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An Open Letter to the New FAA Administrator, on Drones BY JAMES POSS, MAJ GEN (RET)

On Wednesday, September 11, 2019, Major General Poss (ret), USAF, published an open letter to the new FAA Administrator with suggestions for optimizing the business growth of the Drone industry. General Poss is a leading expert on UAS and is CEO of ISR Ideas, an intelligence, unmanned systems and cyber warfare consulting company. Owing to the letter’s length, portions are excerpted, here. Click here for the full text.

An Open Letter to the New FAA Administrator, on Drones BY JAMES POSS, MAJ GEN (RET)

New Administrator of the Federal Aviation Administration Stephen Dickson. Photo: FAA.
Victory! We finally have a former Airman appointed Administrator of the Federal Aviation Administration. And not just any Airman; Stephen Dickson is an Air Force Academy grad AND a former F-15 pilot.

Dear Administrator Dickson,
An Open Letter to the New FAA Administrator, on Drones - Inside Unmanned Systems

Use research better: ASSURE, your unmanned center of excellence, has done a great job with its tasks. Its drone air and ground collision work are world firsts. However, it takes forever to clear research tasks through your staff/DOT to get ASSURE working, and ASSURE can help much more with some of your big problems, like remote ID, training/airworthiness standards and C2 spectrum. Cybersecurity for autonomy is a crucial area that you can get ASSURE working on now.
Your Test Center in New Jersey is also underutilized. It’s doing great work, but it’s mostly for manned aviation. Research is your long-range radar; you can’t fight BVR if your researchers aren’t looking at issues before they become problems. Also, please make sure you use research to write rules.

…Recommend doing things the NASA way. Invite a lot of people to write your concept of operations (CONOPS), give a lot of feedback as they write it, hand the hard part over to researchers and leave no doubt in stakeholders’ minds as to why their idea was brilliant—or stupid.  …Get some straight stats from the staff. Don’t ask how many waivers they’ve approved; ask how many they’ve turned down. For example, the approval stats for drone night ops are great, but terrible for beyond visual line of sight (BVLOS) and operations over people. …Congress told the FAA to start giving feedback on all waiver refusals and that’s a great idea. When you turn down 90% of waivers, it’s not the writer’s fault; a feedback loop is broken somewhere.

…Ask why we can’t do Red Flag waiver debriefs and tell everyone how to get better.
Beware the triad: This triad isn’t a Chinese crime gang; it’s an attempt by the Communist Chinese to take over drone traffic management and remote ID in the United States. Communist Chinese companies own more than 80% of the US consumer/prosumer drone airframe market and are using this position to take over the other two legs of the triad—unmanned traffic management and remote ID. …The CIA can brief you on the Communist Chinese plan to dominate key tech sectors. NSA has a great demo on what an adversary can do if they make the chips, firmware and software. It’s sobering.

…Want a safe and secure UTM? Write security into UTM and remote ID rules. Security must be “baked in” at the design phase to be effective, so you must work quickly. You have an Executive Order from President Trump that gives you all the cover you need to act on keeping hostile nations out of our networks.

UTM will take over the earth: No one has fielded a fully automated air traffic management system yet, but UTM will work and it will be automated. Right now, your staff is letting industry lead UTM development.  …Recommend that even though the FAA won’t own the UTM infrastructure, you will set standards and ensure they’re enforced.

It’s the data link, stupid: Sorry about the title, but command and control (C2) for BVLOS is a mid-air waiting to happen. EVERYONE one wants BVLOS but no one is thinking about the C2. The Air Force makes BVLOS look easy because it can afford SATCOM and has plenty of military bandwidth to use. But once you subtract military bandwidth and cell phone spectrum, there ain’t much spectrum left for commercial drone C2. …BVLOS links/autonomy are a great problem to turn over to your research folks and convene one of those big NASA-style CONOPS conventions.
   Remote ID: I’ve heard that the draft rules went to the Office of Management and Budget and the rules require all drones over 250 grams to have remote ID. That’s great! Everyone must have remote ID or we’ll never be able to tell hobbyist from terrorist. ASTM International has already produced a great remote ID standard for you.
   Operations Over People: The FAA draft Operations of Small UAS Over People was a swing and a miss. You can easily fix it by getting with your ASSURE team to get the ground impact numbers correct and by removing the prohibition on small drone flight over moving vehicles. The rest of the rule is pretty good.
   Large UAS in the National Airspace: We had great aviation rulemaking committee meeting on this subject and everyone (even the Air Traffic folks) agreed to use modified USAF procedures for flying drones over 55 pounds in controlled airspace. That was two years ago and your staff has gone NORDO on large drones since. Can we see some draft rules, please?
   Counter Drone: Congress gave you a lot of guidance on counter-drone operations. Recommend you move quickly on it. Congress told you to do a Counter-UAS ARC, but how about a big “open tent” counter-UAS CONOPS meeting first?
Sensible Automation
…It’s popular to talk about getting government out of the way of industry, but this is one industry that won’t progress without your rules. …A single drone squadron at Creech AFB routinely flies more hours annually than all the fighter squadrons in PACAF (Pacific Air Forces). Automation, autonomy and drones are the future, and you can do a lot on your watch to make that future happen safely, securely and profitably!
With Respect,
James Poss, Fellow Air Force Vet

 

Thanks to CDR David Place (USN/Ret), davidplace47[at]gmail[dot]com, and Robin E. Alexander, President ATC, alexander technical[at]gmail[dot]com, for their assistance with this report.