Overcoming the Barriers for Safe UAS / RPAS Entry into the NAS

Patrick Egan

Contributors:

Gary Mortimer

Veronica Luther

Kirk Greninger

With language in the FAA Reform Act and the November ruling by the NTSB we are all now firmly in the Aviation business. With this comes great responsibility as well as cost in bringing new technologies forward and to realize the full potential.

The FAA has repeatedly affirmed the need for data, but has heretofore not been able to articulate what data it requires to satisfy its safety mandate. As a result, the UAS/RPAS community has had to rely uniquely on introspect when searching for answers to what “data” may or may not be relevant. All the trite rock analogies aside, this endeavor has proven costly, time consuming and has produced little in the way of tangible results.

The need for data has proven to be a moving target at best, but some constants have been the mantra of the AOPA, APLA and the HAI: Demands for UA to “maintain equivalent levels of safety as manned aircraft.” In most instances this includes See And Avoid/Sense And Avoid (SAA), and certification for aircraft and pilots (14 CFR).

The reality is that we have very little direction from the FAA beside the notion that the community will be designing, building, operating and maintaining its own Unmanned Traffic Management (UTM) system. Ultimately and as stated by FAA personnel, they will have to sell our proposal (I fear something along the lines of a Rube Goldberg apparatus) to AOPA, ALPA, et al. I find this notion less then agreeable. Not because there are doubts about the FAA’s salesmanship praxis, but the plan lacks a certain ‘we’re all in this together’ sentiment associated with regulator participation.

Background –

We will start with ACCESS 5. While the assumptions for this program were centered on High Altitude Long Endurance (HALE) Concept of Operations (CONOPS), they do share some of the same issues and raise similar questions.

Besides those HALE assumptions, there were also assumptions about commercial UAS being primarily large aircraft. Those notions have been proven wrong with the sheer numbers of small unmanned aircraft sold and furthermore, in use. Commercial use cases for operations that cost $7500 to $37,000 per hour are not viable.

Solution –

Even now with the release of the NPRM, comments will be made based on feelings, as the community has not invested in the research that would allow it to build a data set supporting safe and regular UA entry into the NAS. The industries ultimate commercial viability hangs in the balance as it lacks the scientific data to substantiate the community’s claims. There are some that believe the NPRM is very liberal, and that there will more than likely be pushback, it is only prudent for us to be prepared.

We need to take the constants and apply the scientific method. If we hope to move forward in a timely fashion we must establish the baselines to build on with scientific data pertaining to the following topics:

1. Visual acuity for human sight for See And Avoid (SAA).

Some of this work has been done; we can build on it and do the research necessary to verify the findings. This will give us a starting point for a hardware/software SAA solution.

2. Kinetic energy study for small UAS/RPAS. Structures as well as aircraft components.

Conclusion –

Even now with the release of the NPRM, comments will be made based on feelings, as the community has not invested in the research that would allow it to build a case built on data for safe and regular entry into the NAS. The industries ultimate commercial viability hangs in the balance as it lacks the scientific data to substantiate the community’s claims.

If we as a community are to move forward, we have to first be able to define and then aptly defend the risk we pose to the NAS and those nonparticipants on the ground. This risk is presently an unknown quantity and is almost entirely defined by the feelings (emotions) of the existing airspace stakeholders and ultimately the regulator.

Low cost and firmware/software and hardware certification are almost a misnomer. It is getting difficult to find people even amongst technology proponents who believe that UAS/RPAS BVLOS operations will be possible without software certification. Cursory investigation has put estimates for DO178 B/C certification at a staggering $100 per line of code, which could easily run into the millions of dollars. Of course this estimate does not include OEM development and testing.

Certification costs and the unquantifiable feelings of stakeholders necessitate the need for scientific testing. Any and all findings would require QA/QC of third party independent verification to be beyond reproach of bias for one or a group of vendors trying to influence FAA policy. This is the only logical way to expedite an already 23-year-old process.