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27

Oct,2015

Pilot Deviation Penalties

Pilot deviation penalties can be stiff. What is a pilot deviation? A pilot deviation is an action of or by a pilot that results in a failure to comply with an ATC clearance and/or instruction. The penalties for pilot deviations can range anywhere from a FAA Administrative or Enforcement Action, a “709” ride requirement, or even death. Possibly the best (and worst) example of how disastrous a pilot deviation can be comes from the deadliest aviation accident in history…the Tenerife Airport disaster.

 

On March 22, 1977, at the Los Rodeos Airport (now Tenerife North Airport) in the Canary Islands, two Boeing 747s collided on the runway causing the death of 583 people. At the time of the accident, the Tenerife airport was under dense fog and the taxiways were congested with overflow traffic. Immediately after lining up, the Captain of KLM Flight 4805 advanced the throttles and the aircraft started to move forward. The First Officer advised the Captain that ATC clearance had not yet been given, to which Captain Veldhuyzen van Zanten responded, “I know that. Go ahead, ask.” First Officer Meurs then radioed the tower that they were “ready for takeoff” and “waiting for our ATC clearance”. The KLM crew then received instructions which specified the route that the aircraft was to follow after takeoff. The instructions used the word “takeoff,” but did not include an explicit statement that the flight was “cleared for takeoff.”

 

First Officer Meurs read the flight clearance back to the controller, completing the read-back with the statement: “We are now at takeoff.” Captain Veldhuyzen van Zanten interrupted the First Officer’s read-back with the comment, “We’re going.” The controller then immediately said “OK” followed by “stand by for takeoff, I will call you,” indicating that he had not intended the clearance to be interpreted as a takeoff clearance. Unbeknownst to the KLM crew, Pan Am Flight 1736 was not clear of the runway. As a result, the two 747s collided, causing the deadliest aviation accident in history.

 

Let’s use this disaster to learn more about pilot deviations and their associated penalties. As evidenced by the Tenerife collision, the most important thing to know is that pilot deviations can be deadly. Some pilots may be able to stomach a potential FAA Enforcement Action brought against their certificate, but there is not one pilot on this planet that could stomach the death of passengers, crew, and those on the ground. While it may be easy to think “ATC probably won’t notice my screw up if I fly at 25,000 feet instead of 24,700 feet,” or “the FAA won’t ding me for such a small deviation,” you MUST remember that a simple deviation such as that could be the difference between life and death.

 

However, let’s say for example that the two Boeing 747s at Tenerife managed to avoid collision. Maybe KLM Flight 4805 was able to prematurely rotate and get airborne before striking Pan Am Flight 1736. What would the penalty be for a deviation like this? There were no fatalities. There was no property damage. There was, however, potential for disaster…which is what the FAA is concerned about. In this scenario, the FAA would likely initiate investigation and potentially administrative or enforcement proceedings. There is a litany of Federal Aviation Regulations that the FAA would claim the crew violated, however 14 C.F.R. §91. 123 and 14 C.F.R. §91.13 are used most often. §91.123 speaks to compliance with ATC clearances and instructions and §91.13 speaks to careless and reckless operations. Note that the §91.13 “careless and reckless operation” card is one that the FAA regularly plays, ancillary to other FAR violations. The penalties to such violations could include no action, a warning notice or letter of correction, a “709” ride, certificate suspension, civil penalties, and even certificate revocation.

 

If you are the subject of a FAA investigation, administrative or enforcement action, or civil penalty, make sure you contact an aviation attorney to speak about your possible defenses. In most cases, filing a NASA report is a good idea if you deviated from ATC clearance or instruction. If you have any questions about pilot deviation penalties and defenses, call an aviation attorney at The Ison Law Firm. We are standing by to vector you through legal turbulence…call us at 863-712-9472 or e-mail to Anthony@ThePilotLawyer.com.

20

Oct,2015

FAA Civil Penalties for Drone Operators – Everything You Need To Know

On October 19, 2015, DOT Secretary Anthony Foxx and FAA Administrator Michael Huerta revealed the news that essentially recreational drone pilots will need to register their drones with the government before the end of the year. These new registration requirements are largely in response to the numerous complaints of “close calls” with UAVs and other aircraft. Anthony Foxx said that “[r]egistration will reinforce the need for unmanned aircraft users, including consumers and hobbyists, to operate their drones safely. It’s hard to follow rules if you don’t know what the rules are…this will help us enforce the rules against those who operate unsafely by allowing the FAA to identify the operators of unmanned aircraft…we want to ramp up on enforcement.” The key words here are: we want to ramp up on enforcement. Essentially, enforcement means civil penalties. In other words, we are seeing that the FAA wants to make the skies safer AND they want to build up their bank account while they’re at it. So what does this mean for you?

