EAA Responds to Amazon Petition: All Areas of Aviation Safety Must be Priority as UAS/drones Integrated into Airspace

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Safety for manned aircraft in all areas of aviation, including those operating at lower altitudes, must be the priority for federal air regulators as they consider an exemption application by Amazon regarding package deliveries by unmanned aerial systems (UAS). The Experimental Aircraft Association made those remarks in its formal comments to the Federal Aviation Administration in response to Amazon's petition.

EAA has welcomed Unmanned Aerial Systems of all sizes and complexities to its EAA AirVenture Oshkosh fly-in convention for several years. (EAA photo)

EAA is not opposed to integrating unmanned systems into the airspace, as long as they observe appropriate safety protocols and do not lead to additional regulations and mandated equipment for manned aircraft. In addition, manned aircraft must have the right-of-way in all circumstances.

Safety for manned aircraft, not commercial expediency, must be the priority for federal air regulators as they consider an exemption application by Amazon regarding package deliveries by unmanned aerial systems (UAS), noted the Experimental Aircraft Association in formal comments to the Federal Aviation Administration.

EAA made the comments in response to Amazon’s petition to the FAA that requested relief from certain rules in order to conduct deliveries by UAS, commonly known as drones. The exemption would allow Amazon additional freedom to operate below 400 feet above ground level (AGL) without the line-of-sight observation requirements for UAS operations.

“There is an asymmetrical challenge to safety as UAS flights are integrated into the national airspace, as the priority must be preventing hazards to people in the event of a collision over threats to unmanned machinery,” said Sean Elliott, EAA’s vice president of advocacy and safety, “EAA is not opposed to integrating unmanned systems into the airspace, as long as they observe appropriate safety protocols and do not lead to additional regulations and mandated equipment for manned aircraft. In addition, manned aircraft must have the right-of-way in all circumstances.”

In addition to reaffirming EAA's long-standing position on UAS integration, the organization’s comments give specific examples of various types of flying that takes place on a regular basis below 400 feet AGL, where Amazon intends to operate. Those operations include ultralight vehicles, private airports and helipads, emergency medical flight operations, backcountry flying, seaplanes, and flights over open water or sparsely populated areas. This affirms the need for extremely reliable sense-and-avoid technology aboard unmanned systems that can detect any and all manned aircraft.

“While we are pleased that Amazon stated in its petition that it must demonstrate an equivalent level of safety to ‘see-and-avoid’ principles of manned aircraft, we urge the FAA review and confirm Amazon’s risk assumptions are accurate and its redundancy procedures are as vigorous as those for manned aircraft,” Elliott said. “It is the responsibility of every entity using the airspace to maintain the equivalent safety standards as we explore the opportunities and benefits of this new technology. The stakes are too high for any alternative to be acceptable.”

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Dick Knapinski
EAA - The Spirit of Aviation
since: 11/2009
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