Hi all –
No surprise that this week’s edition of Dronin’ On is given over to covering the coverage of the DOT Christmas registration announcement.
For new readers, I started Dronin’ On almost a year ago. It has turned into a breathtaking story of social policy trying to keep up with technology. A No Fly Zone has become the new normal at high profile events. For me it all came to a head in this announcement. I normally don’t blog here but I really wanted to express my opinion in one hard to ignore, much too long piece.
If you’re in a hurry
I think that hurry-up policy making is a bad idea. This process is starting too late to have any influence on Christmas 2015 and could well end up being seen as another failure that the DOT and the FAA can ill afford.
- Exclusions are a bad idea.
- Not using technology is a bad idea.
- Catering to very small special interest groups is a bad idea.
- And mostly we need a much broader definition of safety for a class of products that will be as ubiquitous as these.
Here is the fundamental question that needs to be answered:
Are we serious about safety? Or is this nothing but CYA?
For context I recommend you watch the presser (35 minutes). Be sure to stay tuned when the reporters start lobbing questions…
The idea of safety has to go well beyond threats to NAS and airliners.
In fact accidents have happened – not in the NAS but on streets and in parks and stadiums around the world. Men, women and children have been hurt and property has been damaged through carelessness, software and hardware failures of various kinds and plain old bad luck.
Let’s start with the two primary catalysts of what appears to be a knee-jerk political reaction.
1) The 700+ reported sightings.
This number has been thoroughly debunked by the AMA – a story that got no traction at all. Here is the AMA analysis.
Compare that to the number of wildlife aircraft strikes annually reported to the FAA. Which have increased 7.4-fold from 1,851 in 1990 to a record 13,668 in 2014.
Some science is desperately needed if only to define at what size and speed a drone becomes a threat… Because the discussion is going to be all about “it’s a toy that is too small to hurt anything… so exclude it.”
- Here’s the problem. In 2012, there were an estimated 265,000 toy-related injuries treated in U.S. hospital emergency departments.
Managing this “threat” is what this tempest in a teapot is all about.
2) The 1,000,000 units for Christmas estimate. If you Google this, you will see that every single article attributes this forecast to the FAA. What is interesting is that I cannot find a press release from the FAA that announces, much less substantiates the claim.
In fact, the FAA forecast exceeds the already bullish CES 2015 forecast by a full 50%.
Come let us reason together.
- Do we really think that Parrot, 3DR and DJI can build 1,000,000 drones for the US market in a few months?
- Do we really think that there are container ships full of them unloading up and down our shores right now?
The slippery slope.
3) DOT claims that by registering every drone we will know whose drone it is. Makes perfect sense. We should register every single one of them, big and small.
In a manufacturer’s registry. And an owner’s registry.
A number of articles have already picked up on the fact that there is no way to read an N number on a 250mm, 18” or even 96″ drone in an air-to-air situation. Everyone agrees that a physical display is not going to tell you anything. What is needed is a live digital N number. (More below.)
If one crashes, if there is anything left, and if it carries a registered serial number, yes you will know who registered it. Which brings with it all the challenges and pitfalls of gun control.
“Who me? Billy borrowed it Saturday night – I told him to be careful. I would never fly it there…”
And the always popular
“That old thing, I sold it to Tommy two weeks ago. Bill of sale? C’mon man, we’re friends… He traded me this gun for it.”
4) If one looks at the current FAA 333 process you see a completely different emphasis. The emphasis is on the credentials of the pilot and the ground crew’s SOP. There was very little emphasis on the airframe – hundreds of types have been approved.
This new focus on airframe registration turns the attention away from the operator to the craft. All in the name of professing to educate the operator. (A highly advanced, utterly unproven learning concept.)
To say with a straight face that people will absorb the necessary information and skills by completing an 8 or 10 field registration form simply flies in the face of common sense.
We know how to do this properly. And there is no apparent reason not to.
- Develop a tiered system based on experience and risk.
- Observe, gather data and adjust.
The players and the played
5) The AMA was on the stage desperately seeking to preserve their time-honored, Congressionally bestowed exclusion to fly their toys.
When the time comes to decide what is a toy and what isn’t, I hope the committee members from the AMA use this simple test:
Launch the drone and ask yourself if you would be comfortable having it fly near your spouse, parents, children and pets. Yes they are perfectly safe… Great it’s a toy.
