Droning Onward: Unmanned Aircraft Systems

Unmanned Aerial Vehicles (UAVs), Unmanned Aircraft (UA), Unmanned Aircraft Systems (UAS), or simply “drones,” as they are colloquially known, are now ordinary fixtures of society.  They’ve become so commonplace in fact that their range spans broadly from childhood playthings, such as remote controlled miniature quad-copters generally bought for less than $20 USD, to complex military reconnaissance systems, such as the Northrop Grumman MQ-4C Triton Unmanned Aircraft System (UAS) with costs reaching upwards of $187 million USD per production unit as of 2017.  The wide gamut of variety in use today is inclusive of more types than would be practicably listed.  Platform uses vary from recreational hobby and sport, to commercial and industrial utility, as well as civil and military missions.  Continued growth is expected with their current and potential use cases; yet, only the future will reveal how they might become fully integrated into the fabric of the current aviation system.

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Henceforth, for clarity’s sake, the term Unmanned Aircraft Systems (UAS) will be generally used in reference to UAVs, UA, UAS, and drones.  U.S. Congress, Public Law 112-95, otherwise known as the “FAA Modernization and Reform Act of 2012” defines:

 

Unmanned aircraft system. – The term “unmanned aircraft system” means an unmanned aircraft and associated elements (including communication links and the components that control the unmanned aircraft) that are required for the pilot in command to operate safely and efficiently in the national airspace system (FAA Modernization and Reform Act of 2012).

 

The Federal Aviation Administration (FAA) was tasked by the “FAA Modernization and Reform Act of 2012” for development of UAS regulations within the National Airspace System (NAS) of which oversight is their responsibility.  This was deemed necessary to maintain the integrity of NAS safety following an exponential growth of UAS manufacturing and availability and a resultant increase of civilian UAS operating within proximity of aircraft operations.  The FAA responded with creation of new Title 14 CFR Part 107, Small Unmanned Aircraft Systems (sUAS) regulations, with specific sUAS definitions, operational limitations, aircraft requirements, and remote pilot in command certification and responsibilities.

 

The FAA Unmanned Aircraft Systems webpage titled “Fly under the Small UAS Rule” explains in summary (2018):

 

To fly under the FAA's Small UAS Rule (14 CFR part 107), you must:

 

• Get a Remote Pilot Certificate from the FAA.
• Register your UAS as a "non-modeler."
• Follow all part 107 rules.

 

Remote Pilot Certification:

• Be at least 16 years old.
• Pass an aeronautical knowledge test at an FAA-approved knowledge testing center.*

(* A person who already holds a pilot certificate issued under 14 CFR part 61 and has successfully completed a flight review within the previous 24 months can complete a part 107 online training course at www.faasafety.gov to satisfy this requirement.)

• Undergo Transportation Safety Administration (TSA) security screening. 

Registration Requirements:

• Unmanned aircraft not flown under section 336 must be registered under part 107.

 

Part 107 Operating Rules:

• Unmanned aircraft must weigh less than 55 pounds, including payload, at takeoff.
• Fly in Class G airspace.*
• Keep the unmanned aircraft within visual line-of-sight.*
• Fly at or below 400 feet.*
• Fly during daylight or civil twilight.*
• Fly at or under 100 mph.*
• Yield right of way to manned aircraft.*
• Do not fly directly over people.*
• Do not fly from a moving vehicle, unless in a sparsely populated area.*

(*These rules are subject to waiver. (FAA, 2018.))

 

The FAA regulations however received considerable backlash from the well-established nationwide model aircraft community for overreaching and negative impact upon their hobby which previously operated safely and in harmony with the NAS.  The FAA responded with the “Special Rule for Model Aircraft” with provisions that exempted hobbyists from specifics within the sUAS Part 107 regulations.

 

The FAA Unmanned Aircraft Systems webpage titled "Fly under the Special Rule for Model Aircraft" explains in summary (2018):

To fly under the Special Rule for Model Aircraft you must:

• Fly for hobby or recreation ONLY.
• Register your model aircraft.
• Fly within visual line-of-sight.
• Follow community-based safety guidelines and fly within the programming of a nationwide community-based organization.
• Fly a drone under 55 lbs. unless certified by a community-based organization.
• Never fly near other aircraft.
• Notify the airport and air traffic control tower prior to flying within 5 miles of an airport.*

(*The person flying the model aircraft is responsible for contacting the airport directly.)

