Amazon requesting insane exceptions for its drones

[gtae07]

I'm not wholeheartedly behind their proposal, but (as is usually the case) actually reading the details presents a much different picture than OP would seem to present.

Specifically (and of greatest concern) Amazon isn't requesting to be able to ignore right-of-way rules and operate with impunity, all others be damned. Instead, they intend to meet the intent of the right-of-way rules even though they can't technically comply with the letter of the law:

Although our combined separation assurance systems do not technically satisfy the right-of-way rules in 14 C.F.R. § 91.113(c)-(f) as written (i.e., they cannot “see” objects), the aggregate of onboard sensor-based and off-board communication solutions, along with carefully screened operating areas, is an alternate means of meeting the intent of the rule. Accordingly, Amazon requests relief from these requirements.

Indeed, the rule is written with the assumption of a direct man-in-the-loop pilot seeing with the Mk.1 Mod 0 eyeball.


In the aircraft certification world, such things are accomplished through ELOS (Equivalent Level of Safety), which basically is approval from the FAA to meet the intent of a certification requirement though means other than the specified means. For example, the "old" Part 23 required the main fuel pump (on aircraft that needed fuel pumps) be mechanically driven by the engine. A hypothetical aircraft with redundant electric pumps could get around that prescriptive requirement using an ELOS, provided they showed sufficient redundancy and reliability. However, there is no such thing as an ELOS for the operating rules, and so they're requesting this through exemption.

It should also be noted that they do reference including sensors (presumably, cameras, LIDAR, radar, etc.) that allow the drone to perform the equivalent of "see and avoid".

Prime Air made the early program decision to prioritize creating the technological means by which our UA can remain independently safe and demonstrate the equivalent means of performing the SAA functions that would otherwise be the responsibility of an onboard pilot. This meant developing a highly reliable capability for the UA to independently detect and avoid another aircraft—both unmanned and manned, as well as obstructions and other objects, as opposed to a “blind autonomous” solution where the UA would be incapable of operating safely in an environment where emergent, unidentified obstacles may be present.

I don't have an issue with allowing them to operate without type certification--I believe that to be overkill for light manned aircraft, and absurd for drones. One might also note that even transport-category aircraft are sometimes granted exemptions from cert requirements (for limited time periods) in order to enable flight crew training, deliveries, early operations, etc.


I haven't really been able to dig in detail but as a whole it looks like a far more reasonable proposal than it first sounds.

 

[BBerson]

I didn't get the impression that the base "pilot" would have any visual "see and be seen" ability.
I think he would only be monitoring systems of multiple autonomous units.

 

[TFF]

You know the end discussion is not about technology or the waver. It is the degeneration of jobs because of technology pacing the way for lower wages forced by bottom line stock holders who whine to government they need help to make sure they make money from all citizens no matter. That discussion is not allowed on this site. I say don’t allow the waver. There is no real need. Everybody needs to get off their but and go to the store on their own.

 

[Charles_says]

When negotiating,(And that is what Amazon is doing),
one most always asks for more than one truly wants.
If they get it, fine. they just got a Big Plus!

On the other hand it's a bargaining chip ie:
Well, suppose I give back "A"? Will you then give me "B"?
One really doesn't care if they get "A" or not,
"B" is what they are really after.

Used that ploy, many a time!

 

[12notes]

I'm not wholeheartedly behind their proposal, but (as is usually the case) actually reading the details presents a much different picture than OP would seem to present.

Specifically (and of greatest concern) Amazon isn't requesting to be able to ignore right-of-way rules and operate with impunity, all others be damned. Instead, they intend to meet the intent of the right-of-way rules even though they can't technically comply with the letter of the law:
Indeed, the rule is written with the assumption of a direct man-in-the-loop pilot seeing with the Mk.1 Mod 0 eyeball.

The rule is NOT written that way. Read the regulation and that statement you quoted again. 91.113(c)-(f) do not mention anything about sight, that is the specific set Amazon defends using the "sight" excuse. 91.113(b) states "vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft.", but (c)-(f) are not dependent on (b), it ends with a period, not an ", and "

If they just requested an exception to 91.113(b) to relieve them from having to "see", fine, but an exception on (c)-(f) would excuse them from the responsibility of "avoiding". There is zero reason for an exception to 91.113(c)-(f). If they can't detect and give way to other aircraft, then they're not ready to be part of the airspace. It's not a reasonable exception any way you look at it.

