• No “data” or safety risk analysis going in
• Bins and boxes are a rehash of unacceptable RTCA
• Those with operational experience are woefully
• Overall document lacks comprehensive tone
• International Harmonization = Weights in kilo’s???
• Economic impact of recommendations are
• Unwarranted and heavy-handed regulation of
• Type I operations leave little in the way of
• Operating greater than 3 NM of an airport
• System certification (what does it look like???)
• Manual flight control
• Type II operations put small operators in direct
competition with vendors (major enterprises for
sUAS ARC Observations
• Type III operations shut out small operators
• Operating greater than 10 NM sometimes 30NM from an
• System certification
• Required equipment takes most of payload
• Type IIII way beyond the reach of many.
• Type V LTA Lighter Than Air left out of
sUAS ARC impressions
Unanswered ARC Questions
• Confines of what is safe is yet to be scientifically defined?
• Were is the empirical data that proves AC 91-57 type sUAS OPS are
• If we are to be held to the same level of safety as manned
aviation, what is the relative differential? (size/weight/speed how does
10-6 apply, if at all?)
• Required “data” yet to be identified/quantified?
• Are these arbitrary operating envelopes viable ( e.g. 400’ AGL) for
empirical data gathering and business?
• Can a Data-set be captured in this small of an operating envelope?
• Do we fit the definition of comp and hire? 14 CFR FAR Part 1.1 and 119?
• Lack of empirical data gathering.
• Too onerous = Lack of compliance
• Regulatory apathy/denial
• Law abiding operators locked out
• Airspace safety suffers
• No closer to a workable solution
• Operators not purchasing
• Investment in technology will
Post sUAS ARC and the Road Ahead
• Testimony by RTCA President Margaret Jenny
to the House Aviation Subcommittee
- No reference to UAS. RTCA timeline for commercial UAS in
the NAS is out to 2018.
• “Not in my Airspace!” J. Randolph Babbitt
• F-38 participation has an overall lack of
objectivity and a feigned sense of regulator