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•  Pilot-induced oscillation.      developed over time to prevent them, and   “The protections built into the
          •  Malicious interference.         the deference such operations receive and   present-day aviation system are far
                                             should receive in that environment.
          When one familiar with UAS looks at   On the other hand, unmanned aircraft   more robust than they used to be,
        this list, it is immediately obvious that   asserting a need or a “right” to operate   although the foundation of RPAS
        UAS are vulnerable to many of the same   amid other aircraft, whether receiving   ‘detect-and-avoid’ technologies
        conditions, albeit for many different   air traffic services or flying purely under   rests on understanding that it
        reasons. Chief among them is the RPIC’s   some interpretation of “visual flight rules”   is not enough for unmanned
        inability to directly perceive what is   (VFR), represent an entirely different
        happening to the aircraft from moment to   challenge. Current aviation stakeholders   aircraft to ‘see’only aircraft
        moment. However, even as work contin-  can and should consider the rules they   emitting transponder or Automatic
        ues on addressing these issues in manned   are required to follow; regulators must   Dependent Surveillance–Broadcast
        aviation, it is clear that preventive or   take an objective look at how much relief   (ADS-B) Out signals; they must be
        corrective measures that might be effec-  from rules unmanned aircraft operat-  able to actively detect nonemitting
        tive in that domain may be completely   ing in shared airspace should enjoy and   aircraft as well."
        inadequate for unmanned operations.  how much is warranted. In making such
          One of the great virtues of unmanned   determinations, the past will continue to
        aircraft is that many are inherently   matter.                            similar to that seen in the tragic 1986
        more stable than manned aircraft under   Finally, attentive readers undoubtedly   collision of an Aeromexico airliner and a
        normal conditions. Onboard automation   have noticed that the second question   general aviation (GA) aircraft over Cerri-
        provided in many makes them extreme-  posed at the start of this paper has yet to   tos, California. The former was operating
        ly effective at stabilizing themselves,   be directly addressed: Are past accident   under instrument flight rules in the Los
        responding to transient conditions that   scenarios in danger of being repeated due   Angeles terminal control area (TCA),
        might take them off their programed   to the expansion of minimally regulated   the predecessor to the current Class A
        course, etc. However, some of their design   unmanned aircraft operations in the   airspace; the latter was operating legally
        features—such as supercritical wings and   midst of manned aircraft?      under VFR but strayed into the TCA. Most
        satellite antennae subject to “fuselage   The author’s view is that the answer to   GA aircraft at that time lacked Mode C
        blanking” in some attitudes—render   this is a qualified “yes.” The protections   pressure reporting transponders, and the
        them vulnerable to unexpected depar-  built into the present-day aviation system   profusion of 1200 VFR targets flying un-
        tures from controlled flight.        are far more robust than they used to   der the TCA boundaries complicated the
          Experienced UAS pilots often can   be, although the foundation of RPAS   air traffic controllers’ task immensely.
        diagnose structural problems, inadvert-  “detect-and-avoid” technologies rests on   The Cerritos accident resulted in quite
        ent gear extensions, and the like through   understanding that it is not enough for   a few changes in the U.S., including
        close monitoring of the need for unusual   unmanned aircraft to “see” only aircraft   creation of the “Mode C veil” concept
        throttle settings, higher than normal   emitting transponder or Automatic De-  and more-stringent communications
        fuel consumption, or a constant need for   pendent Surveillance–Broadcast (ADS-B)   requirements for VFR aircraft flying in
        heading or altitude corrections.     Out signals; they must be able to actively   Class B and C airspace. However, it also
                                             detect nonemitting aircraft as well.  highlighted the distraction inherent in
                                               Current-generation transport-category   having numerous transponder targets
        Summing up                           aircraft use aircraft collision avoidance   flying outside airspace for which ATC
        Current conversations about the effects of   systems (ACAS) and only can detect   was responsible. The potential for repeat
        unmanned aviation on airspace include   aircraft equipped with transponders.   accidents led many facilities to suppress
        a significant amount of incompletely   Therefore, it is possible to envision RPAS   display of targets below a certain altitude
        informed—and occasionally misleading—  given relief from the requirement to be   to avoid clutter, which in turn may indi-
        blurring of existing distinctions between   equipped with such avionics on the basis   rectly have led to the FAA’s new guidance
        “small” RPAS and larger unmanned air-  of their not being designed or certified   to controllers that air traffic services are
        craft seeking to operate side by side with   with them. The current architectures   not provided to unmanned aircraft below
        other aircraft, especially in controlled   of both the Single European Sky ATM   400 feet AGL.
        airspace. There is a not inconsiderable   Research (SESAR) Joint Undertaking and   Small unmanned aircraft bring with
        amount of risk associated with those at   the U.S. next generation air transporta-  them their own unique issues, but also
        the small end of the size and weight spec-  tion system (NextGen) heavily rely upon   can be managed to some extent by
        trum interfering with terminal operations   participating aircraft being comprehen-  keeping them as segregated as possible
        at low altitude, especially when permitted   sively equipped to serve as interactive   from manned aircraft. This approach
        to operate in that environment more or   nodes of trajectory information upon   cannot work for RPAS flown among
        less at will and without the possibility of   which optimal clearances for all aircraft   manned aircraft. In those cases, history
        being “seen” either visually or electroni-  may be based. Again, if equivalent equi-  has taught many lessons that apply to all
        cally. Addressing the hazards those oper-  page requirements are not imposed upon   flying, regardless of the pilot’s physical
        ations present mostly will be a matter of   unmanned aircraft, they will be effectively   location. The aviation community would
        looking at the history of midair collisions,   invisible to all other aircraft in the system.  be wise to reflect on them as unmanned
        rules (including mandatory equipage)   It is possible to envision a scenario   aircraft operations continue to expand.
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