Originally published at: Industry Groups Weigh In on FAA BVLOS Rulemaking
Stakeholders outline differing paths for electronic conspicuity, right-of-way and detect-and-avoid during re-opened Part 108 comment period.
Wing Aviation states the obvious: broad mandates for non-cooperative detect and avoid systems add weight, cost and complexity. Wing wishes to avoid the absolute necessity of detect and avoid aircraft however they are equipped. These see and avoid rules and rights of way have been in existence practically since the time the first two boats collided on water and have continued to be the prime rule of the seas and now of the air. Wing and others like it wish to mandate EC systems to replace their see and avoid responsibility and obedience to standard navigation rights of way. They can pay the cost of installing, inspecting and maintaining every single one in every single aircraft including NORDO aircraft without electrical systems who fly the airspace outside of Class ABCD. It seems they are perfectly willing to add cost, complexity and risk to every single aircraft but their own. Broad mandates for non-cooperating manned aircraft are essential to safety and have been supported by over a thousand years of admiralty law. Airspace merely adds a third dimension. Once the BVLOS is fully permitted, how long to you think companies like this will take to completely saturate the package delivery BVLOS airspaces surface to 800’ AGL, in urban or rural or sparsely populated areas? The reason we have Class B/C/D/E airspace in the first place is because there is higher traffic density in those areas and that traffic needs coordination, whether from ATC or rights of way rules or pilot cooperation. To add aircraft exempt from cooperation is simply irresponsible.
The simple truth is that a manned aircraft pilot cannot see and avoid a small drone. I’ve flown several forest fires where I was told there were drones flying. It’s impossible to see them while circling a fire in a bank at 90 knots. The burden of avoidance has to be on the drone operator no matter whether the manned aircraft is squawking ADS-B.
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