By Mark Davis,
Most of you are aware that Special Rule 336 is under attack, primarily due to the explosion in drone hobbyists, not all of whom have been responsible pilots. There is also UAS ID, which will impose some requirement for automatic ID broadcast (although it is still TBD exactly how it will affect us). These are both long topics that I won’t try to cover here. But another less often discussed force might also affect our hobby soon – UTM, or UAS Traffic Management.
Commercial operations today require a Part 107 pilot to control the UAS and keep it in visual line of sight. Many of our club members are licensed under Part 107.
But at some point in the near future, commercial operations will be fully autonomous. A computer or artificial intelligence (AI) bot will be able to dispatch a drone to collect information or deliver a package, with the entire flight conducted by AI from start to finish. And with fully automated flight, many interleaving flights can be rapidly routed through the same area in narrow, disjoint corridors. It is not hard to envision a sky crowded with automated drones whizzing around delivering food, monitoring traffic, and executing hundreds of other use case.
In theory this would not necessarily mean Part 101e pilots (i.e., hobbyists flying under the 336 exemption) would have to do anything differently, but in practice there are reasons to believe that this will impact us eventually.
First of all, the traffic management interfaces conceived by NASA do include some messaging for Part 101e flights. And initial UTM test integration with FAA (which kicked off March 15) does include test cases for automated notifications and dynamic flight restrictions for Part 101e pilots. So far, both NASA and FAA say that this is just for generality, and the actual plans/requirements are not decided. But the test cases are there. You might at some point be required to do something before you fly, and have a means of monitoring dynamic restrictions in real time.
Secondly and probably more significantly, the airspace below 400ft will be more commercially valuable. The use cases are too long and varied to describe. But for just one example of what the future could hold, check out the video at this link.
This kind of air taxi service will likely start (soon) under existing VFR rules, but the clear goal is to remove the pilot and operate under some future generation of UTM.
Many other lucrative business uses are under discussion, all of which may eventually dwarf our hobby in terms of market size. Commerce may increasingly encroach on what is today a vastly under-utilized public resource: low-altitude airspace.
But what about Special Rule 336? Doesn’t it protect us from all of this? As I said, that is not the subject of this article, but briefly, Special Rule 336 is in jeopardy. AMA Government Relations has already raised the alarm about this through all their channels (magazine, emails, etc.). See their site for more detail, and please follow their advice about contacting our congressional representatives on this topic.
The AMA government relations team is doing what can be done for hobbyists. They have a great understanding and competence, and are looking for sustainable, realistic solutions. But, it is not easy to indefinitely hold back the tide of crowded skies and commercial interests.
So while irresponsible novices get the bulk of the press attention today, the real impact to our hobby may come from AI bots flying under UTM.