UAS vs. Manned License Discussion

         One of the major issues regarding integrating Unmanned Aerial Systems (UAS) into the National Airspace (NAS) is determining the correct level of license required for commercial operations.  For the purpose of this discussion I will focus on the commercial requirement which would allow an individual to operate a UAS within certain parameters in the NAS for business purposes.  According to the FAA, There are three ways to fly a UAS for work, business, or non-recreational reasons:

• Following the requirements in the Small UAS rule (Part 107)
• Following the rules in your Section 333 grant of exemption
• Obtain an airworthiness certificate for the aircraft

(FAA, n.d.)

I won’t go into the methods in which a person must navigate each of those procedures but I do want to highlight the difference between the requirements to operate a UAS for business purposes and the requirements necessary for operating a manned aircraft in a commercial manner. 

Two factors basically render a flight (manned) commercial: carriage of passengers (or cargo) and compensation (Wieand, 2016).  There are a multitude of Federal Aviation Regulations (FARs) that govern how individuals will operate aircraft in commercial operations.  Typically they are broken down into specific “Parts” (91, 121, 135).  In a very simplified manner, the pilot must have a commercial pilot license at a minimum and most often have a charter certificate (air carrier certificate) in order to operate for income.   Essentially, while it’s reasonable to assume you’ll be careful flying yourself around, the FAA considers Part 135 rules necessary to ensure that people in the business of providing air transportation will exercise special care to ensure passenger safety (Wieand, 2016).  The cost to obtain a commercial pilot license can be quite expensive and the time it takes to obtain the skillset is a tremendous commitment and investment.  It starts out with a private pilot license that costs about $8,000 dollars, then you get your instrument rating, so that you can fly into clouds, and that’s another five or six grand (Greene, 2014).  Most pilots report spending close to $100,000 in order to get all of the required licenses necessary to operate an aircraft for air transport.  At the very minimum (i.e. banner carrying Cessna), a pilot will spend close to $20,000 and a minimum of 6 months in order to have the right certifications.  Not to mention, they must maintain a medical certificate.

The purpose of this entire discussion is simply to point out that the commercial manned pilot has a tremendous amount of time and money invested in their tradecraft.  They are highly motivated to operate within the rules and regulations of the FAA.  There are plenty of examples of folks who haven’t, and the FAA is never afraid to take action and remove certificates for bad decisions.  Now, as we compare that to the UAS industry, the difference is tremendous.  Someone who has a couple thousand dollars invested in the licenses, certificates, and requirements listed above doesn’t have the same motivation to ensure they are following the proper procedures.  The risk versus reward can be easily skewed.  Say for instance a business is willing to pay you $5,000 to conduct UAS photography over an area that you know is a Temporary Flight Restriction (TFR).  Your total investment is only a few thousand dollars at most so your reward is far greater than the risk.

UAS don’t have passengers so the stance that the regulation keeps passenger safe becomes mute.  However, UAS do fall from the sky when not operated correctly and I don’t care if it is 20 pounds, or 2,000 pounds, an object falling from the sky can cause irreparable damage and death.       

FAA (n.d.). Unmanned Aircraft Systems (UAS) Frequently Asked Questions.  Retrieved from https://www.faa.gov/uas/faqs/

Greene, L. (2014, November 21). So You Want to Be a Pilot: What It Costs And How Much You’ll Make.  Billfold.  Retrieved from https://www.thebillfold.com/2014/11/so-you-want-to-be-a-pilot-what-it-costs-and-how-much-youll-make/

Wieand, J. (2016, February). The Rules of the Game; Business Jet Traveller.  Retrieved from https://www.bjtonline.com/business-jet-news/the-rules-of-the-game

Military to Civilian UAS Applications

Military applications often bleed over to the civilian market place where they are used for commercial applications.  The MQ-9 Predator B has been in military use for numerous years with great success and the U.S. Customs and Border Protection have implemented this aircraft in the protection of domestic borders.  While this example technically represents a transition from military to civilian, let’s explore even deeper by reviewing a new proposal the U.S. Customs and Border Protection is soliciting to re-design their technological advantage and how that can translate into an emerging civilian sector technology.
     
