This week’s announcement that the FAA closed comments on the NPRM for small UAS so caught me by surprise that I never got around to submitting my own comments. Not that it matters much; my views were well represented by many others, perhaps with just a couple of exceptions I’ll get to in a moment.
The comment closure surprised me because many of the people I talked to about the NPRM thought the FAA would be buried in 100,000 comments and would be so overwhelmed that it would have to extend the comment period. But that didn’t happen, although the agency did receive a range of opinions in more than 4000 comments. I didn’t slog through them all, but followed the first 1500 at a distance. In these, I found an encouraging, measured view of how regulations might mitigate the risk sUAS pose to manned aircraft. A small percentage of commenters called for an outright ban of this technology, but the majority acknowledged the FAA NPRM as a good first step; a basic framework for additional guidance.
There continues to be confusion about the size of sUAS these first regulations apply to. They apply only to under 55-pound operated line of sight. They do not apply to the hordes of Amazon and Google drones we imagine poised on the horizon. Those regulations are thought to be five to seven years away, but I think the pressure is going to mount to compose and publish them sooner than that. Because these UAS will likely be heavier and definitely operated autonomously beyond line of sight, they are to LOS sUAS as a Cirrus is to a 737. They’re just an entirely different thing and beyond the scope of the discussion for the moment.
Having accumulated some drone time myself for photography, my opinion of the proposed altitude limit changed. The NPRM recommended 500 feet maximum, but many commenters suggested 400 feet and some 300. Surprisingly, I’m in the 300-foot camp. My Phantom is set up to fly no higher than this altitude and I can tell you at 250 feet, it’s a dot; much above that, I’m not comfortable controlling it visually. And I sure as hell don’t want to risk losing my $400 GoPro. I’ve done most of my shooting from 50 to 100 feet and I think the majority of commercial work that such aircraft might do can be done at 300 feet or under. Some can’t. That’s why helicopters will remain players in aerial imaging.
The exception I’d make would be 400 feet for RC aircraft flown at areas intended for the purpose under the Academy of Model Aeronautics guidelines. I hate to see AMA members restricted because the influx of readily accessible technology that means anyone—and I mean anyone—can now be an RC pilot. There are thousands of fields set up for this very purpose and 400 feet is a safe and practical limit. It has been for years.
Any operator who needs to fly an sUAS above that, whether it’s 300 or 400 feet, should be allowed to do so only by approval or with discrete permitting, in my view. I think keeping sUAS at 300 feet or below significantly reduces whatever small risk sUAS represent to manned aircraft. And where I part company with most of the commenters is that I’d make below 300 feet entirely unregulated, commercial or otherwise, for the smallest class—Micro UAS two pounds or under. The reality is that it will be de facto unregulated anyway because the FAA simply isn’t going to have the resources to enforce once this NPRM is baked into law. Many existing and new commercial operators will simply fly under the rule’s umbrella without bothering with the required certification and registration. The technology is simply too cheap and too pervasive and getting more so. I think the FAA’s best shot at de-confliction with manned aircraft is a combination of enforcement with what resources it has available and massive education for the hobbiest non-commercial operators and for those commercial operators who won’t bother with certification and training.
Speaking of all that, I wonder if the FAA could still shoot itself in the bureaucratic foot here by failing to build the administrative infrastructure quickly enough to handle to what could be a massive influx of applications. It being 2015 and all, the agency has a rare opportunity to clean sheet a streamlined oversight process. I hope it’s creative enough to seize the opportunity. But we are dealing with the government, after all.
Drones or UAS?
What to call these blasted things continues to baffle the press and we’re no different. Last month, a reader wrote to complain that we should stop calling them drones and we can’t call them UAVs, either. He said the best choice was UAS. Maybe. The most accurate descriptor is RPAS—remotely piloted aircraft systems. Manned or unmanned sort of doesn’t matter much in this context.
In deciding on terminology to describe something that’s not necessarily in our center lane of coverage, I look to the industry to which the subject applies, in this case UAS manufacturers and associations. I’ve noticed on press releases, trade groups such as the Association of Unmanned Vehicle Systems International is using the word drone, so I called them to ask what their official policy is. They don’t exactly have one, but at last year’s AUVSI trade show in Orlando, the password for the pressroom WiFi told the tale: dontusedrone.
AUVSI has since evolved, to use the vernacular. It felt drone had a negative connotation related to weaponry that no longer exists, or at least exists to a lesser degree. So it uses both the term drone and UAS, for aircraft applications. It should be obvious by now that AVweb uses both. I prefer drone in the headline because it reads better than UAS and UAS in the body of copy.
I draw some guidance from inside aviation. We never use the term “blackbox” to describe flight recorders because people in the industry don’t use it. Blackbox continues to be a media confection. But the same clearly isn’t true of drones. I mean UAS.
