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2020 Identifying Opportunities Available through Utilization of Unmanned Aerial Delivery Programs in Support of Public Safety in the United States, Based on Present Use Cases Around the World Holden Luc Schmidt Bradley

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Identifying Opportunities Available through Utilization of Unmanned Aerial Delivery Programs in Support of Public Safety in the United States, Based on Present Use Cases around the World

By

HOLDEN L. S. BRADLEY

A Thesis submitted to the Department of International Affairs in partial fulfillment of the requirements for graduation with Honors in the Major

Degree Awarded: Spring, 2020

Bradley 2

The members of the Defense Committee approve the thesis of Holden L. S. Bradley defended on

April 15, 2020.

David Merrick Thesis Director

Dr. Michael Devine Outside Committee Member

Jarrett Broder Committee Member

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Table of Contents

Abstract 4

Introduction 5

Research Methodology 7

Context by Country 10

Commonwealth of Australia 10

Republic of /Zipline Inc 13

Japan 15

People’s Republic of China 17

United States of America 20

Survey Results 28

Analysis 30

Recommendations for Future Research 37

Conclusion 38

Appendix 39

References 40

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Abstract

This investigation aims to gain a clearer picture of how usage of unmanned aircraft systems (UAS) in the United States can feasibly evolve based on models already in place domestically and in other countries. Specifically, this investigation focuses on usage related to the utilization of UAS for the delivery of physical objects in support of public safety. Based on the evidence collected in this investigation, the primary impediment to more extensive American usage of UAS in this context is restrictions on beyond visual line of sight flight and flight over human beings of UAS maintained by the Federal Aviation Administration. For this reason, the most numerous and impactful opportunities available through the utilization of UAS delivery systems in the U.S. are dependent on the relaxation of those regulations. Data for this investigation was compiled from legal code, peer-reviewed literature, news media coverage of organizational UAS users’ activities, and organizational UAS users’ primary accounts of their activities. The latter accounts are mainly gathered from self-published media by these users, but also include some information from operational climate survey results.

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Introduction

Although promises of unmanned aerial product delivery systems supplementing and supplanting traditional delivery channels in the United States (U.S.) have been present in the media for years now, these forecasts have not yet come to fruition. However, there is evidence that these ambitions may be realized in the future, based on advancements domestically and overseas. This investigation aims to gain a clearer picture of how the usage of unmanned aircraft systems (UAS) in the U.S. can feasibly evolve based on models already in place domestically and in other countries. Specifically, this investigation focuses on usage related to the utilization of UAS for the delivery of physical objects in support of public safety. Based on the evidence found in this investigation, the primary impediments to more extensive American usage of UAS in this context are restrictions on certain operational categories of unmanned flight, such as on beyond visual line of sight (BVLOS) flight and flight over human beings, maintained by the

Federal Aviation Administration (FAA). In addition to this, there seem to be some other challenges, including economic, technological, and geographic obstacles, which currently limit the expansion of employment of UAS by organizations in the U.S. Nonetheless, delivery operations utilizing UAS have overcome many of these same challenges in other parts of the world. Knowing this, it is worth exploring the feasibility of applying solutions from these foreign use cases to problems facing American UAS users.

The FAA defines “UAS” in this way:

“An unmanned aircraft system is an unmanned aircraft and the equipment necessary for the safe and efficient operation of that aircraft. An unmanned aircraft is a component of a UAS.

It is defined by statute as an aircraft that is operated without the possibility of direct human Bradley 6

intervention from within or on the aircraft (Public Law 112-95, Section 331(8))” (Federal

Aviation Administration [FAA], 2018c).

This is the definition for UAS used in this investigation. UAS delivery systems in the context of this investigation refer to processes by which UAS are used to transport physical payloads, unrelated to the operation of the aircraft itself, from one location to another. For the purposes of this investigation, “public safety” refers to the preservation of human life and humans’ physical well being across a given community. Given the context above, the research question to serve as the basis of this investigation is this: Based on present use cases around the world, what opportunities are available through the utilization of UAS in object delivery systems to support public safety in the United States of America? The answers to this question are important because lives are already being improved and saved around the world by UAS technology. The technology, usage techniques, and regulatory infrastructure driving UAS operations worldwide are evolving rapidly, and can be difficult to describe at any given moment accurately. It is essential to investigate this topic because ignorance about the actual state of affairs has the potential to slow and limit the advancement of practices which can make people’s lives safer and better. At this point, the U.S. has seen notable usage and development of UAS and even UAS delivery technology specifically, but this technology still possesses untapped potential.

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Research Methodology

As a starting point, the context for this topic can be provided by peer-reviewed sources to some extent. Even still, the rapidly evolving nature of the legal, economic, and technological environments surrounding UAS usage across the world makes it difficult for scholarly literature to keep pace with some situational realities. With that in mind, it seemed the most effective way to study the state of this topic in the world today was to approach actors and stakeholders themselves in the U.S. and overseas. In this investigation, this was attempted, in part, through interviews with representatives of organizations such as companies, nonprofit organizations, and government entities engaged in usage or regulation of UAS, support of public safety, or both.

When possible, data regarding the regulatory environment of unmanned aviation in the countries investigated was gathered from a direct literary review of the documents governing unmanned aviation in each country. The documents concerning this topic in each country came from sources ranging from legislative documents to advisory circulars published by the aviation authorities of various countries. Some rules formally proposed by the U.S. federal government were also reviewed due to their relevance in describing the regulatory future of the country.

Understanding the regulatory boundaries of UAS operations in each country is necessary for framing investigation of those operations themselves.

In order to standardize the outputs from direct inquiries to UAS operators and regulators as much as possible, and ensure ethical conduct of research involving human beings, standard survey instruments were created. These survey instruments were developed from a pool of questions about UAS operational environments, visible in Appendix A. Each survey instrument is structured to ask organizations questions specifically tailored to the nature of their operations Bradley 8 in the ecosystem of civil UAS. The variations between surveys are respectively oriented towards gathering information from private enterprises employing UAS, public entities employing UAS, and government entities regulating UAS operations. Although many questions asked were the same across all survey variants, some questions were included or excluded between versions in order to draw more relevant information from different types of organizations. For example, it is pertinent to ask a UAS-focused corporation how much startup capital was needed for its launch, whereas this is not likely to be a useful question to ask a regulatory authority.

Links to the website hosting the electronic survey were distributed via email to private enterprises employing UAS, public entities employing UAS, and government entities regulating

UAS operations. Unfortunately, online survey participation of organizations contacted was minimal. Most organizations did not visit the website. Fewer than ten followed the link, with only two organizations completing the survey beyond the optional question asking for the name of the organization participating. Because of the minimal survey response rate, the majority of data regarding UAS operators and regulators was collected from a literature review of scholarly articles, news media coverage of their activities, and primary accounts of their activities published in the form of press releases and literature on their websites.

