, say, urgent medical supplies I can see, but not flying an expensive drone over the hood with an expensive gadget package hanging underneath...can you imagine?
 
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egildersleeve

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If you don't want to read it all, at least the 11 separate recommendations to the FAA should give a good summary of its content:

This was a very well thought out recommendation. One thing ainwould point out however is that the FAA is taking a scientific approach to their studies. However, this is being done to basically only two groups. The first, being done to original 333 exemptions which of course they will not be renewing soon (except possibly for academia). Second, Public Safety COA users. We have to submit monthly detailed flight logs, information about damages, lost link, and many other parameters. It has become so burdensome to complete these logs on an antiquated yet brand new webpage that I am planning on testing for the 107. Why they can not mandate users to share automatic flight logs to them is beyond me.

I also believe we will soon see an alternative to the new airplane transponders. ATC has been pretty clear they don’t want to see them cluttering up their scopes with drones. However, the need is still present so I believe there will be a 2-Way communication capability coming that beacons some basic data such as make/model/lat/long/elevation of aircraft and controllers. It may also include 24/7 contact information. Perhaps even afford an ATC a way to force an aircraft to return home and land. I believe there will also be manadatory information for hobbyists to transmit with some data being modified for commercial and COA.
 

lisadoc

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Can you break this one down a little? Who is qualified to do this type of PRA and how is comparative risk quantified or considered in the equation?

Wow. That's a seemingly very simple question with an actual extremely complex answer. The short answer for the first part of your question is it depends on which of the PRA references in that report you're asking about. For the one you cite above, it's usually a panel or committee of risk assessment experts and risk analysts within the FAA that is convened to look at the data and come up with the PRA. In recommendation 3 (of the report) though, it's suggesting that industry applicants themselves provide the PRA along with their application (until the FAA devises a more permanent approach).

For the last part of your question, it's like asking someone to explain nuclear fission in an online forum post. It would take pages just to get a better understanding how these things are derived and what goes into them. NASA, for example, is a great resource for this type of work. The concept was originally developed for the nuclear industry. PRAs are essentially about low probability events that can result in extremely high consequence outcomes. You can see why the nuclear industry needed such an analysis. It's been picked up by other industries, such as the oil and gas industry, space flight, and even aviation.

There are a number of better resources out there that go into this in great detail. If you're looking for such information or a deep dive into such things, this paper gives a pretty good summary and is a decent place to start (despite the fact that it is about the oil and gas industry).

https://www.bsee.gov/sites/bsee.gov/files/pra-05012017-whitepaper.pdf
 
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toddellis

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this is good news, but even IF you get past the FAA - you still have to suffer DJI's draconian NFZ
 
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