Safe Integration of Unmanned Aircraft Systems

Unmanned aircraft systems (UAS), aka remotely piloted aircraft (RPA), or the popular term “drones” are flown autonomously and/or without a pilot on board the aircraft. UAS will eventually be integrated into the national airspace system (NAS), interacting with other aircraft in a manner similar to “pilot on board” aircraft today. This integration must not introduce any risk that could negatively impact the airline industry safety record.

The technology that supports these autonomous or 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. But they must not allow pressure to rapidly integrate UAS into the NAS to rush a process that must be solely focused on safety. Safety and technology standards must be in place before a UAS can occupy the same airspace as manned aircraft or operate in areas where it might inadvertently stray into airspace occupied by airliners. If UAS share our airspace, airline pilots need to be able to see them on cockpit displays, and air traffic controllers need to see them on their displays to safely separate air traffic. Further, the UAS must be equipped with active collision-avoidance technology.

If the UAS is not intended to be operated in the same airspace as airliners, then those restrictions must be programmed into the UAS in a way that cannot be overridden. Licensed pilots with experience operating in the NAS have a better understanding of and ability to plan ahead for contingencies involving weather, system malfunctions, and operations around other aircraft or near critical infrastructures such as airports. They understand the role and mission of ATC and know where to go for help should an unforeseen circumstance arise.

The FAA has already produced rules to integrate small UAS (under 55 pounds) into our airspace system. These vehicles must operate below 500 feet above the surface, be flown within sight of the pilot, cannot be flown at night, and cannot be flown within five miles of an airport. This is a functional rule; however, Congress has forbidden it to be applied to “hobbyists.” Section 336 of P.L. 112-95, the FAA Modernization and Reform Act of 2012, specifically exempts hobby and recreational use of drones.

FAA has slated rulemaking to govern large (over 55 pounds) UAS and, in the distant future, potential rules governing autonomously operated aircraft. For all of these rulemakings, it is essential that the FAA hold these new entrants to the same standards as existing commercial aircraft operations, both technical and operational.


  • Congress must eliminate the hobbyist exemption, Section 336 of P.L. 112-95, the FAA Reauthorization Act of 2012.
  • Any operator of small or large UAS used in commercial service should be subject to the same operation approval and oversight as a commercial airline.
  • If a UAS has the capability to or is intended to operate in the airspace shared by air carrier aircraft, then it must be designed to the same standards as air carrier aircraft and it must be equipped with the same “safety enhancing equipment” as air carrier aircraft, including an active collision-avoidance system, and must have the technology to allow it to be clearly shown on pilot and controller displays.
  • Altitude-limiting and geographic-avoidance features must be included if the aircraft is not intended to operate in airspace occupied by “pilot on board” aircraft.
  • Lost link must be addressed in the rulemaking procedures to ensure UAS are capable of safely landing without endangering other aircraft or persons on the ground though features such as “land immediately” or “return to home.”
  • Any person(s) in direct control of a UAS must be limited to the control of a single aircraft.

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.