Collecting data from primary sources self-assessing their situations comes with potential problems. The main problem associated with this is the fact that the contemporary organizations in question still have vested interest in how their situations are portrayed to the public, including researchers, because their public image could affect their future dealings. Because of this, analysis of interview data and self-published information must take into consideration how some parties' responses may be designed to shape public perception rather than precisely explain actualities. Ultimately, the mix of scholarly literature and legal code for context, and interviews Bradley 9 with primary stakeholders for more detailed information provided ample data, and a nuanced selection of perspectives for this investigation. These sources laid the groundwork for analysis, which clearly describes the current state of affairs of UAS delivery operations and operational environments around the world.

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Context by Country

Commonwealth of Australia

The Commonwealth of Australia is a world leader in civilian unmanned aerial delivery because its regulatory environment allows for ample experimentation and encourages UAS research and development. Australia claims the honor of being the first country to regulate UAS operations, using Advisory Circular (AC) 101-2 in 2002 (Civil Aviation Safety Authority

[CASA], 2016). Today, as described in AC 116-24 v3.0, Australia’s UAS regulations are some of the most future-minded anywhere in the world.

Beginning with the status of BVLOS operations, this category of flights is not routinely permitted, with some exceptions. In a similar operational category, extended visual line of sight

(EVLOS) flight, the remote pilot does not have direct visual sight of the RPA. However, with assistance from trained RPA observers (persons who demonstrate competency via the operator's approved training requirements), the remote pilot is still able to ensure the safe operation of the

RPA (CASA, 2019, p. 37). During these flights, all areas of the intended operational airspace will be visible at all times, by at least one of the remote crew during the operation. This assessment should take into account physical obstacles and meteorological conditions. Electronic aids, such as on-screen or moving map displays, and first-person view may be used to assist the remote pilot in safely operating the aircraft, but cannot be used instead of direct eye contact

(CASA, 2019, p. 37).

Approval for BVLOS (including flight in other than visual meteorological conditions) and EVLOS are above the standard Remote Operator’s Certificate (ReOC) privilege, but can be granted by CASA (CASA, 2019, p. 55). In order to conduct a BVLOS flight, the holder of the Bradley 11

Remote Pilot License (RePL) who will fly the aircraft must have a license for BVLOS flight.

The application for this license requires the applicant to pass at least one of the following exams:

“an aeronautical knowledge examination for an instrument rating under Part 61; the former instrument theory examination (IREX) under Part 5 of the Civil Aviation Regulations 1988

(CAR); an approved examination for this purpose” (CASA, 2019, p. 53). CASA also requires operators to conduct a case-by-case safety risk assessment and mitigation strategy before any application for approval to operate BVLOS (CASA, 2019, p. 38). Additionally, the following equipment must be fitted to the RPA and operable for a BVLOS flight: position lights

(navigation lights), anti-collision or strobe lights, landing lights, transponders, aeronautical radio, navigation equipment, and any additional equipment that the operator has included in its safety case for the approval of the operation (CASA, 2019, p. 38-39). Special permission may also be granted for flight over populous areas (CASA, 2019, p. 29).

Within the Australian regulatory environment, there appears to be thriving UAS industry exploration and activity. According to the Australian Trade and Investment Commission, there are over 1200 drone operators in Australia (2019). Among other things, UAS operators are drawn to Australia as a growing hub for Beyond Visual Line Of Sight (BVLOS) testing

(Australian Trade and Investment Commission, 2019). An example of Australia's status as a global leader in UAS innovation is the World of Drones Congress, created in 2017. The convention focuses “on the business of drones, and how drones can be applied to industry, business and the delivery of government services. The 2018 Congress focused on the burgeoning commercial applications of drones, including planning smart cities, training, agriculture, health and humanitarian needs. It also discusses drone laws, regulation and future jobs.” The gathering Bradley 12 draws UAS exhibitors from countries across the Asia-Pacific region, including Australia, China, and Japan (Australian Trade and Investment Commission, 2019).

Focusing on one of the most notable UAS operators in Australia as a particularly compelling case study in delivery applications, take the example of Alphabet Inc subsidiary Wing Aviation

LLC. In the Australian cities of Canberra and Logan, Wing is engaged in the distribution of consumer goods from establishments such as coffee restaurants, grocery stores, and FedEx

(Dormehl, 2020). Customers order using an app, and their order is transported to them using unmanned vertical take-off and landing (VTOL) aircraft. The system boasts fast delivery times.

One particularly impressive manifestation of this is their frequent delivery of ice cream. This feat is significant because ice cream typically cannot be delivered without melting. The unique speed of UAS delivery allows consumers to quickly receive the product while it is still at its predetermined temperature for consumption (Dormehl, 2020).

From this current experimental system, it is predicted that the Australian UAS delivery market could see massive growth. In a predictive analytical market report prepared for Wing by

AlphaBeta in 2019, the company forecasted significant opportunities for growth of the unmanned aerial delivery industry in the State of Queensland. Among the forecasts in the report are: the growth of "retail sales in Queensland by $400-450 million of which $150 million could accrue to small businesses in Queensland in 2030” (AlphaBeta, 2019, p. 5) and that "Drones could deliver more than one in four take-away food orders, and up to 4-6% of all purchases in

Queensland by 2030" (AlphaBeta, 2019, p. 13). While Wing’s direct current and proposed impact on Australia is focused on the delivery of consumer goods, its activities demonstrate the potential for innovation in other areas. Wing’s demonstrated ability to locally deliver such highly perishable goods as ice cream could seemingly translate to utilization in emergency response, Bradley 13 where the aircraft could quickly transport lifesaving cargo. Additionally, Wing's operations in

Canberra and Logan demonstrate the effectiveness of CASA's regulation of airspace, which fosters innovation in UAS delivery techniques.

Republic of Rwanda/Zipline Inc

Airspace, and by extension unmanned aviation, in the Republic of Rwanda is managed by the Rwanda Civil Aviation Authority (RCAA) (Rwanda Civil Aviation Authority, 2020). That said, the entity in charge of creating regulation for unmanned aviation in Rwanda is the Ministry of Infrastructure (Ministry of Infrastructure, 2018, p. 38). Unmanned aviation rules instituted by the Ministry of Infrastructure foster a small, but functional UAS industry in Rwanda. To mention a few key regulations: flights over people are not allowed, unless the UAS operator obtains permission to do so from the RCAA (Ministry of Infrastructure, 2018, p. 55). Authorization for

BVLOS flight in Rwanda is available for private users with permission from the authorities

(Ministry of Infrastructure, 2018, p. 60). UAS may not be flown over any “congested area of a city, town or settlement unless approved by the [Rwanda Civil Aviation] Authority” (Ministry of

Infrastructure, 2018, p. 53). Rwanda requires any person conducting remotely piloted aircraft operations to maintain liability insurance “commensurate with the risk of the operation”

(Ministry of Infrastructure, 2018, p. 63).

