Even someone who has never touched a controller and thinks that Part 107 is a household cleaning product can tell you that the answer is “No!” Their evidence? No Amazon delivery drones have yet graced their front porch. Likewise, there have been no routine operations beyond visual line of sight (BVLOS) for linear infrastructure inspection, no fully autonomous flights for perimeter security around sensitive facilities, and so on.
These types of missions are the hallmarks of full integration, but none has been achieved except by a waiver to Part 107 under tightly controlled circumstances. However, we cannot waive our way to making uncrewed aircraft systems (UAS) full participants in the national airspace system (NAS). That will require three things: rules, technology, and a plan. The good news is that we’ve got the plan.
Actually, it’s the second draft of a plan—so we’ve still got a ways to go, but even a journey of 1,000 miles begins with a single footstep.
UTM CONOPS 2.0
Let’s begin by defining a few terms, starting with UTM. It’s an acronym for UAS Traffic Management, the system which must be put in place to permit the full integration of drones in the NAS. Briefly—because the balance of this article will be spent describing it in more detail—UTM is air traffic control (ATC) for drones.
What about “ConOps”? That’s a contraction for “Concept of Operations,” a term widely used in aviation, engineering and the military, but less familiar to people who are not deeply embedded any of those fields. Just like it sounds, a ConOps is a document that describes the functioning of a system from the perspective of its end user. It’s a disciplined approach to transforming an idea into a real-world product or service, by identifying all of the individual components and how they will interact with each other.
Remember when I said that we have a plan? That wasn’t quite true. What we actually have is the second version of a UTM ConOps developed by the FAA in partnership with a litany of other aviation- and standardsrelated organizations. These include the National Aeronautics and Space Administration (NASA), the American National Standards Institute (ANSI), and a whole bunch of other rarefied groups with convoluted acronyms for names that you would forget by the time you finished reading the paragraph, anyway—so I’ll spare you the trouble.
The goal of the ConOps is to define a system that will permit UAS operations up to 400 feet above ground level (AGL), including BVLOS and autonomous operations, in both controlled and uncontrolled airspace. That’s right: when this system is fully implemented, you’ll be able to fly farther than you can see in the airspace right around major airports. That’s something you can’t do today even in uncontrolled airspace, miles away from the nearest grass strip.
If you think it’s going to be a long journey to get from where we are now to that vision of the future, you’re most certainly right. Maybe my initial estimate of 1,000 miles wasn’t far enough—how about 2,000? 5,000? I hope you’re wearing comfortable shoes, because we’re just getting started.
So, why has the FAA decided to move forward with the development of UTM at this particular moment in history? I’ll refrain from speculating that the agency needed time to work through the five stages of grief—denial, anger, bargaining, depression and acceptance—around the fact that UAS are now a permanent and growing part of the aviation community. Instead, I’ll offer the agency’s own explanation, straight from pages 1 and 2 of the ConOps:
“The predicted volume of small UAS (sUAS) operations across both controlled and uncontrolled airspace... could be on a scale comparable, if not greater, to that of present-day manned air traffic ... The number of daily operations could potentially reach into the millions, taxing the NAS well beyond its current service requirements ...
“Given the number, type and duration of UAS operations envisioned, the existing Air Traffic Management (ATM) System infrastructure and associated resources cannot costeffectively scale to deliver services for UAS.”
Said another way, the years ahead will see an immense number of UAS operations each day. Putting a control tower on every street corner with humans inside desperately trying to keep track of it all and make sure that none of these things run into each other simply isn’t going to work. The problem is too big, so it requires and entirely new approach.
When it comes to UAS, controlling air traffic will essentially be the domain of an Internet-based computer network, to be called “Skynet” (if I get a vote). Drone pilots will submit their intended operations—where and when they plan to fly—to the system and the network will look at every other flight scheduled to occur in the same general vicinity, in order to prevent conflicts between UAS or crewed air traffic.
On page 8 of the ConOps, the FAA describes the system, thus: “Within the UTM ecosystem, the FAA maintains its regulatory and operational authority for airspace and traffic operations; however, the operations are not managed by ATC. Rather, they are organized, coordinated, and managed by a federated set of actors in a distributed network of highly automated systems via application programming interfaces (APIs).”
PAY TO PLAY?
So, one key difference between existing ATC and UTM is that computers, rather than human controllers, will be running the show. Another distinction is that when you seek airspace authorization, rather than interacting with a government employee sitting in a control tower, you will instead interface with a private, for-profit corporation.
We have already seen this with the development of the Low-Altitude Authorization and Notification Capability (LAANC) system. Right now, you don’t seek authorization to fly in controlled airspace via LAANC from the FAA—you seek it from AirMap, KittyHawk, or Skyward, to name a few—who then interface with the agency on your behalf.