It should also be noted that they do reference including sensors (presumably, cameras, LIDAR, radar, etc.) that allow the drone to perform the equivalent of "see and avoid".

Then they should have no problem giving right of way to other aircraft. The fact that they want an exception implies that they are not confident enough in their own technology to be legally liable for collisions with other aircraft, and should not be allowed to fly outside of line of sight or over populated areas.

Their 88lb, 60kt drone should have way more scrutiny to be operated over people outside of line of sight than an aircraft. The airworthiness certificate alone is too lax. An airworthiness certificate and 40 hours testing over unpopulated areas for every single drone sounds reasonable to me. After all, that's what we have to do, and their operation is WAY more experimental than the average kit builder. Letting them fly without one is wildly irresponsible.

 

[PW_Plack]

DJI has already announced all their drones will include ADS-B detection starting next year. It still relies on the human pilot for response to the detection of an imminent collision, but that's just a software upgrade away if they decide to implement it. (Probably can't right now due to 91.113.)

 

[BBerson]

EAA says they will protect our airspace from exclusive use rights given to drones: https://www.eaa.org/-/media/Files/AirVenture/EAA-Radio-Archive/2019/2019-07-22/Lily-Johnson-and-Sean-Elliot-1.ashx?la=en

 

[pictsidhe]

I eventually found the application and read it. Well, I skipped a lot of the marketese. It's a sales pitch aimed at non technical people (politicians?) rather than the FAA. I did notice that they only seem to consider certficated aircraft. Other than model aircraft fields, nowhere else did I see mentioned flying vehicles that are off the FAA radar. Such as ultralights, PPGs, base jumpers. Those tend to fly (or plummet) at below 400'. Exactly where Amazon wants to operate. They are often small harder to see, too. A base jump just isn't going to end well hitting an 88lb drone that may not be seen from hundreds of feet up. Since they will only avoid known model aircraft fields, that will become the only place that you can fly model aircraft. If Amazon get these exemptions, they will pretty much own all the airspace below 400'.

Although I saw several mentions of all flight below 400' except for safety reasons, I didn't see any safety reason given, but I did skip bits... I strongly suspect that they want an exemption from see and avoid as their technology does not yet match the Mk1 eyeball. They wouldn't need it if it was up to par. As for remote pilots monitoring them? Yeah, have a look at the Uber self drive car accident to see what would frequently go wrong with their low wage 'pilots' there.

 

[RonL]

The thought that comes to mind for me, is that Amazon will get what they need and so many drones will be used that many will drop to the ground for many different reasons and there will be a market where people will return them for a fee, like the deposit paid on old pop bottles, As a kid in the 50's this is how I got to go to the movies

 

[bmcj]

The thought that comes to mind for me, is that Amazon will get what they need and so many drones will be used that many will drop to the ground for many different reasons and there will be a market where people will return them for a fee, like the deposit paid on old pop bottles, As a kid in the 50's this is how I got to go to the movies

Dropping from the Sky? I see that as a recipe for lots of law suits... trespassing, property damage, personal injury, or PTSD, all either legit or contrived.

 

[BBerson]

Some will crash, get shot down, etc. But they likely do have a BRS.

 

[proppastie]

I was just told by a "drone expert" today that there already have been accidents in Australia and that will slow down the process......however as an Engineer and Designer I believe the mission is technically feasible in theory, however like the "self-driving cars" I doubt they have solved all the problems.

 

[BJC]

I wonder how the drones will avoid NORDO aircraft in the pattern when making a delivery to an airpark.


BJC

 

[Pops]

I wonder how the drones will avoid NORDO aircraft in the pattern when making a delivery to an airpark.


BJC

That is easy, just ground the NORDO airplanes. Not many and those are just poor pilots with no money and influence. Money talks.

 

[BJC]

That is easy, just ground the NORDO airplanes. Not many and those are just poor pilots with no money and influence. Money talks.

I’m afraid that you are right, Pops.


BJC

 

[BBerson]

Amazon proposal excludes all airports.