It is fair to say Zipline Inc, an international UAS company based out of California

(Ackerman & Koziol, 2019, p. 24), is the most illustrious actor in the Rwandan UAS industry.

The company has become internationally famous for its employment of UAS in the delivery of blood to Rwandan hospitals. Zipline Inc has found a niche in Rwanda because of a handful of factors. First, the cargo carried by Zipline's aircraft is incredibly precious. Unlike some proposed Bradley 14

UAS delivery services, Zipline already ships blood to Rwandan hospitals that is necessary to save lives on limited timeframes. Secondly, Rwanda’s infrastructure, unlike many wealthier nations, limits healthcare providers’ ability to transport lifesaving supplies quickly. The nation’s congested highways and dirt paths traversing challenging terrain make fast airborne transportation an appealing channel in the case of deliveries needed to save patients’ lives in a hurry (Ackerman & Koziol, 2019, p. 26-27). Thirdly, the Rwandan government explicitly encourages the expansion of UAS operations within its borders and, at the time of Ravich’s writing in 2017, had already begun “preparing regulations ahead of investor interest in building a logistics system in to transport medicine in areas difficult to reach by road” (2017, p.

614).

Zipline’s success in Rwanda has spurred other African nations to explore the possibility of utilizing UAS medical deliveries to work around infrastructural and geographic problems similar to those in Rwanda. Although Zipline Inc’s, negotiations to implement a UAS delivery system in fell through, Zipline now delivers medical supplies in (Ackerman &

Koziol, 2019, p. 31). As of April 2019, a report from CNBC claimed Zipline Inc to be “the world’s largest drone-delivery network” with its official commencement of operations in Ghana.

Africa is not the only locale where UAS have been used to allow blood deliveries to circumvent weak infrastructure in rural areas of the Global South. To name another, Richard, Bempong, &

Hahault document the employment of UAS in Papua New Guinea to transport blood samples from a rural health clinic to a hospital 63 kilometers away with more sophisticated analysis equipment (2019, p. 864).

Similar to the case of Wing in Australia, Zipline's operations in Rwanda serve as a successful proof of concept for the ability of unmanned aircraft to cross spaces rapidly and make time- Bradley 15 sensitive deliveries. What is even more compelling in the case of Zipline is the truly lifesaving nature of the cargo carried, and the use of UAS to overcome road infrastructure which makes delivery by road difficult. Moreover, the success of Zipline in Rwanda serves as a promising model of how countries in the global south may be able to spur economic and infrastructural development through fostering a UAS-friendly regulatory environment. Based on the expansion of Zipline’s system to Ghana, it appears more countries may come to see the value in the proposition of UAS delivery programs.

Japan

Japan's introduction to civil UAS usage came in the 1980s with the advent of remote- controlled aircraft used to fertilize crop fields. This use case, in part, came about as a preemptive measure to minimize the amount of labor needed to support the Japanese agricultural sector as the aging population demographics of the country threatened the availability of agricultural workers (Sheets, 2018, p. 515). At the time of Sheets' writing in 2018, the Japanese government's attitude towards UAS is described as "extremely pro-drone." One manifestation of this sentiment is an announcement by Prime Minister Shinzo Abe to utilize drones to serve “rural and depopulated areas” by delivering medical supplies via UAS. Perhaps most importantly, the government has passed laws to enable companies and universities to field test UAS to accelerate the arrival of everyday UAS delivery systems (p. 517-518). UAS have also seen employment in

Japan as a tool for disaster response, having been used to monitor radiation following the

Fukushima Daiichi Nuclear Power Plant disaster (Schootman et al., 2016, p. 4).

Turning discussion of the regulatory environment in Japan, the country's regulations show a flexible attitude towards flight restrictions. The Civil Aviation Bureau states on their Bradley 16

website: “An amendment to the Aeronautical Act was issued on Sep. 11, 2015 to introduce safety rules on Unmanned Aircraft (UA)/Drones.” (2015). Under these regulations, the term

"UA/Drone" means any airplane, rotorcraft, glider, or airship which cannot accommodate any person on board and can be remotely or automatically piloted, excluding those lighter than 200g.

In all cases, the weight of a UA/Drone includes that of its battery (Civil Aviation Bureau, 2015).

If UAS operators intend to fly unmanned aircraft BVLOS or over “sites where many people gather,” they must obtain approval from the Regional Civil Aviation Bureau in advance (Civil

Aviation Bureau, 2015). Requirements stated in “Airspace in which Flights are Prohibited” and

“Operational Limitations” are not applied to flights for search and rescue operations by public organizations in case of accidents and disasters (Civil Aviation Bureau, 2015).

A notable example of UAS delivery innovation in Japan is Terra Drone. January 2020,

Japan Airlines (JAL) entered into an agreement with Yabu City in southern Japan to verify the feasibility of delivering emergency goods to unpopulated areas of Japan using UAS. JAL is partnering with the Japanese UAS company, Terra Drone, to conduct this testing (Terra News,

2020a). In addition to the development of UAS delivery operations within its borders, Japanese companies have also led the way in exporting their UAS capabilities abroad. A Chinese-based group company of the Terra Drone Corporation, Antwork, made headlines for establishing a

UAS delivery system in support of efforts fighting the coronavirus, COVID-19, in Xinchang

County, China in February 2020 (Terra News, 2020c). Another company in that same group,

Terra Drone , has partnered with Unilever to conduct delivery tests of ice cream in New

York State to explore commercial UAS delivery in the U.S. (Terra News, 2020b).

Even though Terra Drone has yet to establish a dedicated unmanned aerial delivery network in Japan, the Company has demonstrated initiative in testing UAS delivery techniques Bradley 17 outside of Japan, and forming partnerships with partner organizations such as JAL and Unilever.

Japan's unmanned aviation regulations clearly have the makings of a system that enables experimentation through situation government permission. Sooner rather than later, Terra Drone will likely bring the expertise it has gained from international testing to enhance domestic systems such as the one it is developing with JAL. Also, Terra Drone's track record of seeking strategic corporate partnerships is likely to expedite the process of integrating UAS into various sectors of the economy, and not merely the national airspace.

