Thank you.....
This is a big report. Lots to digest.
If you don't want to read it all, at least the 11 separate recommendations to the FAA should give a good summary of its content:
1) Recommendation: The FAA should meet requests for certifications or operations approvals with an initial response of “How can we approve this?” Where the FAA employs internal boards of executives throughout the agency to provide input on decisions, final responsibility and authority and accountability for the decision should rest with the executive overseeing such boards. A time limit should be placed on responses from each member of the board, and any “No” vote should be accompanied with a clearly articulated rationale and suggestion for how that “No” vote could be made a “Yes.”
2) Recommendation: The FAA should expand its perspective on a quantitative risk assessment to look more holistically at the total safety risk. Safety benefits, including those outside of aviation (e.g., the benefit of cell tower inspections without a human climbing a cell tower), should be part of the equation. UAS operations should be allowed if they decrease safety risks in society—even if they introduce new aviation safety risks—as long as they result in a net reduction in total safety risk.
3) Recommendation: Within the next 12 months, the FAA should establish and publish specific guidelines for implementing a predictable, repeatable, quantitative, risk-based process for
certifying UAS systems and aircraft and granting operations approval. These guidelines should interpret the Safety Risk Management Policy process described in Order 8040.4B (and in
accordance with International Civil Aviation Organization Doc. 9859) in the unique context of UAS. This should include the following: (1) Provide, within 18-24 months, risk-based quantitative performance standards that can serve to establish compliance with FAA rules and regulations. (2) In the interim, encourage applicants to provide quantitative probabilistic risk assessments (PRAs) to demonstrate that their operation achieves the requisite level of safety. (3) Within 18-36 months, update FAA rules to reference new performance standards with the goal of minimizing the need to grant waivers or Certificates of Authorization (COAs).
4) Recommendation: Where operational data are insufficient to credibly estimate likelihood and severity components of risk, the FAA should use a comparative risk analysis approach to compare proposed UAS operations to comparable existing or de minimis levels of risk. The FAA should research and publish applicable quantitative levels of acceptable risk in comparison to other societal activities that pose de minimis risk to people. Risk level and risk mitigation strategies should consider not only aircraft collisions but also third-party risks (e.g., to people on the ground).
5) Recommendation: Over the next 5 years, the FAA should evolve away from subjectivities present in portions of the Order 8040.4B process for UAS to a probabilistic risk analysis (PRA) process based on acceptable safety risk. In the interim, the FAA should improve the 8040.4B process to conform better with quantitative PRA practice. For the new acceptable risk process, the FAA should consider relying on the applicant to provide a PRA demonstrating the achieved level of safety, as is common in other regulatory sectors such as nuclear, dam, or drug safety.
The FAA should screen applicant PRAs by comparison to existing or de minimis levels of risk. The FAA needs to research applicable quantitative levels of acceptable risk in comparison to other societal activities in establishing a level of de minimis risk for aviation.
These acceptable levels of risk need to include risk to people on the ground and risk of collisions with a manned aircraft, particularly with regard to collision with a large commercial transport.
In evaluating applicant-generated PRA, the FAA should value the importance of risk mitigation opportunities and their potential for simplifying the analysis of risk.
In situations where the risk is low enough, the FAA should encourage applicants to obtain insurance for UAS operations in lieu of having a separate risk analysis.
6) Recommendation: The FAA should create the following two mechanisms that empower and reward safety risk management decisions that consider the broad charter of the Department of
Transportation to “serve the United States by ensuring a fast, safe, efficient, accessible and convenient transportation system that meets our vital national interests and enhances the quality of life of the American people, today and into the future”:
- The FAA administrator should establish an incentive system that measures, promotes, and
- rewards individuals who support balanced comparative risk assessments.
Within the next 6 months, the FAA administrator should publicly commit to ensuring timebound reviews of risk assessments so that proponents receive timely feedback.
7) Recommendation: Within 6 months, the FAA should undertake a top-to-bottom change management process aimed at moving smartly to a risk-based decision-making organization with clearly defined lines of authority, responsibility, and accountability. To that end, the FAA should establish and maintain technical training programs to ensure that agency risk decision professionals can fully comprehend the assumptions and limitations of the probabilistic risk assessment techniques appropriate to current and future UAS operations.
8) Recommendation: The FAA should identify classes of operations where the level of additional risk is expected to be so low that it is appropriate to base approval of those operations on requiring insurance in lieu of having a separate risk analysis.
9) Recommendation: The FAA should, within 6 months, collaborate with industry to define a minimum operational safety data set and develop a plan for the voluntary collection and retention of data by the operators in a central repository, following the model of the Commercial Aviation Safety Team (CAST) and the General Aviation Joint Steering Committee (GAJSC), with a goal of full implementation within 1 year. The FAA should also consult with the Drone Advisory Committee to help define the minimum operational safety data set and plan for collecting, archiving, and disseminating the data.
10) Recommendation: For operations approvals for which there are no standards, as operational data are collected and analyzed, the FAA should, as part of Improved Safety Risk Management,
- Publish requirements for operational approvals with associated restrictions that can be adjusted and scaled based on industry past experience and the accumulation of related data;
- Expand single operation approvals as experiential data accumulate and risks are assessed;
- Permit repeated or routine operations based on the accumulation and analysis of additional data; and
- Continuously update operational approval practices to incorporate emerging safety enhancements based on industry lessons learned until standards have been established.
11) Recommendation: In coordination with other domestic and international agencies, the FAA should pursue a planned research program in probabilistic risk analysis (PRA), including the aspect of comparative risk, so that FAA personnel can interpret or apply PRA for proposed technology innovations.