On Thursday, October 22nd, the FAA held their Drone Advisory Committee ( DAC ) meeting and live streamed it via YouTube and Facebook. And while I encourage everyone to go watch the entire event and read the accompanying "eBook", I know that most of you don't have the time to do that, so I'll try to hit some highlights of the meeting for you.
In case you are not familiar with it, according to the FAA, the DAC is “ a broad-based, long-term Federal advisory committee that provides the FAA with advice on key UAS integration issues by helping to identify challenges and prioritize improvements. The committee helps to create broad support for an overall integration strategy and vision.”
DAC charter is here: https://www.faa.gov/uas/programs_partnerships/drone_advisory_committee/media/DAC_Charter.pdf
The actual DAC meeting is basically a formality. The majority of the work happens before the meeting and in the tasking groups. So before the meeting even happens they publish what they call the “eBook”. As I mentioned before, I encourage you all to read the eBook to get a much better sense of what goes on at the DAC.
Meeting Highlights
During the opening remarks, Secretary of Transportation Elaine Chao mentions there are 75 applications to fill the 6 vacancies on the DAC. If you look in the eBook it lists the current DAC members and the 6 vacancies, including the "stakeholder group" each vacancy is associated with. If you look closely, it is stacked very heavily with people from the commercial industry. Both manned and unmanned. We will get into this a little more later, but there does not appear to be a category for recreational flyers, nor is there any vacancy for such a group. The closest thing we have to recreational representation is the AMA and they are in the "other" group.
The FAA then stated that they “hope to have any new members in place for the next DAC meeting” which is currently scheduled for early next year. Which I take to mean some time around February 2021.
Task Group 8 on Safety Culture
Back at the DAC meeting in February 2020, the FAA tasked the DAC with answering the following question. "What are ways we can help the drone community fully adopt the safety culture that is so engrained in manned aviation?"
Given that task, the DAC created 4 subgroups to find answers to that question. The groups are:
Traditional Manned Aviation
Recreational/Community Operators
Small Commercial Operators
National UAS Operators
Manned Aviation Subgroup
First up was the manned aviation subgroup. They presented 3 recommendations to the FAA, none of which really caught my attention and it was pretty clear they are thinking mainly of large scale commercial operations with their recommendations, not so much the small recreational users like myself.
Those 3 recommendations are:
The FAA should develop and adopt a UAS integration strategy that encourages “safety ownership” and a “learning culture” throughout the UAS community.
The FAA should develop and adopt a UAS integration strategy that fosters the safety culture tenets of “trust” and facilitates a “systemwide approach” toward ensuring UAS safety
The FAA should create a UAS integration strategy that helps to grow the safety culture tenets of “executive level leadership” and “organizational values” into the DNA of the UAS community.
Recreational/Community Subgroup
Next was the recreational/community users sub group. This is the one that is most relevant to me, and thus had the most interesting content as far as I was concerned. This group also admitted they had a lot of cross over and close work with the small commercial operators group which the FPVFC president, Dave Messina, was a part of. And I can't help but believe that many of the good things I liked about what this sub group mentioned were influenced by Dave.
The first big noteworthy item that caught my attention was when they stated, “Aside from nefarious acts and outlier incidents, the subgroup could not identify a repeatable history of significant safety issues to mitigate. Therefore, the subgroup’s recommendations focus on how the FAA can educate, reduce potential risks, and build rapport and trust with recreational operators while integrating in the NAS.”
This basically calls out the fact that recreational use of a UAS over the past 100 years has been extremely safe, and thus even the question the task group was asked was a little bit misleading and unnecessary. I really hope the FAA also takes note of this particular sentence and understands what it is saying.
They go on to say, “The FAA should work with the community, influencers, events, and grassroots efforts to build trust among the drone community. The subgroup strongly recommends FAA’s participation at UAS recreational events”
Here the subgroup is suggesting that the FAA do a much better job of building trust with the community. I know in the FPV world, there is basically zero trust for the FAA. The FAA has a lot of work and a long road ahead of them to attempt to gain the trust of these recreational flyers and the Remote ID NPRM released last December did a LOT of harm to whatever trust there might have been. I'll be very curious to see if the FAA does any outreach to "influencers" like Bruce Simpson, Mr. Steele, Joshua Bardwell, etc. Or maybe their numbers/influence is not big enough?
“The FAA should attend events with the primary intent of education and trust building and not to impose their authority on regulatory and policy matters.” Would also be interesting to see what would happen if the FAA sent representation to events like MultiGP IO.
This group also made this very important statement, “The FAA should further integrate recreational UAS manufacturers, community-based organizations, and recreational stakeholder leaders into its advisory and policy processes, so that this long-standing and evolving segment of recreational aviation has an equivalent seat at the table to segments of manned aviation.” If I wrote this statement, I would add that recreational stakeholders need a seat at the table equivalent to manned aviation and commercial UAS interests. Right now recreational use of UAS seems largely forgotten entirely in the regulations and as I mentioned in the beginning, there is no group as part of the DAC that represents recreational flyers. Only the AMA being stuck in the "others" group. Despite recreational UAS having the largest numbers. So I totally agree here, the DAC needs to add more recreational representation and the FAA needs to dedicate more seats at all the tables to this group.