 

The following is for commercial drone operators and hobbyists alike. In this article, you will learn:

1. What a FAA civil penalty is

2. What to do if you are the subject of a civil penalty

3. How to avoid civil penalties in the future

 

What is a FAA civil penalty? To answer this question, you must start with the broader term of “FAA enforcement action.” When the FAA believes that a certificate holder (i.e. an airman, air carrier, repair station or otherwise) has violated a Federal Aviation Regulation (“FAR”), it may pursue enforcement action against the offending party. At this point, an enforcement action essentially branches off into two subdivisions: certificate actions and civil penalties. A certificate action or proposed certificate action is usually when the FAA seeks to suspend or revoke a certificated person’s license, as a penalty for violating the FARs.

 

Alternatively, the FAA could also seek to impose a civil penalty upon a person or entity operating contrary to the FARs. Civil penalties are likely more appropriate for recreational drone operators because recreational drone operators typically don’t hold a certificate that can be revoked or suspended. As such, civil penalties are can be imposed against companies, entities, and individuals alike. How much are you looking at per violation? The FAA determines the amount of the civil penalty using a Sanction Guidance Table, which provides ranges for civil penalties based upon the type and size of the certificate holder, the type of alleged violation, and the number of alleged violations. A proposed civil penalty for anything over $50,000, leaves the FAA’s jurisdiction and is prosecuted by the United States Attorney’s office. But watch your clock! The FAA must bring the proposed civil penalty against you within 2 years of discovering an alleged violation of the Federal Aviation Regulations.

 

What do you do if you are the subject of a civil penalty? First, if the FAA believes that you violated a FAR, they will send you a “Notice of Proposed Civil Penalty.” In the notice, there will be a recitation of the relevant facts, which FARs you allegedly violated, and the cost of the proposed civil penalty. When you read the letter, your gut instinct will be to call the investigator of record and tell him or her why you should not have to pay the civil penalty. Don’t do this.

 

Have you ever watched the television program called COPS? Usually, a police officer will be arresting a suspect for selling drugs and while the police are putting him in handcuffs, the suspect says, “I shouldn’t be arrested; I use drugs but I don’t sell drugs!” All the while, you are sitting there, screaming at the TV, saying “anything you say can be held against you in a court of law!” Maybe you aren’t a nerd like we are while watching COPS. Nonetheless, your situation with the notice of proposed civil penalty is very much like the drug dealer’s situation on COPS. Anything you tell the FAA investigator, can and will be used against you during the course of your enforcement action. So, your first step should ALWAYS be to call your aviation attorney…let him or her respond to the FAA on your behalf.

 

That being said, you have roughly seven options when it comes to responding to the notice of proposed civil penalty. First, you can outright pay the civil penalty and be done with the whole situation. Beyond that, your attorney can send a letter showing that either you did not violate the FARs, you are not able to pay the proposed civil penalty, or that the penalty fee should be lowered. Ultimately, what you may consider doing is essentially fighting the penalty in a formal evidentiary hearing before an Administrative Law Judge (“ALJ”). If you chose to go this route, the ALJ will decide issues of fact and law and will determine whether, and in what amount, a civil penalty will be assessed against you. A formal hearing before an ALJ is very similar to a trial…like on Law & Order.

 

Every civil penalty is like a snowflake. Every case is different. Every drone operator is different. Every set of facts are different. Essentially, if you are sent a notice of proposed civil penalty, you should speak with your drone attorney about what the best way of moving forward with your case would be.

 

How can you avoid civil penalties in the future? The simple answer is: pay attention to the FARs and use common sense. A good rule of thumb would be that a drone that is flown strictly for hobby or recreational must be:

 

*operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization;

*limited to not more than 55 pounds unless otherwise certified through a design, construction, inspection, flight test, and operational safety program administered by a community-based organization;

*operated in a manner that does not interfere with and gives way to any manned aircraft;

*not flown within 5 miles of an airport, the operator of the aircraft provides the airport operator and the airport air traffic control tower…with prior notice of the operation;

*flown within visual line sight of the operator.