People’s Republic of China

In China’s institutional efforts to contain and eradicate COVID-19 unmanned aircraft systems (UAS) have played a remarkable and unconventional role. During the outbreak in China,

UAS have been used to replace humans in some functions, and also extend users’ capabilities to employ other technologies. While some of the most notable examples of UAS usage in efforts combating COVID-19 come from the Chinese government’s direct employment of UAS to enforce and support their emergency policies, there is also striking utilization of UAS by the

Chinese private sector. Furthermore, UAS-based adaptations to the COVID-19 outbreak in China are not only impressive for their short term effects, but also for what they may signal about the future of life in China. On a regulatory level, one of the most interesting peculiarities of the

Chinese operating environment is the integration of the Unmanned Aircraft Cloud System

(UACS) into regulations themselves. The UACS mentioned by the Civil Aviation

Administration of China is a real-time electronic monitoring system for unmanned aircraft, which also includes an electronic fence and alarm to ensure flights do not enter restricted airspace (Capello, Dentis, Guglieri, Mascarello, & Cuomo, 2017, p 193). In China, BVLOS flights are allowed, as long as the flight is compliant with some restrictions, including avoiding Bradley 18 restricted airspace, yielding the right of way to manned aviation, and ensuring a human pilot can override the autonomous aircraft at all times (Global Drone Regulations Database, 2019).

Beginning with accounts of the civil UAS response to COVID-19 in China, one variety of UAS usage is the initiatives in which aircraft are used to replace human activities. One of the most popular varieties of UAS which has risen to prominence in China as a result of the outbreak is a type of multirotor aircraft which is used to broadcast messages via loudspeaker in public spaces

(Liu, 2020). The messages broadcasted from these aircraft are primarily targeted at directing traffic and enforcing rules regarding citizens' use of personal protective equipment and compliance with quarantine measures requiring them to stay indoors. There are also aircraft which specialize in spraying disinfectant in public places (Marr, 2020). By doing this, Chinese officials can reduce their chance of transmitting COVID-19 to themselves and others. Alongside uses of UAS which seek to replace human in various roles, there are some uses which provide the Chinese government with capabilities humans do not have. One notable private sector UAS partner of the Chinese government is Shenzhen MicroMultiCopter Aero Technology, whose

UAS are used to patrol the streets of 11 Chinese cities in support of agencies in charge of policing, transportation, and propaganda. According to the chairman of that company, each aircraft can patrol a 10 square kilometer urban area in an hour. This purportedly relieves the efforts of more than “100 police officers and dozens of patrol cars.” (Liu, 2020) Additionally, some of the unmanned aircraft above Chinese cities are equipped with thermal sensors, designed to detect people with high body temperatures as possible carriers of COVID-19 (Jakhar, 2020).

Turning next to description of commercial UAS activities related to COVID-19, like many civil initiatives, private sector operators are using UAS to fill roles otherwise occupied by humans before this outbreak. One important private sector use case is the employment of UAS in Bradley 19 the automation of Chinese agriculture. XAG, a major agricultural UAS maker based out of the city of Guangzhou, expects its revenue to quadruple this year, in part due to demand caused by the COVID-19 outbreak (Ye, 2020). Since early February, 2020, the leading national group for fighting COVID-19 has prioritized agriculture as a top priority. Because of this, government support, including special financing, has allowed the Chinese agricultural industry to invest in critical equipment, including UAS. This has led to predictions that agriculture might be one of the Chinese industries least affected by COVID-19. On the other hand, some commercial UAS initiatives have achieved feats their human counterparts could not. As mentioned in a previous section, Antwork, a Chinese-based group company of the Terra Drone Corporation, made headlines for establishing a UAS delivery system in support of efforts fighting COVID-19, in

Xinchang County, China in February 2020 (Terra News, 2020c). Antwork launched an “urban air transportation channel” to support local hospitals and government agencies through the secure and rapid movement of medical sample and protection equipment (Terra News, 2020c). This transportation channel has two main benefits. First, transporting samples of COVID-19 via UAS lowers the risk of exposing humans to the virus, and secondly, according to GPS World, UAS transportation is roughly 50% faster than road transportation (Marr, 2020). By implementing this system, Antwork has not merely replaced human delivery workers with robots, but created a system which is faster and safer than one dependent on human personnel.

In some ways, the utilization of UAS in the COVID-19 outbreak is par for the course in the People’s Republic of China. Many of the same MicroMultiCopter aircraft which have now risen to global prominence during the outbreak were already in use by the Chinese government to conduct surveillance, criminal arrests, and public event security (Liu, 2020). Moreover, many critics of the Chinese government claim that the Chinese government has used the COVID-19 Bradley 20 outbreak as justification to expand its already vast state surveillance network (Jakhar, 2020). It is also worth considering the true potency of UAS-based initiatives combating COVID-19. Elliot

Zaagman, a journalist covering the Chinese technology industry, commented on coverage of technology-focused COVID-19 responses by saying to the British Broadcast Corporation "The state media apparatus, even under normal circumstances, takes every opportunity to send a message about China's technological sophistication, even if a story has little substance to it,” continuing “I suspect that most of the stories we see about disinfecting robots, drones, etc, are mostly just performative gimmicks. However, tech's 'less-sexy' role in controlling this outbreak should not be dismissed.” (Jakhar, 2020). Even still, some changes are undeniably indicative of more significant change. For example, to enable Antwork to develop its urban air transportation channel, the company was issued China's first urban UAS delivery license by the Civil Aviation

Administration of China (Marr, 2020). Going forward from this year's outbreak, UAS may retain some roles they gained in China as a result of the outbreak, but likely there will be cases of UAS declining in usage in some applications as the outbreak declines.

United States of America

Like many countries, the U.S began its history of UAS usage amidst twentieth-century wars. The early American UAS employed in this period which most resembled contemporary aircraft appeared during World War II and the Vietnam War as bombing and reconnaissance aircraft (Sheets, 2018, p. 519). Despite the progress made in UAS technology during this period, the civilian sector in the U.S. fell behind foreign markets and governments for decades (p. 514).

At the present moment, recent rules put forth by the FAA, the national entity tasked with regulating aviation, provide hope for rapid advancement in UAS technology and usage. Bradley 21

As it is commonly understood, a few FAA regulations inhibit broader usage of UAS in the U.S., including the parameters that unmanned aircraft must weigh less than 25 kilograms, fly at altitudes below 400ft, and travel at ground speeds below 100mph (Laksham, 2019, p. 342).

