The document provides feedback from participants on the proposed sUAS NAS Integration Guidelines. It summarizes that: - The guidelines lack safety analysis and operational experience input. The recommendations are overly restrictive and could have devastating economic impacts. - The proposed type I, II, and III operations leave little viability for small operators or ability to gather meaningful data through limited operating envelopes. - Many questions around safely defining operating parameters and applying manned aviation standards to small UAS remain unanswered. The lack of data and overly restrictive rules could lead to lack of compliance, regulatory apathy, and stalled technology investment and integration. - The road ahead remains unclear with no clear path or timeline to a workable solution according to

1. sUAS ARC
Participants Perspective
Prepared by Patrick Egan for the
membership of WG-73, Sub-group 4.

2. Proposed sUAS NAS Integration Guidelines

3. • No “data” or safety risk analysis going in
• Bins and boxes are a rehash of unacceptable RTCA
work
• Those with operational experience are woefully
underrepresented
• Overall document lacks comprehensive tone
• International Harmonization = Weights in kilo’s???
• Economic impact of recommendations are
devastating
sUAS ARCObservations

4. • Unwarranted and heavy-handed regulation of
model aviation
• Type I operations leave little in the way of
viability
• Operating greater than 3 NM of an airport
• System certification (what does it look like???)
• Manual flight control
• Type II operations put small operators in direct
competition with vendors (major enterprises for
profit)
sUAS ARC Observations
continued...

5. • Type III operations shut out small operators
• Operating greater than 10 NM sometimes 30NM from an
airport
• System certification
• Required equipment takes most of payload
• Type IIII way beyond the reach of many.
• Type V LTA Lighter Than Air left out of
recommendation.
sUAS ARC impressions
continued...

6. Unanswered ARC Questions
Impeding Integration
• Confines of what is safe is yet to be scientifically defined?
• Were is the empirical data that proves AC 91-57 type sUAS OPS are
unsafe?
• If we are to be held to the same level of safety as manned
aviation, what is the relative differential? (size/weight/speed how does
10-6 apply, if at all?)
• Required “data” yet to be identified/quantified?
• Are these arbitrary operating envelopes viable ( e.g. 400’ AGL) for
empirical data gathering and business?
• Can a Data-set be captured in this small of an operating envelope?
• Do we fit the definition of comp and hire? 14 CFR FAR Part 1.1 and 119?

7. Consequences
• Lack of empirical data gathering.
• Too onerous = Lack of compliance
• Regulatory apathy/denial
• Law abiding operators locked out
• Airspace safety suffers
• No closer to a workable solution
• Operators not purchasing
insurance
• Investment in technology will
suffer

8. Post sUAS ARC and the Road Ahead
• Testimony by RTCA President Margaret Jenny
to the House Aviation Subcommittee
- No reference to UAS. RTCA timeline for commercial UAS in
the NAS is out to 2018.
• “Not in my Airspace!” J. Randolph Babbitt
• F-38 participation has an overall lack of
objectivity and a feigned sense of regulator
involvement.