 

If you have questions about how to legally operate your drone, if you are the subject of a FAA civil penalty, looking to operate your drone commercially, or just want to chat, call a drone attorney at The Ison Law Firm. We are standing by to vector you through legal turbulence…call us at 863-712-9472 or e-mail to Anthony@ThePilotLawyer.com.

08

Oct,2015

Avoiding Civil Penalties for UAV Operations: Don’t Be the Next SkyPan International

As you may or may not know, the Federal Aviation Administration recently announced that it is expecting to fine SkyPan International, a Chicago-based drone company, a whopping $1.9 million for “endangering the safety of [American] airspace.” The announcement of this incredible enforcement action seems to be the FAA’s warning to the public that unauthorized UAV operations will not be tolerated. Many of us in the drone community were expecting this eventual crackdown on unauthorized drone use – but maybe not to this magnitude. Nonetheless, this announcement is coming at a curious time – right before the holiday season (during which the FAA expects that over a million drones will be sold). As such, everyone from Corporate America to Little Billy with a DJI Phantom 3 on his Christmas list, is shaking in their boots wondering if they will be the next SkyPan International – with a debt of close to $2 million. But don’t worry; if YOU employ some of the following precautions in your UAV operations, you can attempt to shield your pocketbook from the FAA and its civil penalty wrath.

 

The first thing to know is that the $1.9 million fine is the result of 65 unauthorized flights, which SkyPan conducted within New York and Chicago’s airspaces over the course of a two year period. Essentially, these were hobbyist flights because during this period, SkyPan did not have a Section 333 Exemption. So what does that mean to you? First, if you are operating your drone for commercial purposes, get a Section 333 Exemption now. Secondly, whether you are a hobbyist or commercial operator, you need to know exactly where/how you can and cannot fly your UAV. Thirdly, remember that while it is against regulations to violate certain airspaces and that you would likely be subject to penalties for doing so, it’s likely you won’t be the subject of a $1.9 million fine for a one-time accidental flight above 400 feet. It will all depend on where you are and what you are doing – it took SkyPan 65 flights over congested airspace to hit the $1.9 million mark. So, let’s go through each step of protecting yourself.

 

First, all commercial UAV operators must have Section 333 Exemption from the FAA. Let’s say that together: ALL COMMERCIAL UAV OPERATORS MUST HAVE A SECTION 333 EXEMPTION FROM THE FAA. What is a Section 333 Exemption? A Section 333 Exemption essentially gives an individual or entity relief from certain FAA regulations. For example, an individual seeking a Section 333 Exemption may request to be exempt from the following Federal Aviation Regulations:

  • 14 C.F.R. §91.121: which provides guidelines for the use of altimeter settings while operating an aircraft
  • 14 C.F.R §91.119(c): which provides that except when necessary for takeoff or landing, no person may operate an aircraft below an altitude of 500 feet above the surface. Furthermore, this section provides that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.
  • 14 C.F.R. §91.7(a): which prohibits the operation of civil aircraft unless it is in airworthy condition
  • 14 C.F.R. §§ 61.101(e)(4) and (5) which prohibits recreational pilots from receiving compensation for hire or providing flight services in furtherance of a business
  • 14 C.F.R. §91.151(a)(1): which provides that no person may begin a flight in an airplane under VFR conditions with less than 30 minutes of reserve fuel

As you can see, the Section 333 Exemption keeps commercial operators from having to jump through various FAA hoops. As such, if you are a hobbyist, you don’t have exemption from these regulations and must adhere to these rules…which SkyPan International did not.

 

Secondly, the friendly, blue skies are not the wild, wild west. A drone operator cannot switch his or her drone to the “on” position and takeoff to photograph the Empire State Building at 1,200 feet. No, instead, whether you are a commercial drone operator or hobbyist, you must adhere to certain altitude and area restrictions. For commercial operators with a Section 333 Exemption, the FAA will typically allow UAV operation up to 400 feet for aircraft that weigh less than 55 pounds, operating during daytime Visual Flight Rules (VFR) conditions, operating within visual line of sight (VLOS) of the pilots, and staying certain distances away from airports or heliports:

  • 5 nautical miles (NM) from an airport having an operational control tower; or
  • 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or
  • 2 NM from an airport without a published instrument flight procedure or an operational tower; or
  • 2 NM from a heliport with a published instrument flight procedure.