Still, the main limiting factor of UAS operations in the U.S., which particularly impacts plans for delivery systems is the requirement that unmanned aircraft must be flown within visual line of sight (VLOS) of their operator. This rule exists in order to mitigate potential safety hazards of

UAS flights. (Schootman et al., 2016, p. 5). Until this requirement changes, sophisticated

American UAS delivery systems will be unlikely to grow beyond small, experimental operations.

Luckily for organizations operating UAS, there are signs that line of slight restrictions could be changing in the near future. Remarking on the specific legal literature governing UAS operations, recreational users are covered under 49 U.S.C. § 44809 (2018), civil UAS activity in the U.S. is almost entirely covered under 14 C.F.R Part 107 (2016) for commercial users and 49

U.S.C. § 44806 (2018) for public users.

In situations where users flying under Part 107 wish to conduct a flight that would violate specific regulations, they may apply for a certificate of waiver from the FAA to deviate from those provisions. The list of waivable sections under a Certificate of Waiver is as follows:

 Section 107.25, Operation from a moving vehicle or aircraft. However, no waiver of this

provision will be issued to allow the carriage of property of another by aircraft for

compensation or hire.

 Section 107.29, Daylight operation. Bradley 22

 Section 107.31, Visual line of sight aircraft operation. However, no waiver of this

provision will be issued to allow the carriage of property of another by aircraft for

compensation or hire.

 Section 107.33, Visual observer.

 Section 107.35, Operation of multiple small unmanned aircraft systems.

 Section 107.37(a), Yielding the right of way.

 Section 107.39, Operation over people.

 Section 107.41, Operation in certain airspace.

 Section 107.51, Operating limitations for small unmanned aircraft.” (14 C.F.R. § 107,

2016).

Like users flying under Part 107, unmanned public aircraft operators (PAO) can request permission to conduct flights BVLOS, over people, or in other operational categories, which are not standard for private operations under Part 107 (FAA, 2018b). Once a PAO has received certification to conduct operations within its requested blanket, the limitations of its flights within that umbrella may go above and beyond the rights of commercial or hobbyist operators.

Even still, aircraft flown under the certificate of authorization of a PAO are limited by the statute governing all operations in U.S. airspace, manned and unmanned (FAA, 2018b).

The issuance of waivers to users for missions taking place under exceptional circumstances is an important tool the U.S. government has used to expand the development of civil UAS incrementally. Through these mechanisms, the FAA can allow users to conduct missions that would otherwise violate restrictions on how and when civil users can fly, on a case- by-case basis. In the present day, there is a visible divide between the scale of public safety UAS Bradley 23 operations and those in the commercial sector. Generally speaking, it is users acting in the interest of public safety who are granted the most leeway by the FAA, while commercial users are granted such leeway less frequently. For example, waivers for VLOS restrictions under are available under a Certificate of Authorization (FAA, 2019b) and Part 107, but not for Part 107 users to perform “the carriage of property of another by aircraft for compensation or hire” (14

C.F.R. § 107, 2016). Despite this, commercial users are still gaining more freedom to operate within the bounds of standard FAA regulations. Before 2016, commercial UAS operators in the

U.S. were expected to obtain authorization through Section 333 of the FAA Modernization and

Reform Act of 2012 (Sheets, 2018, p. 521). This process of obtaining authorization was expensive and time-consuming, serving as a barrier to entry for businesses wishing to utilize

UAS. Starting in 2016, when the FAA released Part 107, private UAS operators became able to obtain cheaper and more streamlined authorization for select flights (p. 524). Although users authorized under Section 333 are allowed to continue to fly using their exemption until it expires, most of those would likely have expired in 2018 and made impractical to renew by the advent of

Part 107 (FAA, 2016). The introduction of Part 107 was a watershed for American UAS users because it enables more individuals and organizations to enter the unmanned aviation market.

Intending to loosen its current VLOS restrictions potentially, the FAA has been testing extended visual line of sight (EVLOS) UAS flights since 2015. This is a type of contact wherein the UAS pilot is not required to maintain VLOS to the aircraft, and remote observers may be used to maintain visual contact. Additionally, the FAA has more recently been testing BVLOS flights for the same reason (FAA, 2018a, p. 13-14). The FAA even planned to allow Zipline Inc to test flights delivering medical supplies in the U.S. sometime in 2019 (Ackerman & Koziol,

2019, p. 31). It is also worth noting, the FAA already allows for exceptions to its current rules Bradley 24 governing UAS flights for civil or public operators in response to catastrophes, disasters, and other emergencies (FAA, 2018a, p. 55).

In the interest of growing domestic UAS innovation, the U.S. government has taken multiple steps in recent years to make the regulatory environment more permissive of previously restricted UAS activity. One high-profile turning point in this process was the creation of the

Integration Pilot Program (IPP). The program has led the FAA to partner with state, local, and tribal governments in order to “develop and safely test new and innovative UAS concepts of operations” and “inform the development of future Federal guidelines and regulatory decisions on UAS operations nationwide” (Trump, 2017). IPP Lead Participants include the Choctaw

Nation of Oklahoma, the City of San Diego, CA, and the Innovation and Entrepreneurship

Investment Authority in Herndon, VA, among others (FAA, 2019a). Under the IPP, the first U.S.

BVLOS flight by an operator flying under Part 107 was conducted in Alaska on July 31st, 2019, by a UAS team associated with the University of Alaska Fairbanks. The landmark flight was used to inspect a 3.87-mile section of the Trans-Alaska Pipeline System (RBR Staff, 2019).

While the direct effects of this program itself are not large in scale, and have primarily sentimental significance, the program's existence does demonstrate an interest in developing

UAS industry at multiple levels of government, across the U.S. One example of this sentiment taking hold at sub-national levels of government can be seen in a November of 2019 development. At that time, New York Governor Andrew Cuomo announced the completion of a

50-mile long UAS BVLOS flight corridor in the State. That unmanned traffic management corridor, running from Central New York to the Mohawk Valley, was developed in collaboration with the nonprofit UAS research organization NUAIR (NUAIR, 2019). Specific national provisions regarding the expansion of UAS testing were introduced in the FAA Reauthorization Bradley 25

Act of 2018 and are covered under 49 U.S.C. § 44803. This more robust piece of legislation has led to the FAA’s authorization of UAS delivery testing beyond the IPP, which will be described in more detail later in this section. Also of note, provisions concerning unique unmanned aircraft airworthiness certifications can be found in 49 U.S.C. § 44807 (2018). These rules open the door for more considerable experimentation in the types of aircraft which may be engaged in special

UAS flights.

