The Shakedown – Troubled waters in 107 land

Who doesn’t love a good shakedown? Well, usually the person or group getting shaken down (the shakee) unless of course, they are unaware that they’re getting shaken down. That is where we are today, and it is okay if you are because a good shakedown artist doesn’t let on to the mark that they’ve been taken advantage of until after the mandate.   

I’m going to run through some of the 2018 topics of relevance; Drone Integration Pilot Program, ID and Tracking, LAANC, Registration, and cell phone UTM. Now rest assured that these topics didn’t just arbitrarily show up. They are all a figment of someone’s business plan to scale some VC money on solutions for problems that don’t yet exist or just merely move more hardware. There has been a rush to get in the air at all costs, and well, it has cost us a lot. Credibility is one of the major issues that beg for the limelight. Namely the idea that local municipalities should make rules for aviation. (Follow the VC money!)

Heaven help us if we start hearing the drone “advocates” and “experts” braying that we need some commercial end-user participation in the effort. The only part of that commercial end-user relationship will be a shill on the payroll to round out the “unbiased” influence and possibly a fall guy or gal to throw under the bus when things go pear-shaped.

I am going to warn everyone right up front that his one is in-depth and long, but it has got something for everyone. I’m throttling way back on the intellectual honesty routine, as all that accomplished was the mass alienation of the selfie-drone devotees and snake oil peddlers. Feedback suggests that even the word pairing can put folks in a darker place than a 3D Robotics investor in fall of 2016.

Warning! If anyone reading has the slightest aversion to reality, they should just skip down to the solutions section to forego any possible feelings of consternation and or grief.

(If you are a fanboy/girl, self described drone “expert”, “advocate” aficionado, forecaster, skip chaser or anyone else needing blog stuff to fill in around the sponsored material you are in luck as you’ll be able to poach and parrot this piece without attribution for the next six to eighteen months.)

Drone Algebra –

As a baseline, we must try and wrap our heads around the fresh crop of numbers. The latest’s estimates make that world’s largest advocacy group telephone book stuff look like Nobel Prize-worthy science. The Pew research folks are now estimating that 8% of Americans own drones. That would mean we are north of 25 million +/- drones in the United States. The Pew Research Center is a highly respected for their polling methodology, but I say all polls are suspect and anyone that doesn’t believe me, can just ask President Donald J. Trump.

I know, you’re thinking what do these forecasts have to do with the price of tea in China? These forecasts as the basis for most of the crises based regulation, and what proprietary solutions are built on. If you have been around long enough you will accept at face value that the Flywheel, Shyster and Flywheel research group said there would be 1.2 (+/- 2.6%) million drones sold at Christmas. Then some middle manager or consultant is given leeway to gin up a crisis and tell folks that it means there will be 2.4 million and the sky will be black with drones and we need a solution to stop rouge drones at airports. Here’s where the scaling (aka shakedown) starts so let’s fire up a committee or two and get a handle on this problem we’ve been nursing for 25 years or so. A few “experts” have made a career out of this committee and consulting merry-go-round.

If we go back to the Pew forecast, we have to postulate that either the numbers are bogus, or the FAA has a compliance issue of colossal proportions that may warrant revisiting the regulatory drawing board, square one or the wishing well. Hard to hype a program when success hovers in the single digits, and that is regardless of how good the intentions may have been at the outset or end. We have 70K +/- Part 107 pilots, and I know this is a heavy statement, but anyone who still believes educating the AMA hobbyist is the key to regulatory compliance is doomed to more of the same sighting numbers trend. Not that I am discounting the notion of education out of hand, just saying the choir may not be the biggest problem just the easiest folks to find.

A casual peruse of the numbers could suggest that current educational curricula and dissemination methodology is lacking a certain tangible degree of traction with the Big Box store flock. On a side note, the worlds largest drone advocacy group can’t bust the 7500 member (6000 now) ceiling, so I’m not holding out much hope for an educational sea change there.  Know Before You Fly not so much, and many doubt charging constituents a few hundred dollars for access to UASIO office personnel will do much to remedy the shortfall.

Forecast spoiler alert for those who may have already spent their share of the income from the 82 billion dollar market. Drones have always held value as tools for self-guided data collection and have been successful in augment existing businesses. The drones as a service model never really worked out as planned. Why train a guy/girl to be an expert in (insert profession here) when you the professional can easily learn to fly the drone? The barriers to entry are mighty low folks. If you can quantify the value they bring to the various industries and economy I am all ears, the rest is dartboards and click bait for the new annual crop of Christmas drone experts.