This group then reiterated that “One size does not fit all” when it comes to UAS regulations and again, I completely agree. Regulations ( based on risk ) for your tiny whoop in your backyard are not the same as a drone delivering an organ transplant to a hospital or someone flying a large scale model aircraft, or someone trying to fly many miles beyond visual line of sight (BVLOS). Different activities have different risk and thus deserve different regulations.
And finally, this group mentioned that, “The FAA should educate the general public to help promote a culture of safety through a greater understanding and acceptance of UAS.” Absolutely. The general public appears to have an unjustified fear of "drones". If there is anything the FAA can do to educate the population and show drones in a positive light, perhaps many cities and states would not be so quick to create anti drone regulations on their own.
Small Commercial Operators Subgroup
The third subgroup to give their recommendations was the Small Commercial Operators group with a presentation given by Dave Messina ( FPV Freedom Coalition President). So while not an official DAC member, he has been working hard as a part of the subcommittee trying to give the perspective of a recreational FPV pilot, with some success. He has also applied to be a member of the DAC. Hopefully that will happen, but as I mentioned earlier, there is no vacancy for a recreational representative. But the recreational subgroup did tell the FAA they need more recreational representation.
Dave mentions that there are approximately 1.3 million recreational pilots in the USA, or 7 times more than the number of commercial operators. And yet there is only 1 DAC member representing a small portion of recreational users? How does that make any sense?
This group recommended a FRAT or Flight Risk Assessment Tool to be used before every flight. For example there would be a series of simple questions in your LAANC app that you would read before you fly. This would be a view only thing. Not something you would fill out and submit to the FAA. So really just a quick reminder to help you assess the risk of your planned flight.
One final highlight from this group , posted in the eBook, was the statement, "While the Safety Culture Small Commercial subgroup recognizes the inherent risks of integrating UAS in the NAS, it is important to note Small Commercial UAS operations have had zero deaths in the U.S". So, like the recreational group, they are pointing out that it is very hard to beat a perfect safety record when it comes to deaths caused by UAS in the US. So again we ask, what are the risks UAS pose and where is the risk assessment the FAA is required to do to justify increased regulations?
National UAS Operators
This group talked about the fact that complex activities should require more safety policies and procedures and less complex BVLOS and line of sight activities should have a more graduated approach. To which I completely agree. Again, one size does not fit all. There should be much less regulation involved in flying a small model aircraft at an AMA field or recreationally flying FPV in your back yard vs flying a cargo delivery across state lines or inspecting hundreds of miles of railway.
“Risk-based/performance-based safety policies should be leveraged to ensure safe operating requirements are a natural fit with the overall operation and the established safety culture of the organization.” Again, a good point that I agree with and one more time, where is the risk assessment behind the remote ID regulations?
Thank You Slide
As a hard working volunteer for the FPV Freedom Coalition, it was nice to see the FPVFC listed on the thank you slide.
Q&A For Tasking Group 8
James Burgess from Google’s Wing corporation wanted to bring attention to the fact that there are no existing safety and risk issues with UAS today. He highlights performance based and risk based regulations quite a few times which gives a glimpse into the thoughts about UAS regulations at Wing. This also helps explain why the Wing Remote ID response was so positive in my eyes.
FAA Response to Previous Task Group Submissions
The UAS Facility Maps group suggested that the FAA shrink the grids used for LAANC.The FAA agrees and is working on implementing this in late 2021.
What about Shielded Operations? Why did the FAA not respond at all to that part of the recommendation? If you read the eBook for this meeting you will see that this group made a big deal about shielded operations like is currently in use in New Zealand. However during the FAA response to this section they completely ignored anything to do with shielded operations. Why?
New Tasking from the FAA to the DAC
The manned aircraft community believes remote ID is probably inadequate to affect safety, and is mostly security centered, which I also agree with. It’s not about safety even though that has been what we have been told over and over again. The manned aircraft community states, “Any solutions should integrate with current avionics (EFB, ADS-B).” Which is exactly the opposite of what the FAA and the NRPM have stated.
It seems like the FAA didn’t like the responses they got from the manned aviation community so they want to ask the question again. So they are asking the DAC, “Can Remote ID be used to increase situational awareness between manned aviation that routinely operates at low altitudes away from airports and UAS operating in the same airspace? ” Curious to see if they will get the answers they are looking for this time.
Final Discussion
Near the end, James Burgess from Googe’s WING gives us a glimpse into his history and how model aviation at a young age got him into aviation. Again, this is possibly the reason that Wing’s NPRM response was very favorable to hobbyists.
Final Thoughts
What can we do to get more people actively involved with UAS regulations? I did as much as I could think of to spread the word that this meeting was taking place, yet of the 1.3 million recreational flyers in the US ( and many more around the world ) only about 180 people were watching on YouTube and another 125 on Facebook ( I know, this is during the day and most of you have to work, but a few days later and the YouTube video only has 2k views). The most common response I got when sharing links to the stream was, "I don't care, I'm going to fly no matter what the rules are". How can we show the FAA that we exist and in large numbers when possibly the majority of "us" are not willing to let the FAA know we are here?
