Send in the Drones? (cont'd)

I guess we have to talk about this. A post appeared on this blog 20 months ago, saying in part:

..we are being prepared for the day, not very far off, when we will be sharing the skies with Unmanned Aircraft Systems (UAS), also known as drones or remotely piloted vehicles (RPV's)...

As of Valentine's Day, when the President signed the recently passed FAA Reauthorization Act (Public Law 112-95), that day is upon us. There are some who are evincing surprise at the developments in this arena. I can only surmise that they have of late been asleep.

Section 332 et seq. of P.L. 112-95 has quite a lot to say on the topic of Unmanned Aircraft Systems. To begin with, the Law requires that on or before the 14th of May of this year the Secretary of Transportation must enter into agreements with "appropriate governmental agencies" that streamline the issuance of waivers or authorizations to operate "public unmanned aircraft systems" in the National Airspace System [P.L. 112-95 Sec. 334 (c)(1)].

The contemplated agreements must provide for expedited review, approval action within 60 business days, and expedited appeal in the event of disapproval. These agreements will, further, permit one-time approval of "similar operations carried out during a fixed period", and allow a "government public safety agency" to operate UAS's weighing up to 2 kg. within the operator's line of sight, up to 400 feet AGL during daylight conditions in uncontrolled airspace outside of 5 statute miles from any airport, heliport, etc.

One suspects that after about mid-August, anyone that flies low in uncontrolled airspace (agricultural applicators? pipeline patrols? balloonists? transiting helicopters?) is going to need to keep a sharp lookout for little 4 pound camera carriers buzzing around to help the constables search for marijuana patches, meth labs and undocumented immigrants. Will it be the responsibility of the operators of these devices to "see-and-avoid" other traffic? That would seem to be a rule-making matter,but the expedited schedule allows little time for orderly rule-making.

Once that little piece of business is under control, P.L. 112-95 gives the Administrator of the FAA until the 12th of August to set up a program of, at most, five years duration, that will establish six "test ranges" for the integration of UAS's into the National Airspace System (NAS) [P.L. 112-95 Sec. 332 (c)(1) et seq.]. In selecting locations for the test ranges, the Administrator is required to consider "geographic and climatic diversity", "ground infrastructure and research needs", the views of NASA and DoD, and no doubt (though not explicitly required), the location of the districts represented by the relevant congressional committee chairs.

The program's goals are fairly ambitious:

• To "safely designate airspace" for integrated manned and UAS operations;
  
• To "develop certification standards and air traffic requirements" for UAS's;
  
• To "coordinate and leverage" NASA and Dod resources;
  
• To "address both civil and public" UAS's;
  
• To coordinate with NextGen;
  
• To verify the safety of UAS's and related navigation procedures before integration into the NAS.
  

With these pilot projects established, no doubt to the financial pleasure of the usual suspects among DoT contractors, the cognizant managers will need to hustle to comply with the next requirement of P.L. 112-95. The act gives the Secretary until November 10th of this year to develop a "comprehensive plan to safely accelerate the integration of civil [UAS's] into the [NAS]." This plan is to be formulated "in consultation with representatives of the aviation industry, Federal agencies that employ [UAS] technology in the [NAS], and the [UAS] industry." [P.L. 112-95 Sec. 332 (a)(1) et seq.] (One wonders whether the GA community will have a seat at that table.)

The Act is fairly explicit on what it expects this "comprehensive plan" to comprehend, among other things (emphasis added):

• The anticipated rulemaking that will (i) define operating and certification standards for civil UAS's, (ii) ensure that UAS's incorporate "sense-and-avoid" capability, (iii) establish standards (including registration and licensing) for operators and pilots of UAS's;
  
• To project methods to enhance the technologies needed to achieve safe and routine operation of UAS's in the NAS;
  
• To recommend a phased-in approach to the integration of civil UAS's in the NAS;
  
• To project a timeline for this phased-in approach;
  

The plan is required to provide for the "safe integration" of UAS's into the NAS "as soon as practicable, but not later than September 30th, 2015."

The Act requires that the integration plan be forwarded to congress within a year (i.e., by February 14th, 2013), and that also by that date "the Secretary shall approve and make available in print and on the Administration’s Internet Web site a 5-year roadmap for the introduction of civil unmanned aircraft systems into the national airspace system...," said roadmap to be updated annually.

