Meeting the challenge of UAS and sUAVs in the NAS: The FAA’s dilema.

The main problem with the apparent reluctance of FAA to move more quickly to set the standards for UAV/UAS operators may well be about the prospect of facing down a monster. The parallel, as I see it, is where the FCC was in the 1970s when the CB market exploded and became a tiger that the FCC has never really managed to tame.

477px-Frankenstein's_monster_(Boris_Karloff)The problem, as I see it, is that the FAA may now be a bit gun-shy about the monumental task of building another licensing structure like the what has evolved for pilots and “piloted” aircraft. The UAS world does not fit the pilot licensing model , the aircraft are very much different, it would not be a good idea to add potentially 100,000 more people on the limited FAA communications channels, and nobody at the FAA wants to take responsibility for creating a monster.

And I don’t think the FAA fully grasps the reality of how many UAVs are actually out there now, and how fast it is growing. Evidence for that was the statement by FAA Chief Michael Huerta’s statement last November he said that FAA expects that there “could be 7,500 SUAVs” in use in the next 5 years. The reality is there were about 15,000 sold just in that month (November 2013).

The existing pilot and airframe regulating structure they are comfortable with does not fit the UAV market. The small size of the majority of UAV’s makes current the “N” number tail marking requirements (12 inches) unworkable.  Nobody in the FAA wants to stick their neck out and take responsibility for a parallel licensing structure for UAVs. Who wants to bite off that large a task that they have to get right the first time because there will be no going back once it starts?

But because of the burgeoning growth of UAV sales and use, it is imperative that the FAA get a handle on the situation sooner (now) rather than later (into 2019).

A certification and licensing structure and process should fit the specific use and UAV model being used, while providing a place in the process for licensed commercial pilots as well as DOD trained drone pilots and operators, which in turn would relieve a large part of the anticipated administrative load from the FAA. At the same there should be a process for creating an immediate registration process that would enable the FAA to communicate future requirements and to advise current operators of the ongoing rule making process, and provide a structure adapted to the specific nature and goals of operating UAVs in the NAS.  There should be a process for manufacturers to qualify their products for certification. UAV operators (“pilots”) would then be certified to operate specific levels of UAVs in much the same way as commercial pilots qualify for upgrades from single engine to multi-engine, IFR/VFR, and so on, in that they would need to demonstrate proficiency to someone qualified to make that assessment and administer an appropriate written test (a licensed private pilot, for example).

Ex-military, DOD trained “drone” pilots might be “grandfathered” as qualified to operate (heavy) UAVs which are basically the same things they were controlling in the military (the ones that run $30,000 into the millions) that would be applicable to long range tasks such as monitoring oil pipelines and oil rigs, for example, which would require flight plans, collision avoidance systems, ADS_B, ATC coordination, etc. That eliminates much of the task of processing pilots of the larger UAS class. Border Patrol operations would likely fit into this classification.

However, the FAA clearly can’t expect operators of 5 pound quadcopters shooting real estate videos or farmers wishing to motor their crops , or fire and rescue to meet those same requirements, nor should they. One size clearly does NOT fit all.

The temptation is for the FAA to attempt to make the UAV market fit the existing pilot/airframe licensing and certification process which is not only largely unworkable but unsuitable. Attempting to make existing UAV operators obtain a commercial pilot’s license would not only be largely unattainable by many, unacceptable by most, and would be largely ignored. It can only get worse with every day that passes. That’s reality.

The fact that a recent NOTAM “suggested” that UAV operators “keep a log” is a step in the right direction because a certain amount of experience is necessary to become sufficiently proficient for safe UAV operation. That’s a good first step, but the FAA would not be realistic to expect that the UAV world will wait patiently for the next step in 2015 or 2016 or …(??)

Rather than further postponing action beyond the 2015 deadline, the FAA needs to begin implementing preliminary registration and authorizations in the next few months, not years before this cat gets so far out of the bag it can’t be tamed. (Please pardon my mangled metaphores)

(PDF) UAV Class Proposal (Suggestion)