“US automated waiver procedures likely within two years for rural BVLOS” – Executive Director, ASSURE  

Unmanned Airspace talks to Stephen P Luxion Col (ret) Executive Director of the Alliance for System Safety of UAS through Research Excellence (ASSURE) about US activities to bring drones closer into routine operations

Commercial operators want to operate beyond visual line of sight (BVLOS), but this is hindered by the lack of standards and regulations. When will these be available?

BVLOS is critical to commercial operations and we want to enable that.  However, it’s a bit of a chicken and egg process. We need data from operations to establish performance standards and regulations, but operations are currently restricted because there are no regulations in place to allow them. The good news is we are currently conducting flight tests and researchers are working with industry standards groups, the Federal Aviation Administration (FAA), and industry itself, to build the performance standards and the methods for industry to certify that they can meet those standards. This has been a challenge, it’s a difficult problem. But we should complete testing and provide results by the year end.

Will this be similar to the Low Altitude Authorization and Notification Capability (LAANC)?

Yes – an automated system, or list of what your UAS needs to do to fly BVLOS. This might include detect & avoid, manoeuvre this way, react in this way in an emergency, the specifics of which can be adjusted by industry standards boards. Based on current research, BVLOS operations will likely be routine within the next two years in rural sectors such as agriculture.

The goal is to not to just lay out a standard, but to establish the complete methodology for certification. Initially, this will be for waivers but will be broadly available for everyone.

The situation is very different in urban environments. This could take as long as 15 years, although additional resources might accelerate this process. I would say we’re not going to see general urban deliveries inside cities this decade. This environment presents challenges such as micro-weather patterns inside a city and between tall buildings; the need to deconflict with other UAS and fixed infrastructure; and signal interference in communications channels, just to name a few.

What will be the next steps?

More money and more research is needed. ASSURE is working with Congress and with the universities to secure more support from the states.  Additionally, we are increasing our international reach, collaboration and coordination to share research tasks and costs. This should speed the safe expansion and integration of unmanned aircraft into airspace systems. I would like to see resources directed at specific problems, such as how to certify autonomous systems, use of Artificial Intelligence (AI), cyber protocol, cyber security levels, communications, and operations around airfields.

There are areas we have not even tackled yet, like communication protocols, the level of security, certification of autonomous systems for different missions and operations. These topics will be featured in the next batch of research projects, which are coming down the line in 1-2 years’ time. We will start to look at how you fly in and around airports, move around the taxiways, approaches and departures.

The commercial sector has been acting very responsibly and this is paying off. Industry is working with the research institutes and regulators. Over time, we will collect more data and be able to validate this material for the FAA. But until we have that data, the FAA will continue to adopt a very cautious approach.

What we really need is a strong push from the commercial sector on all aspects, including the political element, investment and more vocal campaigns. This helps us to understand industry’s priorities and align those with the regulators and researchers. If not, the whole process will not move forward as quickly and efficiently as possible.

How does ASSURE contribute to standards development?

ASSURE is a group of 23 research universities and their industry partners in the US, including some in the UK, Canada and Israel, working on the requirements needed to enable drones to operate safely in the US national airspace. The 15 core universities on the ASSURE board receive Federal Aviation Administration (FAA) research grants which they then distribute to other partners through research projects. ASSURE works closely with the FAA to define and build the requirements which come from different departments within the agency. For example, there is an office responsible for all the FAA centres of excellence which is run out of the FAA Technical Center in Atlantic City; the Programme Management Office responsible for the development of NextGen technology; and the UAS Integration Office whose job is to integrate all the different lines of business within the FAA and build the requirements.

ASSURE projects are peer reviewed by the National Aeronautical Space Agency (NASA), the Department of Defense, and different parts of the FAA.

Each project may take a year or even two years to complete, and possibly extend beyond that depending on the project. The FAA receives updates to rule-making throughout the process which means there is constant interchange between the researchers and the programme sponsors to ensure everything is flowing correctly.

This is the standard, long-term method by which research infuses into the FAA rule-making process. In the short-term, ASSURE contributes in other ways: For example, many researchers participate in industry standards committees and boards, and contribute to the FAA waiver process. ASSURE is also becoming more and more involved in the international arena by sharing research with other schools and industry partners. We want to align our data and methodology and avoid duplication of work. ASSURE sits in the middle of this process by reaching out to many different institutions.