And, finally, the Act requires [P.L. 112-95 Sec. 332 (b)] that:

• "not later than 18 months after the date on which the (integration) plan...is submitted (i.e., at latest, by August, 2014)...the Secretary shall publish...a final rule on small (i.e., 25 kg or less) unmanned aircraft systems that will allow for civil operation of such systems in the national airspace system...",and;
  
• "a notice of proposed rulemaking to implement the recommendations of the (implementation) plan (presumably to encompass UAS's other than "small")...with the final rule to be published not later than 16 months after the date of publication of the notice (i.e., not later than December, 2015)."
  

So let us summarize the timeline:

• May, 2012: Agreements with government agencies on waiver procedures for operating public UAS's (of max. wt. 2 kg) in the NAS;
  
• August, 2012: Likely first operations of public UAS's in the NAS under waivers;
  
• August, 2012: Establish "test ranges" for development of UAS technologies and methods needed for integration;
  
• February, 2013: UAS Integration Plan due to Congress; Roadmap published in print and on-line;
  
• August, 2014: Deadline for final rule for civil operation of "small" (i.e., 25 kg.) UAS's in the NAS.
  
• December, 2015: Deadline for final rule for civil operation of all UAS's in the NAS.
  

The planning and rulemaking processes set in motion by the recent act of Congress deserve close watching, particularly as each key milestone is reached. It's going to get busy up there over the next few years!

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"Some National Security Thing"

Apropos of nothing that this post will talk about, let me start with the pretty bird at left - a Globe Swift that seems to act as the mascot for Volo Aviation at KBDR. It nests there among the Gulfstreams and the Challengers and makes it a pleasure to walk past the open hangar door.

I snapped the Swift's picture on my way to N631S Friday afternoon. My flight plan called for a 2030Z departure toward KVKX and I was already anticipating a long-ish trip due to forecast headwinds in the range of 35 to 40 knots. FltPlan.com was telling me to expect 2:31 en route.

I pre-flighted N631S, picked up my clearance, started the engine and was cleared to taxi to Runway 24. By 2033Z I was at the hold short line and transmitted, "Bridgeport Tower, Skylane 631S ready for Runway 24 at Hotel." There was no immediate response.

Then, for something completely different, the tower controller said, "ATC has just informed us that it will be at least 20 minutes before they can issue any IFR releases. N631S, say intentions."

"N631S would like to make a 180 and return to parking to wait it out." No point in continuing to burn avgas. That was approved as requested and I went back and shut down.

For most of the week there'd been a TFR covering the maximum lateral area of the New York Class "B" airspace, from the surface to 18,000 feet, due to the United Nations General Assembly meeting. Now, that was ending and I inferred that assorted Presidents, Potentates and Supreme Leaders were getting out of town - which overloaded both ATC and the security apparatus.

I kept the hand-held radio tuned to KBDR's ground control frequency and after about 15 minutes heard, "631 Sierra, are you up?" I responded with, "31 Sierra is up," and got back, "31 Sierra, go ahead and start your engine. I believe we can get you out of here."

So N631S and I were back at the hold-short line at 2051Z and this time got an immediate release. But that doesn't mean the fun was over.

After takeoff from Runway 24, I contacted New York Approach and got the customary vector to the north. A couple miles later, I received a non-customary "Skylane 31 Sierra, turn right to a heading of 060, vector for spacing to Carmel - eventually. We'll try to get you headed back west in ten miles or so."

The green track shown above (courtesy of the useful folks at FlightAware.com) shows my peripatetic departure. During this tour, I heard a helicopter inbound from the north calling New York Approach:

[345AB]: "New York, Helicopter 345AB. We had a flight plan filed for pickup to get into the Bravo, but Bradley just dumped us."

[Approach]: "Helicopter 345AB, say destination."

[345AB]: "5AB is headed to Newark."

[Approach]: "Helicopter 5AB, yeah, they've got some national security thing down there. We've been advised absolutely no more helicopters into the airspace. Say intentions." (I'm starting to think that "Say intentions" may be one of the most unwelcome phrases in the language.)

[345AB]: "OK, I guess 5AB will land at White Plains."

After that, Approach issued them an appropriate vector and frequency change. And, they finally got N631S headed west, slowly. I was getting ground speeds of 95 to 100 knots which implies a headwind component of about 40 knots. Considering the delays so far, it was becoming clear that I'd get to enter the first time of this season in the Night column of my log.

