Transportation Systems Casebook/Integrating drones into civil aviation

Summary

The first recorded use of an unmanned aerial system occurred in 1849 when the Austrian Empire utilized explosive laden balloons to terrorize revolutionaries in besieged Venice. However, it wasn’t until World War II that unmanned aerial systems saw routine use as remotely operated target drones. Technological developments created a new generation of unmanned airborne systems operating as armed and/or surveillance platforms during recent wars in Iraq and Afghanistan. Improvements in electronics, miniaturization and composite materials enabled smaller, lighter and inexpensive unmanned aerial systems available to the public. Although the Federal Aviation Administration (FAA) utilizes the taxonomy unmanned aircraft system (UAS), the public and press prefer the older, simpler nomenclature, drone.

Recent industry and FAA estimates indicate that sales of small UASs will exceed one million units during the 2015 holiday season. As a result of UAS’s explosive popularity, policy leaders face difficult challenges and questions regarding UAS use and safety. For practical and policy considerations, UAS are classified as small, less than 55 pounds, and large, 55 pounds or more. (A third classification, micro, is proposed and the weight criteria is under development.) Large UAS, popularized during recent wars, carry sophisticated electronic navigation and detection capability to meet mission requirements and ensure safety. Generally, large UAS operate at high altitudes and beyond the operator’s line-of-sight. Due to operating limitations, small UAS do not have the same capabilities. Yet, small UAS have potential viable use for various commercial purposes such as photography, filming, traffic reports, fish spotting, agriculture, pipeline/rail inspection and package delivery.

A basic safety tenant of the civil airspace system requires that all aircraft ‘can see and be seen.’ Therefore, FAA’s proposed rules for small UAS mandate operation within line-of-sight of the operator. Although useful to the recreational operator, this limitation does not efficiently allow for most extended commercial use. Consequently, various UAS stakeholders actively research advance capability known as ‘sense and avoid.’ In this paradigm, technology onboard the aircraft ‘looks’ for other aircraft (including other UAS) and takes autonomous action to avoid risk of collision. Until that technology is developed, tested and deployed, large UAS operate in segregated blocks of airspace to mitigate the risk of collision.

Since ‘sense and avoid’ capability is in early development, full integration of large UAS in the National Airspace System (NAS) remains several years into the future. However, the million-drone Christmas is here today. The affordability, popularity, reliability and fly ability of small UAS presents significant challenges for today’s policy makers. Therefore, this case study examines the public policy implications and develops recommendations for integration of small UAS into the NAS.

Actors

US Senate Transportation, Housing, and Urban Development Subcommittee

The subcommittee is comprised of 17 Senators and has jurisdiction over 31 transportation, housing, and urban development agencies. Some of the transportation related agencies that the subcommittee has jurisdiction over include:the Federal Aviation Administration (FAA), the Department of Transportation (DOT),and the National Transportation Safety Board (NTSB). Since the subcommittee has jurisdiction over the FAA, the issue of integrating small Unmanned Aerial Systems (UAS) into the national airspace has recently been deliberated. On October 28, 2015, the subcommittee held a hearing about integrating UAS into the national airspace in which multiple near collisions between drones and aircraft were discussed.

US House Aviation Subcommittee

The subcommittee is comprised of 35 representatives and "has jurisdiction over all aspects of civil aviation, including safety, infrastructure, labor, commerce, and international issues." The subcommittee has jurisdiction over all FAA programs, except research, and also the NTSB. On October 2nd and 7th of 2015, the subcommittee held hearings on aviation safety concerning UAS.

US Government Accountability Office (GAO)

The mission of the GAO "is to support the Congress in meeting its constitutional responsibilities and to help improve the performance and ensure the accountability of the Federal Government for the benefit of the American people." The GAO performs studies at the request of Congress or as required by "public laws or committee reports." Following the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012, the GAO was directed to oversee the FAA's progress in integrating UAS into US civil aviation.

Congressional Research Service (CRS)

The Congressional Research Service (CRS) functions as a staff to members of Congress and congressional committees. CRS staff members provide services including: reports on policy issues, responses to inquiries, and seminars in addition to analyzing current and proposed policies. On September 9, 2015, the CRS published a report entitled "Unmanned Aircraft Systems (UAS): Commercial Outlook for a New Industry" which highlighted the commercial domestic UAS industry.

US Department of Transportation (DOT) Office of Inspector General (OIG)

The mission of the US Department of Transportation (DOT) Office of the Inspector General (OIG) is to fulfill "its statutory responsibilities and support members of Congress, the Secretary, senior Department officials, and the public in achieving a safe, efficient, and effective transportation system." The OIG works to prevent or cease "fraud, waste, and abuse" through audits in addition to consulting with Congress about newly proposed laws/regulations. On June 26, 2015, the OIG published "FAA Faces Significant Barriers To Safely Integrate Unmanned Aircraft Systems Into the National Airspace System" which spurred the initiation of an audit on the FAA's "approval and oversight processes" for UAS.

