NAAA Safety Concerns

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Unmanned Aircraft and Ag
Aviation: A Cautious
Coexistence
Scott Schertz
Schertz Aerial Services
Hudson, Illinois
Contents
• The Importance of Ag
Aviation
• What is a UAV?
• Implications of FAA
Reauthorization
• UAV Market Studies
• NAAA’s Safety Concerns and
Recommendations
• Responsibility and Liability
• Pirker Case and Recent
Developments
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The Importance of Ag
1,350 aerial applications
Aviation
businesses in the US
20 percent of all applied
crop protection products
on commercial farms
71 million acres of crop
land each year
Allows rapid treatment of
large, remote areas and
hard to reach areas
Conducive to higher crop
yields
UAVs in the News
Drones Find Fans Among Farmers, Filmmakers
- The Wall Street Journal 3/10/14
AgEagle Soaring Toward UAS Success
- Precision Ag 2/10/14
Commercial Agriculture Might Be
Largest Beneficiary of UAVs
- Springfield News-Leader 3/22/14
UAV or Model Aircraft?
• The line between a UAV and a model aircraft was
murky until recently
– Model aircraft standards suggested by AC 91-57 Model
Aircraft Operating Standards
• The 2012 FAA reauthorization, the FAA
Modernization and Reform Act (P.L.112-95), codified
the definition of a model aircraft as one “strictly flown
for hobby or recreational purposes.” The Act defines
UAVs as commercial.
FAA Reauthorization and
Its Implications on UAVs
• UAVs first mentioned in 2004 FAA
Reauthorization (P.L. 108-176)
• Extensive provisions provided in the 2012
reauthorization
– Mandate for full integration by Sept. 30, 2015
– Propagation of special rules for UAVs under
55lbs (Now expected November 2014).
– Selection of six test sites by late 2013
– Creation of UAS Roadmap
Current FAA Policy
• In Feb. 2007 the FAA issued a notice of policy in
the Federal Register declaring that “no person
may operate a UAV in the National Airspace
System without specific authority.”
• Established two methods of legal operation
– Certificate of Waiver or Authorization (COA)
– Special Airworthiness Certificate, Experimental
Category (SAC-EC)
• FAA recently issued first restricted category type
certificate allowing the first commercial use of
UAVs
Aerial Application and
UAVs
• Booz Allen Study
– Predicts UAV annual savings of $159 million for
aerial application by 2035 and $186 million in
crop input savings.
• AUVSI Study
– $13.6 billion economic impact within the first three
years of integration, $82.1 billion between 2015
and 2025
• Several fallacies in the data used
Issues With Study
Estimates/Effectivess of UAVs
•
Extrapolated from the use of UAVs in
Japan
– 90 percent of crop protection in Japan is
performed by UAVs (4 gallon RMAX
helicopter)
– Only 28 percent of Japanese farmers
farm full-time
– Average farm size in Japan is 1.5
hectares (3.7 acres), compared to 441
acres in the US.
•
•
•
AUVSI and Booz Allen studies are
based on experimental technologies
Both studies also assume full integration
by 2015
The amount of air pushed down is
exactly proportional to the weight of the
aircraft that the air is holding up. A 40
pound helicopter does not displace
much air.
The UAV Safety Hazard
• Since 2003
– 9.5 percent of aerial
application accidents
were the result of
collisions with towers
– 12.2 percent were the
result of collisions with
wires
Fatal Air Tractor collision with a meteorological evaluation
tower (MET). August 2013.
NAAA Safety Concerns
• UAV inability to “Sense and Avoid”
– GAO: No adequate technology currently exists
that would allow UAVs to sense and avoid other
traffic
• Security Concerns
– UAV “spoofing” or hacking
• “Lost Link” concerns
– Many aircraft have no lost link procedure and
continue flying until they hit a obstacle or run out
of fuel
NAAA Safety Concerns
• Low-Level UAVs
– Similar to birds except
birds try to avoid
collisions, they are very
motivated and usually
they take sufficient
evasive action to avoid
their peril
– Birds are the second
leading cause of aviation
fatalities
NAAA Safety
Recommendations
• NAAA is urging the FAA and Congress that
UAVs be required to have:
– ADS-B Out transponders
– Strobe lights
– Marking similar to that required for other lowlevel obstacles (aviation orange and white paint)
– A minimum operating altitude of 1000 ft. above
ground level for UAVs
NAAA Safety
Recommendations (continued)
• A comprehensive database of UAV operations
• Issuances of NOTAMs when UAVs are operating
– FAA airworthiness certification for UAV
• Pilot training:
– Commercial pilots license
– Class 2 Medical
– Commercial Pesticide License if treating crops
Recent Developments
• Dec. 2013 - Announcement of UAV test
sites
– Alaska, Nevada, New York, North Dakota,
Texas, Virginia
• March 2014 Pirker v. Huerta
Responsibility and
Liability
• A Financial Times Article reported on this issue on March
7th
• According to the FAA UAS Integration Office liability in
the event of a mid-air with a UAV puts the responsibility
on the UAV operator to be responsible for collision
avoidance
• Regulatory uncertainty, certainty of Court involvement
and near certain unmanned liability in the event of an
accident puts UAV operations at great risk presently.
Pirker v. Huerta
• Raphael Pirker, a Swiss
operator was fined
$10,000 by the FAA
“reckless” operation.
• FAA maintains right to
regulate under airspace
regulation mandate
• Currently on appeal to
the full NTSB
Conclusion
• NAAA urges the FAA to take its time integrating UAVs into the
national airspace and urges the agency to follow a comprehensive,
well thought out safety-oriented approach using the association’s
recommendations.
• UAVs will not be used for spraying anytime soon, but have crop
sensing and other non-application capabilities. Manned aircraft,
such as ag aircraft are able to conduct crop sensing services too.
• Considerable liability risk for UAV operators and providers.
Questions?
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