There have been some exciting announcements in the world of drone deliveries lately. The announcements come more from the FAA than from the tech companies, as there have finally been drone deliveries in the United States.
Is this the beginning of crowded skies delivering our food, drone parts and new socks, or is this just a fad? You and I know drone deliveries can be a sustainable technology, and obviously companies like Amazon, Google and USPS think the same with their projects, but it really comes down to the laws. Let’s explore.
The FAA rules for drone delivery
The FAA, and similar government entities in countries around the globe, have control of the skies. They say where and when any aircraft can take flight with detailed airspace maps and guidelines. Drones are a special case for the FAA, as a law for a toy in the backyard is often governed by the same rules as an inspection drone or a machine making a package delivery.
The rules at this point are straightforward, with several that all but eliminate the viability of drone deliveries, but exemptions can be made, under the right circumstances.
See also: No Drone Zone
Before we dive in, some entertainment:
Delivery drones and BVLOS
The FAA demands a simple rule of all drone pilots, hobby or commercial, you must be able to see your drone at all times while in flight. The acronym VLOS describes this, standing for Visual Line of Sight. Beyond Visual Line of Sight (BVLOS) is exactly what it sounds like, when your drone is in flight such that you can no longer see it.
Line of sight is very important for safety, if nothing else. We can fairly safely rely on the flight systems in a modern drone, using the telemetry and live stream video displayed on the remote control to navigate the drone. That said, most systems are prone to failures such as disconnections, then what? Autonomous modes can bring a drone “home,” relying on GPS for RTH functionality.
System operation and flight controls are only part of the equation. It is your responsibility as a drone pilot to yield right of way to any manned aircraft in the sky. No exceptions. If you cannot see your drone, how do you know that you are not on a collision course with a metal tube full of humans?
You must avoid a collision with a manned aircraft, can you do that if you can't see your drone?
A number of commercial drone systems and manufacturers have been working on sense and avoid systems and protocols. Airspace awareness is the first part, with some radar and other systems being used to vastly improve your time to respond. From there, what should you do when on a bad course, land? Go to the side? Go up?!?
Demonstrating to the FAA that you can avoid a crash will depend on your decisions for operation. It’s not always safe to land, going to the side may offer new obstacles and going up, believe it or not, is allowed if you can prove it was necessary to avoid any danger. We’re not here to debate this topic, but Google and UPS have, and they have been granted waivers from the FAA to fly BVLOS, congrats!
See also: FAA UAS drone rules explained: Part 1
Flight over people
You may feel the FAA is too strict with their drone laws, but they are all written for safety. This time around, the rule that you cannot fly over top of people is to protect folks on the ground. There has been debate what constitutes a danger to humans, and one of the resulting conclusions is that drones under 0.55lbs are pretty safe, while larger drones can mitigate the fall hazard with parachutes, protective bubbles and other fun ideas.
For now, the leading accepted safety measure is parachutes. Teams like Indemnus have bolt-on solutions for many drones, but many commercial manufacturers have similar systems as well.
Ultimately, the goal is to never fall from the sky. Proving the efficiency and reliability of your flight systems is just as important as explaining your parachute when seeking a waiver for this drone restriction.
See also: FAA UAS drone rules explained: Part 2
Drone airspace restrictions
As I hope you are aware, the FAA has segmented the entire country into different classes of airspace, then added some additional restriction over top. If you happen to be in Class G airspace, you can take to the sky with minimal effort. Class G airspace is usually well outside of major centers, so if you live in a city, things change.
At your time of flight, you will need to request and receive LAANC authorization to fly in your desired location. Most LAANC providers assume you will be taking off from a single point, flying around that point within a few hundred feet and returning to that starting point.
LAANC can approve your flight, but what level of authorization do you need?
Likewise, the FAA has overlaid a grid for all controlled airspace, assigning maximum altitude restrictions for each location. It is impossible to receive authorization to fly in multiple blocks of controlled airspace, but it doesn’t help.
This is where logistics comes into play. If we pretend a delivery pilot cannot receive airspace authorization for controlled airspace, and that they cannot receive a waiver for BVLOS, that means that drone deliveries are ultimately limited to rural customers, and the pilot will need to be able to see the drone all the way to your yard. It is a rare case that a driver that is that close to your home anyway will warrant the time to load and launch a drone.
Further, if your town is like mine, Amazon has setup their warehouses close to the airports. Makes sense for ground transport logistics, but potentially eliminates drone delivery opportunities. To that end, your package would need to be delivered internally to an Amazon safe launch location, one that is accessible to your home through the various airspace grids. It is not for me to identify the viability of that, but it sounds like it might not be worth it for Amazon or for you. Still pretty cool though!
