by John Surmont
Some might say, "well that proves the point that the FAA needs to regulate it...like manned aviation!"
I disagree strongly.
I believe that this is the equivelent of a good old fashioned Gold Rush.
The bad news is that there is an arbitrage of information that could marginalize the opportunity this industry represents and that's a shame.
The good news, however, is that there truly can be room for everyone to prosper if this industry is allowed to form and become healthy.
Because the means for this industry is access to the airspace over our heads. Yep, it's simply the air we breathe all around us - and there's lots of it and it's not just concentrated in hard to reach rural or wealthy metro area's or controlled by one group and that to me is revolutionary and holds tremendous promise for our country and shouldn't be diminished or marginalized.
Here's what I mean:
Lots of people involved in small unmanned aerial systems (SUAS) believe that the unmanned systems are solving the problem of flying a small $xxx dollar camera around by flying it around on an $xxx,xxx small unmanned system - which is absolutely false and ridiculous.
When you think about it though, you might be able to understand why this "background of obviousness" might exist. Think about it this way.
- Manned Aviation primarily solve the logistical problem of moving things around that are physical and have mass such as people and stuff.
- Unmanned Systems primarily solve the logistical problem of moving information around.
- Unmanned systems are information technology systems that are expeditionary in nature - they can go anywhere, anytime.
- In the digital age, information is now taken for granted.
- We're in the meta-digital age and meta-layered information ("big data" vis a vis - information with context) is considered (and is proving to be) highly valuable.
- Unmanned Systems are giving people a very early glimpse into a world where real-time 'meta-layer' information coverage exists and it’s only the beginning…
I also wrote a brief narrative with a sketch about where I believe the SUAS industry (and therefore the vision for it) needs to be positioned here.
Think about it this way, here's how the current (de facto) "FAA Centric" proposed process might work.
Someday (whenever that actual day is is to be determined) an SUAS (Small Unmanned Aerial System) aka "small drone" end user will be qualified to operate said equipment by the the original equipment manufacturer and granted permission to operate the equipment by the FAA while he or she provide's a (in this instance public service) to the community and is paid a salary by said community to operate said equipment as a course of their professional duties. (In this instance) This equipment was purchased through public funds (be they local taxes, debt instruments, state / federal grants, or some blend thereof) from an original equipment manufacturer (OEM) or a reputable reseller and accordingly has been certified / approved for use by the FAA and requisite to this the equipment will adhere to some type of manufacturing and airworthiness standard in a way that is acceptable by the aviation industry and Federal, state and local regulatory agencies.
OK. First of all I am not going to go into the existing "band aid" workarounds that are in place to give military suas tech or first responders "emergency access" to the National Airspace System (NAS). This is not scalable and clearly untenable for the existince of a large commercial market. It's a stop gap measure.
My intent is to squarely focus on a truly accessible commercial SUAS market and the point is that if the FAA centric approach to SUAS NAS integration were to become the de facto policy the individual's and their local level municipalities ("communities") themselves are essentially left out of the opportunity for each to become a stakeholder (and participate in some way) for the sake of economic development, etc...
And why is that?
The FAA centric approach to SUAS NAS integration is what amounts to be a form of "imminent domain". And it's a tightly held and secretive process conducted behind closed doors with very little if any local municipal involvement.
Think about it this way, If an oil & gas operator or telecommunications provider wanted temporary, semi-permenant or permanent access to space in a community they'd have to provide compensaton or at least be granted permission, correct? There are processes in place today for this to happen, so why should operating SUAS equipment be any different?
Why is it that the "de facto" approach is through the FAA? The technology in question are small unmanned aerial systems - FYI, there are still questions as to what defines "small" - is it smaller than a "grey goose?" or something else? The thinking is that if a 25lb grey goose flies freely in the sky (without asking for permssion), can't a small drone with appropriate failsafes, trained operator, certification, etc... that weighs less than 25lbs operate safely as well?
Is it truly best for the American people that a Federal Agency grants permission (and access) to commercial or government entities to operate manned aviation to be the exact same organization responsible for regulating and granting permssion for small high tech products to operate as well? Or is this biased thinking based on archaic, legacy systems and technology that quite frankly is impeding progress and advancement of this industry.
Are we the American people to also accept that this same agency will then grant permission for commercial and government agencies to operate/employ (or purchase services through said commercial service provider) - over every inch of our nation - an in no small part over low resource density communities which will then effectively eliminate or bypass the specific community's (or individual's) opportunity to benefit financially in any form?
Seems to me like this business model has an imbalanced economic incentive and that's no good for anybody in the long run.
Rooted deeply in every human being's brainstem is the hardwiring to respond to incentives. So, where is the incentive for local municipalities ("communities")? Seems to me they are seen as sources of revenue as customers, end users and beneficiaries of the capabilities, but they aren't seen as someone to be included in the process (or even the product sale or service transaction). Again I ask why?