US Federal Aviation Administration (FAA)

The mission of the US Federal Aviation Administration (FAA) "is to provide the safest, most efficient aerospace system in the world." The FAA is a subordinate agency of the Department of Transportation which regulates and certifies all US aircraft, airports, and air traffic within the national airspace to ensure that established safety standards are upheld. The FAA is the main Federal agency responsible for ensuring the safe and seamless integration of UAS into the national airspace. As required by Section 332(a)of the FAA Modernization and reform Act of 2012, the FAA published "Unmanned Aircraft Systems (UAS) Comprehensive Plan: A Report on the Nation’s UAS Path Forward" in September of 2013.

US Department of Defense (DOD)

"The mission of the Department of Defense (DOD) is to provide the military forces needed to deter war and to protect the security of our country." The DOD has successfully developed and fielded UAS for use in global combat operations for many years. In 2013, the DOD published “Unmanned Systems Integrated Roadmap FY2011-2036” which highlighted the issue that military UAS operations within the national airspace are limited due to current FAA regulatory issues.

US Department of Homeland Security (DHS)

The overall mission of the US Department of Homeland Security (DHS) "is to ensure a homeland that is safe, secure, and resilient against terrorism and other hazards." The five DHS national security missions include: to prevent terrorism and enhance security, to secure the nation's borders,to enforce immigration laws, to safeguard cyberspace, and to ensure resilience following national disasters. Subordinate DHS agencies such as the US Coast Guard and US Customs and Border Protection have successfully utilized UAS within the national airspace to enhance operations.

US Federal Bureau of Prisons (FBP)

The mission of the US Federal Bureau of Prisons (BOP) is "to protect society by confining offenders in the controlled environments of prisons and community-based facilities that are safe, humane, cost-efficient, and appropriately secure, and that provide work and other self-improvement opportunities to assist offenders in becoming law-abiding citizens." On November 4, 2015, the FBP issued a request for information with the goal of discovering technology "that will allow for detection, tracking, interdiction, engagement and neutralization of small drones."

US Forest Service (USFS)

The mission of the US Forest Service (USFS) "is to sustain the health, diversity, and productivity of the Nation’s forests and grasslands to meet the needs of present and future generations." On June 19, 2014, the director of the USFS signed a policy memorandum entitled "Memorandum 14–05, Unmanned Aircraft – Interim Policy" which prohibits members of the public from operating UAS within the national parks. The USFS currently utilizes UAS for forest fire detection and management.

US Park Police

The mission of the US Park Police (USPP) is to "support and further the mission and goals of the Department of the Interior and the National Park Service by providing quality law enforcement to safeguard lives, protect our national treasures and symbols of democracy, and preserve the natural and cultural resources entrusted to us." On October 9, 2015, the USPP cited a man for flying a small drone in the vicinity of the Washington Monument which was the ninth similar occurrence in 2015 this year in a Washington area park.

US National Aeronautics and Space Administration (NASA)

The mission of the US National Aeronautics and Space Administration is to "drive advances in science, technology, aeronautics, and space exploration to enhance knowledge, education, innovation, economic vitality, and stewardship of Earth." From July 28-30, 2015, NASA held an UAS traffic management convention in which "policy issues including safety and security, emerging markets, strategies for low-altitude traffic management, and international perspectives" were discussed.

NAV Canada

The mission of NAV Canada is to "facilitate the safe movement of aircraft efficiently and cost-effectively through the provision of air navigation services on a long-term sustainable basis." NAV Canada is the entity responsible for controlling Canada's national airspace and approved UAS operators must contact them in order to coordinate airspace use.

US Transportation Research Board (TRB) Airport Cooperative Research Program (ACRP)

The US Transportation research Board (TRB) Airport Cooperative Research Program (ACRP) conducts research on issues facing "airport operating agencies" that have not been addressed by existing Federal research programs. "The ACRP undertakes research and other technical activities in a variety of airport subject areas including design, construction, maintenance, operations, safety, security, policy, planning, human resources, and administration." In 2015, the ACRP published a report entitled "ACRP Report 144: Unmanned Aircraft Systems (UAS) at Airports: A Primer" to help US airports with UAS understanding and integration.

The MITRE Corporation

The mission of the MITRE Corporation is to "work with industry and academia to advance and apply science, technology, systems engineering, and strategy, enabling government and the private sector to make better decisions and implement solutions to complex challenges of national and global significance." In September of 2012, the MITRE Corporation published "Integrating Unmanned Aircraft into Nextgen Automation Systems" which addressed possible solutions to the challenges posed by UAS integration into the "National Airspace System (NAS), known as Next Generation Air Transportation System(NextGen)."