• Never fly near emergency response efforts.

 

For more information about what you can do with a model aircraft, please read FAA Advisory Circular 91-57A or read the Interpretation of the Special Rule for Model Aircraft.

If you do not meet these requirements, you must fly under the FAA's small UAS Rule (part 107).

 

Many airports have processes for people who fly near their airport, and the model aircraft operator can talk with them directly about how to meet this rule.

 

Registration Requirements:

 

The FAA requires you to register as a "modeler" and mark your model aircraft with your registration number in case it is lost or stolen.

 

Registration costs $5 and is valid for 3 years (FAA, 2018).

 

The special rule while less restrictive than sUAS regulations overall, still in the end was less well received by many of the affected community for restrictions that were previously unimposed upon their hitherto self-regulated hobby.

 

Aviation Acronym Segue:  Yes, apologies are in order for the streaming plethora of acronyms – admittedly these may have become quite confusing.

 

Aviation is one of those specialized industries, encamped with the sciences and medicines amongst others, which has developed a unique flavor of acronym soup.  Selected excerpts from the academic-comedic article "Acronymesis: The Exploding Misuse of Acronyms," written by authors Fred, H. L., & Cheng, T. O expand nicely upon the acronym phenomenon (2003):

 

In fact, improper use of acronyms has become a nemesis.  Hence, our term ‘acronymesis.’ … We are not saying that all acronyms are ‘evil.’  On the contrary.  Acronyms can simplify and facilitate communication, enhance recall, and save time, space, and effort for everyone involved. … Failure to define acronyms is all too frequent and reflects inconsiderate writing, careless editing, and irresponsible publishing. ... In conclusion, acronymesis has become a Macho-driven Major Malady of Modern Medical Miscommunication (MMMMMM).  Meaningful Management of this MMMMMM Mandates Maximum effort to Minimize acronymic Misuse (MMMMMM).  Oops!  We just used the same ‘acronym’ for 2 different messages.  Does that ring a bell? (Fred, H. L., & Cheng, T. O. 2003.)

 

However, the use of acronyms is practically required for efficient communications between air traffic control (ATC) and pilots operating within the NAS.  Nonetheless, aviation and acronyms are more than likely forever and symbiotically intertwined with one another.  For this reason, handbooks will continue to exist with sole dedication to aviation acronym definition.  Sincerest apologies for so many three letter descriptors laid down in quick succession.

 

Now, we shall return to regularly scheduled UAS programming.

 

Following the FAA sUAS regulations, commercial UAS business ventures were required to comply with Part 107 in order to continue operating legally.  Market areas impacted greatest by the regulations were the aerial photography and videography media, and aerial real estate property surveyor, segments.  Of which had previously experienced a surge in growth with the access to more affordable and technologically capable mass produced UAS; such as UAS market leader “DJI Innovations” Phantom series of quad-copters and other competitor like kinds.  The UAS media capture market had become a wild west of sorts and businesses were popping up, a dime-a-dozen, across the country, across the globe.  The FAA sUAS regulations were in all probability expedited by the flush of UAS that were suddenly buzzing around the NAS.

 

Commercial UAS market utilization has been projected with an outlook of considerable fiscal growth.  Business Insider, an online business news website, published the July 13^th, 2017 article “Drone Technology and Usage: Current Usage and Future Drone Technology” supporting the promising UAS outlook (Business Insider, 2017):

 

From technically manning sensitive military areas to luring hobbyists throughout the world, drone technology has developed and prospered in the last few years. Individuals, commercial entities, and governments have come to realize that drones have multiple uses, which include:

 

• Aerial photography for journalism and film.
• Express shipping and delivery.
• Gathering information or supplying essentials for disaster management.
• Thermal sensor drones for search and rescue operations.
• Geographic mapping of inaccessible terrain and locations.
• Building safety inspections.
• Precision crop monitoring.
• Unmanned cargo transport.
• Law enforcement and border control surveillance.
• Storm tracking and forecasting hurricanes and tornadoes.