As for hobbyists, the altitude and airspace restrictions are similar if not identical. According to the FAA Modernization and Reform Act of 2012, a drone that is flown strictly for hobby or recreational must be:

  • operated in accordance with a community-based set of safety guidelines and within the programming of a nationwide community-based organization;
  • limited to not more than 55 pounds unless otherwise certified through a design, construction, inspection, flight test, and operational safety program administered by a community-based organization;
  • operated in a manner that does not interfere with and gives way to any manned aircraft;
  • not flown within 5 miles of an airport, the operator of the aircraft provides the airport operator and the airport air traffic control tower…with prior notice of the operation;
  • flown within visual line sight of the operator.

The general rule is to use common sense. Beyond that, if you are a hobbyist, make sure you stay within all Federal Aviation Regulations, especially those requiring altimeter and transponder equipment. If you study the SkyPan case, you will notice that the FAA specifically cites the company for flying within certain airspaces without transponder or altimeter equipment. Remember, if you are a hobbyist, you don’t have the leniency of someone operating under a Section 333 Exemption. Read up on the Federal Aviation Regulations and know the rules before you fly.

 

Everyone makes mistakes. If you operate your drone contrary to the above regulations, don’t panic – you likely won’t get hit with a $1.9 million fine. If you have any questions about where you can and cannot operate your drone or if you are already the subject of a FAA civil penalty or enforcement action, contact your friends at The Ison Law Firm. We are standing by to vector you through legal turbulence…call us at 863-712-9472 or e-mail to Anthony@ThePilotLawyer.com.

05

Oct,2015

PRIA: FAA Enforcement Actions And Your Aviation Career

Did you ever fall off your bike as a child and scrape your knee? If so, what did your mom do when she saw your “boo boo?” Did she pull out the Morton salt and pour it on the raw flesh? If she did, we’re sorry to hear that…but, if your mom is anything like ours, she probably just put a Band-Aid on it and sent you on your way. As an aviator, you might know by now that the FAA can sometimes be the mom that pours salt on that fresh, flesh wound. In that, when it comes to the Pilot Records Improvement Act (PRIA) the FAA is pouring salt in our wounds all the time. The following will walk you through how PRIA works and make some suggestions as to how to avoid the FAA’s wrath.

 

PRIA requires that all air carriers operating under 14 CFR parts 121, 125, and 135, request, receive, and evaluate certain information concerning a pilot/applicant’s training, experience, qualification, and safety background, before allowing that individual to begin service as a pilot with their company. Of course, this is a good idea…we don’t need Bozo the Clown being hired to fly a 737 for Southwest just because his resume says he has 20,000 hours. Essentially, PRIA provides potential employers with confirmation from the FAA and one’s previous employers that an applicant’s qualifications are credible and accurate.

 

An airmen’s PRIA records will include files from the FAA, previous employers, and the National Driving Registry. The FAA’s file will include records containing information on your airmen certificates, current medical certificates, and type ratings. However, the frustrating part about PRIA is that the FAA’s file on you can contain career-crushing data. In that, the FAA records required to be reviewed by the hiring airline include your Enforcement Information Subsystem (EIS):

Enforcement Information Subsystem (EIS)

  • Computerized database of enforcement actions
  • Information may be accessed without pilot’s permission
  • Maintained by Flight Standards’ Information Management Section (AFS-624) in Oklahoma City

So, what’s the big deal? Well, everything is hunky-dory until the FAA decides to bring an enforcement action against you or you have an accident. Prior to 2010, records of action brought against your certificate would be expunged after 5 years. However, The Airline Safety and Federal Aviation Administration Extension Act of 2010, signed August 1, 2010, changes how PRIA works. Now, the new law requires the FAA to retain certain legal enforcement records until the agency is notified that a pilot has died. The FAA won’t be happy until we are all dead. As a result, if you are hit with a certificate suspension, your potential employers will know about it…which probably won’t make your application go straight to the top.

 

So what can you do in an effort to keep your PRIA record looking pristine? The obvious first step is to avoid doing anything that would warrant the FAA bringing an enforcement action against your certificate. Unfortunately, that’s easier said than done. The FAA can essentially investigate whatever they feel like investigating. Luckily, the FAA will still expunge letters warning notices and letters of correction after 2 years. Furthermore, open cases are not reported by PRIA. Once fully adjudicated and closed, both suspensions, other formal enforcement events, and revocations will become permanent entries on an airman’s EIS record, and are required to be reported by PRIA. These EIS records will remain on the PRIA report, even in cases where the airman has re-qualified, and has been issued another current and valid airman certificate.