Governor of the Commonwealth of Virginia

Governor Terry McAuliffe is the 72nd Governor of Virginia and his top priority is to ensure economic prosperity for the state through jobs creation and maintenance. On June 12, 2015, Governor McAuliffe signed Executive Order 43 which established the Virginia Unmanned Systems Commission with the goal of making the state a national leader in UAS. Under the Governor's leadership, the state was selected by the FAA as a UAS test site "to develop unmanned aerial technologies through the Mid-Atlantic Aviation Partnership."

Mid-Atlantic Aviation Partnership (MAAP)

The Mid-Atlantic Aviation Partnership (MAAP) is a collaboration effort between academic institutions from Virginia, Maryland, and New Jersey with the goal of executing a successful UAS "test capability for the nation." In December of 2013, the FAA selected the MAAP as one of its six designated UAS test sites which is located at Virginia Tech University.

Virginia UAS Commission

The 19 member Virginia UAS Commission was established by Governor McAuliff's Executive Order 43 to "be a key asset in charting the way forward to grow (the UAS) industry and create new, good jobs and economic opportunities across the Commonwealth." The established goals of the Virginia UAS Commission include: "identify the state of all unmanned systems industries in Virginia, identify challenges and needs of the unmanned system industry that may be met with Virginia assets for each domain of unmanned systems, provide recommendations that will encourage the development of the unmanned systems industry, and develop the value proposition for Virginia that will provide a basis for marketing Virginia to the current unmanned systems industry."

Google Incorporated

"Google’s mission is to organize the world’s information and make it universally accessible and useful." Google in conjunction with other major corporations, signed an agreement with NASA "to help devise the first air-traffic system to coordinate small, low-altitude drones, which the agency calls the Unmanned Aerial System Traffic Management" The company is also researching novel UAS applications such as internet provision and parcel delivery.

Amazon Incorporated

The mission of Amazon is "to be Earth's most customer centric company; to build a place where people can come to find and discover anything they might want to buy online." Amazon has been testing its parcel delivery UAS in a secret location in Canada, due to FAA regulations. Amazon's small parcel UAS are being developed to operate at an altitude of 200ft-500ft with a range of about 10 miles, "carrying payloads of up to 5lbs which accounts for 86% of all the company’s packages." Amazon has termed its vision for parcel delivery via UAS as "Amazon Prime Air."

Academy of Model Aeronautics (AMA)

The mission of the Academy of Model Aeronautics is to provide "leadership, organization, competition, communication, protection, representation, recognition, education, and scientific/technical development to modelers." The AMA is the world's largest "model aviation association" with over 175,000 members,"organized for the purpose of promotion, development, education, advancement, and safeguarding of modeling activities."

International Drone Racing Association (IDRA)

The mission of the International Drone Racing Association (IDRA) is to provide a world class racing experience, promote innovation, and foster education on UAS. The IDRA enables the global "First Person View (FPV) racing community exciting, professionally organized, highly competitive racing competitions."

Association for Unmanned Vehicles Systems International (AUVSI)

The Association for Unmanned Vehicle Systems International (AUVSI) "is the world's largest nonprofit organization devoted exclusively to advancing the unmanned systems and robotics community." The organization serves over 7,500 members from government, academia, and industry; "AUVSI members support defense, civil and commercial sectors."

Air Line Pilot Association (ALPA)

"The mission of the Air Line Pilots Association (ALPA) is to promote and champion all aspects of aviation safety throughout all segments of the aviation community; to represent, in both specific and general respects, the collective interests of all pilots in commercial aviation; to assist in collective bargaining activities on behalf of all pilots represented by the Association; to promote the health and welfare of the members of the Association before all governmental agencies; to be a strong, forceful advocate of the airline piloting profession, through all forms of media, and with the public at large; and to be the ultimate guardian and defender of the rights and privileges of the professional pilots who are members of the Association." As of October 1, 2015, the ALPA became the most recent supporter of the "Know Before You Fly" campaign. The campaign was implemented in December of 2014 by the AUVSI and the AMA, in partnership with the FAA,"to provide UAS users with the information and guidance they need to fly safely and responsibly."

Competitive Enterprise Institute (CEI)

The mission of the Competitive Enterprise Institute (CEI)"is to promote both freedom and fairness by making good policy good politics." CEI is a non-profit organization "dedicated to advancing the principles of limited government, free enterprise, and individual liberty." On November 6,2015, the CEI submitted a formal response to the FAA's request for information, in reference to UAS registration.

National Corn Grower's Association (NCGA)

The mission of the National Corn Grower's Association (NCGA) is to "create and increase opportunities for corn growers." On April 20, 2015, the NCGA submitted a formal letter to the US DOT and US Department of Commerce’s National Telecommunications and Information Administration which highlighted the fact that "unmanned aerial systems have widespread potential applications for farmers."

Electronic Frontier Foundation (EFF)

The Electronic Frontier Foundation is the leading nonprofit organization defending civil liberties in the digital world. Founded in 1990, EFF champions user privacy, free expression, and innovation through impact litigation, policy analysis, grassroots activism, and technology development.

