Please explain in the area below why an STA is necessary:
This request for an STA is related to one previously granted by the FCC. Call sign: WT9XWB. File Number: 1684-EX-ST-2022. (Also previously File Number: 0794-EX-ST-2022). This request updates the area of operation for the two mobile stations, increasing the radius only slightly. This is the only change. Text below is verbatim from the previous application.
This request focuses on two new locations and expands the operational use of the radio to include airborne operations. Airborne operations would be extremely limited – in duration and location - and carefully planned and conducted by the Mid-Atlantic Aviation Partnership (MAAP), an FAA-designated UAS test organization with a dedicated research flight test range. MAAP practices a robust Safety Management program to mitigate risks to persons, aircraft, and property.
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This request for an STA is necessary to support aviation safety-related research sponsored and administered by the National Aeronautics and Space Administration (NASA) Glenn Research Center (GRC). Mosaic ATM is the prime contractor for the research project, a two-year Small Business Innovation Research (SBIR) effort (NASA contract number 80NSSC21C0465). Mosaic ATM is pursuing an STA for the limited use of a Bluetooth radio beacon which, in its high-power mode, would violate FCC Part 15.247(e). Use of the beacon in the high-power mode would be limited to a maximum of eight hours per day for a maximum of seven business days. The research team anticipates actual use of the high-powered mode to be significantly less than this maximum, and closer to three hours per day for up to four business days. The maximum is given here to account for unforeseen issues, such as weather delays. This STA would allow the research team to test and compare the inflight efficacy of the high-power level radio beacon against the standard-power level radio beacon. Flight testing of the standard-power level radio beacon will proceed regardless of the outcome of this STA, however, FCC grant of this STA to allow high-power inflight testing would greatly benefit the research project and aviation safety knowledge in general.
The research involves investigating a concept of how a Bluetooth radio beacon, when affixed to a small Unmanned Aircraft System (sUAS), can improve aviation safety by informing General Aviation (GA) pilots of sUAS 3D locations in real-time.
In the concept, the Bluetooth radio broadcast includes sUAS 3D position and speed information, such as latitude, longitude, altitude, heading, and groundspeed. A computer tablet (e.g., iPad), collocated in the cockpit with the GA pilot and capable of receiving the Bluetooth signal, can then display to the pilot the sUAS location. Figure 1, available upon request, shares the cockpit display of traffic information (CDTI) that would be presented to the pilot on the tablet. In the figure, the display is suggesting to the pilot to turn right to stay clear of other traffic. Yellow and red bands indicate velocities, headings, and altitudes that should be avoided by the pilot because they would lead an unsafe proximity between the two aircraft. Longer broadcast ranges provide better forewarning and lead-time for the GA pilot.
The CDTI is supplementary and informational only and not required for aviation. Responsibility for seeing and avoiding other aircraft lies with the pilot alone. The research devices do not provide separation services. All aircraft involved in the research flight test will be strategically separated by an offset (e.g., a 500-foot vertical separation). No FAA aircraft certification is required for this STA; the research devices to not impact airworthiness. ASTM International is aware of the research project and interested in the results. The Mid-Atlantic Aviation Partnership (MAAP), an FAA-designated UAS research organization, will plan and administer all airborne-related testing. MAAP practices a robust Safety Management program to mitigate risk and has years of experience conducting flight tests.
In support of the research, Mosaic ATM has designed and produced a prototype Bluetooth radio beacon which follows the Federal Aviation Administration Remote ID Rule: https://www.faa.gov/uas/getting_started/remote_id/. This rule is now implemented as Title 14 Part 89 under the Code of Federal Regulations. This rule mandates the broadcast of sUAS position information for certain types of sUAS operations via Bluetooth or Wi-Fi.
Mosaic ATM’s research prototype is capable of two different transmission power levels. One standard-power level that conforms with FCC Part 15, transmitting at 13 dBm. And a second, high-power level, that transmits at 20 dBm. The high-power level would violate FCC Part 15.247(e) where the power spectral density exceeds 8 dBm within a 3 kHZ band during continuous transmission. The research team notes that 20 dBM is within the legal range of broadcast power and therefore anticipates that negative impacts to any nearby devices would be extremely minimal.
The rationale behind the second, experimental high-power level is to extend the realized broadcast range closer to the ideal range which was defined in previous research conducted by Mosaic ATM. In this previous research, Mosaic ATM defined a 3.0 nautical mile range as the ideal broadcast range for improving aviation safety for general aviation pilots with respect to encounters with sUAS. The research team, by way of a statistical RF link budget model, believes the standard power level – 13 dBm – is capable of approximately a 0.9 nautical mile range. And the high-power level – 20 dBm - capable of around a 2.8 nautical mile range. The STA would allow the research team to explore and define the effective range of the 20 dBm broadcast, providing NASA and the FAA important information regarding the potential performance envelope.
The use of the high-powered broadcast would be carefully limited, in duration and geographic location, and be constrained to two locations:
1) The first location is at the VT Montgomery Executive (KBCB) Airport. All radio testing at this location will take place on the ground. Two aircraft will be involved, again both will be on the ground and not airborne. One will be a representative GA aircraft, such as a Cessna 172. The other will be a representative small UAS. No UAS flight is allowed at KBCB. As a preventive and safety measure, the UAS propellers will be removed. This test will be administered and conducted by MAAP.
2) The second location is at MAAP’s FAA-designated UAS test site: the Kentland Experimental Aerial Systems (KEAS) laboratory [‘Kentland Farm’ for short]. Kentland Farm is an 1800-acre UAS test range 9 miles west of Blacksburg, VA. MAAP has been conducting UAS-GA flight tests at Kentland Farm since 2016 and has a proven safety record. Radio testing at Kentland Farm would involve airborne aircraft, a Diamond DA-40 GA aircraft and a Tarot sUAS. This test will be administered and conducted by MAAP.
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