UAS Industry Safety and Profit Margins Depend on Bold Weather Policies and Solutions
Last week I attended and participated in the NBAA Friends and Partners of Aviation Weather meeting in Las Vegas. First, I want to acknowledge several folks who arranged for the Unmanned Autonomous Systems session—a full afternoon dedicated to this topic! Rex Alexander, Joel Siegel, Matthias Steiner and Matt Fronzak—outstanding job unmasking the elephants in the room on the challenges and opportunities for the FAA, NASA and Weather Industry in taking on this “unprecedented challenge.”
What is that challenge? Providing weather services that capture micro climates at the surface and above ground level in cities, suburbs and rural communities with varying degrees, but generally woefully insufficient, weather data measurements and granular weather predictions.
Here is the question posed to the group at FPAW during my presentation:
How do we enhance ubiquitous UAS/UAM operations…
…Through a risk-based UAS weather regulatory framework…
…With a 1 trillion dollar US deficit…
…That encourages rapid delivery of cutting edge sensing, predictions and weather analytics…
…Vital to accelerating UAS/UAM industry growth?
Some may see this as a solution looking for a problem. I heard this two years ago from naysayers that said “we have all the weather data we need on the internet!” In this time, the TruWeather team has been working with several companies, states and test ranges gathering a good deal of “in the trenches” intelligence on the ground. Listening to FPAW speakers last week, others are coming to the same conclusions as the TruWeather team. Is this “a the canary in the coal mine” moment? OK, maybe not that dire…but here are some thought provoking questions to get the juices flowing (with my initial answers for provocation):
- Can the UAS Industry operate with the current weather products available? Yes.
- Will they see greater parachute pulling and ground incidents than if more granular data existed? Yes.
- Will it matter? Depends on how the general public responds to such occurrences as operations scale and how it affects UAS Industry profitability and reliability.
- Will the uncertainty associated with weather and winds aloft impact operations tempo? Absolutely.
- Will this uncertainty drive up risk taking and conservative flight decision-making? Yes, both…some by the same operator in the same week (experience informs this.)
- What percent of the time when adverse weather and winds are a factor (translation: possible) will pilots sit on the ground when they could have flown? Experience pegs this up to 40% of the time without better weather data and analytics.
- Will the industry be happy with this cancel flight rate when they could fly if data existed to reduce uncertainty? NO…Air Force and Army pilots hated when they were grounded unnecessarily and it did not cost them a penny out of their pocket. For the record, I was responsible for several Air Force organizations that supported over 500,000 pilot briefs in total and we never had a known weather related incident—a tribute to the professional men and women serving these pilots.
- Can UAS weather reports solve the “uncertainty problem? Partially, but keep in mind, there will not be many UAS flying when conditions are out of air worthiness thresholds, and how will you know when conditions aloft have subsided? Or what about resource management and scheduling in advance? Real-time data may or may not well inform the planning process in dynamically changing weather events (this is where better predictions become key.)
The FPAW meeting was a crystalizing moment and here are my takeaways thus far:
Establishing weather policy and standards for UAS weather are significantly lagging when compared to other UAS areas such as remote ID, detect and avoid, communication protocols, UTM standards, etc. This is a potential industry growth inhibitor as a MIT Lincoln Lab study, funded by the FAA, concluded current aviation weather products are not sufficient to meet UAS Industry weather requirements. This is not a reflection of the work of the National Weather Service or the FAA…it is a bandwidth and resource issue.
The FAA has found that a segment of UAS pilots are inadequately trained on aviation weather for Part 107 operations, and especially Beyond Visual Line of Sight (BVLOS) missions—not all pilots, mainly those that were not pilots before they became UAS pilots. Those without the experience of flying themselves in weather.
