Remotely Piloted Aircraft Must be Compatible with Piloted Aircraft Operations
Frank Hofmann, IAOPA Representative to ICAO
The 450,000 owners and pilots of private and business aircraft who are members of their State organizations comprising the International Council of Aircraft Owner and Pilot Associations (IAOPA) are quite concerned about the rapid rise of both civil and military remotely piloted aircraft (RPA) operations. RPAs and their supporting unmanned aircraft systems (UAS) are viewed as a potential threat to the safety and operational flexibility of civil aircraft operations. Importantly, the impetus supporting the proliferation of RPA and their missions is strong, often outstripping the ability of State airspace allocation and regulatory authorities to accommodate these new operations fairly and safetly.
Our principle concern is the inability of the RPA to assure its separation from other aircraft, regardless of where they operate. Ground-based command and control systems have not demonstrated their ability to ensure avoidance other aircraft in the same manner as with manned aircraft. Similarly, internal sense and avoid systems have not been able to adequately avoid aircraft not equipped with complementary electronic devices. This is important since many general aviation aircraft do not have and are not required to be equipped with emitters compatible with secondary surveillance systems. Moreover, many light aircraft are not equipped with electrical generating systems, obviating any viable complementary electronic avoidance devices. Requiring complementary avoidance electronic equipment is impractical due to the expense involved.
The current trend to segregate RPAs into lightweight and other categories is disturbing to the owner/pilot of a light aircraft. Even a one kilogram RPA colliding with a manned aircraft traveling at 150 mph will cause substantial if not catastrophic damage. This is an important lesson learned from a century of birds colliding with aircraft. And, evidence suggests that birds have efficient sense and avoid characteristics.
Similarly, lesser restrictions proposed for line-of-sight RPA operations is worrisome since the definition for what constitutes line-of-sight, controllability of the RPA, poor spatial relations perception by the operator, lack of altitude determination and qualification and experience of the operator are both ill-defined and lacking in specificity.
Finally, general aviation operations enjoy considerable freedom of movement when operating under visual flight rules (VFR) in State airspace systems. It is those relatively low altitude uncongested areas designated as uncontrolled airspace (International Civil Aviation Organization (ICAO) Class E and G airspace) where many general aircraft operate. Unfortunately, for the same reasons that light aircraft prefer operations in these areas, RPAs do as well. We are concerned, and proof exists, that RPA preferred operating areas will generate restrictions for manned aircraft. Even if these restrictions are imposed temporarily, the effects on direct, efficient and safe operations of manned aircraft are considerable. Our preference would be to have RPA operations confined to closely- controlled airspace where positive control can be assured by ground control methods. IAOPA continues to press the RPA community to develop its detect and avoid capability to the point where it will be more capable to carry out that required function than are GA pilots. Adding another form of aircraft operations into the current mix, a group of aircraft with unique operating parameters and failure modes not incorporating detect and avoid capabilities, simply cannot be considered safe when mixed with conventional aircraft.
IAOPA has been an active participant in the ICAO Unmanned Aircraft Systems Study Group (UASSG) meetings since its inception. This group is quite aware of the extent of the work still required by ICAO, relating to all of their Annexes, before that organization would consider permitting international operations on the civilian side.
IAOPA’s interest continues to be, as from the outset, that the RPA community develops its technology deliberately and methodically, in addition to demonstrating its capability in all areas of concern before it demands to share airspace currently used by the traditional operators. Our continued belief is that introduction of RPA guaranteed positive avoidance devices not requiring complementary equipment in conventional aircraft, that current airspace not be restricted in favor of RPA operations either permanently or by notices to airmen (NOTAMs), and that ICAO standards and guidance provide States with uniform direction are the key elements ensuring safe and efficient operations for both manned and RPAs. ---
The International Council of Aircraft Owner and Pilot Associations (IAOPA) represents the interests of AOPA affiliates in 69 countries, comprising more than 450,000 general aviation and aerial work pilots and aircraft owners. The Council was formed in 1962 to provide a voice for general aviation in world aviation forums. For more information, visit www.iaopa.org.