MIT Lincoln Laboratory Response to FAA UAS BVLOS Request for Comment
Andrew Weinert
Technical Staff @ MIT Lincoln Laboratory | Airspace Integration Expert
Today MIT Lincoln Laboratory responded to the Federal Aviation Administration request for comment on "UAS Beyond Visual Line-of-Sight Operations." I've included notable excerpts from the MIT LL response on the applicability of the ASTM F3442/F3442M–23 DAA Standard, well clear criteria, requirements within the Mode C veil, and shielded operations. I strongly recommend reviewing the entire comprehensive MIT LL response.
Links to request and comment
Applicability of the ASTM F3442/F3442M–23 DAA Standard (C1)
The ASTM F3442/F3442M–23 “hockey puck” should be applicable in the following circumstances:
Note that these circumstances extend the ASTM F3442/F3442M-23 defined scope, but align with the analysis used to establish the “hockey puck.”
It should not be used under these circumstances:
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Alternative well clear criteria (C2)
The ASTM “hockey puck” was defined as a relative separation where a desired unmitigated risk threshold is achieved and informed by operational acceptability. Accordingly, maintaining 2000 ft (horizontally) or 250 ft (vertically) separation can be viewed as a general mitigation to reduce collision risk but will not be operationally suitable in all circumstances nor does the simple “hockey puck” take advantage of additional information or mitigations. If the 2000 and 250 ft “hockey puck” was codified by the FAA, the FAA could permit exemptions if an operator can demonstrate that with additional mitigations or information that a separation criteria corresponds to a 10% or less likelihood of an NMAC because this would satisfy the key design objective and assumptions of the “hockey puck.” An alternative would be to grant an exemption to the LoWC functional and performance requirements from ASTM F3442/F3442M-23, with the exemption either changing the performance requirement or not requiring it all together
Requirements within Mode C Veil (E1)
General strategic deconfliction capabilities or procedures should be employed in all airspaces: this may include technical deconfliction capabilities or airspace constructs (e.g., operating altitude, location). No aircraft, including UAS, should be permitted to fly without mitigations to reduce airborne and ground risk. Specifically, strategic deconfliction services and conformance monitoring should be required within airspace classes A, B, C, and D and the lateral limits of a Mode C Veil because of the relatively high traffic density of crewed aircraft and complexity of the airspace around Class B airports and large metropolitan areas.
Conformance monitoring should not be required in Class E or G airspace, unless the operation requires strategic deconfliction and conformance monitoring to sufficiently reduce risk.
Operating Environments in which the FAA should not authorize shielded operations (G2)
Due to security risks, the FAA should limit operations in the National Capital Region airspace and near secure detention facilities. The FAA should also not authorize operations if the total risk near a specific critical infrastructure sector is not acceptable
If operating in airspace classes A, B, C, or D, or within the lateral limits of a Mode C veil, the sUAS operator should have ADS-B In surveillance capabilities, and land or operate closer to the obstacle/infrastructure if the shielded area is compromised.
To minimize risk to airport operations, shielded operations should not be authorized, in the near-term, within 0.5 nautical mile from the end of a runway for all types of landing facilities (to include vertiports/heliports). Airport based keep out zones should be judiciously implemented.
Applicability of 100' above and 100' lateral offsets from an obstacle for shielded operations (G3)
The 100’ above and lateral offsets is supported by evidence from a 2019 analysis of helicopter air ambulance tracks near buildings in Boston and a 2021 analysis of aircraft broadcasting 1090 MHz ADS-B near point obstacles and bridges.
Both of these evidence sources could also be used to justify offsets greater than 100 feet and the FAA should make a data-driven decision for defining an appropriate offset.
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1 年Looking for some answers that maybe you can help me with or lead me in the correct path [email protected]
Disabled USMC Veteran, Retired FAA, Air Traffic Management, Airspace, Safety Risk Management, Unmanned Aircraft and Aviation Security Expert.
1 年I am sorry as I truly respect the work MIT produce, but I have been integrating UAS since the mid 90’s and they are simply validating what we “FAA” new decades ago. The FAA is simply become such a lethargic agency. And it’s leadership is so reluctant and politically afraid of leading the world with new technology and aviation advancement to the detriment of its sole purpose.
Technical Staff @ MIT Lincoln Laboratory | Airspace Integration Expert
1 年Ufuk Topcu Mary Cook. The MIT LL response included "To minimize risk to airport operations, shielded operations should not be authorized, in the near-term, within 0.5 nautical mile from the end of a runway for all types of landing facilities (to include vertiports/heliports). Airport based keep out zones should be judiciously implemented. For example, a general 2.0 nautical miles or more separation away from ends of runways would encompass a notable amount of airspace and could hinder airspace integration efforts. Similarly, keep out zones based on civic features, like schools or hospitals, should be appropriately sized as an air or ground risk mitigation. For example, maintaining 0.5 nautical mile separation from all schools would severely restrict UAS operations and may not achieved the desired risk reduction."
Technical Staff @ MIT Lincoln Laboratory | Airspace Integration Expert
1 年DRONERESPONDERS (Charles Werner). The MIT LL response about shielded operations included "42 U.S.C. 5195(c) could be overly broad because the acceptable level of risk widely varies across critical infrastructure. For example, risks associated with government facilities are different than the risks to commercial facilities (e.g., stadiums). The FAA should determine applicability for each 16 critical infrastructure sectors defined by the Cybersecurity & Infrastructure Security Agency (CISA) (https://www.cisa.gov/topics/critical-infrastructure-security-and-resilience/critical-infrastructure-sectors)."
Technical Staff @ MIT Lincoln Laboratory | Airspace Integration Expert
1 年Acubed (Scot Campbell): The MIT LL response included "Metrics are required to assess the performance of a UA-to-UA DAA system, and should be consistent to ensure interoperability and performance. One metric should be analogous to an NMAC for encounters with crewed aircraft and this UA-to-UA metric could be (but is not required to be) related to incident investigation and hazard severity like an NMAC, as codified in FAA Order 8020.11D. As discussed in response to question C.2, to evaluate encounters between UAS each with a maximum dimension of 25 ft or less, RTCA DO-396 employs a smaller NMAC (sNMAC) metric of a simultaneous loss of 50 ft horizontal separation and 15 ft vertical separation. The FAA should assess the applicability of the RTCA sNMAC criteria for both DAA evaluation and incident investigation, and if applicable, update FAA Order 8020.11D to include an appropriate sNMAC criteria."