Altitude restrictions for drones
Don’t forget, you cannot fly your drone above 400ft altitude above the ground (AGL.) At what height will a delivery drone need to fly to get from the warehouse to your door? Ignoring the logistics of navigating buildings and radio towers, most drones set ground level at launch, they do not dynamically update as you traverse uneven terrain.
I often fly my drones at -80 feet. I take off from the top of a hill, then fly out and down the hillside beside me. The drones do not know that the ground has dropped away and they often react funny when they reach 0 feet, thinking they are about to crash.
Can your drone identify AGL changes when you go up a hill?
The hill effect, as I’ll call it, has two problems for legal flight. In the first scenario, if I launch at the top of a hill and fly up to 120 feet AGL, I’m completely legal. If I then fly out from the hill top, and the hill is 300 feet tall, all of a sudden I would be at 420 feet AGL and breaking the law.
The second hill problem is easier to understand. If I am flying in the valley at 200 feet AGL, I can then fly right into the hillside and crash the drone. If the drone is altitude limited, as most DJI drones are, then I would be entirely unable to get up over any hill that is 400 feet or taller. In the Portland area, this is a common obstacle.
There are many decisions to be made in terms of the best altitude to fly in a given area, and a huge technical challenge to ensure that the drone has accurate GPS, altitude and topography measures at all times.
At this time, there are no ground based airspace-claims to worry about, but there is a strong push to consider an amount of airspace above a property as owned by the property. That is perhaps incorrect, the potential rule is more that flying above private property can be considered trespassing. The number thrown around in these talks is 200ft. We have very mixed feelings on this, but if passed, would require delivery drones to remain in that small window of 200 – 400 feet above the ground.
Drop the package, or land the delivery drone?
Speaking of altitude, how high is your home? Perhaps the altitude of your dwelling is less important than the layout of your property, but a drone will need some serious autonomous abilities to ensure a safe landing in your yard. What if you don’t have a yard, can we just drop a package to you?
Allow me to over-simplify the current drone laws: The FAA basically says that you can’t drop products from a drone. The hazards to people on the ground are just too high. What if the wind blows the package out into the street, or worse.
There have been some fun package delivery control patents applied for, including a parachute system combined with compressed air to guide the package. Again, over-simplifying things, does that not make the package a sUAS itself? Once separated from the delivery drone, does the package then need its own airspace authorization and approved waivers, and a pilot?
For safety’s sake, landing the delivery drone becomes the safest and most legal delivery method, which will greatly limit the number of customers one can deliver to.
One pilot per drone
There is another logistical problem, PiC. Current rules are fairly simple, there must be one Pilot in Command for every drone in the sky. The PiC does not have to actually be piloting the drone, buy they must be involved in the operation, and they are legally responsible for everything that the drone does in the sky.
The logistics of sending out one delivery driver in a van with dozens, even hundreds of packages to deliver, makes perfect sense. The idea of handling just one customer per flight is wildly inefficient. Sure, you can likely hit two or three customers in a single flight, but not many more, and if you are tying up one or two people to manage that single flight, your man-hour costs will not be sustainable.
Relying on powerful flight management systems and ground control software is not unrealistic, technically speaking, but the laws are not there yet.
Perhaps with all the restrictions, drone deliveries should be used for the backbone of product transportation, not the last mile of delivery. A large drone could carry dozens of packages from a warehouse over to a hub for further distribution. The idea has merit, but the FAA still mandates a maximum take-off weight of under 55 lbs.
The FAA drone laws are for machines from 0.55 lbs up to 55 lbs.
55 lbs is a fairly limiting number when you are talking about packages. As is size, but that’s not a regulation to overcome, just a physical obstacle. I bet we’ve all received a box in the mail that was more than half filled with packing paper. I had one last week, my ordered product was no more than half an ounce, smaller than a pack of gum, but the box was large enough to hold a dozen flagship smartphones and weighed almost a pound.
It is possible to grow your drone beyond the 55 lb mark, but this requires an entirely new set of registration, regulation and certification to fly. As I like to over-simplify things, you basically now just have a helicopter. An unmanned, electric helicopter, sure, but I’ll let you tell me the last time a helicopter delivered a package to your house.
I also live in one of the rainier parts of the world. Let’s not talk about the hazards of the weather, as I assume drone deliveries just wont happen on bad days, for now. Instead, I worry about the integrity of the cardboard box when it gets wet. Not only can it fall apart, dropping my new toys to the earth below, but it retains the water, increasing the weight of the drone. It is unlikely that this increased weight will really matter, but it does make a difference for legal and battery life purposes. To avoid this risk, perhaps new packaging solutions are required.<