Historical Background Barriers to Growth

Barriers to Growth Impediments to UAV Commercial Growth   The UAS industry enjoys mature airframe and sensor technologies and unlimited application potential for commercial use. Barriers to flight remain, however once they are eliminated, capital will flow and the industry will be poised for very rapid growth. The areas listed below are compiled by UAV MarketSpace. To the degree that they are impolitic, we apologize in advance for anyone who might take offense. Ultimately, we believe that is a valid and useful assessment and is intended to do nothing more than stimulate thinking to move the industry forward. Professor Rob Owen, in his presentation to the United States Congress on March 30, 2006, and speaking to the same issues, has much to add to my outline below.   The Primary Barrier   1.      Airspace Authorization for UAS Flight in the NAS by the FAA a.      FAA was initially (understandably) caught off guard by the demand for NAS access for UASs. FAA elected first follow Europe’s lead. (Eurocontrol, the EASA, and member regulators such as the CAA (UK) are still ahead from an infrastructure and programmatic perspective.) FAA followed with a proposed system of staged SFARs. Current policy is AFS 400 05-1 – To summarize it states - No Commercial COAs – No Way – only Civil COAs are being considered. FAA has granted two experimental tickets to General Atomics Altair and Bell Heli's Eagle Eye UASs and is evaluating a two other experimental airworthiness certificate applications in order that developmental flight can proceed. The Global Hawk flies under a military AW ticket.(The reality is that UAVs are currently being flown in the NAS – the economics are forcing the issue) b.      FAA is currently working on new regulatory guidance – perhaps an update to AC 91-57 and perhaps formulating AFS 400 UAS Policy 05-02. c.       Exclusive reliance on RTCA SC-203 (High Guidance Level MASPS and MOSPS) is limiting progress in the standards area. – ASTM F-38 needs to be formally tasked by FAA to create specific working level standards and to coordinate with RTCA SC-203 - working in concert. Many ASTM Standards are already under development ( Fifteen work items - Two Published) and will be candidates for inclusion in FAA regulation/policy by reference as directed by OMB and US Public Law. d.      In January of 2006 – FAA organizationally restructured and names Kenneth D. Davis to head up a dedicated headquarters organization tasked with the safe integration of UASs into the USNAS. This is a major step forward. Mr. Davis, a 27 year veteran, will build an organization that makes use of emerging standards and excellent UAS work products such as the PSL TAAC HALE FAA Certification Roadmap to create regulation guidance and policy.   Secondary Barriers 1.    Technology a.    DSA – Collision Avoidance – candidate technologies are near of here. ASTM F-2411-04e DSA Standard, defining minimum DSA performance criteria, is published however no test paradigm and methodology or certifying authority (FAA) has a mechanism is in place for testing UAS DSA candidate technologies. 2.    Insurance – Liability, Casualty, Loss - extreemly limited availability and costly. a.    An ASTM Standard Practice is in the works to assess what underwriters require (data) in order that actuaries can compute risk and assign rates for liability and flight operations. b.    Combined with other concensus standards and FAA Airworthiness COA guidance– actuarial basis for reasonable rates should be forthcoming. 3.    Lack of Federal Support (Funding and Prioritization) a.    Funding Tech Development and COEs - $10,000,000 Grant properly allocated would go a long way for DSA Collision Avoidance. (for example)             i.      Sandia MiniSAR           ii.      NASA AMES UAV App Center Ground Radar            iii.      LYNX SAR and Amphitech OASys SAR           iv.      L3 Avionics SkyWatch            v.      Foster Flight Optical Head-on b.    Access5 Funding Ended – a myopic decision by the Congress the origins of which are not apparent. Partially rooted in Administrator Griffins refocus on space away from aeronautics and partly the high quality but non-prolific work product from A5. c.    No common focus or vision has resulted in limited little support infrastructure, programmatic or regulatory emphasis. 4.    Federal Government does not yet Recognize UAS Potential a.    Incorrect Focus – Small UAVs are where the potential is – HALE/MALE important but secondary. UA systems of 100 lb and less, flying in Class G airspace 1000 ft or lower, at speeds of less than 100 mph represent 90+ percent of the operational capability of the large HALE/MALE airframes and at a fraction of the capital and operating cost. b.    High Growth Industry -  Jobs in Manufacturing and Service Sectors c.     Europe - ahead in infrastructure, programmatically and organizationally – US is unfocused – priority set exclusively by market pioneers – UNITE Alliance sets priorities for HALE MALE – and military Tactical UAVs. d.    Access5 and AUVSI focused principally on UNITE priorities and airframes and military programs. 5.    Financial Services are Non-existent – Little Investment to Date a.    Grants Required to stimulate industry SBIR – not just to aerospace primes. b.    No VCs/Angels – only investment by DoD to Primes and limited SBIR and DARPA contracte – most investment is entrepreneurial bootstrap or strategic investment by companies with deep pockets. It does not appear to be in the VC radar screen yet. 6.    AOPA is currently, somehow, able to contain its enthusiasm for UASs. AOPA objection to TFR’s is valid and addressable. Safety and Certification mechanisms are not yet fully formed. However, AOPA should envision the UAS pilot as full equal members of the aviation community and work in areas of pilot certification – not fight a rear guard action to block the industry based on jobs concerns. 7.    Vocabulary – Economics – Cost/Benefit Analysis - no useful metrics or paradigm to date – Much white noise floated to fortify advocacy positions. a.    Embry – Riddle / University of Western Michigan - North Dakota University - Georgia Tech or other Academic COE –  in conjunction with an aviation economist resource could rapidly develop a cost metric, (e.g. total cost per flight, marginal cost per flight) and a vocabulary that normalizes the cost/benefit discussion. 8.    MTCR – Export Controls – International Enforcement is not Uniform– US Department of State is strict – this hurts domestic industry. Every signatory to the MTCR is authorized to implement according to its own export control mechanism. In fact the ISR capabilities of UASs could in fact argue for a wider deployment not restriction. 9.    UAV vendors need to coalesce into an effective Trade Organization that speaks for all manufacturers of airframes and sensors not just the MALE/MALE manufacturers – AUVSI appears principally focused on UNITE Alliance priorities and Defense Applications – a broader horizon is needed for Unmanned Systems in the US.