It’s the beginning of the end!
The very first UAS commercial type certificates have been granted by the Federal Aviation Administration! Now, commercial flights will be everywhere, all the time. No one is safe! The metallic birds, with their electronic chirps and flashing lights will pollute the skies near you – all day, every day!
Huh? Why not?
Well, let me tell you what happened – explain the thought process behind it, and identify why it doesn’t really mean much more than what the FAA (and Congress) has already said.
First and foremost, because facts matter and hearsay causes more problems than much else:
What is actually happening?
Well, as of Tuesday July 20th, 2013 the FAA has issued the first commercial UAS Type Certificates to two small unmanned aircraft systems. These systems, the Insitu-Boeing Scan Eagle X200 and the AeroVironment Puma, both fall under the FAA classification guidelines for small UAS – both are under 4.5 feet in length and 55 pounds in weight. Prior to this, only experimental airworthiness certifications were available in the domestic regions for UAS operations – these being intended not for operational or commercial use but for testing the stalwart characteristics of the communications, airframe, and other sub-systems excluding payloads.
Proponents and opponents are clamoring as to the implications of this development and, from what I have seen, they all seem to over state what this development *could* mean, for what it *does mean*. Conjecture aside, it is very important to identify what makes this unique and why it matters from a regulatory context – luckily I HAVE a regulatory context and experience.
The Arctic and ELOS
These two type certificates are only applicable to operations in the Arctic Circle. Yes, let me say that again, the Arctic Circle.
Are they testing Cold Weather sub-systems? Well that would make sense if this was that other certification process that I mentioned; so the answer to that is…no.
Are they going to be hunting Penguins for the newly blossoming penguin meat addiction erupting on the border cities of Canada? Well, no to that one as well as they are not weaponised and in fact penguins live very, very far away from the Arctic.
No, the reason that the Arctic proves to be a perfect beginning spot for unmanned flight is ELOS – Equivalent Levels of Safety; the go-to tolerance allocation that the Federal Aviation Administration uses to certify new technologies that are relevant to another, already existing, technology. The idea behind ELOS is that by achieving a similar level of safety standard, the new technology should be able to operate within the same hazardous environment that the previous technology operated within.
If p(A) = tolerable, and p(B) = p(A), then p(B) is also tolerable.
Now, when I was sitting on RTCA Special Committee 203, we discussed Equivalent Levels of Safety ad nauseum – it is very important for the allocation of safety objectives and requirements when forming public policy.
Co-location of the pilot and the airframe isn’t necessary, is the thought, if the unmanned planes’ safety tolerances are equivalent to the manned planes. This brings us to the problems of “What exactly is holding back unmanned safety tolerances.” They are:
1. Sense and Avoid technology
2. Airspace Allocation
3. Bandwidth Allocation – fixed for now 4. Regulatory Framework – fixed for these two airframes
So, looking at our small list above, sense and avoid technology and airspace allocation are the greatest setbacks for ELOS. By this we mean they aren’t on par for safety with manned aviation. However, the Arctic represents a very interesting case.
The environment is barren. There is practically no traffic in the region and the little there is operates mostly instruments anyways. There are nearly 0 obstructions and the visual range is difficult to use on a snowy background so sense and avoid technology would not be any better than the current technologies. Finally, the airspace allocation issue is nearly non-existent.
We can say that the level of safety of unmanned aircraft to anyone in the air or on the ground – given how barren, how desolate, how sparse, how un-populated, how remote the area is – is about equal to that of manned aircraft based on possible accidents or incidents that would cause damage; an airstrike or ground collision.
In conclusion, the certification of these two airframes is not marking the coming of bugbots, hydro-drones, mechanized arctic warfare, or the beginning of the end of privacy. These Remotely Piloted Vehicles are the first commercial drones that will help protect lives, monitor pipelines, promote awareness of the environment, and enable companies to minimize their environmental impact while not impacting the environment (with their aircraft).
I’d say, rather than the beginning of the end, this may be, the end of the beginning.