Despite the apparent potential of expanded UAS operations to contribute to U.S. society, safety concerns regarding the technology remain. In order to remedy this, a rule proposed by the

FAA in December 2019 titled “Remote Identification of Unmanned Aircraft Systems,” is officially summarized as follows:

“This action would require the remote identification of unmanned aircraft systems. The remote identification of unmanned aircraft systems in the airspace of the United States would address safety, national security, and law enforcement concerns regarding the further integration of these aircraft into the airspace of the United States while also enabling greater operational capabilities” (FAA, 2019d).

While not strictly loosening regulations, this rule is crucial because it could alleviate many of the concerns which currently motivate American regulators to limit civil UAS operations. With mandatory remote identification for unmanned aircraft, air traffic controllers and law enforcement agencies would be able to maintain a more complete picture of unmanned aviation activity at any given time. If this change gave agencies greater confidence in their ability to recognize and respond to UAS-based threats, it is likely they will feel less compelled to prevent dangerous UAS incidents by simply limiting UAS activity. Members of the private sector have Bradley 26 reacted favorably to this proposition, with Wing support of remote identification in 2020 as a tool for further integrating UAS into the national airspace (Wing Medium, 2020).

Also relevant to the topic of UAS security concerns in the U.S. is the grounding of all non-emergency unmanned aircraft in the Department of the Interior (DOI) fleet in February of

2020. This was done to facilitate a review of the DOI UAS program to “ensure that cybersecurity, technology and domestic production concerns are adequately addressed”

(Douglas, 2020). This was ostensibly done in response to security concerns related to equipment made in the People's Republic of China. The motives behind the decision are made additionally clear by the further decision by the DOI in October of 2019 to ground all non-emergency unmanned aircraft manufactured in China, or containing Chinese-made parts (McCabe, 2020). In order to end the use of Chinese-made unmanned aircraft by the whole of the federal government, the American Security Drone Act of 2019 was proposed in September of that year. The Act would prevent the federal government from procuring and operating UAS from a “covered foreign entity” (S. 2502, 2019). In the context of the Act, “covered foreign entity” essentially refers to any entity determined to be a national security risk, with specific attention given to UAS made in China (S. 2502, 2019).

One asset to the development of UAS delivery systems in the U.S. is widespread commercial interest surrounding the implementation of such technology. Among the list of companies that have publicized intention to incorporate UAS into their delivery operations are

Amazon, Walmart (Swanson, 2019, p. 154), Google, and even Dominos Pizza (Ackerman &

Koziol, 2019, p. 26). Many of these companies' primary interest in UAS delivery systems lies with the "last mile problem," and desire to reduce overall delivery times and costs (Swanson,

2019, 154-155). Arguably the most significant American regulatory development of the past Bradley 27

year, in terms of gravity in the private sector, has been the certification of America’s first unmanned air carriers under 14 C.F.R. Part 135. This set of regulations, traditionally used to describe operations by manned air carriers, has enabled two U.S. companies so far to generate revenue through package delivery using UAS (FAA, 2019c).

In October of 2019, American delivery giant (UPS) received the first Part 135 Standard certification. As the first citified U.S. unmanned air carrier, UPS conducted the first-ever revenue-generating BVLOS flight in the U.S. on September 27th, 2019

(United Parcel Service [UPS], 2019). So far, the central accomplishment of UPS Flight Forward, the subsidiary which holds Part 135 certification, has been the delivery of medical samples on

WakeMed’s hospital campus in Raleigh, NC (UPS, 2019). In March 2020, UPS announced an official partnership with Wingcopter, a German manufacturer of UAS (Wingcopter, 2020).

Closely following UPS, Wing has been operating a small consumer UAS delivery network in

Christiansburg, VA, since October 2019 (Wing Medium, 2019). The so-called "Early Flyers

Program" operates in the same vein as its operations in Australia and Finland delivering consumer goods from local businesses directly to individuals using VTOL aircraft (Dormehl,

2020). As of March 2020, Zipline is also in the process of applying for Part 135 certification in order to launch medical delivery operations in North Carolina (Boudway, 2020).

Bradley 28

Survey Results

For the purposes of gathering up to date qualitative information about the operations of organizations involved in the usage of regulation of UAS in various countries, a list of 18 organizations were contacted using a standard survey instrument. Only two organizations completed the survey: a manufacturer of unmanned aircraft parts based out of Canada and a local police department in the U.S. In effect, the low response rate and small sample size prevent the results of the survey alone from providing a broadly relevant understanding of UAS operations around the world. Regardless, the two responses gathered do provide interesting supplementary information for this investigation.

In the survey submission provided by the manufacturing firm, they indicated two primary themes regarding their relationship to their operating environment. Firstly, the manufacturer remarked “It [regulation] also affects our testing and ensuring compliance. This has required our team to be aware of potential issues with our testing site.” Secondly,

“UAS operations are starting to mature. When the drone is used as a tool to augment performance (police, engineering), there will be slower growth but sustainable. I believe the market is moving from early projects to daily use. This also means companies/users will need to professionalize how they operate and the "cowboy" mentality will not prevail.”

Both of these statements support the assumption UAS regulations are quickly evolving, to the point of viscerally affecting the internal operations of organizations engaged in UAS-related activity. In addition to the two previously mentioned themes, the manufacturer also claimed

"regulations help our business" but did not elaborate upon this point. This could be interpreted as a reflection on a relationship between the advent of more sophisticated UAS airworthiness Bradley 29 regulations and the subsequent rise in demand for supplementary UAS parts, such as safety measures, communication equipment, or others.

In the response provided by the local police department, the primary impediment to their

UAS operations is misinformation, within their agency and other government entities, regarding the usage of the department’s aircraft. The key example of this provided in their submission was characterized as follows

“Texas Government Code 423 defines an "image" as any capturing of sound waves, thermal, infrared, ultraviolet, visible light, or other electromagnetic waves, odor, or other conditions existing on or about real property in this state or an individual located on that property. The statute does not define what capture means. There are criminal offenses associated with illegal capturing of an image. In those offenses is a defense to prosecution if said images are deleted. Non-supportive administrators spread misinformation to upper level administration that the term capture means data transmission from camera to monitor, without the pilot ever having possession of the image. This misinterpretation of the statute limited our ability to provide overwatch for Officer Safety, Agency asset safety, and person of interest safety to only lawful capturing of images as defined by the ‘non-applicable’ section.”

