Panel: Drones Regulations and Incident Mitigation
The unmanned industry has exploded in the last few years, and with it, so has drone regulations. As a result, our Web Manuals drone community has grown at a fast pace and we are very happy to have some of them with us today to discuss drones for the first time at Go Digital!
Jon Hanlon, Zipline
I’m the director of maintenance and air worthiness for Zipline. Zipline’s mission is to provide essential medical products to every human on the planet. We believe that everybody should be able to have access to the vital health care products they need, no matter where they are in the world. And we’re working to that mission every day. UAS is a huge enabler for that, obviously, so it is sort of where we landed on our implementation.
In my role, I’m focused on maintenance and airworthiness, and specifically our current efforts in attaining certification in the US. That means partnering with our design and manufacturing teams and then also in my responsibilities as an air carrier, Director of maintenance.
I’ve been with the company now for over a year and been growing that team, really driving that programme forward. Prior to Zipline, I was at Amazon for nine years. A portion of that on the primary programme, and prior to that, a technical programme manager in e-commerce. Then, I also spent about a decade in the commercial airline industry, including Alaska Airlines.
We use Web Manuals for our operating documentation, all of our GMM GOM – to throw a few acronyms out there, but those that have involved themselves in air carrier certification will start to recognise some of those as the manuals that you use to the regulators in order to operate. We also do use it for some of our aircraft maintenance manuals and our flight manuals as well. So the interaction between the manufacturing and production, design aspects and our operations – we use Web Manuals across those areas currently.
Stephan van Vuren, Airhub
I’m from the Netherlands. My role within Airhub I’m a drone consultant and one of the co-founders. My personal background is in aviation, I used to be an airline pilot until I made the switch about four or five years ago when we started Airhub. At ERP, we develop software and consultancy solutions that enable companies to safely, legally, and efficiently use drones within their business processes.
We have a software platform, which consists of a SORA Tool, we’ll probably get to that down the road, but a SORA tool helps operators obtain their operational approvals. And our drone operation software enables operators to plan, execute and manage their flight, both in fields and even from the office over 4g or or 5g.
We currently use Web Manuals on our consultancy side where we assist operators in obtaining their approvals for setting up their operations manuals and other documentation, keeping this documentation compliant with all the other regulations – for example, ISO standards.
Alex Norman, Matternet
I’m with Matternet, since now, already more than three and a half years. My background is also from the manned aviation side and aerospace engineering. I was previously working also at Airbus in Hamburg, and, and then shifted a little bit more to the unmanned world. I basically started back in 2017, with the first beyond visual line of sight operations in a real urban setting in Switzerland, where we connect hospitals and laboratories. From there, we basically grew our operations arm into what you could probably almost call an airline nowadays, so this is one side of my responsibilities. And then the other side is a little bit on the service side. We are the interface to our partners that are airlines, where we need to provide support – for example, technical publication services.
As such, we’re using the suite basically as an OEM for some of the products that we have. But then as well for our own airline, the operating manuals that we need in order to operate safely and efficiently.
Being one of the largest drone operators in the world with operations in over 6 countries, how have Zipline’s operations evolved since the start?
Jon: One of Zipline’s core values is continuous improvement. The constant pace of improvement and how much we’re maturing across the board every day. We really take a sharp eye towards the customer. Once again, we have a very important mission so as there is development in focus, we are always looking into how do we make this into a better customer experience and how we enable more productive use of our systems. It’s been light-years of improvement in a short amount of time and it continues to accelerate. Right before starting, I was looking at our website, we have a live page of operations. To date, we have flown over 9.2 million miles with 134,088 deliveries. So I think we have racked up about 10 since prepping for this meeting. We’re just really excited about that progress and continuing to expand.
Matternet has grown tremendously too since its start in 2017, why are drone deliveries so important and how do you see the industry grow over the next couple of years?
Alex: There’s a couple of problems that we are trying to solve and Zipline has demonstrated it really nice also, especially in Africa, in how to overcome these problems or challenges that exist there in terms of infrastructure. We actually have the same problems but due to a completely different reason than in the developed countries. We see trends like more people are in cities, especially now as we are ordering much more than before and want that to be delivered.
Some of these trends, we’re not necessarily trying to solve them all by drones but they have secondary effects on our roads and congestions on the road that leads to other challenges in the logistics of really urgent and important deliveries that we sometimes need. That’s where at least our primary focus is right now and where our industry as a whole is trying to solve some of these challenges, to ensure that we can get goods to the people that need them the most and then go from there.
The vision of Matternet is somewhat similar to what Zipline essentially has – to make the access of goods as frictionless as access to information for example. In a city, that can be quite important. Especially as cities are becoming more and more congested, that piece is becoming more and more important. Also, the predictability of having access to these sorts of services will become more and more important.
There are many different use cases of drones. Before we get into the capabilities of Airhub, tell us about the various different drone operators you work with?