Plodding along near Carmel (CMK), this exchange got a smile from me:

[804L]: "Approach, Baron 804L, request."

[Approach]: "Zero four Lima, say request."

[804L]: "They've got us way up here by Barrington, way out of our way...any chance of direct BREZY from here?"

[Approach]: (without any hesitation) "No!"

[804L]: "Okaaayyy..."

After entering Allentown's airspace I requested and got a descent from 8,000 to 6,000 feet that got me about 5 more knots of groundspeed. Also, the wind out of the southwest eased a bit (to a mere 30 knots or so) so by the time Baltimore was coming into view the Garmin 530W was telling me I was up to 112 knots or so. And the sun had set.

The first night landing of the season was uneventful. I picked up the airport beacon about 10 miles from the field, reported the field in sight and got, "Skylane 31 Sierra, cleared for the visual approach, proceed directly to VKX, frequency change is approved." I cancelled IFR, made my traffic calls, and entered the right downwind for 24. The runway was right where it was supposed to be, and I had wheels on pavement at 2346Z. 2 hours + 55 minutes airport-to-airport, 3.2 tach hours with all of the thrashing around. It was nice to have that one in the can.

Here's the track for the whole trip:

Send in the Drones?

There can be no doubt that we are being prepared for the day, not very far off, when we will be sharing the skies with Unmanned Aircraft Systems (UAS), also known as drones or remotely piloted vehicles (RPV's). According to a recent Associated Press article, the FAA is coming under heavy political pressure to admit UAS's to the national airspace:

Texas officials, including Gov. Rick Perry, Sens. Kay Bailey Hutchison and John Cornyn, and Rep. Henry Cuellar, have been leaning on the FAA to approve requests to use unmanned aircraft along the Texas-Mexico border. ...

Homeland Security Secretary Janet Napolitano has told lawmakers that safety concerns are behind the delays. Cornyn is blocking a Senate confirmation vote on President Barack Obama's nominee for the No. 2 FAA job, Michael Huerta, to keep the pressure on.

Other lawmakers want an overall plan to speed up use of the planes beyond the border.

There are, to put it mildly, safety concerns. In the same article, the FAA's head of air traffic operations, Hank Krakowski, is quoted as saying:

I think industry and some of the operators are frustrated that we're not moving fast enough, but safety is first. This isn't Afghanistan. This isn't Iraq. This is a part of the world that has a lot of light airplanes flying around, a lot of business jets."

In April 2008 the National Transportation Safety Board held a 2-day Unmanned Aircraft Systems Safety Forum discussing the safety issues surrounding integration of UAS's into the national airspace. The forum was organized in the aftermath of a mishap two years earlier when an RPV operating in civil airspace suffered the loss of both power and communication due to operator mis-management and subsequently crashed. The NTSB Final Report reads like one of those "nothing can go wrong...go wrong...go wrong..." scenarios.

Of course, the FAA is reacting to the pressure. Now comes the May/June 2010 issue of the publication FAA Safety Briefing, offering on page 20 an article titled "Eye in the Sky." The subtitle is "Assuring the Safe Operation of Unmanned Aircraft Systems." The article observes that:

[D]espite the numerous environmental, economic, and safety benefits of UAS, there remains an underlying, and understandable, apprehension of how these “flying robots” will perform alongside manned aircraft, especially during an unexpected event or emergency.

In discussing this apprehension, the article reviews ongoing FAA research regarding the characteristics and behaviors of UAS's, and acknowledges the need to address the "sense-and-avoid" (sic) issue.

Of course, the "sense-and-avoid" issue (which used to be called "see-and-avoid") is the elephant in the room. Here's what an executive of Insitu, Inc. (a Boeing subsidiary in the UAS business) has to say:

While we don’t have a pair of eyeballs on the aircraft, there are several feasible alternatives that need to be tested and evaluated.” Existing test data show current ground-based radar and TCAS systems are able to pick up nearly any vehicle within 12 to 15 miles of a UAS. “By working with the FAA, we’re seeking to obtain the safety ‘street’ credit for these systems, along with rules that permit reasonable access.”

