Safe Integration Affirmed by EAA in Response to UPS Petition

September 12, 2019 - EAA expressed concerns in comments filed on Wednesday in response to a petition by UPS detailing the company's Forward Flight initiative, which contains plans for unmanned aircraft system (UAS) operation beyond visual line of sight without reliable sense-and-avoid systems.

"The visual observer principle established in Part 107, as well as the FAA's rules on model aircraft, is a well-proven strategy in avoiding conflicts with manned aircraft and other UAS," the comments state. "If UPS FF seeks to move away from this principle, some other means of actively detecting other aircraft must be employed — either through onboard sense-and-avoid as other petitioners have proposed or some type of ground-based sensing system along the route of flight. Flying a UAS in the NAS without any way to monitor other aircraft is not consistent with the concept of integration."

In addition to reaffirming EAA's long-standing position on UAS integration, the comments note that even in suburban and urban areas, there are aircraft operating below 400 feet AGL, and that other areas can contain traffic such as helicopters, ultralight vehicles, and aircraft flying from backcountry areas and uncharted private airports.

EAA will continue to closely monitor this issue going forward, to ensure safe integration of UAS users into the national airspace. Find the comments made by EAA in their entirety below.