It’s been 5 long years since the FAA first convened the Small UAS Aviation Rulemaking Committee. Perhaps now would be a good time to consider where we are in the small UAS community, where we would like to go, and how best to get there.
As to where we are, we know that in 2009 the sUAS ARC made a set of recommendations to the FAA that were unnecessarily restrictive, and as such, did not achieve any kind of “consensus” of the sUAS community. The FAA took these recommendations and began to construct some kind of sUAS rule in-house. Since even a draft of the rule has not been released, we are not supposed to know what is inside. (This is by statute so that there is no insider advanced knowledge that might allow an unfair advantage.) Nonetheless, we can use many of the FAA’s public comments and recently published “roadmaps” to get a good indication that the draft rule is likely to be somewhat draconian in its restrictions. If this turns out to be the case, the nascent small UAS commercial industry may be stillborn.
Instead of lamenting the unknown level of National Airspace System (NAS) access the draft rule may (or may not) allow, perhaps it would be more useful for us to ask ourselves: “What level of access do we as a community WANT to have?” Then we can determine what is keeping that from happening and work as a community to solve those logjams.
A recent paper on the economic impact of small UAS estimated that if NAS access was broad enough, there could be as much as $8 BILLION per year in new business in the US alone. That’s a really big impact. But, in order to achieve that level, small UASs would essentially need to fly just about everywhere, anytime. This means that small UAS would have to be “integrated”, not “segregated” into the NAS. (Where have we heard this before?) So, what’s stopping this from happening?
The FAA has consistently used the mantra “We need data” as the reason why they have, so far, been unable to allow broad access to the NAS for small UAS. However, extracting what kind of data the FAA needs and who should generate that data have been elusive. But, do we really need them to tell us or should it really be us telling them? Let’s look at what kind of data would be useful to the FAA to make safe access to the NAS available to us.
First, there is currently no measured data on what level of hazard small UAS may or may not pose to people and property on the ground (or in the air for that matter). Congress recognized this and explicitly told the FAA in the FAA Modernization Act to figure it out. Along with this, there is precious little measured reliability numbers of the components and systems we in the small UAS community regularly use. (We usually just replace something when it breaks or fails.) So, the FAA really doesn’t have a good fundamental understanding of how much or how little of an issue integrating sUAS really is.
In addition, while many in the model airplane world have been flying at the limits of their skill level and have an admirable safety record, in the small UAS world, we don’t really know what the limits of “within visual line-of-sight” really means. Does it mean the ability to manually fly a sUAS? Does it mean the ability to see the sUAS? Or, does it mean the ability to de-conflict the airspace to make sure there aren’t any collisions? What about daytime vs. nighttime? Again, the FAA doesn’t have the measured data that would help them to decide which type of operations are safe and which are not.
Speaking of night, many model airplane flyers have started flying at night with good results. First responders such as firefighters and search and rescue operators want to be able to fly at night as well. In the small UAS community, there has been some recent efforts that are tending to show that night flights might actually be SAFER than daytime flights because manned aircraft are more likely to see the small UAS if it’s lighted properly. This make intuitive sense since most manned aircraft pilots are trained to see-and-avoid strobes without asking what size vehicle is carrying the strobe. Again, more actual data based on real measurements, not opinion, is needed to show this to be definitively true.
What about other types of airspace? For the most part, the small UAS ARC suggested staying in uncontrolled airspace, several miles from any airport. This would eliminate over half of the potential applications, and probably 2/3 of the commercial ones since they are likely to be in urban areas. What does it actually take to operate a small UAS in these types of airspace? What kind of equipment is needed, if any? Can some of the functions normally done by equipment be done procedurally? How should a small UAS interact with ATC, if at all? Again, the FAA doesn’t have the experience base to answer some of these questions.
What about operating beyond visual line-of-sight? The cost of autonomy has plummeted in the past 5 years to the point where most hobbyists can buy a reasonably good GPS-based autonavigation unit fully capable of performing a mission beyond the limits of vision. But what technologies are available to keep the small UAS from running into other aircraft (or buildings) and, more importantly, how well do they work? How well do they NEED to work? Again, the FAA doesn’t have the data and doesn’t have the technical facilities to answer some of these questions.
So, what are we to do with this conundrum? On the one hand, the FAA continues to say they don’t have data, and on the other, the community wants more access to the airspace but also doesn’t have the data to give the FAA to help them give us the very access we seek.
One answer may be in the form of the topic for one of our sUASNews podcasts. We recently interviewed Chuck Johnson who heads up a UAS in the NAS project for NASA. Listen here Chuck gave glowing reports about how smart some of the NASA guys were specifically when it comes to small UAS. We know that NASA not only has the technical resources to answer all of these questions, but is a trusted member of the small UAS community who will put out the data and let the chips fall where they may. (After all, NASA is not a regulatory agency so they don’t have a vested interest in keeping small UAS out of the NAS.) However, in order for NASA to expend the resources required to generate the needed data, they need to hear from the small UAS community that working these issues is vital to our future. As Chuck said, “We’d like for the community to speak with one voice.”
We have an opportunity to do just that. Coming up on July 18-19, there is an open-to-the-public meeting where NASA will be discussing the UAS in the NAS project and soliciting public comment. story We, as a community, need to have our voices heard. We need to let NASA know that we’re counting on them to provide the technical data the FAA needs to allow all of us access to the NAS. We need to make sure NASA understands that the data they generate will directly impact the ability of all of us to operate in the airspace both now and in the future. And, we need to let NASA know that our community of small UAS users (and potential users) is very large, indeed, and every bit as important, if not more so, than the large UAS users (who, honestly, is just Uncle Sam since they’re the only ones that can afford them). So, if you’re in the DC area, go to the meeting in person. If you can’t make it in person, sign up for the on-line conference. Either way, let’s make sure that we “speak with one voice” and let’s make it a very loud voice impossible to ignore.