Over my integration tenure, I’ve seen a lot of experts come and go, and have heard how the FAA would never regulate model RC flying, rockets or drones. Plenty of braggadocio from those champions on how they were going to clean the FAA’s clock and assurances that whatever the outcome common sense would prevail.
Are Drones aircraft as the FAA, DoT, and ICAO classify them, or are they consumer electronic products like hair dryers? The messaging is bifurcated and the goals unclear. What is the terminal velocity of a desktop printer from 32 inches and do the manned stakeholders care?
The following was written in March of 2017 for educational purposes and uses the highlighted white paper from DJI lamenting some of the Drone Registration Task Force shortcomings. What I have highlighted were some of my concerns prior, during, NPRM time, and since about a process that has turned out to be less than desirable for some and expensive for others.
RCAPA :- Comments on Registration and Marking Requirements FAA-2015-7396
We have to be cautious when we represent other stakeholders’ interests as there is a lot at stake, just ask the Canadians how they like their new 250-gram registration scheme.
Are we talking about consumer electronics or aircraft?
The silver lining: the white paper does help to illustrate why everyone in the stakeholder community including the commercial end-user still lacks credible representation. See the Drone Czar proposal
Drone Advisory Committee Follow Up and The Drone Czar Proposal
Now, I’m not insinuating that anyone who got a golden ticket invite from the DoT Secretary assumed they would be getting the regulatory doormat treatment, but fair-minded stakeholders (more) are now wondering if it was a setup, or some of the stated and ignored advocacy concerns were warranted. Again, flashing back to the naïveté scene, when we had repeatedly been told that the RC hobby would not be regulated, yadda, yadda, yadda. Now the hobby folks aren’t only registered (without a dissenting opinion) welcome to Part 101 and who knows what in the future.
I’d be remiss if I didn’t give some background on how this debacle went down. Task force members were warned in advance about the FAA’s agenda. While some of the companies thought their participation would be positive, time has shown that the notion may be wrong. The retailers went along with the program they just didn’t want to be saddled with paperwork. Some companies thought they’d get lucrative registration contracts from the FAA and CAA’s around the world, as they knew for sure that whatever the FAA does other CAA’s are sure to follow. This is a glaring example of gullibility as a cell phone app start up thought they were going to consensus their way into a registration contract pork chop.
The list of “representatives, drone experts, et al.”
Some retailers have stated publicly that since drone registration was decreed business has declined. I was unable to find anyone who could tell me that business was up 200% or 400% year to year. Contrary to that, representatives stated that it was like someone hit the brakes. Whatever the percentage reality is we know several companies have lost over a hundred million dollars each since drone registration. Those retailers who may have thought they dodged bullets are in some case stuck heavily discounting drones, as the $82 billion tide has gone out.
The white paper itself is full of misguided and baseless assumptions, so much so that this can be employed as an example of flawed assumption one-upmanship. This offering makes the “bird strikes are just like drone strikes” papers and models, etc. look scientific. I saw no mention of industry-sponsored research to bolster assumptions like “Without combustible fuel, they will not explode or erupt into flames.” Furthermore, no mention of third party peer reviewed MTBF data, the low hanging fruit on the credibility fault tree. For reference, drone industry representatives speculated that drone MTBF (Mean Time Between Failures) were one failure in every 100 hours and rumors are that FAA sponsored research came in at one failure in 74 hours. Too many unexplained variables on both of those numbers for my liking.
While riding the rails on the assumption train, we can only imagine there is trouble in paradise (AKA Shenzhen, the de facto Silicon Valley of drones) for DJI government policy representation to trot out this thinly veiled (not really) mea culpa.
At the time, registration task force members said [the FAA gave assurances they wouldn’t use 250 grams for anything in the future besides registration] even though the registration task force was about safety. The big victory was that the FAA “people” registration scheme fee was only $5.
You can’t say in this instance that the FAA made promises they would have liked to keep, but the staff makes promises the FAA just can’t keep. If you don’t believe me, just ask the AMA. It is hard to believe that the risk to the NAS has yet to be defined and folks are still espousing their feelings about a huge “potential” aviation market they obviously don’t understand.