Electronic Privacy Information Center (EPIC)

EPIC is a non-profit research and educational organization established in 1994 to focus public attention on emerging human rights issues, and to defend privacy, freedom of expression, and democratic values.

SkyPan International Incorporated

A Chicago based aerial photography company that utilizes proprietary Remote Piloted Vehicles (RPV) that usher in a whole new world of aerial and panoramic photography. SkyPan spent many years researching, developing and advancing these technologies that allow us to shoot unique, 360-degree, "bird's-eye views" from a full range of platforms. On October 6, 2015, the Federal Aviation Administration proposed a record $1.9 million fine against SkyPan for flying small UASs in crowded New York and Chicago airspace without permission.

DJI

DJI Innovations is a privately owned and operated company based in Shenzhen, China. DJI is the world's largest manufacturer of small UAS platforms with many equipped for high-definition video and still photography. DJI platforms are used in filmmaking, agriculture, conservation, search and rescue, and energy infrastructure with flying and camera stabilization systems that redefine camera placement and motion. On November 18, 2015, DJI announced development of new operating software that prevents UAS flights over sensitive areas. DJI recently launched an UAV specifically designed for spraying crops.

Timeline of Events

June 9, 1981 – The United States (US) Federal Aviation Administration (FAA) issues Advisory Circular 91-57 "Model Aircraft Operating Standards" that outlines and encourages voluntary compliance with safety standards for operating model aircraft.

February 1, 2010 – MITRE Corporation publishes "Airspace Integration Alternatives for Unmanned Aircraft (UAS)".

2012 – MITRE Corporation publishes "A New Paradigm for Small UAS".

February 14, 2012 – The US Congress passes FAA Modernization and Reform Act of 2012 that includes requirements and timelines for integration of civil Unmanned Aircraft Systems (UAS) into the National Airspace System (NAS). Public Law 112-95 Subtitle III, Subtitle B.

September 18, 2012 – US Government Accountability Office (GAO) publishes "Unmanned Aircraft Systems: Measuring Progress and Addressing Potential Privacy Concerns Would Facilitate Integration into the National Airspace System".

October 16, 2012 – MITRE Corporation publishes "Integrating Unmanned Aircraft into NEXTGEN Automation Systems".

2013 – US Department of Defense (DOD) publishes Unmanned Systems Integrated Roadmap: FY2013 - 2038.

September 2013 – FAA publishes "Unmanned Aircraft Systems (UAS) Comprehensive Plan".

November 7, 2013 – FAA publishes "Roadmap for Integration of Civil Unmanned Aircraft Systems (UAS) in the National Airspace System".

December 30, 2013 – FAA selects six UAS research and test site operators across the country.

January 6, 2014 – FAA publishes "Fact Sheet – Unmanned Aircraft Systems (UAS)".

February 15, 2014 – GAO publishes "Unmanned Aircraft Systems: Continued Coordination, Operational Data, and Performance Standards Needed to Guide Research and Development".

June 26, 2014 – US Department of Transportation (DOT) Office of Inspector General (OIG) publishes "FAA Faces Significant Barriers to Safely Integrate Unmanned Aircraft Systems into the National Airspace System".

December 10, 2014 – GAO publishes "Unmanned Aerial System: Efforts Made Toward Integration into the National Airspace Continue, but Many Actions Still Required".

2015 – Under the FAA sponsored Airport Cooperative Research Program (ACRP), the Transportation Research Board (TRB) publishes "Unmanned Aircraft Systems (UAS) at Airports: A Primer".

February 23, 2015 – FAA publishes proposed rules for the operation and certification of small UAS.

March 31, 2015 - Electronic Privacy Information Center (EPIC) initiates legal action against the FAA for failing to address privacy in small UAS proposed rules.

June 12, 2015 – Governor Terry McAuliffe of the Commonwealth of Virginia announces the formation of the Virginia Unmanned Systems Commission.

July 2015 – GAO publishes "Unmanned Aerial Systems: FAA Continues Progress toward Integration into National Airspace".

July 28, 2015 – US National Aeronautics and Space Administration (NASA) conducts a three-day conference regarding air traffic management of UAS attended by Google and Amazon.

August 13, 2015 – FAA releases database of pilot reports concerning UAS sightings highlighting 500% increase in 2015 over 2014.

August 30, 2015 – The Commonwealth of Virginia publishes "Virginia Unmanned Systems Business Plan".

September 2, 2015 – FAA issues Advisory Circular 91-57A that revises standards for model aircraft for hobby and recreational purposes.

September 14, 2015 – Academy of Model Aeronautics releases an analysis of FAA database of UAS pilot sightings finding dozens versus hundreds of “near misses.”

September 15, 2015 – FAA announces prohibition of UAS operations ahead of Papal visits to Washington, Philadelphia and New York.

September 18, 2015 – Virginia Governor McAuliffe opens the first meeting of the Virginia UAS Commission at George Mason University Arlington Campus.

