I read the complete Embry-Riddle Report & have some observations & comments:
1. This report was done in the Daytona Beach area - a high density population and a high density of air traffic (10 "aerodromes") including international commercial jets, private aviation, helicopter, sea plane and off shore "banner flying" traffic. For the commercial & private pilots this is considered a high workload area. The approach rules for each airport, communication with controllers, the tower, weather, local traffic awareness AND flying their airplane can make going in & out of the area quite stressful.
2. They used data recording software (DJI's AeroScope software) that examined all Mavic products flying for the period of 13 days. They can record your type of drone & its flight data (drone serial number, date, time, duration, location, altitude, etc) quite accurately, as well as how many flights were made that day.
3. FYI, Embry-Riddle Aeronautical University (ERAU) is immediately adjacent to the Daytona Beach international Airport to the North East. It is a large, multi building campus (approx 0.5 X 0.5 miles sq.). They have nearly 400 flights daily for their students. Their web site describes their fleet as: " ... the university’s fleet of 42 Cessna Skyhawks, 10 Diamond DA42 L-360s, and the Super Decathlon". Lots of low time pilots flying in the high workload, high stress area. I understand their concern for maintaining a safe airspace around the area they fly.
3. There were 73 different DJI drones observed, producing 190 flights during the 13 day period. Very small sample size - more of a proof of concept experiment rather than a conclusive exercise.
4. 96.8% (n = 184) of the drone flights were detected within 5 Statute Miles of an aerodrome. 84.2% (n = 160) detected within 5 SM of two or more aerodromes. This puts the commercial & private very ill at ease; were are encroaching in their high work load area. In the test area drone flyers were not flying according the FAA requirements to keep away from these high density flight areas. Note: the E-R Report made no mention of any of the 190 flights were conducted by FAA Part 107 certified pilots.
5. Of the 73 different DJI drones, 8 drones (with no specific number of flights mentioned - an oversight or intentional omission is not known) operated from three large, open areas within 1 mile of the Daytona International airport ( NASCAR Speedway parking lots Volusia Mall parking lots , and commercial parking lots near Builder’s Square). It appears the vast majority were very low level with only two reported as "58 ft" & "nearly 200 ft.". In my opinion, these drone pilots were trying to fly safely on one of the few open areas in the Daytona area but they DID BUST the no fly zone around the airport.
6. 5 out of 190 flights busted the 400 ft. max, height for drones (single drone pilot?, multiple pilots?). One of the 5 flights went to 1,200 ft. No excuse for these violations! PLEASE NOTE: 185 of 190 flights DID NOT bust the maximum limit for drone flying altitude.
7. Geofencing Effectiveness - The E-R Report stated: "All sUAS flights detected during the field sampling occurred within one or more geofencing zones. The collection area contained one Restricted Zone, two Authorization Zones, two Enhanced Warning Zones, and five Warning Zones". Well yes, they were flying their drones in a very busy air space. I bet most were Recreational drone pilots with little or no knowledge of these Zones & UAS Facility Maps. Improvements to the inputs to Geofencing (read FAA completion of the UAS Facility Maps & LAANC system) will improve the data drone pilots will improve Geofencing Effectiveness. Mandatory training from DJI ( or someone else) on the proper use of Geofencing might be good think to debate.
8. E-R's Conclusions - The E-R Report stated: "The data suggests that cumulatively, single- and multi-family homes make up 48% of sUAS operating locations. This data strongly suggests that a preponderance of sUAS operators are flying for personal use around their own residences. Commercial, industrial, and public locations also appear popular flight locations of sUAS operations—primarily in parking lots or other adjacent open areas...". My response: Other than the flying within so many ft. of the 10 high risk Zones these flights indicate to me these drone pilots were trying to act safely by using flat open spaces or flying low in their own residential areas. Note to E-R: If a commercial or private pilot was flying below 400 ft in these areas they were experiencing problems NOT CAUSED by those 48% of the drone pilots. I believe the FAA should allow a "Special Drone Airspace" in those areas mentioned in the Report of say "max 50 to 75 ft. to allow drones to fly recreationally.
9. E-R's Recommendations: (Geofencing) - The E-R Report stated: "...The authors propose manufacturers consider modifying Geofencing protections to align with the FAA LAANC UASFM grid system and impose altitude restrictions that align with UASFM altitude limits within each respective grid area...". This is a one sided response from the big boy flying community that totally locks out drone flying from the Daytona area. There was no consideration from E-R to accommodate the Recreational drone pilots. FYI, many of the Commercial flying community have this same attitude toward private pilots.
Tony's Conclusions:
A. I feel that the drone pilots are suffering from some of the established flying community that the very first automobile owners suffered from the "horse-centered society" of the early 1900's. For instance: Autos can't drive faster that a horse's walking pace so not to scare them and autos must yield to horse drawn carriages on bridges. Highly capable, economically priced drones are new hobby/sport/business tool that will require an evolution of the rules of the road in the crowed airspace. It must not be one sided.
B. E-R's Report was a admittedly small sample size, both geographically & duration. I would shout a VERY LOUD OBJECTION if anyone tries to change FFA or Local rules based upon this sole document. I suggest representatives from the drone community participate in redesigning any future E-R tests.
C. Education of ALL DRONE PILOTS concerning flying in congested areas. Embry-Riddle Aeronautical University should design an inexpensive course for flying in Daytona for drone pilots as a model for the country. They need to dumb down to FAA Airspace rules regarding Classes; it's very confusing. Base the course around the use of Geofencing.
D. Improve Geofencing to help the drone pilots. We can do away with needing to read confusing FAA VFR Sectional Charts for drone flyers. We have evolved automobile GPS systems to eliminate the paper map - let's do the same with Geofencing.
E. Allow drone pilots to fly at lower maximums (50 to 75 ft) in residential & large parking lots even though they might be within a high risk area defined by current FAA flight maps.
Wow, I didn't plan to write a comment this long but I feel that it was needed to call out the short comings of the E-R Report. Also as a retired Project Manager I felt obliged to bring solutions to the table for discussion, not just shake a fist at the problem. Please feel free to call out my flaws but please offer constructive alternatives to refine the possible solution.
Thanks,
Tony