I am of the opinion that this is an incentive that needs to be explored and not simply dismissed or ignored. Especially since on the one hand the production and manufacturing of these SUAS products or the delivery of such services will likely be based, concentrated or clustered in certain area's with high resource densities of academic, science, technology and engineering resources as well as access to federal/military requirements, decisionmakers and the associated funds - while on the other hand, this equipment will be used in (ostensibly) every area and quite possibly with the highest demand in those area's with the lowest resource densities.
The point I'm making is that the existing and proposed processes and policies produce an economic incentive and benefit that is too concentrated (unbalanced) and in the hands of too few right now and needs to be extended, expanded and rebalanced.
AT LEAST ONE TEST SITE IN EVERY STATE SHOULD BE THE MINIMUM. Period. And that's only the beginning wth an eventual goal (with ambitious timetables and economic diversity objectives) to blanket every inch of US soil to be made available for safe commercial (and consumer) SUAS activities and flight operations. This industry growth or accessibility shouldn't be limited or predicated by the ability of the FAA to staff airspace managers to be doling out COA's (certificate of authorization WAIVER's). There shouldn't be a waiver - it should become status quo - not an exemption based process.
This also eliminates any infighting to "get in early" as one of UAS test sites in the proposed six site plan.
I believe that in addition to the other already involved constituencies that the FCC and telecom industry (and eventually consumer tech industry) needs to be better involved and included in understanding and helping in the development and building the requisite "infrastructure" and even lend a hand in considering alternative business models and other incentives that truly enable this industry to become healthy and prosperous and all inclusive - as well because they have learned critical and important lessons in building their own industry's (in conjunction with federal regulators) infrastructure in every US community and they have developed the systems, processes and the means to effect the emergence and growth of this industry. (i.e. radio spectrum - vis a vis "airspace") Why can't our industry look to them for advice, lessons learned, etc.. for truly enabling the emergence and growth of a large, healthy and open SUAS industry that becomes something truly substantial and directly beneficial to all involved.
Why should and since when did SUAS tech get a pass from these issues, concerns and most importantly opportunities?
The Power of GroupThink and Reality Distortion
In October 2010 I attended a conference in San Diego, CA and publicly advised the AUVSI representative on one of the panel's that this was thin ice for AUVSI and that the organization needed to be very careful in how it promotes the "promise" of a free and open national airspace system. My comments were received well by some and I was even invited to speak at a few meetings post conference, however the sense that I got from others was that I was "making waves" or "rocking the boat" and not contributing to the overall effort to produce "feel good narratives that promote interest and involvement" and to continue to find ways to foster cooperation with the FAA, which was believed to be needed at the time.
I was essentially cautioning the group that this was a dangerous trap and that full disclosure to anyone considering an attempt to enter this nascent space was the only credible course of action forward for the association as a whole. In other words, any industry or association representative must ensure that:
- Fidelity in their messaging that all is not well and their is danger ahead and no guarantee that the market will open in a timely fashion.
- This must be fully disclosed and also discussed in these conferences to equip attendee's with the bottom line information so they can plan accordingly and not end up surprised or devastated at some point when they realize how difficult it truly will be for them to bring their products or technologies to market.
- This industry group has decided on behalf of its membership to yield to the authority of the FAA as the manned aviation regulator to then grant them by default unmanned aviation proponency.
- That the consequences of taking this position mean that the possibility of accessing paying customers in the US commercial market is in the hands of a regulating body who views unmanned aviation with suspicion, as a niche industry, and as a very low priority.
I'm sure there's alot of "gnashing of teeth", shock, frustration and quite possibly even fear - right now about the latest reality check vis a vis the FAA decision to suspend site selection for UAS airspace integration. I get it and feel for the inventor or entrepeuner or small business owner betting that this market will have opened to them by now. As one of the early early contributors of SUAS tech in the US Military and Special Operations and Naval Special Warfare communities, all I could do was sigh and shake my head in amazement at the bizarre display of how devastating groupthink can be. The Unmanned System caucus is the latest case in point.
This was a predictable scenario because the present vision for the SUAS commercial market is way too small relative to it's actual impact and promise which is much too large for one constituency or group to control and here are just a few key distortion field and reality check talking points that need to be carefully considered as this industry evolves and (I hope) eventually gets it's footing.
Distortion vs. Reality (Part One)
1. Guarantee'd certainty Distortion: Investors and business love predictability. They thrive when they have it and fall apart when they don't have it (or realize they never did have the sure fire where, when, who, how much and how long answer). This has put pressure on those in the SUAS industry to establish timetables for commercial market revenue generation which has been wildly optimistic and is frankly one of the primary enablers for the disfunctional state of such a young and still forming industry. Rushing to show that as the wars draw down and defense spending cuts take hold the commercial market opportunity will "take up some slack" is simply wishful thinking and unfortunately a narrative that many investors (and analysts) have bought into based on the naive notion that they can exploit the existing information and access arbitrage much like they do with other successful investment decisions they make - except it's not working in this instance...
