FAA Poison Pill for First Responders UAVs

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FAA Poison Pill for First Responders UAVs

The US Federal Aviation Administration (FAA) recently released its “UAS Roadmap”.  The small Unmanned Aircraft System (sUAS) community is rapidly noticing what appears to be a poison pill that will essentially destroy their industry.

What poison?

That roadmap, and an accompanying comprehensive plan, both state that all unmanned aircraft must have pilots (obviously controlling from the ground).

That may sound like a good and normal idea until you think of the differences between sUAS and the other unmanned aircraft.  The smallest sUASs are functionally identical to today’s radio controlled model aircraft.  In the US, anyone can buy a radio controlled model helicopter or airplane for less than $100, step outside and fly it.  That’s it.  No pilot’s license, no permissions, no flying with the big boys (higher than 400’ above the ground).

According to the FAA’s documents, flying that same model helicopter for a first responder like firefighters will require pilot training, licensing, perhaps even a pilot’s medical clearance.  The UAS Roadmap states:  “1.4.1 FAA UAS Policy Basis:  Established FAA aviation policies support an acceptable level of safety for the NAS.  At the core of these policies is the concept that each aircraft is flown by a pilot in accordance with required procedures and practices.  This same policy applies to UAS.”

The FAA’s UAS Comprehensive Plan states:

UAS NATIONAL OBJECTIVES

  • Establish Applicable Certification and Training Requirements for Pilots/Crew Members, Other UAS Operational Personnel, and Appropriate Air Navigation Service Provider (ANSP) Personnel
  • Determine the roles and responsibilities of applicable pilots/crew members, other UAS operational personnel, and appropriate ANSP personnel for safe UAS integration.
  • Develop and propose regulatory changes, as required, to define licensing (certification) and training requirements for pilots/crew members, other UAS operational personnel, and appropriate ANSP personnel (address in 14 CFR Part 61, 63, 65, and 141-147).
  • Publish, if required, final rule requirements for applicable pilots/crew members, other UAS operational personnel, and appropriate ANSP personnel.
  • Begin training and certification initiatives for pilots/crew members, other UAS operational personnel, and appropriate ANSP personnel.

Both plans consistently require “pilots” for all UAS.  That’s the poison pill for unmanned aircraft that are really just upgraded model airplanes.  Their operators simply can’t afford to become pilots, don’t want to and shouldn’t have to.  That’s the whole point to small unmanned aircraft: getting limited airplane-like capabilities without having to get the manned airplane (and all that goes with it).  Why, after all, should an sUAS operator be tested on FAA requirements for flight amongst the airliners above FL180, like UHF and VHF emergency frequencies with ATC, and lost communications procedures, and named intersections on jetways, and penetration approaches and much more, when they can’t fly higher than 400’ and don’t have radios?  Why should they even be required to learn that odd language?  They’ll never use it.

The sUAS industry simply won’t ‘get off the ground’ if operators must also be pilots.  First Responders will simply not be able to afford the sUAS that will save lives if they must add the expense and time of pilot training, annual medical exams and airspace testing, creating formal flight operations to track all of that, etc.  The same is true with realtors, farmers, videographers, surveyors, wedding planners, marine biologists, wildlife sanctuary managers, security companies, homeowner’s associations, race organizers, high schools, etc. etc. etc.  There will be so little benefit to sUAS that commercial operators will favor manned aircraft.  They are, after all, much easier to operate in FAA airspace.  More likely, we’ll just do without the new capabilities.

The simple sounding rule of treating all UAS the same will kill the small ones in the US.  That’s really too bad.  Besides being the obvious starting point for the American UAS industry, they would have saved lives, maybe even yours and ours.

Attached Materials: Unmanned Systems Integrated Roadmap FY2013-2038

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