Not near my loved ones… Not so great. Register it.
6) AUVSI was on the stage seeking to establish their legitimacy. They proudly announced that they have 7,500 members. What the CEO didn’t say is that the majority of their members are from defense and aerospace.
AUVSI can hardly be said to represent the hundreds of thousands of consumers necessary to buy one million drones.
Let’s not forget AUVSI’s wild, unsubstantiated forecasts about the size of the drone market… could they be the source of the FAA 1M XMAS forecast?
So what to do?
7) I know that some of you will disagree but let’s try not get all wound up in some 2nd Amendment red herring like “If they take that from us, what will they take next?”
I don’t believe that anyone’s inalienable Right to the pursuit of happiness is dependent on having a drone. Nor, as un-American as it sounds, is it anyone’s right to make money selling drones. Or that some bogus right to privacy concept applies.
If you want to fly in the NAS, if you want to play or do business in the sky, you give up your right to privacy just like every other licensed aviator has for decades.
That kind of accountability has stood us in good stead for a long time. And is very much what is needed now.
You’ve seen the bozo behavior and the jackassery – what do you want to protect bozos for?
Nor do I think that making it hard(er) to get a drone represents a hardship for dronepreneurs, or that it will curtail the growth of the market for anyone but the retailers and manufacturers who take their profit at the time of the sale.
Owning and operating a drone is an elite privilege not a God-given right.
I don’t think that someone who can’t be bothered to pass a test and demonstrate their proficiency should fly.
There either is or there isn’t a safety issue. If there is, require everyone to pass an exam.
If that discourages the fringe – job done.
8) Conspicuously absent from the stage were the two groups on whom implementation of the proposed registration concepts should fall. The manufacturers and the retailers (brick and mortar, online US, online worldwide.)
This is especially true if registration is to be done at the POS (point of sale) which is one of the two options offered in the DOT Request for Information. Of course one of the immediate challenges is that anyone can buy and sell drones so there is no way to tell who is in the business.
Where is the ADM – the Association of Drone Manufacturers? And the ADR – Association of Drone Retailers? They did get a weak nod – “they are putting our pamphlets in their boxes.”
That is so cool.
What about this? A unique number that must be registered with the FAA when the drone is manufactured – as a condition of import or sale.
9) If you want to know who built it and bought it, require that every drone sold in the US incorporate a unique, hard-to-destroy physical registration number.
This is exactly what is required of every single airframe, automobile, boat etc. Drones are vehicles.
- Register them like vehicles.
- Charge users enough to cover the cost of development, maintenance and support of the registration process.
- Let’s not get lost in some silly concern about there are not enough N numbers in the universe. Keep N numbers for general aviation aircraft that are liable to fly across borders (which was the original purpose of the number) and create a new, bigger class of numbers for UAVs.
You have a new problem, find a new solution… no one ever runs out of barcode numbers.
Then with the Industrial Revolution era problems out of the way, let’s apply the same technologies that have skyrocketed the drone industry to it’s current state.
The stated goal is to use registration to educate the owner. So do it.
10) Make it so that a drone can’t operate (won’t start, won’t fly) without a number that is only issued after the registration process is completed.
Registration may be tedious, but it is not a hardship. You get something that you want for your time and trouble. Which is a deal that most of us make every day.
The stated goal is to use registration to identify the pilot. So do it.
Require a thumb or retina scan linking the drone with the person who registered it in order to lift off. Link it to a mini ADS-B while you’re at it.
If a $20 Breathalyzer can assess if you can drive, a $350 iPhone recognizes your thumbprint and a $750 DJI already employs geo-fencing to avoid 10,000 places, this is hardly a stretch for our industry. Put it on a chip and it is probably under $5.
And yes the insurers will gladly help by making registration and certification a condition of buying cover.
These things will not be accomplished by Christmas 2015. But then to go back to the beginning, my bet is that nothing meaningful will be accomplished by then.
So let me ask you again – are we serious about safety?
If we are, and we should be, then let’s bite the bullet and do what needs doing. There is no need to reinvent the wheel – just the need to leverage our experience and match our will to our objectives. Everyone feels a little pain, those who can’t stand it go away. By by.
If we are not serious, then let’s shut this down until the problem is better understood and the leadership is in place to create a lasting solution.
Thanks for reading and for sharing – and yes, commenting.