RCAPA uses the FAA UASARC charter as a basis for appeal and inclusion on the recently formed Advisory Rulemaking Committee (ARC) as an amended charter member. It is very apparent that the intention is to follow up on work from the sUAS ARC. The document in its entirety is of concern to the small business, academic and end-user communities. This oversight counters the espoused notion that the FAA is out in front in the Global Airspace integration effort, and only serves to raise more questions about leadership and management of the FAA’s Unmanned Aircraft Program Office.
The RCAPA has been a long-standing process contributor and sole voice for the small business community. All highlighted in the letter addressed to Associate Administrator for Aviation Safety, Margaret “Peggy” Gilligan.
(Letter attached, dated December 29, 2011)
However, the glaring issues contained in the UAS ARC charter document are as follows:
1. Sec 5.b reads, “Coordinate the resolution of any comments on related proposed rulemaking.” This ARC has a two-year time line. If past performance is any indication of pace for rulemaking, it would be near imposable for rulemaking to come out of this ARC for them to resolve comments from.
2. Four manned stakeholder groups are represented.
AOPA, ALPA, ATA and ATA. None for the unmanned community running counter to section 7.b which states “The FAA will provide participation and support from all affected business lines.”
3. Two representatives from defense contractor General Atomics. (Charles Sternberg and R. Scott Dann)
Many find it odd that the FAA would accommodate two representatives from one company, but not have room for representation from small business.
4. 8.b “The membership will be balanced in points of view, interests, and knowledge of the objectives and scope of the committee.”
RCAPA meets all of the aforementioned criteria.
The second page is the list of Congresspersons, FAA, and news outlets, et al that are in the process of being contacted on behalf of the U.S. UAS stakeholder community.
I first got wind of the UAS ARC at UAS 2011 in Paris, at what many consider the world’s premier regulatory conference. Without a doubt, the must attend symposium for anyone with a stake in the Global Airspace integration effort. Unfortunately, there was no representation from the FAA UAPO this year for us to make inquires about ARC membership and charter. Puzzling as the charter clearly states, “In concert with the International Civil Aviation Organization (ICAO) UAS Study Group and other international organizations, harmonizing certification, operations, procedures and standards to support and facilitate the global aspects of aviation operations and unmanned aircraft production.” The official reason was budgetary but… If you’re going to assume the lead you’ll have to do better than that.
In American football, this would be called fumbling the ball. In this case, it amounts to a stakeholder community being disenfranchised from a “public” process.
To be continued…