It is quite well known that the U.S. Customs and Border Protection have been using Unmanned Aerial Systems (UAS) for quite some time with limited success and a robust cry from the public due to exorbitant cost.    The use of drones has been criticized by government auditors as costing too much — about $60 million a year — and producing too little, less than 2 percent of all apprehensions and drug arrests by the Border Patrol (Nixon, 2016).  The Unmanned Aerial Vehicle (UAV) currently being utilized is the MQ-9 Predator B.  An audit of the drone program, performed by Homeland Security’s Office of Inspector General and released last year, suggested that money spent on the drone program could be used better on ground-based sensors and radar towers than on drones, which cost nearly $20 million each and $12,255 an hour to operate (Nixon, 2016).  While these aircraft have proven their worth in the defense of our nation overseas for numerous years, it is becoming increasingly difficult to justify the program.  Therefore, the U.S. Customs and Border Protection is looking for Small UAS (sUAS) to fill a niche market for serving their mission and reducing their cost.

Various sUAS manufacturers have made great strides over the last couple of years with technological advancements that allow for sense/avoid, increased payload capability, increased endurance, etc.  These advancements have paved the way for sUAS to take on large roles in both military and civilian applications.  The agency (U.S. Customs and Border Protection) is currently soliciting proposals for small unmanned aerial systems, similar to consumer drones manufactured by DJI and Parrot, to be deployed by U.S. Border Patrol agents in the field (Brandom, 2017).  The obvious cost savings over the Predator would be tremendous with a limited reduction in capability.  The crafts would also be outfitted with sophisticated sensors, which may include infrared cameras and facial-recognition capabilities (Brandom, 2017).  As this technology is developed, implemented, and refined it can easily find a commercial use case in the civilian market place.

Amazon and UPS are both working on methods in which to deliver packages via UAS.  While these companies focus mostly on the delivery vehicle, platform and method, they neglect to see how technology can also enhance their service.  Recently, UPS did trial deliveries of packages.  When the UPS driver approached the intended home for delivery, she parked the car, and then launched the drone from its roof (Vanian, 2017). From there, the drone flew to the home based on a pre-programmed flight path, dropped off the package held inside a small cage, and then flew off to rendezvous back with the van—which had since been driven to a spot miles away (Vanian, 2017).  While this method works well for delivering packages that don’t require a signature or delivery confirmation, it leaves open the opportunity for package theft.  A nefarious individual will easily take note of a UAV approaching and departing a particular home.  However, with the requirements posted by the U.S. Customs and Border Protection the technology may be able to eventually leverage facial recognition in order to confirm package recipient.  The test was intended to show that UPS drivers could eventually use drones to handle more deliveries than they would otherwise be able to do using the traditional method of going house-to-house by truck (Vanian, 2017).

Technological advancement is often driven by military as they set the requirements and can demand the research & development.  The need for the product drives companies to produce products that would otherwise never be developed due to a lack of demand for commercial use.  However, once the product transitions through its developmental cycle the public becomes aware and finds creative means to implement the products in innovative uses. 

Brandom, R. (2017, April 6).  The US Border Patrol is trying to build face-reading drones. The Verge.  Retrieved from https://www.theverge.com/2017/4/6/15208820/customs-border-patrol-drone-facial-recognition-silicon-valley-dhs.

Nixon, R. (2016, November 2).  Drones, So Useful in War, May Be Too Costly for Border Duty. The New York Times.  Retrieved from https://www.nytimes.com/2016/11/03/us/drones-canadian-border.html.

Vanian, J. (2017, February 21). UPS Has a New Trick to Make Drone Deliveries a Reality.  Fortune.  Retrieved from http://fortune.com/2017/02/21/ups-drone-deliveries-florida/.