sUAS ARCParticipants Perspective

Prepared by Patrick Egan for the membership of WG-73, Sub-group 4.

Proposed sUAS NAS Integration Guidelines

• 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 ARC Observations

• 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 Observationscontinued...

• 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 impressionscontinued...

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?

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

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.