Sg4arc

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Sub Group 4 sUAS ARC Debrief

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Sg4arc

  1. 1. sUAS ARC Participants Perspective Prepared by Patrick Egan for the membership of WG-73, Sub-group 4.
  2. 2. Proposed sUAS NAS Integration Guidelines
  3. 3. • No “data” or safety risk analysis going in • Bins and boxes are a rehash of unacceptable RTCA work • Those with operational experience are woefully underrepresented • Overall document lacks comprehensive tone • International Harmonization = Weights in kilo’s??? • Economic impact of recommendations are devastating sUAS ARCObservations
  4. 4. • Unwarranted and heavy-handed regulation of model aviation • Type I operations leave little in the way of viability • 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 profit) sUAS ARC Observations continued...
  5. 5. • Type III operations shut out small operators • Operating greater than 10 NM sometimes 30NM from an airport • 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 recommendation. sUAS ARC impressions continued...
  6. 6. Unanswered ARC Questions Impeding Integration • 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 unsafe? • 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?
  7. 7. Consequences • 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 insurance • Investment in technology will suffer
  8. 8. 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 involvement.

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