The integration of Unmanned Aircraft Systems (UAS), or “drones,” into our nation’s airspace has received much attention in recent months. Striking the right balance between the absolute necessity of maintaining existing safety levels in the National Airspace System (NAS), the potential value of UAS to the economy, and the need for regulations that encompass the spectrum of UAS operations, is a monumental challenge. The widespread commercial application of drones must not be permitted until the U.S. government establishes clear and enforceable operating standards that will ensure safe integration into the NAS.
The much-publicized use of drones in combat operations has created what many believe will be a large market for the use of UAS by commercial enterprises. As the number and variety of UAS increase, along with their potential for use in business, so does pressure to allow their unrestricted access to and operation in the NAS. However, the introduction of such “unmanned” or “remotely piloted” aircraft into an integrated NAS represents an entirely new concept that could profoundly degrade the safety of commercial and general aviation flight operations if this integration is not accomplished in a responsible, safety focused, and comprehensive manner. Simply because Amazon’s CEO is in a hurry to fill our skies with the company’s “Prime Air vehicles” is not a good reason to hastily open the floodgates to commercial drone use in our NAS.
When the last Federal Aviation Administration (FAA) Reauthorization Act was passed into law in 2012, it included a section requiring the FAA to develop a comprehensive plan for integration of UAS into the NAS by December 31, 2014, and to finalize that plan by September 2015. On February 15, 2015 – two and a half years after the law was passed – the FAA released a long-awaited proposed rule regulating the introduction of small UAS into the NAS for commercial use. This proposal seeks to address many of the safety and security concerns that we have, but still leaves some questions unanswered. The rule also must go through an extensive public notice and comment period that will surely draw calls from special interests for the rapid expansion of the use of UAS for commercial purposes. Transportation labor will participate fully in the rulemaking process to ensure that the final rule requires that drone operations meet all of the standards imposed on all those who currently use the NAS. This means UAS must be designed with similar performance and functional requirements as required by currently certified commercial and general aviation airspace users depending on mission.
The delayed timetable for this rulemaking has already resulted in mounting pressure by the UAS industry to gain access to the NAS for commercial applications. Hundreds of petitions for exemption under the law have been received by the FAA to perform operations in areas like film making, environmental surveying, infrastructure inspection, 3-dimensional map making, and agriculture applications. Until the FAA promulgates a comprehensive final rule, however, no unmanned or remotely piloted aircraft, whether for public, commercial, or hobby use, should be allowed unrestricted access to conduct flight operations into the NAS.
To ensure the safety of passengers and crewmembers, current aircraft operators using the NAS need to be able to see and avoid UAS operating in the same area. The same is true for air traffic controllers who are responsible for safely separating air traffic within the NAS. Additionally, those approved to operate UAS for commercial purposes in the NAS must meet all the certification and fitness standards required of air carriers, and the pilots flying drones must meet an equivalent level of training, qualification, and licensing requirements applicable to aircraft pilots operating in the same airspace flying the same mission. Those who might object to the FAA’s imposition of these requirements should be forced to explain to the public why our already complicated and highly congested airspace should be occupied by unqualified and unsafe drone operators.
While the potential commercial opportunities for UAS are broad, it is vital that the FAA’s rulemaking be carefully considered and be primarily geared toward ensuring the safety of the millions of passengers and crew who fly in the NAS every day. Though special interest groups have put pressure on the FAA to rapidly introduce UAS to the airspace, the agency must be sure to avoid hastily or carelessly promulgating a rulemaking. Standards and technologies for UAS must be in place to ensure that we maintain the current high level of safety in the NAS before drones are authorized to occupy the same airspace as airlines or to operate in areas where UAS might inadvertently stray into airspace used by commercial flights. Additionally, if drones are not intended to operate in airspace occupied by manned aircraft, then UAS must be equipped with altitude-limiting and geographic-avoidance features. This technology is available and is even being voluntarily adopted by some UAS manufacturers. While many UAS have preprogrammed instructions upon which they rely on in the event that they lose connection with their operator, an unmanned aircraft that is not being directly controlled would be a serious safety concern if this occurred near airspace occupied by other conventionally piloted aircraft. Any FAA rulemaking must adequately address this and other potential safety concerns.
Transportation labor cannot endorse the commercial application of drones until the necessary FAA safety standards are in place ensuring one level of safety for any type of aircraft or operator that seek permission to fly in America’s airspace. If properly regulated with strong safety standards in effect, the safe integration of commercial drones is possible.
Policy Statement No. W15-02
Adopted February 22, 2015
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