Unmanned Aerial System: Taking Surveying to a Higher Level

Technological advances continually bring new products onto the market that offer improved and more efficient methods of completing everyday engineering and surveying tasks.  A recent example of new technology involving engineering and surveying services is that of drone usage.  Over the past few years drone technology has spread downward from strictly military use to the public sector.  While some of the rapid increase in drone ownership is purely for recreational enjoyment, the engineering community has also experienced an increase in drone use for the gathering of topographical survey data.  Often the question of whether to adopt a new technology is more of a “when” decision than an “if” decision.  For those of us old enough to remember when hand-held calculators replaced the sliderule, computers largely replaced hand-held calculators, and CADD software/plotting made drafting tables obsolete, these “cutting edge” changes each offered a promised increase in efficiency but required a business decision of when to adopt the technology.

ECSI faced such a decision approximately one year ago with consideration of buying a survey capable drone while the technology was still relatively new, or to wait for further improvements in the technology coupled with probable falling prices.  Uncertainty of how the Federal Aviation Administration (FAA) was going to regulate the private and commercial use of drones only added further complexity to the decision making process.  Ultimately, ECSI decided to proceed with the purchase of a fixed-wing eBee™ drone and associated software to enhance our surveying capabilities.

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Having been recently granted approval from the FAA to operate this Unmanned Aerial System (UAS or “Drone”) in a commercial capacity, ECSI has put it to good use providing aerial photogrammetric services for clients in Kentucky, West Virginia and Ohio.  Since our purchase of this technology, we have had ample opportunity to assess the accuracy and precision of measurements made with the Drone compared to more conventional surveying methods of total stations and GPS.  ECSI, and its clients, have been very pleased with the surveying performance of this system, as well as with the quality, high-definition composite photographs that are produced.  It has proven to be an effective way to perform annual updates of progress maps necessary to comply with regulatory requirements of mineral producers, to calculate stockpile volumes, assist in the calculation of overburden volumes to be excavated or which have already been excavated, and to produce as-built drawings of larger earthen structures for certification, such as coal processing waste disposal embankments, spoil disposal structures and roads.

Use of this aerial platform for certain surveying and mapping projects affords our clients not only improved economics, but it takes our personnel out of harm’s way when working around active operations and highwalls or steep rugged terrain.  Whereas a conventional, or even GPS, survey of a tract of land may require one or more days of work for a two or three person crew, the same tract of land may be covered by UAS in a single twenty or thirty minute flight.  Furthermore, the aerial survey would not “miss” hard to reach areas, and many more observation points would be recorded.  There are limits, however, to the effectiveness of aerial surveys, including inclement weather, dense vegetation or proximity to “no-fly zones” (airports, residential communities, etc), and each project must be investigated to determine the best course of action.

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With the growing availability and affordability of this technology, the surveying field has been flooded with companies trying to compete with this service. Clients should be wary of new firms popping up offering similar services at a cut-rate deal. Don’t be misled, having the funds to purchase this equipment and obtaining a waiver to legally fly it does not necessarily qualify a company to produce survey documents or engineering measurements without the appropriate licensure. Many companies performing surveying and engineering services without the appropriate licenses are being reported to their respective boards and legal action will likely follow.

Don’t get caught needing to have a survey redone because government agencies reject an uncertified document. Stick with the names you know and have been around for the long haul.

The Stream Protection Rule: A Final Blow to America’s Coal Industry

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The Office of Surface Mining Reclamation and Enforcement (OSMRE) is expected to publish the final Stream Protection Rule in the coming months.  Despite the controversy, congressional hearings and substantial number of comments the draft rule received, industry and states expect that the rule will be finalized with little change from the published draft rule.  So what exactly does this mean for America’s coal mining industry?  In a nutshell, it will create additional obstacles to obtain permits and place additional costs on both industry and regulatory authorities.  The end result will be little environmental benefit at significant cost to those who depend on mining to make an honest living.  The most significant job and production impacts will be felt in Appalachia, a region already stricken by unemployment and poverty.

Coal mining is one of the most highly regulated industries today, right below firearm manufacturing and nuclear power facilities.  To a layperson unfamiliar with the current regulatory scheme, this Stream Protection Rule may seem to be a much needed change to the current laws.  After all, the Surface Mining Control and Reclamation Act (SMCRA) has been on the books since the late 1970s.  Is SMCRA so antiquated that a re-write of the regulations is necessary?  The short answer is no.  SMCRA has been interpreted, litigated and reinterpreted for nearly four decades by the courts and the regulatory authorities.  The Stream Protection Rule is such a significant change from the current regulatory environment that it will require another 40 years of interpretation, litigation and reinterpretation at great cost.  Since the passage of SMCRA, the mining industry has made great strides in implementing environmental protection measures and there are many mechanisms already in existence to enforce the laws.

The key provisions of the Stream Protection Rule include: defining “material damage to the hydrologic balance outside the permit area”; significant additional baseline data gathering for the mine site and adjacent areas; additional surface and groundwater monitoring requirements; specific requirements for the protection or restoration of perennial and intermittent streams; and additional bonding and financial assurance requirements.

While the provisions identified above may appear to have noble intent, the end result will decimate what is left of the coal industry for three basic reasons: additional costs will be placed on an industry already operating on extremely slim margins; uncertainty will abound for mining companies on the ability to obtain a permit and stay in compliance with the permit; and the surety industry will not issue reclamation bonds when there is a likelihood that those bonds will never be released even if reclamation is performed to specification.

One final point is that OSMRE has gone about this rulemaking in a “one size fits all” approach.  While nobody in the federal government will likely admit this, the SPR was designed to significantly reduce or eliminate Mountaintop Removal Mining in Appalachia.  But rather than looking to the states (who have “primacy” or primary responsibility for implementation and enforcement of SMCRA) that host Mountaintop Removal operations for regulatory solutions, OSMRE is attempting to impose these regulations nationwide.  A basic premise of the SMCRA program is states’ rights, the recognition of which is a clear directive of Congress in Title I, Section 101 of the Act:

“because of the diversity in terrain, climate, biologic, chemical, and other physical conditions in the areas subject to mining operations, the primary governmental responsibility for developing, authorizing, issuing and enforcing regulations for surface mining and reclamation operations subject to this Act should rest with the states.”

Interestingly, if one takes the time to look over annual state oversight reports by OSMRE, it is difficult to find where OSMRE finds there are state regulatory program deficiencies.  Most states have implemented effective SMCRA programs tailored to meet the needs of the physical and regulatory landscape that is unique to each state.  OSMRE has demonstrated no need for a modification to the federal standards, and this attempt to impose such sweeping new standards without such a demonstration undermines the statutory scheme crafted by Congress four decades ago.

For more information on the Stream Protection Rule visit http://streamprotectionrule.com.