BVLOS ARC Report live webinar

[Vic Moss]

Are you a US 107 Pilot? Or are you getting your 107?

The FAA recently released the 381 page BVLOS ARC report. BLVOS ARC stands for Beyond Visual Line of Sight Aviation Rulemaking Committee.

This report is full of great info and suggestion for the FAA when it comes to BVLOS flight in the US. However, as I mentioned, it's also 381 pages long.

To that end, we've scheduled a live webinar for Friday, March 18th, at 6:00PM ET. Kenji Sugahara, CEO/Pres of DSPA and Greg Reverdiau from @pilotinstitute will talk about the process, contents, and what happens next. We'll also have a live Q&A.

Kenji was on the BVLOS ARC, so he'll have some great insight, and Greg has spent the last few days slowly reading and digesting the report. They'll have some great content.

Greg will be hosting it on his YT channel, go here and set the reminder.

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[BigAl07]

Thanks Vic. I'm going to "copy" this on all of our forums right now

 

[Smooth Rhythm]

Thanks for sharing, Vic

 

[Vic Moss]

For those who couldn't make it, we recorded it. It'll be on the PI channel soon. I'll post a link.

 

[Deleted member 93449]

I'm in the process of reading the report and some troubling and conflicting statements are made in the first section regarding Acceptable Levels of Risk (ALR).

On page 17 the report acknowledges that "A UA accident in an in populated area is assumed to provided minimal risk to persons or structures on the ground." That said on page 25 the report states "Matching UA rates (i.e. Acceptable Level of Risk) with GA fatality rates currently experienced in the NAS provides a common risk benchmark accepted by both the aviation community and the public." It goes on to say "The ground risk ALR should similarly be base primarily upon the currently accepted general aviation risk rate to 3rd party, none participating people on the ground."

You have to be kidding me!!!

 

[Vic Moss]

I'm in the process of reading the report and some troubling and conflicting statements are made in the first section regarding Acceptable Levels of Risk (ALR).

On page 17 the report acknowledges that "A UA accident in an in populated area is assumed to provided minimal risk to persons or structures on the ground." That said on page 25 the report states "Matching UA rates (i.e. Acceptable Level of Risk) with GA fatality rates currently experienced in the NAS provides a common risk benchmark accepted by both the aviation community and the public." It goes on to say "The ground risk ALR should similarly be base primarily upon the currently accepted general aviation risk rate to 3rd party, none participating people on the ground."

You have to be kidding me!!!

Ground risk is pretty minimal. Kenji and Greg explain this a bit in the video. I'll post a link once it's up.

 

[Deleted member 93449]

Ground risk is pretty minimal. Kenji and Greg explain this a bit in the video. I'll post a link once it's up.

I'll listen but if ground risk is minimal why in the world would they equate the risk as being equivalent to the risk of GA aircraft? How is the risk of flying a one pound drone going 30 mph with a 1' x 1' cross section equivalent to a 2,000 pound manned aircraft going 80 mph with a 30' x 30' cross section? It makes no sense.

 

[Deleted member 93449]

I listen to Kanji try to rationalize using the GA risk in the UA risk assessment and I think he had a hard time doing it with a straight face. They estimate UA risk at 1 fatality in every 1,000,000 flight hours (mentioning 1 fatality when an RC helicopter went out of control) while GA is 1 fatality in every 100,000 flight hours. That's 10x greater risk in GA against a guesstimate for UA operations. The foundation for the rule making (risk assessment) is woefully flawed so how can there be confidence in the rules that come out based on this assessment?

 

[Vic Moss]

I'll listen but if ground risk is minimal why in the world would they equate the risk as being equivalent to the risk of GA aircraft? How is the risk of flying a one pound drone going 30 mph with a 1' x 1' cross section equivalent to a 2,000 pound manned aircraft going 80 mph with a 30' x 30' cross section? It makes no sense.

They're not equating it.

There is no standard to base this on, so if you have a better idea, I'm sure they'd love to hear it.

 

[DoomMeister]

They were picking a point to start as an acceptable risk level and chose GA aircraft for the report. It was pointed out that the GA risk is currently 10X greater than what is currently estimated as the high end for drones. The estimated data puts drones at 1/10th of that or 1 serious injury in > 10,000,000 flight hours (and no deaths).

That gives a lot of leeway to set a tighter standard when rules are actually proposed. So not a bad thing, as you try to make out.

 

[Deleted member 93449]

They're not equating it.

There is no standard to base this on, so if you have a better idea, I'm sure they'd love to hear it.