This response supports the idea UAS technology and regulation can be easily misunderstood by individuals, due to their novel and continuously developing nature. This case is relevant because it illustrates even individuals who rely upon utilization of UAS in public affairs may be confused about the details of their operational environment. In addition to this, the police department’s survey response also indicated there was a strong relationship between public and private organizations engaged in UAS operations in the local community. Bradley 30

Analysis

Specifically addressing available opportunities related to UAS delivery systems focused on public safety in the U.S., there is certainly room for higher utilization of these systems in a technical sense. Two main categories of public safety operations seem suitable for current UAS delivery technology. The first encompasses operations wherein UAS are utilized to expedite the delivery of time-sensitive cargo. The second encompasses operations wherein UAS are utilized to provide greater operational versatility to organizations responding to emergencies wherein utilization of other modes of delivery is impractical or impossible. While the first category of operations is relevant both to routine public safety missions and disaster response, the second category is more exclusively relevant to disaster response.

The clearest contemporary examples of operations in the first category is visible in the models demonstrated by Zipline, UPS Flight Forward, and Antwork through their delivery of medical supplies in their respective locales. These two use cases demonstrate the applicability of these types of operations to multiple environments. Zipline's model in Rwanda and Ghana demonstrates the viability of utilizing UAS to deliver critical medical cargo across longer distances where delivery via road is possible, though dangerously slow. In the U.S., this could be translated to overcoming geographic obstacles in the form of mountainous terrain or infrastructure damaged by natural disasters, such as fallen bridges or flooded roads. UPS Flight

Forward’s model in North Carolina demonstrates the viability of these operations to quicken deliveries across a smaller “campus-sized” area in order to make in-house operations more efficient. Antwork’s model in China demonstrates the viability of these operations across populated urban areas where terrestrial traffic could slow road delivery. Antwork’s model is also particularly relevant in cases where cargo could pose a hazard to humans, and the number of Bradley 31 individuals in proximity to it should be minimized. Wing's operations in Australia and the U.S. also support the notion that regular operations in this category are feasible, even though their current deliveries are not in support of public safety. In one final example, Archer First Response

Systems is a firm that aims to utilize UAS to deliver life-saving cargo, such as automated external defibrillators (AED) (Archer First Response Systems). Speed is critical in the case of

AED delivery because the probability of ventricular fibrillation and survival decays with time

(Boutilier et al., 2017, pg. 2460). Based on the fact that the operations above are all carried out by private entities, it is import regulations evolve further to integrate private UAS operators into the national airspace.

Turning to the second category of operations, there is unique potential for utilizing UAS delivery systems in support of disaster response operations, as opposed to more routine emergency response. In a scenario where small teams of emergency responders are searching on foot for survivors of a disaster in an area impassible by terrestrial vehicles, unmanned multirotor aircraft could be used to broaden the team’s capabilities. Unmanned deliveries from a nearby supply node could provide teams with supplies they do carry, resupply items they have depleted.

In practice, this would expand the amount and variety of equipment and supplies responders would have at their disposal in a disaster environment, without reducing their mobility by requiring them to carry the items themselves.

Further broadening the applicability of UAS delivery practices in emergency response,

Bhaskaran et al. even propose the viability of personally portable “last-centimeter” aircraft, which could be used to make short-range delivery (Kornatowski et al., 2018). With these aircraft, individuals or teams responding to a disaster could theoretically carry a with them, and have the ability to quickly send small, time-sensitive cargo loads, such as chemical Bradley 32 samples, to the location they are needed. On the same topic of UAS versatility, experimentation in Japan concerning unmanned craft capable of traveling both in the air and on the ground has revealed new potential for the ability of UAS to traverse a wide variety of environments. The capability to travel in multiple domains could enable UAS to traverse spaces inaccessible from the air. These areas could include land beneath restricted airspace or inclement weather that poses a danger to aircraft. Furthermore, moving via ground would also likely allow unmanned multi-domain craft to travel farther due to reduced energy expenditure while moving on the ground. While unmanned multi-domain craft seem to solve a more niche set of problems than

UAS overall, they could provide public safety UAS operators with the means to respond to a slightly broader array of emergencies (Li et al., 2018).

Thankfully, the U.S. is already accommodating emergency UAS operations carried out by PAOs. Despite this, there are two ways the U.S. could better capitalize on operations in this second category. In a technical sense, more operators should test the viability of using UAS delivery in this way in order to develop more effective technology and employment practices. In a regulatory sense, American policymakers should continue to expand the ability of private UAS operators to test the technology associated with this category of operations in order to facilitate more significant innovation surrounding UAS delivery systems in the context of disaster response.

Despite the opportunities presented by the technical capabilities of UAS, larger systems designed to deliver critical supplies across longer distances or in urban areas, require operators to conduct flights outside of current restrictions such as those concerning BVLOS flights and flights over people. In order for these public safety applications to become more widespread,

U.S. regulations will have to become more accommodating. Possibly the most important tool Bradley 33

U.S. regulators and UAS users have at their disposal currently is the usage of waivers to circumvent regulatory restrictions. Despite the broad restrictions which limit the scope of UAS flights in the U.S., waivers for UAS operators flying under Part 107 and PAO rules allow for operators to push the boundaries of UAS employment techniques situationally. In each of the countries researched for this paper, there is regulatory infrastructure in place waive at least some regulatory restrictions for individual flights on a case-by-case basis. In fact, across the many examples of innovation in UAS employment techniques across the countries covered in this paper, it seems most "boundary-pushing" flights are given clearance not by rules which broadly permit BVLOS flight or flight over people, but by situationally granted permission from the aviation regulatory organization responsible for that country. The frequency with which civil organizations are granted permission to conduct these flights seems to be increasing around the world, as countries that never allowed UAS delivery flights in the past are now accommodating organizations that wish to conduct them.

For now, in the U.S. and elsewhere, this system of regulators individually evaluating

UAS operations and granting waivers for specific restrictions works for creating environments where operators can test the capabilities of their hardware and usage techniques on a small scale.

Going forward, the critical challenge facing aviation regulators in this area will be transitioning from a system where waivers are used to facilitate a few small-scale, confined UAS delivery operations to one where regulations at large facilitate the growth of more extensive, more sophisticated UAS delivery networks, and a higher number of those networks. Without a shift in regulations to accommodate the maturation of UAS delivery networks beyond those which survive within the scope of waivers, U.S. transportation authorities cannot nurture or reasonably control an entire industry based on unmanned aerial delivery. At the present moment, regulations Bradley 34 instituted in Australia and Rwanda may serve as models for the next step in the evolution of

FAA regulations regarding operational categories such as BVLOS and flight over people. While

CASA and RCAA regulations regarding BVLOS flight are functionally similar to those in place through the FAA, CASA and RCAA regulations provide clear minimum requirements for operators intending to conduct BVLOS flights, such as necessary equipment and safety procedures. While regulations such as these will likely be insufficient in long term control and growth of civil UAS operations, they do reveal a possible route forward.