October 2, 2015 – The Aviation Subcommittee of the US House of Representatives Transportation and Infrastructure Committee held a public hearing titled, “Ensuring Aviation Safety in the Era of Unmanned Aircraft Systems”

October 7, 2015 – FAA expands industry collaborative research and development initiatives to detect UAS in the vicinity of airports.

October 22, 2015 – FAA releases clarification of registration requirement for UAS and announces the formation of UAS registration task force.

October 28, 2015 – The Transportation, Housing, and Urban Development Subcommittee of the US Senate Appropriations Committee conducts a public hearing titled. “Integrating Unmanned Aircraft Systems Technology into the National Airspace System.”

November 3, 2015 - FAA Administrator Michael Huerta kicks-off 25-member UAS Regestration Task Force chartered to develop recommendations on requirements and procedures for registration of UASs.

November 4, 2015 – US Federal Bureau of Prisons (FBP) publishes a request for information procurement initiative for Protection from Unmanned Air Vehicles.

November 21, 2015 - The UAS Registration Task provides recommendations to the FAA for registration of UAS between .55 and 55 pounds.

Maps of Locations

FAA UAS Test Site Locations

After a rigorous 10-month selection process involving 25 proposals from 24 states, the Federal Aviation Administration chose six unmanned aircraft systems research and test site operators across the country. In selecting the six test site operators, the FAA considered geography, climate, location of ground infrastructure, research needs, airspace use, safety, aviation experience and risk. In totality, these six test applications achieve cross-country geographic and climatic diversity and help the FAA meet its UAS research needs.

Policy Issues

Privacy

While the integration of UAS in the commercial sector presents great opportunities, it also raises questions as to how to achieve UAS integration in a way that is consistent with privacy and civil liberties concerns. Though the FAA’s mission does not include creating or implementing policies related to privacy, experience with the UAS test sites give them the opportunity to learn more concerning the use of UAS technologies and the topic of privacy. The FAA plans to have each test site operator create a privacy policy that will affect operations at the test site. The privacy policy will be publicly accessible and informed by Fair Information Practice Principles. In addition, each test site will create a tool through which the operator can collect and consider comments on its privacy policy. The privacy requirements planned for the UAS test sites are specially designed for the test sites and are not meant to predetermine the long-term policy under which UAS would function. Still, the FAA expects that the privacy policies created by the test sites will help inform the discussion among policymakers and privacy advocates.

Safety

Established FAA policy supports the concept of aircraft over the United States are piloted in accordance with their mandatory procedures and practices, and that same policy extends to UAS. Additionally, all new civil aircraft require an airworthiness certificate, independent of the airspace class where it could be flown.

The application of these established policies to UAS is summarized in the following key points:

Regulatory standards need to be establish to enable current technology for UAS to comply with Title 14 Code of Federal Regulations which states that "in order to ensure safety, the operator is required to establish the UAS airworthiness either from FAA certification, a DoD airworthiness statement, or by other approved means."

Applicants also have to prove that a collision with another aircraft is extremely unlikely.

And the pilot-in-command concept is necessary for manned operations. The FAA’s UAS guidance applies this pilot-in-command concept to UAS and includes minimum qualification and currency requirements.

To gain full access to the national air space, UAS need to be able to improve from existing systems requiring accommodations to future systems that are able to obtain a standard airworthiness certificate. These UAS will also need to be used by a certified pilot in accordance with existing, revised, or new regulations and required standards, policies, and procedures.

Security

Integrating public and civil UAS into the national airspace carries specific national security repercussions. These include security screening for certifications and instructing of UAS-related personnel, focusing on cyber and communications weaknesses, and upholding and improving air defense and air domain awareness capabilities in an increasingly crowded airspace. In some cases, existing security structures used for manned aircraft may be valid. Other security concerns may require developing new security plans entirely. The FAA is working with applicable US departments and agencies, and with stakeholders to proactively address these areas of concern.

Case Narrative

Across the three policy areas, various actors introduced initiatives to determine or influence policy based upon their organizational mission and priorities. Although small UAS certification and operation regulations are not final, the Federal Aviation Administration utilizes current regulations to determine the requirements highlighted in Table 1. By limiting small UAS operations to line-of-sight, daylight, below 400 feet above ground level and outside controlled airspace, the FAA mitigates risk of collision. Additionally, Certificates of Waiver or Authorization contain specific operational requirements that further mitigates collision through isolated airspace, chase aircraft, position and altitude transponders, direct two-way communications, etc. The FAA defines Public Entities as law enforcement, firefighting, border patrol, disaster relief, search and rescue, military training and other governmental missions. This section provides further information on additional policy initiatives.