We have a great working relationship with Transport Canada which participates in several of our projects. Our other overseas partners also contribute to FAA programmes and a university in Singapore and the government of South Korea has approached us to establish links. The FAA has asked ASSURE to be more involved in international research.

Industry standards are extremely important to FAA’s rule making.  While the FAA builds a bare-bone regulatory structure, industry standards add the muscle and flesh out details that lead to the establishment of minimum safety requirements.

For example, the industry is trying to establish research testing methods and parachute protocols for drone operations over people. ASSURE recently completed a Ground Collision Severity Evaluation report which validates methodology used to assess injury potential of various small UAS.

The research flight tested fixed wing and multirotor small UAS to determine their failure modes and built models using 16-different multi-rotor and fixed-wing SUAS and objects (payloads, wood blocks and batteries) with weights ranging from 0.75 – 13.2 lbs. It used automotive injury criteria to measure injury potential during impact tests, and found the previous methodology the FAA was using was largely not applicable to small UAS, calling for development of more accurate injury-risk criteria.

How far away is the US from establishing a regulatory framework that will enable UAS to operate in controlled airspace, over people, without manual waivers?

Some elements are figured out and moving into standard practice, for example we are now establishing processes for waiver which are standardised. In the next two years I expect we will have an automated system, or framework, that will make it much easier to go and get a waiver. Currently, we have a process in place but it’s not necessarily repeatable. Applications can lead to different responses and there are many ‘one-offs’. An example is UPS’ waiver covering a specific concept of operations, specific platform, specific quality of pilot training and specific operation where UPS has carved out a niche area. Now we can capture data from that operation to see how things work beginning in more rural, safer environments. In contrast, urban operations present much more of a challenge.

Right now the FAA is establishing data structures and flight testing aimed at developing a framework for everyone. So you lay out your concept of operations and figure out your risks and mitigations in order to get a waiver. The aim is to capture all that data in a framework based on what we know, even if some aspects still have to be resolved. This would make it a lot quicker for an applicant to obtain a waiver, and the FAA would not have to constantly re-certify things.

We are in the early phases of this. Probably by mid-2020 we will have laid out a model and be able to demonstrate how this can work. There are policy issues to address; for example, what information should be aggregated and protected and what can be shared.  There are practical issues as well, we don’t want a testing protocol where it takes three days to fill out all the paperwork for a 20-minute flight test. So we are trying to strike a balance on the data that is collected and different methodologies to ensure proprietary data is protected.

We are about mid-way through this process.

We are now starting to move into more operational aspects such as what data do we need, and what should the framework of the safety case look like?

What are the challenges in this process?

There are three main areas that still require a considerable amount of work. The first is centred around building a regulatory framework for detect & avoid. There has to be a mechanism to ensure safe separation between unmanned and manned aircraft.

Secondly, communication links are critical for safe operations; so what should the command and control capability look like? How secure is the communications link, and is it vulnerable to interception? This includes developing the proper balance between cybersecurity and the means to re-establish a communications link if it is lost. How is this information communicated to air traffic control? There is a lot of work to be done here.

Thirdly, there is the airworthiness of the aircraft itself.  If you fly beyond visual line of sight (BVLOS) this may involve operations over people and property, in which case the UAS needs the ability to stay airborne and in an emergency still be able to be controlled. It comes down the quality of the aircraft.

These elements are key to enabling UAS BLVOS and operations over people. To do this, you need to convince the regulators that you can do so safely. In the long run, it is not feasible for BLVOS operators to follow UAVs around everywhere.  A much more robust framework ensures all aspects of UAS operations and recovery mechanisms.

Finally, the ability to manage multiple aircraft will become more important as the industry expands. We need operational concepts that are relevant to vehicles flying in complex situations. We need to determine the key variables that determine the number of unmanned aircraft a single pilot can safely fly. In the event of an emergency, how does this effect that number and how do you safely deal with the emergency aircraft? The response needs to be predictable and appropriate.

Stephen P Luxion Col (ret) ‘Lux’ became Executive Director of the Alliance for System Safety of UAS through Research Excellence (ASSURE) in 2018, following a distinguished US Air Force career and several years’ as Associate Director for Operations. Lux leads ASSURE’s activity in support of Federal Aviation Administration (FAA) work to safely integrate unmanned aircraft systems into the national airspace.

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