Return of drone registration –

Information FOIA’ed as a result of the Taylor case indicated that registration wasn’t a factor in any FAA enforcement actions, but hey why should that preclude us from pounding that square peg through the round hole again? The sighting numbers keep going up and depending upon what time frames you sample things can look scary.  Couple that with the modelling ASSURE did and you have a recipe for another federally sponsored CYA disaster committee.

Warning! ASSURE digression alert!

I don’t want to get too far off into the weeds on this one but will pause to make a couple of comments as anchor points for further discussions. I view models like polls, they are biases, and they don’t call it the old “Monte Carlo Method” for nothing. I will say that I was disappointed that the research paper didn’t even get the nomenclature in the acronyms section for the items researched correct. That doesn’t bode well for the assumptions and one of the reasons why I’ve been beating on the OEM’s to sponsor some third party independent research.  (Really hoping this one gets poached sooner rather than later as the feelings based conjecture and birdcage grade white papers aren’t cutting the mustard.) Does $250K for scientific research sounds like too much when they are talking about an industry purported to be worth eighty-two (or a hundred and twenty-four) billion dollars?

On the drone advocacy side, advocates, please do not talk about how the ingestion modelling proves that things aren’t as bad as folks had assumed. Sure, it’s not a guaranteed fireball on the wing, but fin breakage and shutdown will never sound like “no big deal” to members of the manned aviation community.  Not only do you look like a Jackass, but we as a community also suffer as they have no idea you paid lobbyists to get “you” on committees to represent your interests and not us.

Drone Integration Pilot Program –

DIPP shares many of the hallmarks of the Test Site boondoggle from the 2012 FAA reauthorization. First, wasn’t most of what we are going to do in the Drone Pilot cities already supposed to be wrapped up at the Test Sites? Didn’t Congress mandate NAS Integration by September of 2015? I see another round of good-old-boy cronyism without the pork happening here. (I’ve even heard the FAA has had people inquiring about when they can expect the check. LOLZ) Why else would anyone want locals creating ordnances and collecting fines on something with a steep learning curve?

Why would anyone in their right mind advocate for registration of the AMA member hobbyists? I can see the big box store and mall kiosk customers, but 70 plus years of a working program has to count for something, no?? Local Law Enforcement enforcing the FAR’s and municipalities collecting the fines opens the floodgates for an asset forfeiture type of scheme. Even from my own experience where I knew I could legally fly, I don’t make a habit of arguing with the dudes wearing the badges and guns. On the inclusion front, some segments of the population aren’t actively looking for new and exciting ways to interact with the police.  

Golly, how in the heck will droners stay out of trouble with local Law Enforcement? Maybe some guys with a heart gold and a stack of VC funding looking for a market for their product can come up with a cellphone app that keeps up with all of the new local rules and regulations. An enterprising dot IO could put local municipalities on an annual contract so they can update the rules for their revenue-generating totalitarian drone-quashing machine.

My favourites for the Drone Pilot winners are North Dakota, New Mexico, somewhere in the NUAIR sphere and possibly by sheer coincidence the new Amazon hub city.  Heck, I wouldn’t be surprised at all if in three to five years from now we’ll learn that the Amazon airspace plan works like a freaking charm! ;-)

If you feel a little low and you are in need of some comic relief just go over and take a look at the FAA Drone Integration Pilot Program Facebook page.  It is getting so wild over there that even the hucksters are taking a powder. (FAA pulled it down)

LAANC –

Why do we need LAANC anyway? I know the 12 +1 anointed companies and the FAA have lauded this as the key to BVLOS and hear it is even rumored to help drones stay crunchy in milk. Some have their doubts that the 50 cities notion will put much of a dent in the waiver backlog. Furthermore, anyone who is counting on the FAA to build something from scratch in a timely fashion should Google NextGen and let me know how they think that has worked out.

Besides, we already have a flight services system that has been working almost everywhere in place for some time now.  The system for fifty cities in a country the size of the U.S. doesn’t smack of a “we’re leading the way” stratagem. The www.1800wxbrief.com is one checkbox from being an already built, secure and tested LANNC without having to reinvent and pay for the new wheel.  

The eighty-two billion-dollar questions are, why do we want the FAA to build something new when what we have isn’t broken? Did anyone run all of this by NATCA, and if so is it part of the backlog problem? The waiver/authorisation backlog is a testament to regulatory planning done in a vacuum and without qualified Subject Matter Experts (SME’s). On a side note, during the brief government shutdown, LAANC was shut down, but Flight Services was not. I will leave it up to the reader to draw his or her conclusions on just who has redheaded stepchild status.