 

The commercial drone industry is still young, but it has begun to see some consolidation and major investments from industrial conglomerates, chip companies, IT consulting firms, and major defense contractors.  For now, the industry leaders are still a handful of early-stage manufacturers in Europe, Asia, and North America.

 

As it becomes cheaper to customize commercial drones, the door will be opened to allow new functionality in a wide array of niche spaces.  Sophisticated drones could soon be doing everyday tasks like fertilizing crop fields on an automated basis, monitoring traffic incidents, surveying hard-to-reach places, or even delivering pizzas.

 

At the end of the day, the impact of commercial drones could be $82 billion and a 100,000 job boost to the U.S. economy by 2025, according to AUVSI “The Association for Unmanned Vehicle Systems International” (Business Insider, 2017).

 

The most innovative contemporary UAS application that I've discovered to date and possibly the most directly positive, in terms of direct humanitarian impact is that of Zipline International, Inc.

 

The U.S. based company and Government of Rwanda partnership UAS system is especially unique and best described from the Zipline webpage (2018):

 

Lifesaving Deliveries by Drone:

Zipline operates the world’s only drone delivery system at national scale to send urgent medicines, such as blood and animal vaccines, to those in need – no matter where they live.

 

How Zipline Works:

Zipline provides a seamless delivery service, rain or shine.  We manage all aspects of the service, obsessing over every detail, so you can focus on patient health.

 

1. Order by Text Message:

Health workers at remote clinics and hospitals text orders to Zipline for the medical products they need, on demand.

 

2. Packed in Minutes:

Zipline safely stores medical products at its Distribution Center, enabling immediate access to even the most sensitive or scarce items. These items are packaged here and prepare for flight, maintaining cold-chain and product integrity.

 

3. Takeoff:

Within minutes, health workers receive confirmation that their order has launched. Racing along at 110 km/h, products arrive faster than any other mode of transport, no pilot required.

 

4. Direct Delivery:

Fifteen minutes later, the medical products are delivered gently by parachute, landing in a designated area the size of a few parking spaces. Hospital staff are notified via text message.

 

5. Recovery:

Zipline's drones return home, only landing at Zipline's distribution center for a a quick pit stop before taking off again.

About Zipline:

 

Zipline is an automated logistics company based in California.  The company—which includes seasoned aerospace veterans from teams like SpaceX, Google, Boeing, and NASA—designs and operates an autonomous system for delivering lifesaving medicine to the world’s most difficult to reach places.

 

Zipline’s long-term mission is to build instant delivery for the planet, allowing medicines and other products to be delivered on-demand and at low cost without using a drop of gasoline.

 

Zipline is supported by some of the smartest investors in the world, including Sequoia Capital, Google Ventures, SV Angel, Subtraction Capital, Yahoo founder Jerry Yang, Microsoft cofounder Paul Allen, and Stanford University (Zipline, 2018).

 

This is by far my personal favorite contemporary application of commercial UAS technology.  It is in my opinion the best current use case example of how UAS should be used toward positive impact upon humanity.  This seminal UAS development will likely serve as the framework for other such similar developments to be considered for integration within the NAS.  The challenging aspect of course would be the shared use of airspace with traditionally human piloted aircraft.

 

With advancement of technology, the aviation industry will likely one day see a future where UAS and manned aircraft will harmoniously share the NAS.  The expected 2020, FAA NextGen ADS-B, sunrise rollout will probably be the next foundational step toward this endeavor.  In time, I do believe we will see interesting changes within the NAS, both here and around the globe.

 

The aforementioned Northrop Grumman MQ-4C Triton UAS actually poses quite exciting advancements with regard to the idea of NAS integration.  The United States Government Accountability Office (GAO): Report to Congressional Committees: Defense Acquisitions: Assessments of Selected Weapons Programs, March 2017 report outlined how the U.S. Navy has been researching and developing technology to integrate UAS and manned aircraft technology (GAO, 2017):

 

The Navy's MQ-4C Triton is intended to provide persistent maritime intelligence, surveillance, and reconnaissance (ISR) data collection and dissemination capability.  Triton is planned to be an unmanned aircraft system operated from five land-based sites worldwide as part of a family of maritime patrol and reconnaissance systems.  Based on the Air Force's RQ-4B Global Hawk air vehicle, Triton is part of the Navy's plan to recapitalize its airborne ISR assets by the end of the decade.

