Comprehensive, deep agenda
Discussion of FAA safety, especially SMS, was exceptional
FAA Administrator (A) indicates that UAS sector will be held to very high safety standard
You have to congratulate Uber and its Elevate program. Since the publication of the White Paper three years ago, it has exhibited forward-thinking, patience to meet the safety/regulatory requirements, a perspective that includes local/national/international dimensions, attracting the best minds for its team and inclusion of all interested parties (even competitors) in its discussion of the issues. Its most recent summit was impressive in the scope and depth of the agenda.
To set the tone Kate Fraser, Uber’s Head of Policy, provided a comprehensive review of the regulatory path to market. Speaking first after the headliners (a clear indication of her topic’s importance), she outlined all of the FAA certification requirements and touched on the operational tests that will be faced under Part 135.
This presentation was followed by Elevate’s highly qualified Chief Legal Officer, Tony West, who spoke at length about his company’s dedication to safety in general. As to the future flight service, he pointed to former NTSB Chairman Chris Hart’s comprehensive study of the safety challenges and a report filled with insightful recommendations. He then explained that John Illson, Head of Aviation Safety, is fully dedicated to designing and implementing SMS and Safety Culture for the company using his extensive commercial aviation experience.
West and Illson then sat on a panel to discuss Uber’s investment in safety and the need to develop products to reduce risks. The impressive group included:
- Terry McVenes
President & CEO
Radio Technical Commission for Aeronautics (RTCA)
- Peggy Gilligan
FAA Assoc. Administrator for Aviation Safety (retired)
- Michael Quiello
VP, Corporate Safety
- Andreas Flaig
VP Corporate Safety/LH Group Safety Pilot
SMS, CAST, ASIAS, SMS, FOQA, VDRP, ASRS and a number of other existing systems were discussed in great detail. In fact, the commentary by industry and the FAA (retired) is an excellent primer on the new risk-based, collaborative, preventative and non-proprietary safety regime.
The lists of remaining subjects discussed included UTM, eVTOL, Technology and Innovation, Aerial Ridesharing, Food Delivery, Investment, Electric Power/Cells/Batteries/Energy Storage, Skyports, Autonomous Flight, Noise, Certification and testing, Community Management, Urban Airspace, Noise, eVTOL complexity, criticality, reliability, and safety targets and a whole host of Prominent Speakers.
A good mix of safety issues, but not the dominant theme.
Acting Administrator Elwell set the bar for the quickly developing industry in his speech. Yes, UASs are new, but the Administrator made it clear that this innovative flight does not get a pass, that the OPERATIONS OF PART 107 AIRCRAFT WILL HAVE TO MEET THE HIGHEST LEVELS OF SAFETY AS BEING EXPERIENCED BY THE AVIATION SECTOR. He said:
That’s the challenge – taking an industry of incredibly bright minds and fast-moving technology and joining that with a regulatory agency that wants innovation, but only if it can be safely brought into an urban environment.
It’s why we have come up with the crawl, walk, run analogy.
As I said earlier, the FAA can no longer just say no to a new entrant. We are evolving – and quite rapidly for us – into a more responsive regulator.
And just like with technology, the pace of our evolution is accelerating.
Back in the 80s when I got into the business, it was not unusual for the FAA to take five or six years to write a rule – do you have the patience for that?
It was fine to take 10-12 years to develop and certify a new aircraft type – do you have the patience for that??
As you know, today, with the tech eruption that is coming to the aviation world, product cycles can be measured in months.
We don’t have the luxury of so much time any more, but we have to ensure that safety is paramount. That cannot change.
So how do we do that?
We become a data-driven oversight organization that prioritizes safety above all else.
To do safety right, you have to start with a safety culture. A good safety culture produces the data you need to figure out what’s really happening.
If we know about errors, we can fix the processes that led to those errors.
A safety culture demands that we infuse that safety data into all of our processes from top to bottom—in a continuous loop.
When you think about how far aviation has come in a little more than a century, it’s hard to argue the point.
We’ve gone from barnstorming to a safety record that is the envy of all modes of transportation.
We evolve in our rulemaking by transitioning from prescriptive to performance-based rules.
A few years ago, industry helped us modernize Part 23 airworthiness standards for how we certify small aircraft.
Performance-based rules will ultimately form the backbone for how UAM vehicles will be built.
It is clear that Uber is ready for this exacting challenge. The drone industry will be judged by the FAA and more importantly by the public and Congress by the record of all—the large multi-vehicle, sophisticated company and the individual hobbyist. The media will not differentiate between an accident caused by the average person and a highly sophisticated operator. Even more discouragingly, the number of crashes are more likely to some from the drone flier who does not have access to SMS, CAST or any of that risk reducing information.
The value of Uber’s investment in those systems and the challenge of the Administrator(A)’s statement of expectations define a gap within the UAS universe. Collectively, the aviation safety profession needs to focus on
- Creating a UAS/UAM equivalent to CAST
- Establishing a UAS/UAM section on ASIAS and ASRS just for the drone segment to facilitate easy safety reporting and analysis.
- Convincing these new aviators that a Voluntary UAS/UAM SMS pilot program, like the FAA currently has for 145 and 135 operators, is essential for the long term freedom which these new-to-aviation pilots should adopt
- Creating an FAA hotline for reporting suspected unauthorized UAS operations
These are goals stated in very general terms. Many of the early drone fliers have let it be known that they do not appreciate regulation and frankly, the notion that the FAA can interdict any scofflaws. First, it will require a well framed marketing campaign to convince these INDIVIDUALS of the benefits of participating. A critical element of the SMS introduction (listen to the West safety panel to hear the importance of the trust predicate) is to assure that the system is non-punitive and highly likely to be preventative.
Also, it is essential to design the access to and use of these safety systems to be user friendly. Without a portal easily opened, the numbers of entries will be limited and the value of recommendations limited.
Thanks Uber for exposing so many elements to the tasks before the UAS sector. The standard for safety was well defined by your panels and then ELEVATED by the Administrator. There is much more to do and only we can do it.
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