Isn't that nice. We will supplement the UAS's on-board sensor suite with radar data (and, no doubt, ADS-B Out product - another reason to press on with NextGen) so that the robot can "sense-and-avoid" threat platforms. It is unclear how that is going to help the VFR pilot in the Cessna 172 who is squawking 1200 and not talking to ATC to understand that he is potentially in conflict with an aircraft that has only a limited ability to react to his presence. And that doesn't begin to account for the NORDO J-3 Cub or the sailplane or the hot air balloon, any of which may or may not be "sense-able" by the UAS's "sense-and-avoid" systems.

As if "see-and-avoid" were not already sufficiently problematic as a collision avoidance strategy (see, for example, the circumstances surrounding the mid-air over the Hudson in the summer of 2009) we would now shift most of the burden of "seeing-and-avoiding" to the general aviation pilot with the degree of difficulty increased by the typically small size of the UAS.

A few conclusions can be drawn. First, it is apparent that there are political and economic forces in place that are strong enough to ensure that This Will Happen. UAS's are coming to an airspace near you.

Second, it would seem that the only way to accommodate UAS's in the National Airspace System without unacceptable risk is to understand that any airspace in which they operate is de facto Restricted Airspace. As with the Restricted Areas that we're already familiar with, IFR traffic can be separated from UAS operations by ATC; VFR traffic will have to avoid the airspace. Check NOTAM's!

The alternative would be to require UAS's operating in unrestricted airspace to carry Visibility Enhancement Systems to give pilots a fighting chance to see them and avoid them.

• Light 'em up like a Christmas tree!
  
• A colored smoke trail would be nice.
  
• While we're at it, restrict them to 140 knots.
  

Of course, that would eliminate any thought about stealth. The border patrol probably won't like that.

The FAA is planning to publish a Special Federal Aviation Regulation (SFAR) that will govern operation of small (under 55 lb.) UAS's in commercial airspace, by mid-2011 with a final rule
expected in late 2012. That one will bear watching.

Trapped in Security Theater

Operating N631S from Potomac Airfield (KVKX) has proven for over a year to be convenient and trouble free...'til now. I should have known that sooner or later the Security Theater people would find a way to disrupt the lives of we law-abiding denizens of the 'Maryland 3 airports'. Their opportunity arrives in the form of the Nuclear Security Summit.

Presidents, heads-of-state and high factotums will converge on Washington, DC next Monday and Tuesday for discussions aimed at keeping us safe(r) from loose nukes and such threats. It would appear that this has led to the DC Convention Center being considered a Target Rich Environment and so, of course, Something Must Be Done. Actually, several "Somethings" including road closures, Metrorail station closures and NOTAM 0/3400.

The NOTAM establishes a Temporary Flight Restriction (TFR) that provides, among other things:

"D. Effective 1004121200 UTC (0800 local 04/12/10) until 1004140200 UTC (2200 local 04/13/10) all flight operations within the dc FRZ [i.e., the inner red ring, above] are prohibited unless specifically provided below;
...
5. The provisions of FDC NOTAM 9/4399 and 14 CFR part 93, pertaining to the Maryland 3 airports known as Washington executive airport/hyde field (KW32), Potomac airfield (KVKX) [N.B.: That's me!] and college park airport (KCGS), are temporarily suspended. Aircraft operations are not authorized at these airports."

Normally, N631S and I make the trip from KVKX north to KBDR on Monday morning but this week there are personal obligations keeping me in the DC area until Tuesday morning. Thus, the TFR complicates my life considerably. But, there is a work-around:

"C. Effective 1004121200 UTC (0800 local 04/12/10) until 1004140200 UTC (2200 local 04/13/10) daily 1200-0200 utc (0800-2200 local), all flight operations within the DC SFRA are prohibited unless specifically provided below;
...
2. General aviation aircraft on an active IFR flight plan may arrive and/or depart the following airports only: a) Dulles international airport (KIAD) b) Baltimore Washington international airport (BWI) c) Manassas Regional/Davis airport (HEF) (only when tower is operational)"

I've checked...the tower at Manassas (KHEF) opens for business at 0630 local time. So here's my plan: Fly into KVKX Friday evening in the usual way. Arrange for a ride back there on Sunday afternoon and fly over to KHEF. Rent a car and drive home, take care of business on Monday, and head back to Manassas at the crack of dawn on Tuesday to return the rental and fly north. That ought to work, at the cost of two day's auto rental and some lost sleep.

Here's my question: Why can't they convene their Summit in, maybe Sparks, NV? Or Whitefish, MT? Hey, I hear that Ulan Bator is lovely this time of year.