RCAPA Officially Ends Affiliation With ASTM F-38 Technical Committee

sUAS News recently received a copy of a letter (posted as part of this article) that essentially lays out a litany of process grievances that spans a six year plus timeline.  The letter serves to highlight issues that appear to conflict with the public’s best interest and defense contractors “standard stuffing” the process, a condition pandemic in the global UAS airspace integration effort, and in no way implied exclusive to the ASTM.

There are many examples of this throughout the sorted and murky history of this effort, provided one knows where to look. The RTCA had damaged their credibility by installing the ALPA (Airline Pilots Association), representative as the chair of the lightly regulated SC-203 subgroup. That was at least five years ago and the RTCA is still tacking the doldrums, and last I heard, collapsing the scope of deliverables. Equally telling and disappointing, was the lack of system and operational experience (small business aside), of the membership on the sUAS ARC.

I liken it to me being a Part 121 ARC SME on the grounds that I had ridden coach to the meeting!? Undoubtedly, we will be collectively scratching our heads to

incongruities in the SFAR that will be directly attributable to this lack of experience, aggravated by the ASTM Standards (due in part to the FAA’s haphazard direction), and finally, adding insult to injury is the roster and charter for ARC 2.0 (See the post script for more on this subject.)

The straw that broke the camel’s back…

The impetus for the official split was the news that the ASTM had no plans to release the F-38 Technical Committee standards work as part of the NPRM.  Anyone interested in seeing the guidelines would have to become ASTM members and pay $75 in order to see the work.  Worse yet, each standard (6-8 total at this point) will cost $40 when they become “law”. Is this what the taxpayer should expect from a “public” rulemaking process? It should be noted here that the DoD has moved away from ASTM/ANSI standards and is going back to public releasable Military Standards in part due to the limited standard availability in a timely and cost effective manner of the aforementioned documents.

The letter (see below) from RCAPA’s President, Rick Connolly does a good job of illustrating the small businessman’s point of view; with no finger pointing or foot stomping, but straight talk and an unambiguous perspective built on years of hard work and airspace integration effort participation.

“This doesn’t mean that all RCAPA members need to leave the F-38 Technical Committee, or any other consensus effort for that matter, after all it is a public process. What it means is that the RCAPA can no longer “officially” participate in what the board views as a skewed consensus.” Says Connolly about the split.

In closing, it expressively asks ASTM President James Thomas, to put the “public’s” interest above all else.

(Post Script)

Since publishing the ARC 2.0 FOIA story https://www.suasnews.com/2011/11/10245/uas-arc-2-0/

I have been receiving a relatively good amount of feedback regarding the glaring lack of small business representation, and “where the heck is RCAPA on ARC 2.0?” After digesting the documentation, one can only deduce that an obvious oversight was made by the FAA’s UAPO.

Strange that management, or even the members, hadn’t raised question about the lack of business sector representation, but you have to remember, things were pretty quiet re: the ARC formation and charter (hence the old sUAS News FOIA request.) Upon first getting wind of ARC 2.0, (UAS 2011, Paris), I was informed that it was largely system centric and wouldn’t really have bearing on the small business community. The charter suggests otherwise and to an extent that it furthers my resolve for inclusion on said committee.

If there’s room for two representatives from General Atomics, shouldn’t there be room for small business?

To be continued…

The RCAPA letter to ASTM

11/30/11

Mr. James A. Thomas

ASTM

100 Barr Harbor Drive

West Conshohocken, PA 19428

RE: Technical Committee F-38

This letter is meant to officially inform you of the reasons for disaffiliation of the Remote Control Aerial Photography Association (RCAPA) from the ASTM F-38 committee. It comes with much disappointment, as the RCAPA and its membership have been involved with the F-38 since and before the meeting in Reno, NV in 2005. We, as an association of mostly small business commercial users, have volunteered many hours, expended significant resources and provided valuable insight in a relatively unknown segment of use for this technology. In reality, RCAPA has been the lone voice for the truly commercial use of Unmanned Aircraft Systems (UAS) world wide, contributing expertise and proven best practices that are not easy to come by in this community.

It has been the long standing sentiment of the RCAPA board that the consensus process was skewed toward, and overloaded with, military vendors who were crafting standards around existing company products and respective business plans reflecting the military development methodology. By anyone’s estimation, this is a poor way to develop objective standards for a fledgling industry, which cannot stand gold plating and overly burdensome requirements.

These circumstances are definitely nothing new. Over the years the RCAPA has repeatedly voiced its protest to sub-committee Chairs, the committee Chair and even FAA personnel without success. RCAPA has continued to work within the F-38 framework in spite of the potential impact to their small business constituents. The situation has reached a crescendo as of late in the UAS Global airspace integration effort. It is the RCAPA’s position that the defense contractors involved with the F-38 process are using the consensus method (Globally) as a vehicle to circumvent the transparency inherent in the public rulemaking process and to institute processes and regulations that give them a business advantage over small businesses typical of the RCAPA constituency. Herein lies the primary source of contention for the RCAPA board.

We were dismayed to learn that the ASTM had no plans to make the F-38 work public as part of the Notice of Public Rulemaking (NPRM.) This runs counter to what members were told at the end of the sUAS ARC. Members were led to believe by the FAA co-Chair that they were involved in “public” rulemaking, where the impact of the proposed regulation as well as the planned implementation of those regulations could be assessed in an open, thoughtful and deliberate manner. The RCAPA board therefore reasserts the sentiments made known to the F-38 Chair, Jeffrey Goldfinger. On behalf of the public, the RCAPA Board formally request that ASTM make the proposed UAS standards part of the NPRM.

Respectfully,

Rick Connolly, President

CC: The Honorable Howard P. “Buck” McKeon

J. Randolph Babbitt (FAA)

Leslie H. Smith (FAA)

Richard Prosek (FAA)

Editors, sUAS News