 

The program is developing new capabilities for Triton, including enhanced intelligence sensors and an aircraft avoidance capability.  The program plans to integrate these into production aircraft beginning in fiscal years 2020 and 2024, respectively.

 

The program now intends to demonstrate the software for the baseline configuration, along with the enhanced intelligence capabilities, by the May 2021 full-rate production date.

 

According to program officials, the MQ-4C Triton unmanned aircraft system program continues to demonstrate success during development and early operational flight and ground test (GAO, 2017. p. 117-118.).

 

The MQ-4C UAS is one among many U.S. defense UAS weapons systems that are being developed with intention of full integration with human piloted aircraft assets.  The GAO report outlined a long list of such UAS technology advancements that are under continuous development.  While the nature of advanced military technology applications are generally tasked toward maximum efficiency of life-taking – aka military power superiority – those same advancements could later ultimately become repurposed life-saving technologies.

 

This territorial area of ethics approaches taboo and is generally advised best to be left away from the dinner tables; however, most military technologies eventually are cascaded in a trickledown effect to the civilian sectors where they are often implemented as tremendous advancements to systems safety.

 

One might argue that the dark side, just may be as necessary, as the light side certainly is – the yin and yang.  It’s an idea to think about at least.

 

It is my belief that UAS technologies are truly only in their stages of infancy, perhaps even, they are only at the "zygote" stage of development.  What the future holds for them is uncertain but I have strong suspicion that autonomous or pseudo-autonomous aircraft systems are on the horizon.  What impact this might have upon the careers of human pilots currently tasked with operating aircraft in the NAS is unknown.

 

Removing the human pilot from aviation systems entirely has become an actuality that society generally accepts as technologically possible and is practically proven.  Although, this concept doesn’t sit well with people considering the consequences entailed in weighing the potential cost of their own lives when giving entirety of control over to the machine.

 

Society generally finds difficulty in fully trusting technology alone to maintain the assurance of their continued livelihood; this is due to a psychological theory described as “shared fate” where passengers believe humans piloting the machine have as much skin in the game to survive as they do.

 

UAS are posed to replace manned aviation tasks in certain markets and are currently transitioning to do so in select hazardous areas where reduced potential loss of life through UAS use exists; creating the double-effect of reduced overall economic operating cost and mitigating unnecessary risk to human lives.

 

However, potentiality of danger exists in removing the human factor completely from complex aircraft systems control.  Reliance on software, machines, and artificial intelligence of which are engineered and/or programmed to make life or death decisions are technologically unproven to be superior to human aeronautical decision making.  Strong ethical considerations of applicability exist regarding catastrophic automation failures and the potential cost measured in loss of human life.

Automated and human interdependent systems which rely upon linked redundancy of one another should be further explored.  There exists across the technology and humanity divide of automation in aviation, a middle ground where we should aim our innovations.  More research and development must be completed before society will entrust fully automated aviation models to maintain their safety.

 

– Aviator in Progress

References

Business Insider. (2017). Drone Technology and Usage: Current Usage and Future Drone Technology. Business Insider. Retrieved from http://www.businessinsider.com/drone-technology-uses-2017-7

FAA. (2018). Unmanned Aircraft Systems. Federal Aviation Administration. Retrieved from https://www.faa.gov/uas/

FAA Modernization and Reform Act of 2012. (2012). Public Law 112-95. U.S. Government Publishing Office. Retrived from https://www.gpo.gov/fdsys/pkg/PLAW-112publ95/html/PLAW-112publ95.htm

Fred, H. L., & Cheng, T. O. (2003). Acronymesis: The Exploding Misuse of Acronyms. Texas Heart Institute Journal, 30(4), 255–257. Retrieved from https://www.ncbi.nlm.nih.gov/pmc/articles/PMC307708/

GAO. (2017). United States Government Accountability Office: Report to Congressional Committees: Defense Acquisitions: Assessments of Selected Weapon Programs. March 2017. GAO-17-333SP. United States Government Accountability Office. Retrieved from https://www.gao.gov/products/GAO-17-333SP

Zipline. (2018). Lifesaving Deliveries by Drone. Zipline International, Inc. Retrieved from http://www.flyzipline.com/

Effects of Pilot Fatigue: Are All-Cargo Pilots Affected Differently?