Reality Check: While it sounds great and provides an enticing narrative for selling, Basing the emergence and availability of the SUAS industry on effective and successful transition of SUAS military technology into domestic and commercial applications while carefully addressing all constitutional concerns AND tasking a federal agency (the FAA) with an additional and frankly lower priority task (key point is that the FAA is focused on Manned aviation first and always will be - as they should be) to serve as the proverbial "gatekeeper" and then produce a core standardized policy to enable a commercial SUAS market is a daunting challenge and rife with risk and is not a guarantee'd strategy for success.
In my humble opinion, I believe this effort and opportunity is akin to organizing and inventing systems and processes to put a man on the moon and it needs to be taken just as seriously because it can have the same kind of economic benefit to our nation as it should.
No matter how much pressure is applied this industry cannot be created and opened by attempting to eliminate every risk, providing guarantee's for profitable business creation, imposing the will of a few through political access, changing the color of something, or adjusting the product/service bill of materials therebye developing an alternative pricing scheme.
This effort requires MUCH MORE creativity, imagination and effort in the form of thoughtful and rigorous debate, discussion, analysis and action from every constiutency to include innovators, small business owners, entrepeuners, small, medium and large manufacturers, service providers, regulators, policy makers, end users, customers, private citizens and privacy advocates and most importantly local municipalities ("communities"). How many times must we as American's learn and relearn the same lesson: That it's always best to buy and build and stay local. Enabling local communities to participate is not just happy talk - it's crucial.KEY POINT: This isn't a matter of "selling" people on spreadsheets and business cases about end unit sales forecasts and manufacturing jobs creation (which are important - but must be beneficial to most and not just a few). If left to the existing proposed path will produce infighting between states for the economic development opportunity of these actual manufacturing activities - which will as a result of the proposed "six site plan" end up concentrating/coalescing around these "magical" places.
I'm all for competition and free markets - however the existing proposed approach is NOT THAT and gives too much power to too few creating a dramatic imbalance resulting in a SCARCITY (FEAR) Based strategy - "there won't be enough" thinking - which limits and restricts imaginative thinking of many many smart, innovative and capable people in the United States and what we end up with instead of growth, health and prosperity is a small, niche and disfunctional industry.
2. "Trust us" Distortion: "Trust us we know what we're doing because we've been doing it with manned aviation for decades."
Reality Check: Not one group or technology provider or organization or regulator or policy maker or privacy advocate has all of the answers about developing a true commercial industry, and therefore by it's very nature huge uncertainty as to when, how and where this market can and will emerge remain. Saying (or believing) anything else is not only poor taste but bad optics and downright dangerous and to draw parallels between a small unmanned aircraft and a manned aircraft is plain and simply put - crazy.
3. "It's a chicken and egg technology problem" distortion: Many in this industry and the FAA believe if they could just build (and control) the right sense and avoid "magic pill" technology that everything else will fall into place and the skies will be safe and open for business.
Reality Check: NAS integration shouldn't become the "technology/product looking for the problem/market entry point". Every problem isn't solved by a "magic product" - and in the case of the lack of a coherent SUAS commercial industry - it's blatantly obvious to most observers that this is not about a single technology and more and more of a people problem and that the lack of National Airspace System (NAS) integration is a great case study of this point and to ignore this will simply prolong the limited size and scope of this market and that confronting this systemic groupthink can allow for the establishment of a large, healthy and vibrant commercial and (my greatest hope - consumer market) for SUAS technologies, products and services.
4. "Existing business models and business processes will work" Distortion: This belief is that once permission to access the NAS is granted (I and many other's are still fuzzy on who gets permission and how and when and where they get this permission and how long this permission will last) that business will boom through product and services sales and communities will embrace the technology whizzing around their heads because of all of the opportunity that will be created.
Reality Check: Although we're still in the "horse and buggy" stages attempting to overlay a manned aviation process is also disturbingly unimaginative as is simply hiding under a rock or ignoring these issues. Additionally, because people respond to incentives there is a huge incentive imbalance between the FAA, technology industry and private citizens that is the largest single roadblock to a true widespread adoption curve for these kinds of technologies and must be addressed in a coherent and inclusion fashion. If this can be effected quickly then that's even better, however all stake holders (witting and unwitting) must be included.
5. "Just increase pressure and it'll get done" Distortion: The FAA centric proposed "six site plan" is good for American interests and will benefit all and we'll decide how and when and which states this will initially occur in private. But it'll be good for everyone. Don't worry about it. Let's just get this pushed through.
Reality Check: If this were the case then why are the actual "Six Sites" being selected in secret? Who's involved in selecting them? Why only six? Where are they? Who gets to make this decision? This should be a completely public and transparent process that isn't conducted in secrecy and is representative of the American people and not a monopolistic pooling of power, information and access.
Yes, I Believe that this is the equivelent of a good old fashioned Gold Rush. AND the good news is that EVERYONE has the GOLD - it's the air we breathe over our heads and not concentrated in the rural or metro area's or controlled by one group and that to me is revolutionary and holds tremendous promise for our country and shouldn't be diminished, marginalized or monopolized.