Mr. Christopher C. Brown

December 10, 2007

Mr. Christopher C. Brown

Deputy Assistant Administrator

Federal Aviation Administration

Office of Government and Industry Affairs

United States Department of Transportation

800 Independence Avenue, SW

Room 1022

Washington, DC 20591

Dear Mr. Brown:

You will recall that you spoke to MAPPS when you were serving as a professional staff member in the U.S. House of Representatives. MAPPS (www.mapps.org) is the national association of private firms in the aerial surveying, remote sensing, spatial data and geographic information systems field in the United States. Formed in 1982 and currently celebrating its 25th anniversary, MAPPS includes more than 170 firms spanning the entire spectrum of the geospatial community, including Active Member Firms engaged in airborne and satellite remote sensing, surveying, photogrammetry, aerial photography, hydrography, bathymetry, charting, aerial and satellite image processing, GPS, and GIS data collection and conversion services. MAPPS also includes Associate Members Firms, which are companies that provide hardware, software, products and services to the geospatial profession in the United States and other firms from around the world.

Over the past 25 years, MAPPS has worked with the FAA on a number of issues related to photogrammetric aerial survey operations. Just as there are major changes about to take place in the FAA in converting to the “NextGen” Air Traffic Control System, there have been major advancements and growth in aerial acquisition in numerous geospatial-related sciences. For purposes of brevity, these various sciences can summarily be referred to as “aerial survey operations.”

With increased demand for aerial survey operations from all levels of government and the private sector, it has become even more important for MAPPS and the FAA to maintain a working relationship through a permanent, high-level liaison, to address various concerns or events as they arise.

For the better part of this year, our primary contact at the FAA was Mr. Darrell Hood, who has done an outstanding job and has shown great enthusiasm and professionalism. In a relatively short period of time, Mr. Hood addressed several issues, including streamlining the waiver process to access restricted airspace (in particular the Washington DC FRZ), attempting to accommodate the conduct survey operations within the Disney TFRs, and increasing Air Traffic Controller awareness of aerial survey operational requirements [MAPPS is specifically mentioned in FAA Order FAA 7210.3 (section 5-4-6.PHOTOGRAMMETRIC FLIGHTS)].

Aerial survey operations are unique in many ways, which require FAA consideration:

·  Access to Airspace – Aerial survey operations must be conducted over specific project sites on precise flight lines at altitudes appropriate for image capture or data acquisition. These flights are flown to very tight tolerances and survey aircraft cannot simply deviate around TFR’s of other restricted airspace.

John M. Palatiello, Executive Director

1760 Reston Parkway, Suite 515, Reston, Virginia 20190

P (703) 787-6996 F (703) 787-7550 E www.mapps.org

·  Access to airspace is critically important to our profession, and the many government agencies and private firms that benefit from our professional services.

·  Aircraft Modifications and FAA Flight Standards District Offices (FSDO) - FSDO inspectors have been inconsistent in interpreting requirements when inspecting and approving modifications of survey aircraft. What may be approved by a member firm’s home base FSDO, may not be approved by an inspector from a different FSDO. In the event of a ramp check at a distant location, the aircraft could be grounded simply due to a difference of opinion between two FSDO inspectors. With the flood of aerial data acquisition equipment now coming on the market, each with different components, weights, electrical requirements, mounting requirements and racks for on-board computers, we see a need to have a consistent FAA inspection and approval process that will be honored by any FSDO.

·  Flight Altitudes – Many aerial survey operations take place in uncontrolled airspace between 3,000AGL and FL180. These aerial survey operations must be flown at specific altitudes in order to achieve the required mapping scale. Very rarely do the required flight altitudes comply with the requirements of FAR Part 91.159 VFR Cruising Altitude or Flight Level, which require aircraft flying in level cruise flight to be at appropriate odd or even plus 500’ altitudes. Consequently, survey aircraft are forced to intentionally vary flight altitudes slightly for the sole purpose of FAR Part 91.159 compliance. We request that the FAA issue a written determination that aerial survey operations are considered by definition, not to be in level cruise flight while conducting aerial survey operations.

·  Preflight Coordination - The information requested by the FAA in preflight coordination for aerial survey operations varies considerably throughout the country. We request that the requirements be made more uniform so that the appropriate information reaches the ATC controller handling the aerial survey operation. A recent meeting between a MAPPS member firm and Kansas City ARTCC highlighted this issue. We believe the process of pre-flight coordination for aerial survey operations can be improved, and would like to work with Kansas City ARTCC, other facilities, and FAA Headquarters toward that end.

·  NextGen Air Traffic Control System – Aerial survey operations have unique operational requirements. These requirements must be considered in developing the NextGen Air Traffic Control System. MAPPS will be happy to assist in developing the new system so as to accommodate aerial survey operations.

·  UAV/UAS Unmanned Aerial Vehicles / Unmanned Aircraft Systems – MAPPS is primarily concerned on two different points:

o  That UAVs will operate in restricted airspace (FRZ) possibly preventing aerial survey operations access to that same airspace; and

o  That UAV development and utilization may be restricted to government use, resulting in a situation in which the government competes with the private sector.

It is my understanding that Mr. Hood now has new and different responsibilities in the FAA. As you can appreciate from the aforementioned list of issues, the members of MAPPS are impacted by a wide range of FAA activities. With your advice and counsel, MAPPS would like to identify a replacement for Mr. Hood as our primary point of contact to and liaison with the FAA. We respectfully request an individual at the highest possible level of the FAA to recognize the wide range of issues that impacts the MAPPS membership and who recognizes the critical importance and significance of aerial survey operations to our Nation’s economy. We would appreciate an individual who can be engaged with MAPPS in a manner that cross-cuts the various offices, programs and staff within FAA.

We appreciate your consideration as you appoint a high-level replacement for Mr. Hood as the liaison to our community. I would be pleased to discuss this matter with you and please do not hesitate to let me know if MAPPS can be of any additional assistance.

Kindest regards.

Sincerely,

John M. Palatiello

MAPPS Executive Director