Without doubt, the accident and aftermath following Continental Connection flight 3407 operated by Colgan Air, Inc., affected the aviation industry substantially.  Tragedy of that wintery night on February 12th, 2009, just outside Buffalo, NY, resulted in sweeping rulemaking changes which increased airline transport pilot (ATP) minimum standards of qualification.  Alongside ATP changes - serious questions regarding pilot fatigue, fitness for duty, and flight duty period safety specifics were raised, and then subsequent laws were enacted to impose regulations upon those areas as well.

Such questions however had been raised before about pilot fatigue, yet, were legislatively mothballed due to the decidedly cost prohibitive economic effects projected to be felt upon the profits of industry.  Unfortunately the pilot fatigue issues were not seriously revisited, as historically is commonly seen with safety regulation in general, until after the cost of 50 lives was realized to be priceless.  Pilot fatigue was largely suspected toward the accident’s probable cause – fact until then of which was not fully appreciated.

Public outlash was severe following the Colgan accident.  No longer would the impacts of pilot fatigue rules be deemed, as were definitively “negotiated unregulated” by industry interests, as acceptable financial justification above that of safety paramount.  Lawmakers mandated regulation in the interest of aviation safety with regard to the present danger of pilot fatigue.  Following the mandate, the new Federal Aviation Administration (FAA) regulation 14 C.F.R. 117 “Flightcrew Member Duty and Rest Requirements” was created.

The FAA “Flightcrew Member Duty and Rest Requirements” final rule summary first published to the Federal Register on January 1st, 2012 comprehensively explains (2014):

This rule amends the FAA's existing flight, duty and rest regulations applicable to certificate holders and their flightcrew members operating under the domestic, flag, and supplemental operations rules.  The rule recognizes the universality of factors that lead to fatigue in most individuals and regulates these factors to ensure that flightcrew members in passenger operations do not accumulate dangerous amounts of fatigue.  Fatigue threatens aviation safety because it increases the risk of pilot error that could lead to an accident.  This risk is heightened in passenger operations because of the additional number of potentially impacted individuals.  The new requirements eliminate the current distinctions between domestic, flag and supplemental passenger operations.  The rule provides different requirements based on the time of day, whether an individual is acclimated to a new time zone, and the likelihood of being able to sleep under different circumstances (FAA, 2014, p.1).

Yet, key aviation interests were decidedly absent from the tables of regulation – the “All-Cargo” industry’s interests.  The all-cargo industry was purposefully excluded from 14 C.F.R. 117 regulations due to the expected negative financial impacts upon their business with consideration weighted in favor of the relatively “low” human costs of their business model.  An all-cargo aviation accident holds that some human cost risk exists; those statistically few people that may be impacted by a cargo aircraft crashing into them from above, with of course the added human costs of the few crew lives onboard.

Another excerpt from the FAA final rule supports this rationale (2014):

Turning to concerns expressed by air carriers conducting all-cargo operations, as discussed in the regulatory evaluation, the FAA has determined that this rule would create far smaller benefits for all-cargo operations than it does for passenger operations.  Consequently, the FAA is unable to justify imposing the cost of this rule on all-cargo operations.  The FAA notes that in the past it has excluded all-cargo operations from certain mandatory requirements due to the different cost-benefit comparison that applies to all-cargo operations.  For example, in 2007, the FAA excluded all-cargo operations of airplanes with more than two engines from many of the requirements of the extended range operations (ETOPS) rule because the cost of these provisions for all-cargo operations relative to the potential societal benefit was simply too high.  Based on the cost-benefit analysis of this rule and its past precedent, the FAA has amended this rule to make compliance with part 117 voluntary for all-cargo operations and to allow those operations to continue operating under the existing part 121 flight, duty, and rest regulations if they choose to do so.  As such, this rule now allows all-cargo operations to voluntarily determine, as part of their collective bargaining and business decisions, whether they wish to operate under part 117 (FAA, 2014, p.30).