The weather industry is behind the power curve in meeting the granular weather needs of UAS operating below 400 FT AGL. The same for servicing Urban Air Mobility (UAM) eVTOLs flying in urban canyons. As a member of the ASTM F-38 Flight Operations Sub-Committee, I am taking a particular interest in airspace volume reservations in adverse weather conditions. Adverse weather conditions are not defined the same way for small UAS as with manned aviation. Thermals will cause some small UAS to behave like gliders in certain conditions. Low level wind shear has been documented as a cause for taking down small UAS. The NASA TCL4 project in Nevada found that small UAS were impacted by thermals in dry conditions, with one incident where an aircraft was displaced vertically 200 FT by a thermal.
FAA Part 135 authority was recently provided for carefully controlled BVLOS missions. The question is whether there is enough weather service guidance for BVLOS missions that will experience ceilings and visibility in terrain. Experiencing Visual Flight Rules (VFR) at the take-off and landing locations does not mean the route will remain VFR. Fog in terrain or over water at a sub-grid weather measurement scale, not within the resolution of government weather analyses, will occur pretty regularly in cooler weather seasons. The same issue will happen with winds above ground level where a lack of wind measurements will miss wind shear and battery draining winds. As a friend at the FAA stated eloquently at FPAW, “How will operators meet weather requirements if they do not know what they do not know?”
The discussions during FPAW and side conversations indicate consensus that the weather industry and the FAA have work to do regarding small UAS and UAM weather policy and standards (although in my opinion, we have some time for UAM). The term weather industry encompasses government, academic, non-profit and private sector entities—it will take a team effort.
The team needs to focus on how we address these challenges BEFORE they impact UAS and UAM Industry accelerated growth cycles. The UAS industry should advocate and highlight the opportunity to enable industry safety, growth and reliability with better micro climate weather. Especially those that have been flying large scale visual operations and BVLOS for some time now and seeing the impact (you know who you are). I believe the technology, science, sensors, granular models, data fusion tools and analytics are available today in the private sector to tackle and solve low hanging fruit gaps at scale. We can significantly mitigate risk as government and academic researchers study and make progress on the thorny problems like winds, wind eddies and turbulence in urban city canyons. We only need to admit the elephant in the room exists, shed light on the challenge and get to work.
So what is a potential notional roadmap?
Let’s start by reviewing current Part 91, 107, and 135 weather requirements, assess the general weather knowledge level of the less experienced UAS pilots, review pilot weather training requirements, better document UAS weather sensitivities and collect UAS use case data to document gaps associated with a lack of micro-weather data sets. I would suggest government agencies add UTM, UAS and UAM weather and weather data collection and impact use cases in projects and programs.
Next, I propose that NWS and FAA weather policy and requirements decision makers study private sector solutions that make sense for rapid adoption. The goal being to safely lower the bar for entry to onramp private sector solutions through a risked-based framework predicated on “what is good enough for specific use cases”. This approach can accelerate weather improvements without significant government investment. It may require end-users to pay a nominal “weather” fee to optimize and improve industry ecosystem weather decisions. I am confident the ROI for cost versus reward will show up in less incidents and groundings, more flight time, higher client satisfaction and greater margins.
Finally, I suggest with data collected and analyzed from a comprehensive assessment of the suggestions above, we address pilot weather training deficiencies, strive for a risk-based UAS weather regulatory framework, and incentivize private commercial companies to provide calibrated and validated commercial weather observations, predictions and weather analytics to close the micro weather gaps.
As the National Weather Service Science and Technology Director between 2008-2012, we never acquired a dedicated funding stream to meet NEXGEN weather requirements. No government agencies (DOC, DOT, OMB) were able to fund the requirements, and now finally, CSS-WX is coming to fruition 12 years after it was initially conceived to support NEXGEN. Unfortunately, with a trillion dollar deficit, I do not see how the government can respond to UAS weather challenges and requirements rapidly enough, without bold policies and solutions, to enable the safe and productive growth of the industry we all hope to see. It will take a team effort and we need to accelerate addressing the challenges and opportunities now.