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 September 2007

Saurabh Anand graduated from Washington University in St. Louis, Mo., with a degree in mechanical engineering in 2007. While at college, Anand led a team that designed and tested unmanned aircraft systems. This summer, he participated in the Washington Internships for Students of Engineering program and was sponsored by ASTM International.

Case Study: British Use of Unmanned Aircraft Systems

The use of unmanned drones by a Merseyside police station in the United Kingdom provides an example of overcoming the challenges of public UAS integration. The British Civil Aviation Authority grants greater airspace access than the FAA to light UAVs weighing less than seven kilograms, thus allowing the police department to utilize cost-saving UASs. According to Inspector Ian Humphreys, who is responsible for the implementation of the drones, “The cost of one month’s lease of the drone equates to just one hour of flying time for our helicopter.” Currently, Merseyside police have begun a trial period with one-kilogram police drones functioning as high-profile deterrents and evidence gathering tools. Humphreys adds, “having been an operational police officer for over 20 years, I believe the drones usage will become more and more widespread as time goes by, and I can see it being used in a whole host of varied operational ways.”

Legislation similar to that which allows Humphreys to utilize unmanned drones in Britain may be possible in the U.S. today. However, for the long-term domestic use of UASs, industry and regulators need to take steps to ensure the safety of the public without overburdening the industry with excessively restrictive regulation.

Domestic Use of Unmanned Aircraft Systems

An Evaluation of Policy Constraints and the Role of Industry Consensus Standards

This article was excerpted and adapted from a paper written by Saurabh Anand, an intern with the 2007 Washington Internships for Students of Engineering program. ASTM International sponsored Anand’s internship as part of its academic outreach program. The WISE program selects outstanding engineering students who then spend nine weeks in a Washington, D.C.,
summer program to learn how government officials make decisions on complex technological issues and how engineers can contribute to legislative and regulatory public policy decisions.

For information on the WISE program and the full text of this paper
click here.

Unmanned aircraft systems have begun to expand beyond their military role. UASs are aircraft controlled by ground operators; operator controllability ranges from changing only high-level aspects of the mission to taking full control of the UAS. UASs have three advantages over manned aircraft in certain niche applications: they are orders of magnitude cheaper, are not affected by the fatigue of human pilots and do not put human pilots at risk. Nations are using UASs domestically to secure pipelines and offshore oil platforms, monitor criminal activity, spot fires or disasters and take pictures. There are countless other applications for UASs, including crop dusting, advertising, patrolling borders and collecting various data.

So why aren’t UASs in the skies above the U.S. today? Currently, an Experimental Category Special Airworthiness Certificate from the Federal Aviation Administration is required for commercial UAS flight. These certificates must be obtained for every UAS, no matter its size, material composition, level of autonomy or flight path. Not only is this process time consuming and a major deterrent for UAS enterprises, it is also burdensome for the FAA. Only about a dozen experimental certificates have been granted since 2005 out of many more requests. The number of certification applications is growing and resources in the FAA’s Unmanned Aircraft Program Office are being diverted from the task of creating basic regulation in order to process applications.

Past Data and Research

The FAA requires that UASs not exceed an acceptable level of risk in the national airspace system. As discussed in the June 2007 issue of SN, this suggests UASs must be able to “see and avoid” other aircraft while participating in the air traffic management system for manned aircraft. In response, industry has produced collision avoidance sensors with greater air-traffic detection capabilities than pilots. However, other technologies available to replace the human presence of a pilot are still in development. Some of the largest technology gaps include reliable communications relay networks and collision avoidance algorithms, which dictate how aircraft should maneuver when a threat is detected.

Despite the need for continued research, past defense data helps make a case for UAS integration into the NAS (see figure). While the primary focus of military UASs is performance, they have nonetheless reached the safety level of manned military aircraft. In addition, many UASs are designed to be expendable or operate in dangerous conditions, contributing to an inflated mishap rate. With the commercial UAS industry concentrating intently on safety, it is expected that industry can reach the safety level of manned aircraft relatively quickly, especially with the guidance of standards-based regulations. In addition, many commercial UASs will be based on platforms previously proven and tested through military use.