Decidedly ruled were the nominally lower human costs of an all-cargo aircraft accident when compared to substantially higher human costs of a passenger airline aircraft accident.  An aircraft full of cargo, things, and stuff, was declared less valuable than one full of people’s lives.  It makes good sense; or does it?

The Coalition of Airline Pilots Associations (CAPA) is an industry group with strong alternate conviction against the exclusion of the all-cargo industry from the 14 C.F.R. 117 rule making.  They contend that the ruling actually promotes increased risk of danger to the entire aviation industry.  The CAPA website has a Legislative Issues section with Flight Time / Duty Time subsection titled “Cargo Carve-Out” – an interesting epithet for the all-cargo exclusions – that outline viewpoints supporting an inclusion of all-cargo amendments to the 14 C.F.R. 117 regulations.

Quoted from the CAPA Write Congress section of the website is succinct message on their perspective of pilot fatigue and aviation safety (2017):

Support Safe Skies Act

An opportunity to End Unsafe Cargo "Carve-Out" and ensure "One Level of Safety"

Revised flight-and duty-time regulations enacted recently for our nation’s commercial pilots contain an exemption for pilots who fly for cargo carriers, creating an unsafe regulatory double standard.  All commercial aircraft share the same taxiways, runways and airspace.  Permitting cargo carriers to operate by less stringent regulations governing flight and duty time makes no sense.  After all, pilot fatigue poses the same safety risk, whether the aircraft carries passengers or freight.

Congress is debating legislation to renew funding for the Federal Aviation Administration. This legislation provides an opportunity to correct the unsafe regulatory double standard that exists for cargo pilots (CAPA, 2017).

Below the aforementioned statement is a standard fill in the blanks of personal information web-form for easy automated submission to one’s congress person in support of the CAPA organization’s aim.  Their website had another simply stated quote that engaged sincere thought for consideration, “A pilot is a pilot and needs protection from fatigue whether flying for a cargo or flying passenger airline” (CAPA, 2017).  What is certainly clear of their organization is that they are strongly positioned in the interests of all-cargo pilots to be included in the 14 C.F.R. 117 regulations.

How would such inclusion affect the cargo pilot population directly?  A good question: One might assume that it would negatively affect the all-cargo aviation industry with a pilot shortage due to the reduced duty times placed upon the overall pool of pilots.  Inversely though it could positively affect the all-cargo pilot population in terms of financial wage improvement and quality of life.  Such changes could result in the all-cargo industry being forced with necessitated increases in pilot hiring, thereby forcing increased pilot wages, by virtue of "pilot scarcity" value.  Passenger airlines are currently experiencing such an effect of wage increases due to regulation related pilot shortages.  This fact may and very likely will be leveraged upon by the all-cargo industry as financial validation against their inclusion in future 14 C.F.R. 117 regulation amendments.

The CAPA perspective however seems to be a winning scenario for pilots and the flying public in general – less fatigue, higher wages, and most importantly increased safety.  Yet, there is no such thing as a free lunch, ever.  Someone would pick up the bill – probably the end of the line consumer of which ultimately relies upon the all-cargo industry’s services.  Safety however should never be considered as reasonable sacrifice bargained for financial gain.

As with practically all regulation, government actors’ ears are effectively pulled upon by those which present the most persuasive interests; financial considerations are greatly accounted into lawmaking.  The all-cargo industry was very effective at these persuasive aims; one can easily find such evidence in the scores of documentation and cost-benefit analysis studies found within the Federal Register website Supporting/Related Materials documentation section of the FAA final rule (FAA, 2014).  CAPA has presented their supportive persuasive interests as well.  Only time will tell which way the lawmakers will sway next and, as always - the wheels of law turn ever, ever, ever so slowly.

– Aviator in Progress

References

CAPA. (2017). Cargo Carve-Out. The Coalition of Airline Pilots Associations. Retrieved from https://www.capapilots.org/legislative-issues/cargo-carve-out/

FAA. (2014). Flightcrew Member Duty and Rest Requirements. Federal Aviation Administration. Retrieved from https://www.federalregister.gov/documents/2012/01/04/2011-33078/flightcrew-member-duty-and-rest-requirements