Security concerns about equipment from companies such as DJI have the potential to set back UAS operations in the U.S. and abroad. Public users in the U.S. who have developed their

UAS usage around Chinese-made platforms would be likely to face setbacks in their operations with the passage of the American Security Drone Act. The grounding of Chinese-made unmanned aircraft would almost certainly signify a pause or temporary decrease in the capabilities of some public operators until their aircraft could be replaced with alternatives made in countries compliant with the Act. In the case of some public users of Chinese-made UAS with smaller budgets or UAS programs deemed non-essential, the loss of their aircraft could mean a full stop to their operations for the foreseeable future. At the same time, the grounding of

Chinese-made UAS in public use could open a door for American UAS operators to upgrade their hardware overnight. In organizations utilizing Chinese-made UAS where unmanned aviation programs would not be cut entirely as a result of the American Security Drone Act, the necessity to replace aircraft could force some users to purchase newer airframes with increased capabilities. If this mass replacement coincided with the revision and loosening of some significant unmanned aviation restrictions by the FAA, certain public users might be encouraged to invest in UAS, which can, for example, fly farther, carry heavier payloads, or navigate urban Bradley 35 environments. This upgrading would be done in order to perform more ambitious missions, which would become more feasible from a regulatory standpoint, as a result of changes to existing restrictions. In cases where safety and security concerns limit the expansion of UAS operations in the U.S., international cooperation will continue to be critical in the rapid development of civil UAS hardware, software, and employment techniques. By supporting U.S. companies such as Zipline and Wing in testing their technology domestically for broader applications overseas, policymakers can continue to strengthen the capabilities of American companies in preparation for a time when those companies are permitted to operate in the U.S. fully. In addition to this, allowing foreign companies such as Terra Drone and Wingcopter to collaborate with companies in the U.S. enables American policymakers to enhance domestic technology and expertise by tapping into intellectual resources from abroad.

One unfortunate reality of information regarding current UAS operations and operational environments is the omnipresence of misleading information. Contemporary media coverage of events involving UAS, especially those involving UAS delivery systems, often flirts with sensationalism. Despite apprehension towards unmanned aircraft, which does exist as a result of privacy concerns and fear of weaponized drones, the global public is fascinated with UAS technology (Kelly, 2014). Unfortunately, this sometimes results in misleading reporting regarding the actual status of UAS operations and UAS operational environments. One example of this can be seen in reports covering the first Part 135 unmanned air carriers in the U.S. In their article published in Medium, "Wing Launches America's First Commercial Drone Delivery

Service to Homes in Christiansburg, Virginia," Wing leads with a title (Wing Medium, 2019) which is imprecise, if not wholly false. This is because UPS Flight Forward created the first commercial delivery network utilizing UAS in the U.S. in September of 2019, making their first Bradley 36 flight under their Part 135 certification an entire month prior (UPS Staff Writer, 2019). In the body of the article about the launch of Wing's network, clarification is made to the title's initial claim. This more specific claim states, "Wing today became the first company to operate a commercial air delivery service via drone directly to homes in the United States." While the full account of Wing's U.S. launch in the previously mentioned article does not conflict with the reality of UPS having launched its network first, the title of the article is a clear example of intentionally misleading representation of UAS delivery systems in the news media.

Bradley 37

Recommendations for Future Research

During the period in which this paper was written, from the summer of 2019 to the spring of 2020, UAS operational environments across the world changed substantially. The rapidly evolving status of UAS delivery systems worldwide necessitates frequent revisitation in the near future, in order to ensure literature concerning this topic keeps pace with its realities. For example, by the nature of regulations in the countries investigated here, where aviation authorities facilitate most UAS delivery activity within situational waivers, there is potential for dramatic steps forward to be taken as a country’s authority may simply decide to issue more exemptions. In addition to the speed of innovation and regulatory progress which makes accurate information on this topic highly perishable, there is likely much to be learned from research that more successfully approaches stakeholders in the UAS delivery sector directly. Perhaps an organization with more resources and rapport with UAS operators, such as an aviation authority itself, could survey the operators with which it interacts. In the future, it would also be prudent to contact more organizations than were contacted in this investigation in order to generate a larger potential data sample size. Even still, in the vein of this investigation, it would be important for such research to gather data from multiple countries, in order to gain and maintain an understanding of how different national operational environments may or may not support the growth of UAS delivery systems for public safety.

Bradley 38

Conclusion

Based on the evidence found in this investigation, the primary impediments to more extensive American usage of UAS delivery programs in the context of public safety are restrictions on certain operational categories of unmanned flight, such as on beyond visual line of sight flight and flight over human beings, maintained by the FAA. The current technical capabilities of UAS delivery technology affords for its broader utilization to support public safety in the U.S. This is made clear by use cases in the U.S. and abroad, where UAS have been utilized to deliver cargo in direct support of public safety expeditiously, or to deliver other goods in a fashion which could be repurposed to support public safety. These operations are all supported by regulatory environments that overtly foster their existence, to some degree or another. The U.S. is making strides towards widespread usage of UAS delivery systems in support of public safety. Although current FAA regulations limit the capabilities of American

UAS operators, the agency's demonstrated willingness to bend the rules in exceptional cases signals an interest in exploring a more permissive regulatory environment. Going forward, U.S. policymakers must develop more advanced and effective UAS regulations in order to seize more opportunities related to UAS delivery technology, which already has the potential to improve and save lives.

Bradley 39

Appendix: UAS Operational Climate Survey

UAS Operational Climate Survey

If you are responding on behalf of a:

 Private Enterprise Employing UAS, please answer questions 1, 2, 3 and 8.

 Public Entity Employing UAS, please answer questions 1, 2, 4, and 8.

 Public Entity Regulating UAS, please answer questions 5, 6, 7, and 8.

Survey Questions

1. What is the greatest obstacle to the expansion of your organization’s UAS operations?

2. How has the legal/regulatory environment in which your organization conducts UAS

operations facilitated or limited its ability to undertake desired operations?

3. How much startup capital was needed to begin your organization’s UAS operations?

4. How would your organization characterize its relationship with the private sector?

5. How has the nature of regulating/enforcing of laws pertaining to UAS operations changed

since your organization became involved in this process?

6. How does your organization foresee its work changing in the future?

7. What is the greatest challenge your organization faces in regulation/enforcement of laws

pertaining to UAS operations?

8. If your organization has additional comments to provide about the current state of its

UAS operations, or the state of UAS operations in the area(s) it operates, please provide

them here:

Bradley 40

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