They are saying the risk of fatalities in GA is 1 fatality per 100,000 flight hours AND that that level of risk is view as publicly acceptable. They go on to say that a similar fatality rate for drones would also be a publicly acceptable level of risk. If the current estimate of drone fatalities is 1 per 1,000,000 flight hours (much lower than what is considered an acceptable level of rusk) what is the need for further regulations?

 

[Deleted member 93449]

They were picking a point to start as an acceptable risk level and chose GA aircraft for the report. It was pointed out that the GA risk is currently 10X greater than what is currently estimated as the high end for drones. The estimated data puts drones at 1/10th of that or 1 serious injury in > 10,000,000 flight hours (and no deaths).

That gives a lot of leeway to set a tighter standard when rules are actually proposed. So not a bad thing, as you try to make out.

I understand the starting point. My question is if the acceptable level of risk is 1 fatality per 100,000 flight hours and UA operations are 10x lower (1/10 the acceptable level of risk) why the need for additional regulations? And if you are going to regulate why is their no recognition that risk will vary depending on when, where and what you are flying?

 

[DoomMeister]

I understand the starting point. My question is if the acceptable level of risk is 1 fatality per 100,000 flight hours and UA operations are 10x lower (1/10 the acceptable level of risk) why the need for additional regulations? And if you are going to regulate why is their no recognition that risk will vary depending on when, where and what you are flying?

The regulations presently do not allow BVLOS without a waiver. The new regs need to be written so BVLOS can be performed without having to apply for a waiver.

I can pretty much guarantee that the FAA nor the public will accept the ALR of GA for drones, but using it as a starting point allows wiggle room. Hopefully there will never be a fatality from drones, but that is not likely.

If you listen to the discussion all the way through Kenji does address different types of drones, drone flights, and population density were factored into the recommendations. More so for the Part 108 BVLOS regulations that will be much longer and diverse.

Also toward the end there was discussion of keeping EVLOS as Part 107 or adding it to Recreational also. I don’t recall Kenji’s exact words, but he stated that the risk factors are the same so no reason to restrict it to Part 107 and leave recreational unable to. Me thinks you had a friend on the ARC so you might want to cut him some slack.

 

[lookout]

Like the fly over people. Yes the jinsu knives might hurt if they are still spinning when the craft falls. The weight of the craft does become a factor the further it drops although terminal velocity may hit quickly or possibly not at all. If the craft is in good working order with sufficient battery this really should only be a remote possibility that still freaks out the people below who don't know where it is going to go or what it is doing. It is only a problem for people below when and if something does go wrong. While in general it isn't a good idea to be holding something over someone's head, staying away is a measure of safety.

 

[Deleted member 93449]

Why use the GA rate as the starting point when admittedly the risk is 10x or more lower than GA? Over the last years the public has been sold on the idea that UA’s are a tremendous danger when the facts say otherwise. So now the FAA is proposing regulations to address a problem that doesn’t exist.

I don’t know Kenji, his motivations or what pressures he is under to go along with these recommendations. It doesn’t matter if his attitude is friendly and the results are the same.

The public has been primed to accept no risk when it comes to drone operations. The media has sensationalized every incident. I don’t think the general public has been sold on the commercial use of drones for anything other than emergency services. Let one person get killed because a UPS drone fails (no offense UPS) and it won’t matter if the rate is 1 per 1,000,000 or 1 per 10,000,000 the hammer will fall as that death being an unacceptable risk as a result of a less than critical operation.

While they may have discussed the issue of size, performance and areas of operation if the proposals regarding remote ID are any indication those issues won’t be a guiding force in how the regulations are structured. I don’t see them formulating rules that allow for BVLOS in remote, low population areas that are less stringent then the rules for operations in higher density populations or giving allowances for the size/weight of drones.

In my opinion the regulations should be simple. In an area with a population density of X no operations BVLOS. Below that population density BVLOS is allowed. If you want to go a step further limit the weight of drones that can conduct operations BVLOS. If a 1 pound drone in a remote area happens to have that 1 in 10,000,000 freak contact with someone and kills an individual hold the PIC responsible.

Now I can already hear someone saying “if that person was one of your kids you wouldn’t have such a cavalier attitude”. My attitude isn’t cavalier but a recognition that life and freedom come with risk. The government’s attempt to regulate out all risk is a foolish and dangerous game.

 

[DoomMeister]

Like the fly over people. Yes the jinsu knives might hurt if they are still spinning when the craft falls. The weight of the craft does become a factor the further it drops although terminal velocity may hit quickly or possibly not at all. If the craft is in good working order with sufficient battery this really should only be a remote possibility that still freaks out the people below who don't know where it is going to go or what it is doing. It is only a problem for people below when and if something does go wrong. While in general it isn't a good idea to be holding something over someone's head, staying away is a measure of safety.