UTM –

This one has me more concerned than the others and primarily because I don’t want to build or subsidise the build of a system for billionaires under duress.  Namely Amazon, Google and Wal-Mart. Why wouldn’t we just have the flight services contractor incorporate that UTM map grid into the existing system?

You think the drone airspace and scheduling apps are all doing their haphazard work out of altruism, do you? Someone gave the cellphone companies the big idea that they could cure all of the ATC, ID and Tracking and collect fees off of their network if every drone had a sim card in it. There is enough revenue growth potential their for everyone to start coming up with solutions for the FAA in a jiffy. Is anyone talking to the ATO and air traffic controllers union? Anyone who thinks that implementation is going down without the nod from the NATCA folks is suffering from an acute case of wishful thinking.

Spoiler alert! Moving the graphics around on your next round of funding power-point slides or computer-generated animations to make your cellphone app look ATC- esque doesn’t count as global UTM progress.   

ID and Tracking –

The fast track to riches, um, I mean for us to fly over people. While I think it is an excellent future goal we should stop and remember the no practical test for Part 107 and aircraft weighing up to 55lbs at speeds up to 100mph. That is only the first carriage before the dead horse example. Let’s ponder what millions of drones look like on an ATC computer or cell phone app screen.

This industry has some engineering hurdles to overcome. Mainly Mean Time Between Failures (MTBF). Currently, I hear 1 in 25 hours mentioned, but we as a community have to consider that turbines average about one failure in 375,000 hours (according to the interweb). Of course, those numbers do not include inadvertently snapping fins off on some freshly ingested crunchy drones. The airline safety numbers are 10-9. That is about one in a billion, or in layman’s terms, once in never.   

While musing about dark subjects, let’s us take a moment and think about drone Quality Assurance and Quality Control (QA/QC). We are part of an industry built on the customer paying to do the product Beta testing. 3D Robotics instituted an ingenious post-sale crowd-sourced QA/QC program. It relied on DIY Drones paid moderators, company employees and fanboys mocking, shaming and finally deleting negative comments and threads on the IP generating community portal. Mocking your customers is one thing, but alienating your IP base is just freaking schnutz.  

As a fair-minded person, I would find it hard to believe the American public is going to tolerate 28 million uncertified drones falling on their collective heads. I’m not sure flying directly over nonparticipants is the best idea until we have reliable equipment and more robust training. I have to respectfully disagree with anyone advocating for such nonsense without at least a 107 practical test.  

The old how are we going to ID UAS question has been floating around for years. The FAA thought that they might accomplish this with N numbers. The picture accompanying this article is the fuselage (1 cm) of the Cracker Barrel circa 2008. It was done for the benefit of the FAA personnel during the sUAS ARC to highlight some of the drone ID realities.

Solutions section –

First and foremost, the process needs more daylight and qualified SME’s. For some reason this idea gets folks all riled up, but the WaPo DAC story(s) confirmed that the stakeholder (bag holder too) and public deserve much better than the current low standards.

Install a Drone Czar – The Drone Czar cannot work for or consult with a company selling hardware or software. However, considerations should allow for a highly qualified person with a track record of self-funding and integrity. This person cannot maintain a leadership role or board position of an “advocacy” group. This person must be knowledgeable, honest and qualified with many years of empirical experience in the Unmanned Aircraft discipline.  

Stop all (nonessential) actions for six months to do a forensic accounting of the current conundrum and identify any duplicate efforts or dead ends.

Establish 5 to 10 priorities for the next Federal fiscal year

Publish a project schedule of priorities with goals and timelines.

Establish special standards committee (operation teams) from the various standards groups including but not limited to ASTM, RTCA, SAE, etc. Each team is assigned a coordinator. The team coordinators would report directly to the Drone Czar.    

–    Participation limited to 5 to 10 people on each committee team  

–    Participants must be peer-vetted

–    Ability to invite or interview SME’s

–    Findings vetted and peer-reviewed (no rubber stamps)

–    No new rules, regulations or policy without being scientifically validated or at   least independently peer-reviewed

–    No product pedalling as part of the work

Make the entire country part of the Drone Pilot program. Start out in rural areas with lower populations and aircraft traffic. Develop some better training schemes and possibly add some endorsements to the Part 107 certificate, i.e. aviation radio, file a flight plan.   

Add a Practical (flight) test to the Part 107 mix.

If the regulator wants to get a handle on the drones numbers Pew is talking about they can start by taxing and registering anything imported from overseas as aircraft. If that doesn’t work, a point of sale registration and a handout that requires a signature proving that the purchaser at least perused and had been made aware of some of the rudimentary FAA rules, including not buzzing manned aircraft.

If you want more good stuff like this every day, you can follow me on the Twitter @thedronedealer