 

Beyond that, PRIA will retain records of civil penalties. A civil penalty is basically a monetary fine issued either to an individual airman or to an air carrier. When it comes to civil penalties, air carriers are held to a higher standard. An air carrier can be subject to a penalty of up to $11,000 for a single violation. Other certificate holders such as repair stations, pilots or mechanics, can receive a penalty of up to $1,100 for each violation. Civil penalties have also become a permanent entry on an airman’s EIS record and subsequently on their PRIA report.

 

Should the FAA bring legal action against you (either in the form of a certificate action or civil penalty), the ideal modus operandi would be to adjudicate the action to its fullest. This way you can attempt to have your name cleared and your PRIA record remaining faultless. In the event of winning your enforcement action case, the “legal action” notice on your PRIA record will be expunged between 30 and 90 days. The relationship between of PRIA and enforcement actions is frustrating for airmen…such that it feels like the FAA is continuously pouring salt in the proverbial “wound.”

 

If you are the subject of an enforcement action and want to speak with an aviation attorney, call your friends at The Ison Law Group. Let us vector you through your legal turbulence… call us today with your questions at 1-855-LAW-1215.

24

Aug,2015

FAA Ramp Checks: A Survival Guide

You’ve landed, taxied to the ramp, and are tying your Cessna 172 down for the night. But who is that guy walking across the ramp toward your plane…oh no, it’s the FAA! When you see the badge clipped to his shirt that says “FAA” in big letters, you’ll probably want to climb into the baggage compartment and hide, but don’t. If you understand the “Ramp Check” process and are properly prepared for an unexpected chat with the inspector, the chances are you will survive.

 

Remember back to when your flight instructor briefly mentioned “Ramp Checks.” It is likely he or she did not spend too much time going over the process of a “Ramp Check” because they seem fairly rare. If you are a flight instructor, it may be a smart idea to have a mock “Ramp Check” with your students before sending them off to solo. Nonetheless, what is a “Ramp Check?” Essentially, these checks are conducted to ensure that a licensed pilot or student pilot are conducting flight operations safely and within the parameters prescribed by the Federal Aviation Regulations. While most checks end with the inspector shaking your hand and saying “everything looks good,” it is possible for the check to result in an enforcement action. If the FAA initiates an enforcement action as a result of a ramp check, it is possible that your pilot’s license could be suspended or revoked, and/or you could face a civil fine. The stakes are high.

 

When will a “Ramp Check” occur? A ramp check is not scheduled and is unpredictable. A check will commonly occur when an inspector observes an unsafe operation in the traffic pattern or on the ramp, is notified by ATC of an unsafe operation, or just feels like checking out your operation to make sure you are in compliance with the rules. If you are approached by someone claiming to be an FAA inspector, make sure you ask for identification before proceeding with the check, as the inspector is required to present identification prior to initiating a check. If the inspector does not present identification, make note, as that may become part of your defense if the check proceeds to an enforcement action. Furthermore, the inspector may not detain you if it means you will miss a flight or an appointment; he or she may only detain you long enough to check your records.

 

Once the “Ramp Check” is initiated, however, what can you do to ensure you keep your nose clean with the FAA? Most checks will include an inspection of the pilot’s airman and medical certificates, the aircraft paperwork, and an exterior inspection of an aircraft. Your pilot certificate will be inspected to make sure that you are licensed for the operations that you a conducting. For instance, if the inspector witnesses you landing in IFR conditions, he or she will look at your certificate to make sure that you are an instrument rated pilot. Furthermore, your medical certificate will be checked to make sure you are conducting operations within your class medical. Again, the inspector is making sure that for instance you aren’t conducting commercial operations with a third class medical. And if you are a student, your logbook will be checked for records of currency, solo endorsement, etc.

 

As to your aircraft, the inspector will want to make sure you have certain documentation/equipment onboard. Do you remember ARROW from your training – now is the time to use it! The inspector will want to see that you have with you your aircraft’s airworthiness certificate, aircraft registration, weight and balance information, and operating handbook. Beyond that, the inspector is authorized to inspect: the aircraft’s minimum equipment list (if applicable), Aeronautical charts (if applicable), the general airworthiness of the aircraft, the ELT battery, the seats/safety belts. Furthermore, the inspector can conduct a VOR check. It is important to remember, however, that the inspector is not authorized to board your aircraft without the knowledge of the entire crew; however, the inspector may inspect the exterior and look through the windows. Again, if the inspector boards your aircraft without the knowledge of the crew, note that, as it may become part of your defense if the check leads to an enforcement action.

