This is what should happen. We need an NPRM, even if
there are details to be fi lled in later. We need to get to work. The FAA, and those of us who help it craft the rules, must rec- ognize that we’re regulating something that is available off -the- shelf at very low prices. In other words, the economic barriers to entry are quite low. People purchasing microdrones are likely to be individuals and small businesses not now in the aviation industry. If they are confronted with a regulatory process de- signed for type certifi cation of the 787, the Diamond Twin Star, or licensing requirements for instrument-rated medevac helicopter pilots, they are more likely to take the outlaw route. The regula- tory process needs to be much simpler.
Tactical Electronics RAPTR UAS Photo
AIRCRAFT CERTIFICATION Aircraft certifi cation requirements can begin by codifying certain
features already available in most of the microdrone products of- fered for sale. The most fundamental of these are requirements that the control link between microdrone and DROP be robust, that the microdrone respond quickly to DROP control inputs, and that they have various autonomous capabilities that can be brought into play by the DROP, or automatically when the control link is lost or a mishap is about to occur. Autonomous hover and autonomous return to home are available now in most of the commercial products, even at the very low end of the price range. These should be required before microdrone types are certifi cated. How responsibility should be allocated between the DROP and the machine for deciding when to trigger these automatic control algorithms is another matter. We plan to explore, in a subsequent article, the possibility that requiring most of the fl ight rules to be built into the drone could greatly reduce the burden on the FAA of writing detailed fl ight rules and airmen certifi cation rules.
Now, with a reasonable outline of what the microdrone rules
should be, we can take our time with the rules for larger machodrone aircraft, because they will be much more detailed, refl ecting a much diff erent risk profi le. But we can’t take our time with the microdrone rules. Otherwise, we’re going to be fl ying in skies occupied not only by us, but also by millions of small outlaws.
GET TO WORK There’s no reason that translating the outline of microdrone rules
presented in this article into regulatory language should take ten years – or even fi ve – depending on how you interpret Mr. Williams’ prediction. Indeed, a group of motivated helicopter pilots and operators, aviation lawyers, and FAA personnel probably could come up with a NPRM refl ecting this approach by sitting around a table together for a week.
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Helicopter pilots and operators must be at the table, not sitting in the ready room wringing their hands about how “they” are going to introduce drones into their skies. It will not turn out well if helicopter pilots and operators simply avoid the subject—so don’t.
About the authors: Hank Perritt is a professor of law and former dean at Chicago-Kent College of Law and a private helicopter and airplane pilot. Eliot Sprague is a professional news helicopter pilot and a helicopter instrument fl ight instructor. Mr. Sprague taught Mr. Perritt how to fl y helicopters. Together they manage Modovolate Aviation, LCC, which conducts drone research, evaluation, demonstration, and educa- tion programs
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