Costs of Delay

Due to the FAA’s current certification process, the integration of UASs into the NAS has been delayed. Many of the penalties of this delay have been faced by the military. The U.S. Department of Defense faces difficulties accessing the NAS for operational activities, which is causing the unnecessary use of manned aircraft, reducing the number of emergency response tools and delaying UAS ground operator training. Businesses are suffering losses or leaving the market due to a lack of consensus on regulation. Finally, in certain cases, the public is forced to trade the use of UASs in firefighting, police work, security, advertising and disaster response for human-piloted systems that can be less efficient and riskier.

Comparison of UAS Mishaps as a Function of Flight Hours (2004). Note that UASs such as the widely used Predator are approaching the safety level of manned aircraft such as the U-2 and F-16. Source: Office of the Under Secretary of Defense, UAS Roadmap 2005-2030 (enlarge figure)

Industry Challenges

Although the costs of delaying the incorporation of UASs in the public and private sectors are great, industry and regulators face several hurdles to integrating UASs into the NAS in a timely manner. The largest impediment to the domestic use of UASs is that they are currently expected to conform to procedures created for manned aircraft. To avoid such requirements, a lengthy and burdensome experimental certification process designed for stand-alone exceptions in the NAS is used by UAS manufacturers.

Other industry challenges include high insurance costs and public unawareness. Without the use of the NAS, especially in low-risk situations, industry has been unable to collect data that will help reduce high insurance costs, display the advantages of UASs and showcase the reliability of their systems.

Public concern, coupled with the negative stigma that tends to adhere to technology that alters workers’ roles, makes UASs unpopular. Many people continue to mistrust UASs with even small levels of autonomy, while others fear “haywire” autonomous aircraft. However, such concern is misplaced — commercial aircraft routinely use autonomous landing and takeoff capabilities and even the most autonomous UASs will have some human override capabilities.

Adding to such fears is recent terrorist activity. Terrorism using UASs is a real threat being evaluated by the DoD. However, DoD sources state that UASs are not especially attractive to terrorists, who have a multitude of weapons to choose from and are generally willing to sacrifice themselves when attacking.

FAA Challenges

The FAA is facing pressures to develop roadmaps to integrate UASs into the NAS. Further compelling the creation of regulation is a fear of the illegal use of UASs, sometimes in the form of widely available radio-controlled aircraft with modifications.

Since no standards-based regulation exists for UASs, every UAS certification application must be reviewed thoroughly, no matter how simple or low-risk the case. Applications continue to increase with demand for UAS operation in the NAS, and the office is developing a backlog of applications due to a dearth of resources. At the same time, the office is charged with creating regulation for UAS access to the NAS on the same dwindling source of funds and staff.

In addition to requesting more funds, it may be beneficial for the FAA to use outside resources to accomplish its goals. RTCA Inc., a private nonprofit corporation, and ASTM International’s Committee F38 on Unmanned Aircraft Systems have industry volunteers actively working on UAS standards. In addition, the DoD is creating self-verification standards, with the exception of ASTM International’s standards F 2411, Specification for Design and Performance of an Airborne Sense-and-Avoid System, and F 2585, Specification for Design and Performance of Pneumatic-Hydraulic Unmanned Aircraft System (UAS) Launch System, which it has adopted for use. The stakeholders in these organizations have made important contributions to creating regulation, and the FAA should continue to utilize all resources available to reduce its own workload. Collaboration between these entities is necessary to avoid the duplication of effort and create timely integration of UASs.

The Next Steps
Continue Research Activities — Testing combined collision avoidance sensors is essential for UAS operations outside of visual range. Many sensors have been developed and are ready to be demonstrated. Although collision detection technology is reaching levels likely to be considered acceptable, many other areas are restricting broader UAS integration in the NAS. Avoidance algorithms for UASs unable to use current NAS architecture have not been developed. In addition, industry has not solved problems with communication links. Continued research will enable safer UASs to eventually fly in the NAS.