 

Always remember to prepare for an unexpected FAA “Ramp Check,” as preparation is your only chance to survive one of these checks. Furthermore, if the check is in response to a possible violation, anything you say can be used against you. If you have questions about “Ramp Checks” or are the subject of a check, contact your team at The Ison Law Firm. We are standing-by 24/7 to vector you through legal turbulence…call us at 863-712-9472 or e-mail to Anthony@ThePilotLawyer.com.

19

Aug,2015

UAV Operations and the FAA’s New Enforcement Guidelines: We Can Do This The Easy Way or the Hard Way

UAVs are quickly becoming more regulated than the world’s oldest profession. Perhaps more regulation is necessary, however, as every time you turn on the news there is another DJI Phantom flying into the flightpath of a Boeing 737. On August 4, 2015, in an effort to prevent such violations by drone operators in the National Airspace System (NAS), the FAA released an updated notice for “Education, Compliance, and Enforcement of Unauthorized Unmanned Aircraft Systems Operators.” FAA Notice N 8900.313 replaces the now expired FAA Notice N 8900.268; however, both notices essentially contain identical provisions and guidelines. Notice N 8900.313 provides Flight Standards divisions (RFSD), and Flight Standards District Office (FSDO) aviation safety inspectors (ASI) with the “FAA approved” protocol for how drone operators should be “properly educated” if they violate a regulation within the NAS. This notice applies to both recreational (i.e. hobby enthusiasts) UAV operators and those operating under a Section 333 exemption for commercial purposes.

 

Let’s work through the guidelines together. So let’s say for example you are flying your Parrot AR 2.0 Elite Quadcopter on a photography assignment and you lose Visual Line of Sight (VLOS) with the UAV. When you lose VLOS you inadvertently climb to 1,600 feet, right into the path of a Cessna 172 on a VFR flight plan. As a result of this mistake, you are reported by the Cessna pilot and the FAA traces the UAV’s operation back to you. What’s going to happen?

 

As per Notice N 8900.313 the FSDO air safety inspector assigned to your case will first attempt to call you on the phone. The guidelines indicate that the inspector should “conduct an inquiry appropriate to the circumstances.” In our hypothetical, the inspector will likely ask what happened, whether you remained within visual line of sight with the UAV, why you climbed, etc. Beyond that the inspector will review with you the appropriate Code of Federal Regulations (CFR) provisions and counsel you on how to operate your UAV within said provisions. If the inspector deems necessary, he will send you an administrative informational letter that includes website addresses to FAA UAS guidance and relevant CFR provisions. As in any FAA enforcement case, it is advised that you speak with an aviation attorney before speaking with the FAA inspector.

 

The abovementioned scenario is the easy way the inspector may resolve your case. There is, however, another, more odious way the inspector may resolve the case. If, when talking to the inspector, he or she determines that you are “uncooperative, intentionally noncompliant, or the operation poses medium to high potential or actual endangerment to the NAS,” he or she will proceed with an enforcement action as outlined in the Compliance and Enforcement Bulletin No. 2014-2. One lesson here is to not be uncooperative with the inspector, should you talk to him on the phone. Furthermore, keep yourself apprised of the CFR provisions that apply to UAV operations and don’t intentionally violate them.

 

Should the inspector propose an enforcement action, the UAS Integration Office will take over and prepare a memorandum for the Office of the Chief Counsel recommending an appropriate sanction based on the facts of the case and in accordance with the guidance in Order 2150.3 and the Compliance and Enforcement Bulletin No. 2014-2.6. At this point, the FAA could either take legal or administrative action against you. If you are notified that you are the subject of an enforcement action, it is imperative that you contact an aviation attorney.

 

The short and long is that if you violate a regulation within the NAS with your UAV, you could be subject to suspension or loss of licensure, penalties and fees, and/or a very stern talking to by some guy at the FAA. If you feel you have violated a regulation with your UAV and want to speak with an aviation attorney,call us at 863-712-9472 or e-mail to Anthony@ThePilotLawyer.com.

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