While OOP is part of the equation this thread is centered on the ARC recommendations to implement BVLOS operations. There would have to be Category 2 and Category 3 UA’s on the market before a lot useful work can even happen with BVLOS flights and that is being held up due to RID not being completely finalized (litigation is still in progress).

 

[BigAl07]

So @2edgesword would you rather have the regulations stay the way they are NOW (as in very rare and only Waivered BVLOS) or maybe, possibly, hopefully some type of improvement on them allowing SOME degree of legal BLVOS? Without the ARC report and some consideration for change
by the FAA we would have NO improvements or chances of BVLOS in some situations.

Your arguments are ridiculous because everything about this thread and it's true topic (the ARC report to the FAA) have the potential to make more allowances in the existing regulation framework. Isn't that what you're seeking?

 

[Deleted member 93449]

So @2edgesword would you rather have the regulations stay the way they are NOW (as in very rare and only Waivered BVLOS) or maybe, possibly, hopefully some type of improvement on them allowing SOME degree of legal BLVOS? Without the ARC report and some consideration for change
by the FAA we would have NO improvements or chances of BVLOS in some situations.

Your arguments are ridiculous because everything about this thread and it's true topic (the ARC report to the FAA) have the potential to make more allowances in the existing regulation framework. Isn't that what you're seeking?

I would like the regulations changed so the real issue of risk can be addressed in a logical fashion.

Where is the highest level of risk? In densely populated areas. If that's the case require waivers for flying BVLOS in those areas. In sparely populated areas no limitations other than the drone has remain in a sparely populated area. ln both instances you need to be able to view the area in which the drone is located, not to see the drone but to see aircraft entering that area.

If an aircraft happens to enter the general area in which the drone is located point the drone camera down so you can see what is below you and descend to an altitude where there is minimal risk that a conflict will occur. This would require having signal strength to control the drone at that distance and have visual feedback from the drone.

 

[footfly]

Why use the GA rate as the starting point when admittedly the risk is 10x or more lower than GA? Over the last years the public has been sold on the idea that UA’s are a tremendous danger when the facts say otherwise. So now the FAA is proposing regulations to address a problem that doesn’t exist.

I don’t know Kenji, his motivations or what pressures he is under to go along with these recommendations. It doesn’t matter if his attitude is friendly and the results are the same.

The public has been primed to accept no risk when it comes to drone operations. The media has sensationalized every incident. I don’t think the general public has been sold on the commercial use of drones for anything other than emergency services. Let one person get killed because a UPS drone fails (no offense UPS) and it won’t matter if the rate is 1 per 1,000,000 or 1 per 10,000,000 the hammer will fall as that death being an unacceptable risk as a result of a less than critical operation.

While they may have discussed the issue of size, performance and areas of operation if the proposals regarding remote ID are any indication those issues won’t be a guiding force in how the regulations are structured. I don’t see them formulating rules that allow for BVLOS in remote, low population areas that are less stringent then the rules for operations in higher density populations or giving allowances for the size/weight of drones.

In my opinion the regulations should be simple. In an area with a population density of X no operations BVLOS. Below that population density BVLOS is allowed. If you want to go a step further limit the weight of drones that can conduct operations BVLOS. If a 1 pound drone in a remote area happens to have that 1 in 10,000,000 freak contact with someone and kills an individual hold the PIC responsible.

Now I can already hear someone saying “if that person was one of your kids you wouldn’t have such a cavalier attitude”. My attitude isn’t cavalier but a recognition that life and freedom come with risk. The government’s attempt to regulate out all risk is a foolish and dangerous game.

Roger,

I am starting to think all this regulation is for industry standard ...... especially because fatality rate is so small and a drone currently does not carry passenger or a large number of people. FAA is comprised of experts in the field but also people with certain skills and occupation subset, i.e. air controllers, pilots, safety experts, probably a representatives for flight attendants as well.

What is industry standard? To generate a restriction to allow people to populate a certain occupation. If everyone can go BVLOS, there would be no need for a waiver and no need for a 107 and someone would be able to make money in a small niche.
If everyone can fix cars, there would be no need for mechanics and their salaries (I can tell you I don't fix cars very well, so I am glad there are mechanics).

 

[dronerdave]

If an aircraft happens to enter the general area in which the drone is located point the drone camera down so you can see what is below you and descend to an altitude where there is minimal risk that a conflict will occur. This would require having signal strength to control the drone at that distance and have visual feedback from the drone.

Good luck with that. "Having signal strength to control the drone"? Its one reason they are controlling BVLOS unless you could prove distance/signal wouldn't be an issue. It would also probably require your drone itself to detect all incoming aircraft and RID to confirm you actually comply to avoiding incoming aircraft which neither exist at this time at hobby (edit equipment) level.