Unmanned Aircraft Systems (UAS): The Next Frontier

No discussion of the evolving national airspace system (NAS) is complete without recognizing the explosive growth in the development of aircraft whose pilots are remotely located. Unmanned aircraft systems (UAS), remotely piloted aircraft systems (RPAS), or the popular but inaccurate term “drone” have all been used to describe these vehicles, many of which are intended to be fully integrated into the NAS, interacting with other aircraft in a manner similar to aircraft today. Autonomously operated aircraft, those for which no human interaction (remote or otherwise) is needed, are a subset of UAS but not currently envisioned for operations in the NAS and are thus beyond the scope of this discussion.

The technology that supports these remotely piloted operations is developing rapidly, and the number of commercial uses envisioned or already being employed is similarly expanding. Regulators, both in the United States and abroad, are struggling to keep pace. The advent of “small UAS,” those operating below 500 feet above the surface, weighing less than 55 pounds, and typically flown within sight of the pilot, has sparked enormous commercial growth, providing considerable social and economic benefit.

ALPA recognizes and supports beneficial application of this technology, but only if assurances are in place that the safety of the NAS is not jeopardized. Technology exists, but is not currently required, that limits both the geographic and vertical range of these aircraft and, when effectively integrated into the aircraft’s controls, significantly reduces the risk by effectively providing a segregated operating environment.

Conversely, large unmanned aircraft, those weighing 55 pounds and up, some of which are the size of small airline aircraft, are intended to operate in the same airspace with aircraft carrying people and cargo in the NAS today. The risk involved in these types of operations is considerably different. Technology must enable the pilots of these aircraft to control them and interact with other airspace users in the same manner as if the pilot were onboard. Among the greatest challenges to achieving this goal is the development of technology to allow pilots to “see and avoid” other aircraft, including an active collision-avoidance capability, and the technology to ensure continuous communication link between pilot and aircraft. This is a daunting challenge, and one to which ALPA and other stakeholders have dedicated considerable resources. Equally important is development of a regulatory structure that ensures safe operation at the same level of robust standards for design, pilot training, operator certification, and operation as is the foundation of the incredible safety record in aviation today. 

Flight Plan

All rules developed to ensure the safe operation of UAS must be consistent with and compatible with those for other airspace users. No UAS should be allowed unrestricted access to conduct flight operations into the NAS unless it meets all of the high standards currently required for every other airspace user. UAS must be designed with similar safeguards and functional requirements as current certificated commercial and general aviation aircraft.

Pilots of UAS flown “for compensation or hire” in airspace mixed with commercial aircraft must hold a commercial pilot certificate to ensure they possess the appropriate skill and experience to ensure the safety of the NAS. The operator of those commercial aircraft should be subject to the same operational approval and oversight as commercial airlines. Any person in direct control of a UAS must be limited to control of a single aircraft.

UAS intended to be operated in airspace shared with airline aircraft or that could inadvertently stray into that airspace must be required to have active collision-avoidance functionality and must have technology that allows them to be clearly shown on pilots’ and controllers’ displays. UAS not intended to operate in this airspace must have altitude-limiting and geographic-avoidance features included as an incorruptible feature of their software.

The problem of a lost communications link between a UAS pilot and the errant UAS must be addressed in a way that ensures that a UAS can land safely without endangering aircraft or persons on the ground. Above all, UAS operation in the NAS must not introduce any hazard that would negatively impact the unparalleled safety record of U.S. aviation. We must not allow pressure to rapidly integrate UAS into the NAS to rush a process that must be solely focused on safety.

On August 27, 2015 ALPA submitted comments to Transport Canada in response to their NPA on Unmanned Ariel Vehicles.
On April 24, 2015 ALPA submitted comments to the FAA in response to their NPRM for small Unmanned Aircraft Systems (sUAS) operations.