Table 1. Current FAA Requirements for Operation of Small UAS

Use of UAS	Line-of-Sight Operation	Beyond Line-of-Site Operation
Recreational	Below 400’, Daylight, Uncontrolled Airspace	Prohibited
Experimental	Below 400’, Daylight, Uncontrolled Airspace	Experimental Airworthiness Certificate
Commercial	Certificate of Waiver or Authorization	Certificate of Waiver or Authorization
Public Entities	Below 400’, Daylight, Uncontrolled Airspace	Certificate of Waiver or Authorization

Note: Information from FAA Fact Sheet - Unmanned Aircraft Systems

Criticisms of Current Policy

The current FAA UAS policy has been the subject of criticism from certain stakeholders. The major points of contention of the current UAS policy include: failure to address privacy issues, the proposal to mandate registration of all UAS, and the requirement for UAS to be flown via line-of-sight. On March 31, 2015, EPIC filed a suit against the FAA "for failing to establish privacy rules for commercial drones as mandated by Congress." The suit was filed in response to the FAA's notice of proposed rule-making (NPRM) and denial of EPIC's initial petition (filed in 2012), both occurred on February 23, 2015. The NPRM issued by the FAA states, " privacy issues are beyond the scope of this rulemaking." The case is currently awaiting deliberation in the US Court of Appeals for the District of Columbia.

On November 6, 2015, CEI submitted a formal response to the FAA's "Request for Information Regarding Electronic Registration for UAS". In the response, the CEI highlighted three main points including: "(1)the FAA lacks jurisdiction to mandate registration for all unmanned aircraft systems; (2) mere registration, whether point-of-sale or prior-to-operation, will do little to mitigate UAS safety risks; and (3) the FAA cannot dispense with required notice and comment rulemaking requirements by way of the good cause exception to the Administrative Procedure Act (APA)." CEI pointed out that the FAA lacks jurisdiction to mandate UAS registration because Section 336 of the FAA Modernization and Reform Act (FMRA) states that the "FAA is not permitted to promulgate rules targeting small UAS hobbyists." CEI further explained that methods such as geo-fencing would be more effective with countering unsafe UAS operation as opposed to compulsory registration. Finally, CEI asserted that Transportation Secretary Fox's goal to mandate UAS registration by "mid December" violates the APA which states that "substantive agency rulemakings are required to include a notice and comment period of at least 30 days", unless the agency can illustrate good cause. If enacted, the proposed requirement for all UAS to be registered will likely be met with a great deal of opposition from hobbyists and commercial entities alike.

The current FAA UAS policy requires that "UAS must be flown within the line of sight of the operator, less than 400 feet above the ground, during daylight conditions, inside Class G (uncontrolled) airspace, and more than five miles from any airport or other location with aviation activities." The requirement for line of sight UAS operations drastically limits the capabilities of hobbyist and commercial entities alike. For instance, the IDRA hobbyist organization promotes "First Person View (FPW)" UAS racing which is strictly prohibited by the current policy. Amazon wishes to use "highly automated aerial vehicles for Prime Air" with "sense and avoid sensors" to deliver payloads of up to five pounds (accounts for 85% of sold products) within a range of 10 miles. Under the current FAA UAS regulations, Amazon would have to submit a Certificate of Waiver or Authorization for the fleet of Global Positioning System (GPS) navigated and automated UAS.

Jurisdiction/Authority

The FAA Modernization and Reform Act (FMRA) of 2012 grants the Administrator of the Federal Aviation Administrator broad and exclusive authority for the safety of flight. The authority is codified in detailed Federal Aviation Regulations (FAR) that define standards and requirements for the safe operation of airborne systems, airports, airways, procedures and obstructions. Over time, case law recognized FAA authority extending into all airspace not otherwise exempted by law. Therefore, this national authority cannot be preempted by state law. However, other stakeholders offer differing opinions on the applicability of FAA authority to regulate small UAS. Through October 8, 2015, 45 states considered 166 bills in 2015 relating to UAS operations with 20 enacting legislation and 4 adopting resolutions. The role of the state legislation varies widely and face challenges as preempting FAA authority. Other actors, such as SkyPan International, state that the current FAA small UAS requirements lack legal substance because the FAA exceeded current legal authority. However, the Electronic Privacy Information Center (EPIC) opines that the FAA failed to exercise authority and requirement in FMRA by failing to define privacy protections in the proposed small UAS operation and certification requlations. These conflicts require adjudication in the appropriate court systems.

Registration

On November 3, 2015, FAA Administrator Michael Huerta chartered a 25 member task force to provide recommendations on requirements and procedures regarding small UAS. Citing too many close calls between piloted and unmanned aircraft, Administrator Huerta urged the task force to "think outside of the box" and leverage currently available technology to design and quickly implement a registration scheme. The task force members represent various industry and organizational stakeholders. The process could be in place by mid-December in anticipation of millions of new aircraft being given as holiday gifts. The FAA emphasizes the importance of protecting the national airspace and differentiates between remotely operated ground vehicles. Much like owning an automobile, not registering your UAS could provide a reason for law enforcement to focus on you. The main reason for having registration will be to locate the owner if there is an accident (or purposeful) encounter with another aircraft or object on the ground. Additionally, the FAA warned current small UAS owners not utilize advertised "Drone Registration" firms, as the registration process is still in development.

