UAS: ALPA Wish List

The Air Line Pilots Association has not been shy about making their opinions known on UAS issues.  They took a strong stand in favor of requiring a commercial pilot’s license in their comments to the first Section 333 Exemption Petitions.  In addition, they filed rather detailed comments to the Small UAS NPRM on issues related to safety and the proposed UAS Operators Certificate.

Earlier this week, ALPA released a new white paper entitled, Keep America Flying:  A Flight Plan for Safe and Fair Skies.  The white paper addresses a number of issues, including NextGen and air traffic reform, the federal flight deck officer program, the growing problem with transport of lithium ion batteries, open skies agreements, and UAS.

ALPA recognizes that small UAS operations have sparked “enormous commercial growth, providing considerable social and economic benefit.”  ALPA believes that so long as these operations are conducted in the current framework, i.e., segregated from other users of the National Airspace System (NAS) by the 500 foot altitude limits and restrictions on operations near airports, the risks to other operators are significantly reduced.  However, the white paper also shows how moving UAS to the next level and integrating their operations into the NAS will be significantly more difficult.  To that end, ALPA draws a line in the sand and sets out what it sees as the minimum requirements for a fully integrated system:

  1. All safety-based rules applicable to manned aircraft should be applied to UAS.
  2. UAS should not be granted routine access to the NAS unless they meet the same safety standards that apply to current certificated aircraft and operators.
  3. Pilots of commercial UAS must hold a commercial pilot’s certificate.
  4. Operators of commercial UAS should be subject to the same operational approval and oversight as commercial airlines.
  5. No one should be permitted to control more than one aircraft at a time.
  6. UAS must have active collision avoidance functionality.
  7. All UAS that are not intended to be flown in the same airspace as manned aircraft must have geographic and altitude limitations built into them to ensure they cannot enter manned airspace.
  8. All UAS must have the capability to land safely in the event of a lost-link.

Given the enormous time and effort that has gone into the creation of the Small UAS rule, many people have lost sight of the fact that this is actually the easy part of the task Congress has set before the FAA.  Full integration of UAS into the entire airspace is a monumental task, and will require a much more “hands-on” approach from the FAA at all levels, whether it be pilot requirements, training, aircraft certification, air traffic control, or operator certification.  Regardless of whether or not ALPA ultimately gets everything it wants out of this process, all of these issues will have to be examined and addressed in the next round of rulemaking.

(Originally posted July 31, 2015)

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