Page 24 - Forum-2020-JulyToSeptember

mand” (RPIC) to control and maintain inconsequential precedent of permitting be allowed to continue. From a “preven-
situational awareness in the operation some activities that are known to be more tion” perspective, this is by no means an
of the unmanned aircraft. Unless an hazardous than others based on “societal inconsequential part of the landscape.
unmanned aircraft is explicitly designed benefits” asserted to justify them. There is no doubt that some types of
and expensively equipped to clear its own As the International Civil Aviation Or- aviation operations undoubtedly are safer
flight path, it must have either a func- ganization (ICAO) UAS Toolkit observes, to carry out using unmanned aircraft
tioning datalink or totally segregated or “As a regulator, recognizing the societal than is the case with manned aircraft,
protected airspace to allow the RPIC to benefits of UAS and the need to facilitate even using relatively simple RPAS. It also
avoid in-flight conflicts or even midair operations in a safe manner are key and is undeniable that the lack of a human
collisions with other aircraft. Clearly, include humanitarian efforts, search life at risk aboard an unmanned aircraft
unmanned aircraft are different from and rescue, firefighting, infrastructure allows a different perspective on how
manned aircraft, right? monitoring, and research and develop- and from what platform such operations
The real-world perspective on these ment [R&D]. Operations limited to VLOS should be carried out. To date, only a bare
differences—each of which represents a [visual line of sight] operations may limit handful of accidents has been attribut-
limitation that is not necessarily com- benefits obtained by carrying loads or ed to manned and unmanned aircraft
patible with how the current aviation discharging substances (e.g., crop dusting, sharing the same airspace while operat-
system works—is more nuanced, seeking insect control).” Of course, this perspec- ing under different rules. However, such
to accommodate unmanned aircraft tive sidesteps such practical implementa- occurrences are easy to envision as UAS
despite their limitations. However, such a tion considerations as both manned and operations become more common as long
supportive approach also provides poten- unmanned aircraft performing the same as manned and unmanned aircraft are
tially unwarranted latitude to unmanned operations in the same airspace at the regulated and operated differently.
aircraft for shortcomings that would be same time and is essentially silent on the
completely unacceptable for manned larger question of risk. Thinking About the “Manned” Past to
aircraft. In 1962, ISASI’s esteemed founder,
In many states, an unmanned aircraft Jerome Lederer, presented a lecture on Prepare for the “Unmanned” Future
simply is, by definition, “an aircraft.” “Perspectives in Air Safety” on his receipt At this point, it may be best to restate
Various qualifiers often are added to that of the Daniel Guggenheim Medal from the first of the two questions asked at the
fundamental proposition to account for the American Society of Mechanical start of this paper as “In what ways do
the limitations mentioned above, but the Engineers. He asked a number of ques- UAS need to be more or less the same, in
idea behind starting with the same basic tions about risk throughout this talk, all terms of capabilities and operating rules,
definition is that existing operating rules of which resonate in the current debate as manned aircraft in the interests of avi-
and certification standards rules can (and about unmanned aviation; for example, ation safety?” To date, there is no general-
should) be applied equally, regardless of when considering instances in which a ly accepted answer to this question. This
whether an aircraft has a pilot aboard or production aircraft is found to need a is fertile ground for exploring through the
on the surface of the earth. safety-related modification. lessons of manned aviation and historical
This ideal environment has yet to be The aviation industry resents and accidents.
achieved. There is little motivation on protests overregulation and is prone to To start with, consider two proposi-
the part of the unmanned aviation sector combat detailed regulation of the nature tions:
to pursue it, especially to the extent that that would have overcome such a defi- • What has come to be considered a
mandatory equipage associated with spe- ciency. But what is the Federal Aviation shared perspective on aviation safe-
ty—a common basis for a “safety cul-
cific classes of airspace would cost money Administration (FAA) to do when it finds ture”—is not shared by the unmanned
to install and more money to make oper- good safety practices developed by one aviation sector except to the extent it
ate through satellite-based datalinks or organization not adopted by others, yet is obliged to conform to it.
terrestrial networks. It also would reduce both comply with the regulations?
range, endurance, useful payload, or all Should the government, in such cases, • A complex system like aviation is only
of the above. To the unmanned aviation step in retroactively to correct a known as safe as its least safe component.
sector, “integration” often is seen simply hazardous situation by changing the The first proposition might be hot-
as an alternate term for “access to desired regulation, making it more specific? ly contested by the more professional
airspace,” not participation in the existing One should it be careful not to discour- operators and manufacturers of UAS.
aviation system. age original thinking, imagination, and They could argue, rightly, that they do
One of the major advantages of un- ingenuity, which may lead to improved whatever is asked of them to gain access
manned aircraft systems (UAS) is that practices? Should the public, therefore, be to airspace. This is true but somewhat
they cost less to build, less to maintain, asked to assume some risks for the sake disingenuous. Unmanned aircraft cannot
and less to operate than manned aircraft. of progress? The solution to such prob- conform to many rules of certification
These savings often are achieved at the lems should not lie entirely in the domain or operation currently in force, meaning
expense of being significantly less capable of government regulation in a free society. they must seek permission to operate
than the manned aircraft whose airspace It is important to acknowledge that a that is conditioned by mitigations for
they share. However, in facilitating more very high–level risk decision has already their various limitations (or that simply
widespread operations of RPAS regard- been made regarding unmanned aircraft accepts the increased risk associated with
less of their differences, there is the not operations: they are permissible and will them). Since unmanned aviation busi-
24 • July-September 2020 ISASI Forum