MAPPS Executive Director John Palatiello was recently named to a Federal Aviation Administration (FAA) working group to an Aviation Rulemaking Committee (ARC) to advise on beyond visual line of sight (BVLOS) policy and regulations for unmanned aircraft systems.
The ARC's purpose is to provide input from users or potential users of UAS on immediate, near- and long-term issues for integrating UAS into the national airspace system. It will advise on the next group of regulations that the FAA will be writing after establishing the Notice of Proposed Rulemaking that is anticipated to come out later this year.
Each member was asked to submit (1) their 3- to 5-year anticipated requirements for BVLOS UAS operations; (2) perceived barriers to conducting those operations; and (3) recommendations for the FAA to consider on how to remove those barriers.
The following is what Mr. Palatiello submitted, based on input from numerous MAPPS member firm principals.
MAPPS looks forward to a VLOS and BVLOS regulatory environment that will enable UAS to support key industries such as transportation, oil and gas, mining, power transmission, and agriculture. These industries often have specific infrastructure in defined geographies that require more support than what can be efficiently and safely provided by manned aviation. We believe this additional support will enhance public health, welfare and safety while enabling advanced technologies to improve performance and potentially reduce costs. This support can be safely provided sooner through administrative/procedural processes before fully capable sense and avoid capabilities that are certified and standardized are achieved. The same is true for communications systems. Both of these technologies are feasible. However, both are also quite expensive, and therefore not seen as practical in the short term for the very small systems.
As an association of firms that currently operate manned aircraft for geospatial data acquisition and are entering the UAV arena, we are keenly interested in the safety of both manned and unmanned aircraft.
BVLOS becomes an issue, not solely due to the distance of the UAS from the operator, but terrain is also a factor. For example, when conducting a survey of an open pit mine, the operator loses LOS when the UAS flies down into the pit. The operator regains contact when the UAS emerges. Actually, the UAS is technically at a negative Above Ground Level (-AGL) elevation. The second and bigger issue is quarries and stockpiles. This occurs when the UAS cannot be seen for some periods of time due to a stockpile blocking the line of sight.
It is suggested that an "autonomous agent" system be incorporated into the flight management firmware. When activated, the UAS uploads (via cellular technology) its flight plan and tail number to a central database. It also downloads the flight plans of any other vehicle which will be in the vicinity of another. This central database could be run at a private firm and needs not be a government system. Such a system exists today for satellites and could be easily adopted for UAS.
Coupled with the above, the "national database" can also contain "no fly zones". The firmware can have a complete list of permanent, published zones, but when activated, include all new, short-term, and temporary restricted areas. The firmware could be hard coded to PREVENT flight into these areas, regardless of the operator’s flight instructions, or some zones can be restricted only by altitude or time of day. In these cases, the flight plan may enable the aircraft to penetrate these areas only at those unrestricted altitudes or times, such as sports stadiums during an event.
UAS for aerial surveying and mapping will need to fly BVLOS for days on end. They will need to be able to refuel/recharge in unattended mode. Our pilots will need to be able to fly these "across Texas" from a base of operations office in Iowa, for example. We will need to fly across populated and unpopulated areas.
Until operational, affordable “sense and avoid” technology is available, the aforementioned technology and process can be operational.
The BVLOS ideal system will fly at low altitude; carry multiple sensors; and fly autonomously for long distances. Today, this type of work is generally being flown using helicopters, while higher altitude collection occurs via manned, fixed-wing aircraft.
Many new technologies are being developed and tested which should, over the next several years, prove to be capable of meeting the needs for safe BVLOS operations. These new technologies will need to have increasing levels of proficiency as the systems are flown at higher altitude and are flown in more complex airspaces.
The establishment of a graduated set of requirements for BVLOS technologies based on types of airspace, altitudes, proximity to people, etc. may be desirable. The easy approach would be to require all BVLOS operations to have the most sophisticated possible systems available. This would immediately create just two classes of UAS, the very small systems for LOS operations and the large sophisticated systems for all BVLOS operations. However, the technology and applications will become much more sophisticated than that. A “one size fits all” approach is not recommended.
(2) perceived barriers to conducting those operations; and
MAPPS is concerned that technology development will outpace FAA rulemaking. While assuring the safety of the national airspace with the integration of commercial, operational UAS, such rules must be dynamic enough to respond to changing and improving technology.
(3) recommendations for the FAA to consider on how to remove those barriers.
It is important that FAA accept, and educate Congress, state legislatures, other target audiences, and the general public about the expectation of safety. Every day Americans accept a certain risk when the ride in an automobile or board a commercial airliner. While there are safety rules and systems in place, there are still accidents, failures and injuries. The same must be recognized and accepted with UAS. Understanding how to minimize and manage these events will be necessary. Technology and regulations as above will help to greatly minimize and mitigate, but never completely eliminate, such errors, failures, and irresponsible actions.
The focus of regulations should be on outcomes, not the means to outcomes. Technology and innovation will create the means to achieve desired FAA outcomes.