On November 21, 2015, the UAS Registration Task Force provided recommendations to the FAA for registration of small UAS between .55 and 55 pounds. If adopted, small UAS owners would register their name and physical home address to the FAA and receive a single registration number that must be affixed to every drone owned by that registrant. On November 23, 2015, Representative Peter DeFazio, ranking member of the House Transportation and Infrastructure Committee praised the FAA and the Task Force for their quick work and reasonable recommendations. However, the Competitive Enterprise Institute questions the legitimacy of including these regulations in emergency rule-making. Additionally, the Electronic Privacy Information Center stated that the Task Force did not go far enough and require contact information for small UAS operators and full disclosure of registered small UAS surveillance capabilities.

Standards/Regulations

The FAA proposes three categories of UAS. Micro UAS weighs less than 4.4 pounds and will have the most flexible standards and regulations. Small UAS weigh less than 55 pounds and large UAS weigh 55 pounds or more. Some industry and policy stakeholders believe these categories do not effectively describe all the different characteristics across the range of UAS available. In constrast, the DoD has 5 classes of UAS that are categorized by characteristics such as speed, weight, and altitude capabilities. Grouping UAS into specific classes are an essential step in achieving certification standards.

Although proposed and published in February 2015, the FAA has not finalized regulations for integrating small UAS into the airspace. Currently, the FAA allows the use of UAS on a case-by-case basis. To move past the time consuming process, the FAA seeks to establish standards in the following areas: performance standards, certification standards, and categorization. Without governing regulations, UAS will be unable to operate in the national airspace without substantial limitations. The FAA estimates that small UAS regulations and standards will be finalized by June 17, 2016. Some stakeholders do not recommend any regulations or standards for small UAS, as this will unneccesarily constrain the growth and development of a new industry.

Work remains between the FAA and other government agencies and industry participants on minimum performance standards for large UAS. In March 2013, a UAS executive committee was created to focus on “more detailed standards for detect and avoid capabilities and command and control links. In the near term, the focus will be on operations at higher altitudes.” Additionally, there are not yet established standards “necessary for designing, manufacturing, and certifying new UAS”. Because of this, the FAA is unable to certify any new large UAS or offer direction to manufacturers concerning the design specification that would be required for certification. However, a special committee developed and released interim standards for detect-and-avoid systems and command-and-control data links.

Enforcement

As with any standard or regulation, they must be buttressed with the necessary authority to ensure compliance and penalties for noncompliance. Unfortunately with the extraordinary and rapid growth of small UAS ownership and operations, there are numerous and increasing reports of small UAS operating too close to piloted aircraft, airports and restricted airspace. Aircraft pilot reported data maintained by the FAA indicates an increase from 16 incidents in June 2014 to 138 in June of 2015. These events include the need to shutdown aerial forest fire fighting in several Western wildfires due to unauthorized small UAS activity. Therefore, regulators initiated several recent enforcement actions for safety and security violations.

The most significant is a $1.9 million fine by the FAA against Chicago aerial photography company SkyPan International for 65 unauthorized commercial UAS flights including 43 in highly restricted New York airspace. However, other recent events continue to highlight enforcement of restrictions. After a small UAS crashed on the White House grounds in January 2015 and another small UAS flew adjacent to the White House in May 2015, the US Park Service and US Secret Service stepped up enforcement. The Park Service fined a District of Columbia resident after the Secret Service retrieved a small UAS from the White House Ellipse. The problem is not isolated to the United States. The United Kingdom's Civil Aviation Authority (CAA) fined a small UAS operator for filming a promotional video in London. Recognizing the growing problem and increased collision risk, the Chief Executive Officer of NAV Canada, Canada's air navigation service provider, recommends criminal penalties for unauthorized small UAS operations close to airports.

However, the FAA, UK CAA and Transport Canada prefer a multi-pronged approach that includes education and awareness coupled with stronger enforcement. Ahead of the September 2015, Papal visits to New York, Washington and Philadelphia, the FAA partnered with the small UAS and model aircraft industries to educate the public on restrictions to small UAS flights near Pope Francis. In addition, the FAA collaborated with the small UAS industry to create the website, "Know Before You Fly," to increase public awareness and educate the small UAS community.

Geo-Fencing

Geo-fencing is a software feature encoded into small UAS onboard systems and controller applications that prevent activation and flight of the small UAS over restricted or security sensitive areas. DJI, the world's largest small UAS manufacturer, announced on November 19, 2015 the installation and availability of a software update that includes Geo-Fencing around prisons, power plants, airports, restricted airspace, natural disasters and major sporting events. However, public safety organizations such as police and firefighting first responders will be able to deactivate geo-fencing to perform life safety and security functions. During US Congressional hearings in October 2015, many members called for mandatory geo-fencing as part of FAA proposed small UAS regulations.

sUAS Air Traffic Management

Small UAS are versatile and affordable platforms that provide utility beyond the recreational user or amateur photographer, in spite of the proliferation of videos on YouTube. In agriculture, small UAS provides early detection of pest infestations and crop disease, precise application of fertilizers and crop scouting. Small UAS aid in the restoration of power after damaging weather events. Additionally, the Association of Unmanned Vehicle Systems International (AUVSI) estimated that small UAS operations will contribute $80 billion in new business, if safely integrated. However, the most effective small UAS functionally requires the ability to safety navigate during beyond the line-of-sight operations. Two major initiatives are working toward this goal.