Personally, I’m not a big fan of the idea that private corporations will be gatekeepers to a public good: the navigable airspace above US soil, but this notion is deeply embedded in the UTM concept as it has been developed so far.
On page 7 of the ConOps, the FAA justifies this decision by the following logic: “An innovative approach to meeting service requirements, leveraging commercial services that greatly accelerate the provision of capabilities due to market forces and business incentives to meet consumer demand, while placing a much smaller infrastructure and manpower burden (cost) on the government to implement.”
In short, unlike ATC—which you pay for through your federal taxes—you are going to personally pay for UTM services by subscribing to a UAS Service Supplier (USS). Some of these will no doubt be the same companies that already provide us with LAANC authorizations, and more may enter the market as it matures.
I worry about this arrangement because having multiple entities involved in this process muddies the lines of accountability. The FAA and your USS can blame each other if something goes wrong and, in most cases, that means you’ll never really know for sure what happened and whether or not it will be fixed moving forward.
If ATC screws up, you can trace the line of responsibility straight from the individual controller to the FAA administrator, which is a powerful incentive for the agency to keep the number of mistakes to the absolute minimum.
Furthermore, if the FAA ran UTM directly, you would pay (with your taxes) for the services provided. If a for-profit corporation is required to interface between you and the FAA, you will be paying for the services provided, plus a share of that corporation’s profits.
On the plus side, most of the likely USS operating today provide LAANC authorizations for free, profiting by selling complementary services— like insurance—and, of course, by vacuuming up your personal data. So, for the individual drone pilot flying within visual line of sight (VLOS), it isn’t unreasonable to expect that someone will offer basic UTM services under a similar arrangement. However, that is hardly guaranteed.
The ConOps outlines the roles of key participants within UTM. However, if the past century of crewed aviation has taught us anything, it is that everybody—every single person living in the United States—is a participant, even if that participation only involves not having a Cessna 172 crash into your living room. What happens in the air above our heads affects all of us. With that in mind, let’s meet the major players:
The Federal Aviation Administration (FAA). No surprise, the FAA itself is at the top of the list. Within the UTM ConOps, the FAA has two primary responsibilities. The first is to establish the “rules of the road”: developing the policies and standards that will govern the distribution of airspace in a way that is both safe and equitable, as well as publishing information about temporary flight restrictions (TFRs) and other special circumstances. Its second responsibility is to maintain a database of information about aircraft and pilots, such as registration, equipage, certification, training, and so forth.
Necessarily, that database is going to contain a lot of private information about those pilots, such as their names, addresses, telephone numbers and e-mails—as well as the trade secrets of large-scale commercial operators. To prevent other participants within the UTM ecosystem from accessing this information, it will exist behind the Flight Information Management System (FIMS), which will act as a firewall of sorts between the FAA and the rest of the network.
Finally, the FAA will have the ability to observe and record all of the activity occurring within the UTM network. This will allow the agency to detect and anticipate trends, develop new rules and procedures based changing circumstances, and take enforcement action, if necessary.
Operators. These are entities that conduct flight operations. While the term “operator” is often used interchangeably with the word “pilot” when referring to the person guiding a UAS through the atmosphere—indeed, I’ve done this many times myself—it has a more specific meaning in this context. The operator is the person, or entity, that is responsible for the overall activity. If Jeff Bezos ever realizes his dream of establishing a drone delivery network, then Amazon, the corporation itself, will be the “operator.” In addition, even members of the crewed aviation community can also be defined as operators within UTM. More on this in a bit.
Remote Pilots in Command (RPICs). The RPIC is the individual human being that is responsible for the safe conduct of each UAS flight. If you hold what is commonly referred to as a “Part 107 certificate,” your official title within the aviation community is RPIC. The RPIC must ensure that each flight is conducted safely, in accordance with all of the appropriate rules and regulations, that their aircraft avoids potential conflicts with other aircraft, with terrain and obstacles, inclement weather, and the like. If the safety of flight is compromised, the RPIC is responsible for taking the appropriate steps to mitigate the danger. Note that an individual RPIC can also be an operator, as described above.
UAS Service Suppliers (USSs). As mentioned previously, USS are private, for-profit corporations that provide an interface between the UTM network and those individuals or entities conducting UAS operations. It is worth noting that an organization with sufficient needs and resources could establish its own, in-house USS—although the complexity and expense of this option will likely limit it to only the largest operators in the foreseeable future. This is not something you are going to cobble together on weekends for your solo real estate photography business.
Supplemental Data Service Providers (SDSPs). These entities provide additional information about the operating environment, such as detailed data about terrain and obstructions, hyper-local weather reports, aggregated UAS traffic patterns and likely a whole bunch of other things we haven’t even thought about yet. By definition, the information provided by SDSPs is not required for flight, but it may help to enhance safety or improve efficiency. Within the UTM ConOps, SDSPs may make this data available through USS or directly to operators.
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