Increase Participation in Standards Development — Without standards, industry has no guidelines with which to measure their test results. Thus, the debate over “acceptable” levels of safety in the NAS continues because there are no minimum technical requirements for UASs. Members of the UAS industry can help resolve this debate by participating in the standards development process. In addition to representing their views and providing technical expertise, volunteers participating in standards creation make connections with peers in the industry and are well-versed in the standards.

The Next Steps
FAA and Policy-Makers
Establish Regulations for Small Civil UASs in Visual Range Operations — Small UAS in visual range of the operator in restricted regions of the airspace — for example, Class G airspace away from airports — pose a comparable risk to the NAS, as do remote-controlled aircraft. However, since UAS will be used for commercial reasons instead of recreation, new regulations need to establish liability, operational restrictions and other technical factors such as weight, speed and maximum altitude. It may be beneficial to divide this restricted class of UASs based on each type of application — such as agriculture or law enforcement.

Once these regulations are in place, businesses can begin using UASs for commercial purposes and acquiring data for further integration into the NAS. Barriers such as high insurance costs and public unawareness can be lowered with demonstrated operation to best practices derived by the industry and increased data acquisition from continued use. ASTM International standards already exist for visual range operations and for essential components of airframes, and more standards can be created quickly because many problems relating to sensors and avoidance are less severe under the proposed operational limits. In addition, the FAA will see a reduction in special airworthiness certificate applications allowing efficient resource allocation.

Establish Test Centers for Non-Visual Range Civil UAS Research — Visual range operations cover a fraction of the practical applications of UASs. Regulation for UAS use apart from visual line-of-sight requires more deliberation and a larger portfolio of standards. To relieve some pressure on the FAA, independent test centers can be established for research and avoidance technology demonstrations. An independent entity such as a university could be given the power to grant experimental certificates to applicants on behalf of the FAA. This would allow faster access to the NAS for applicants and share certification workload as standards work continues. Again, it may be beneficial to limit such centers to using small UASs, which would capture a large percentage of intended applications without creating high risks.

UASs in the Next Generation Air Transportation System (NextGen) — UAS operation is already a key component of NextGen, a multi-billion dollar initiative in the FAA to upgrade the current air transportation system. UASs can be utilized as forerunners for future technology such as automatic dependent surveillance-broadcast. Although widespread use of ADS-B may require large infrastructure changes, it has several advantages over the current radar-based system used in the NAS. For example, it is unaffected by geographical obstructions, and will allow UASs to safely participate in the NAS by relaying and receiving the state vectors of nearby aircraft. This will greatly reduce UAS industry expenditure on detect-and-avoid technologies and the overall risk of operations in the NAS. Policymakers should begin to mandate the use of ADS-B incrementally over the next few years for safer and cost-effective NAS operations. As the use of ADS-B increases, it is expected that the costs of the system will decrease substantially.

Increase FAA Funding for UAS Integration Regulation — The majority of stakeholders can agree that the safe incorporation of UASs into the NAS is a priority and also a monumental task. Although the FAA Unmanned Aircraft Program Office can reduce costs as it begins to establish regulations for small UASs, it needs extra funds to undertake long-term integration regulations. Reauthorization bills such as H.R. 2698 have provided money to increase UAS research, although they allot no extra funds to FAA to create regulations for UASs that could be given access to the NAS in the near-term. UASs are fundamentally different than other aircraft and current FAA regulations are designed for manned aircraft. In addition to tweaking some of its most core documents, the FAA may need to consider dozens of standards and experimental data before it can regulate all types of UAS use in the NAS.

Hasty UAS integration not supported by technical documentation could result in setbacks for UAS technology and expose the public to unnecessary risk. A variety of stakeholder interests are competing and reaching a consensus will be difficult. However, the aforementioned tools are available to industry and government to facilitate the process and grant society access to the numerous benefits of UASs. //