The FAA established the Pathfinder Program to leverage developing technology to extend small UAS operations beyond line-of-sight. Currently, CNN, PrecisionHawk, BNSF Railway and CACI participate in this collaborative research and development initiative. CNN is exploring small UAS use for news gathering in populated areas while PrecisionHawk is developing beyond line-of-sight in rural areas. BNSF Railways is researching command and control of small UAS to inspect rail infrastructure. CACI will access the safety and security capabilities to detect and track small UAS operations in the vicinity of airports. On November 13, 2015, PrecisionHawk announced live testing of small UAS capability to detect and self-navigate away from other airborne vehicles and obstacles.

NASA is partnering with 21st Century giants, Amazon and Google, to develop an integrated system that allows safe and widespread operation of small UAS in low-altitude airspace. NASA envisions autonomous operation of UAS air traffic management in portable and persistent systems. Google and Amazon propose the use of current cellular systems for command and control while Automatic Dependent Surveillance-Broadcast (ADS-B) provides detection capability. Additionally, Google and Amazon propose a low-altitude airspace design that segregates small UAS into different altitude strata depending upon the flight's purpose. This system's concept of operation prioritizes access through a paradigm where the best-equipped small UAS get the best service.

Defense

Similar to other emerging technology, the criminally minded develop nefarious uses for small UAS. However, due to their size, affordability, flyability and difficulty to detect, small UAS are especially appealing and create an emerging security threat. Current research is exploring several avenues to protect against this threat. First, small UAS have two inherent weaknesses, GPS navigation and data link control. This research explores ways to deactivate the UAS by breaking these links. Second, developers investigated new radar capability to detect the small slow moving UAS. Last, small UAS interdiction through accurate and fast laser platforms which destroy the UAS and eliminates the risk. These technologies remain in development and are not currently available for deployment.

However, the US Federal Bureau of Prisons (BOP) seeks a solution to the growing use of small UAS to smuggle weapons and prohibited items into Federal prisons. Additionally, small UAS are used for unauthorized imagery and surveillance. BOP requests information on an ingrated system with capability to detect, interdict and neutralize small UAS operations in the vicinity of BOP locations. Additionally, this system has potential to protect critical infrastructure and crowded events and mitigates the growing threat of terrorists utilizing small UASs.

Conclusions and Recommendations

The small UAS policy arena is dynamic and growing. As expected in a new transportation sector, many actors engage to advocate or protect their interests. There is no shortage of opinion or ideas across the three policy areas of privacy, safety and security. Therefore, policy makers face a significant challenge piecing together relevant information and developing effective policy without unintended negative consequences and without favoring a specific actor(s). As demonstrated by the 2015 “Million Drone Christmas”, policy makers do not have the luxury of unlimited time to act. This section provides three policy recommendations.

First, privacy policy is beyond the scope of the Federal Aviation Administration. Therefore, US Congress must determine if there is valid threat to individual privacy and develop policy to mitigate that threat. Although small UAS provide easy and inexpensive capability to ‘film’ from new vistas, airborne surveillance by law enforcement and other public agencies is not new. Therefore, the privacy threat may not be as significant as feared. However, the popularity of small UAS may make it more salient.

Second, the proliferation of small UAS creates a risk of collision. Although much easier to operate that previous vehicles, small UAS crash. Also, small UAS lack capability to ‘see and be seen’ in the current aviation environment. Therefore, the FAA must complete review of public comments on proposed small UAS regulations and publish final regulations as soon as possible.

Third, small UAS offer tremendous economic and efficiency benefits across a spectrum of sectors. However, less than a dozen companies participate in consortiums of research and development initiatives across the country. More actors with stake in the growing small UAS industry must contribute more research and development resources in a collaborative environment. Only through emerging technologies will small UAS safely and securely integrate in the National Airspace System.

Additional Readings

FAA Fact Sheet - Unmanned Aircraft Systems

GAO Unmanned Aerial Systems: FAA Continues Progress toward Integration in the National Airspace

CRS Domestic Drones and Privacy: A Primer

Discussion Questions

Are small UAS a threat to the privacy of the general public?

Does mandatory UAS registration create privacy risks for small UAS operators/owners?

Do regulation and standards create a chilling effect on the growing UAS industry?

Do the benefits of small UAS exceed the security and safety risks (perceived or real)?

Is the Federal government moving fast enough to keep up with the growth of small UAS?

What is the state and local role in the regulation of small UAS?

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