7.0 Conclusion

Conclusion

When policy recommendations are put forward on critical national issues, industry and government often have predictable responses. Industry says, “This is so important we can’t wait for the government.” Government replies, “We don’t have the resources to accomplish these measures.” Conscious of this dynamic, the imperatives and recommendations set forth in this report are designed to leverage the large body of existing work performed by the FAA and do not need to be cut from whole cloth.

To date, the FAA has approved well in excess of 8,500 deviations, exemptions, and waivers for UAS operators. In these, the FAA has made determinations of risk, approved best practices, judged safety cases, recognized operating procedures, and assessed pilot qualifications. Largely keeping these to themselves at the behest of industry. All of these forms a body of knowledge from which aeronautical learnings, means of compliance and safety protocols can be extracted and made available to operators. These can and should illuminate the path to a new regulatory framework.

But leveraging this treasure trove of knowledge will require mutual trust replace the wall of trade secrecy that surrounds and in a large manner drives the deviation, exemption, and waiver processes. That’s why very little information is made available on the federal docket or in waiver applications. While it makes sense to keep lines of software code proprietary, it makes no sense to keep the procedures, identified risks, and training that underlie these applications and petitions so.

That is why UAS regulation bears only passing resemblance to the rest of general and commercial aviation where everything is out in the open. Our aviation system would not be as safe and successful as it is if we didn’t share, publish, and engage in the peer review of the procedures that keep airplanes from colliding.

Greater openness as we bridge the gap will benefit the safety of the National Airspace System.