Stephan: As we saw Zipline and Matternet are really operators themselves. We at Airhub, we are not an operator but our software and services actually help operators like Zipline and Matternet with setting up their operations and managing them in a safe, efficient and compliant way. Normally, we start out with the SORA tool as we discussed earlier and then we look at the ground and the areas where they want to conduct and from there they get a specific report which contains all the requirements, including the requirements for the operations manual as I mentioned, which we set up with Web Manuals.
Overall, we work with many different operators, especially throughout Europe but also from many industries. We work with a lot of first responders and security companies, but also operators doing a lot of industrial inspections or that are in construction monitoring their sites. We are also working with drone manufacturers, AV for example, which is also a delivery drone manufacturer and delivery operators in healthcare and offshore. In general, we work with operators that are operating in this new specific category, a category in the regulatory framework of EASA, where most of the operations will be conducted in Europe.
The use cases are many but the challenge is truly becoming compliant. Stephan, tell us in what way does your system help operators from a regulatory standpoint?
Stephan: Most of these drone operations, especially in Europe, will take place in this specific category, a category that is risk-based. So it means that you have to do a risk assessment called the specific operations risk assessment (SORA). SORA helps you determine the operational requirements for your specific operation.
What our SORA tool does is really simplifying this process and guides you towards this process which can be quite complex. It provides you with a very simple report that functions more or less as a checklist with all the requirements you have to fulfill to apply for an operational authorization at the CAA. Once you have the operational authorization, the other part of our software platform comes in, which is the operations software. This software helps you plan your flight, assist the crew with planning and obtaining their authorizations, for example, in CTRs. But you can also fly in certain types of drones straight from our mobile app or even from the dashboard for 5g. Everything is logged automatically so you can also manage your maintenance but also for example incidents. That is more or less how our platforms support operators in obtaining and actually maintaining their approval.
Jon, could you please tell us about Zipline’s regulatory journey? Being the Director of Maintenance & Airworthiness, what are your main focuses today and moving forward?
Jon: My main focus right now is on our US certification activities so as I alluded to earlier Zipline is working to obtain a Part 135 air carrier certificate and part of that is partnering with the FAA and we have been for a while. A couple of other operators have gotten theirs in the US so we are on a similar journey. The FAA laid out what is required and we are making progress towards that objective. It’s an ongoing partnership and it’s really exciting to be apart part of it. The FAA has been engaged across multiple aspects of the agency, from the design side to manufacturing and also the operations both air and ground.
One of the unique things about what we are doing is that it is an autonomous system so the conventional roles of a pilot at the sticks don’t pan out in our system, so you know there are differences. However, and this is what I think is a very important thing, especially for folks that aren’t familiar with where the UAS industry is – for as many differences as there, there are vastly greater things just as if you operate conventionally. So as an air carrier under 135, my maintenance program that I’m building is conventional CAMP, I have a chief inspector, I have a technical training manager. These are rules that you would find walking into any charter operator in the world and you’re probably going to find some of these people around. Becky and Kim, the chief inspector and training manager, both come with decades of conventional and non-conventional aviation work on their resume so we’re taking the conventional and where there are differences, highlight those and try to focus on those areas.
That said though, the maintenance program – I ask for no exemptions in our application. We’re following the law as written. I mean there is obviously going to be an exemption at this point, there are sections and rules that you know – oxygen on board is not so relevant when there’s nobody on board. Working to those things, rule by rule, and being able to strike, this doesn’t make sense but for the pieces that are conventional, that is what we are doing. Again, we have a lot of the same practices in CAMP. If people are familiar with CAST, it’s a continuous improvement requirement that’s been in the maintenance world since the 1960s. It doesn’t get a lot of love, SMS is the new hotness and I say, maintenance person myself, I’m like maintenance and airworthiness people and every airline have been doing CAST forever and now all of a sudden SMS is getting all the love but we, this is just how we do business. You are not allowed to run a commercial airline maintenance program without continuous improvement. I don’t know how you would obtain the highest level of safety by doing anything other than that. Really, that’s our focus. We hold a high bar, we hold ourselves to the standards that anybody else in the industry would, if not, more stringent because we are in this space that we are in. Not having that focus, I think would detract from our mission at a deep level as well. So it’s not suitable to do anything other than this.
We’re continuing to build that out, demonstrate that every day and keep making progress. I’m really excited that we’re partnering with the FAA and really all the regulatory agencies that we interact with wherever we operate. We’re where we have dialogue and relationships with all those different groups where appropriate. At times, it’s very frustrating but at the same time, it’s because it is a new technology and it’s a new integration. I think, outside looking in, I always caution people to assume that we’re just reinventing everything here – that’s not really what we’re after, we’re trying to integrate into the existing systems as much as we can.
Louise: I agree with you there, I think the Part 135 path really shows that you keep up with the same standards. I know there was some talk about creating a new regulatory framework outside of Part 107, but I think what you are doing is better.
Jon: Yeah, if anything, I’m sort of, at times, frustrated with 107 because it didn’t contemplate airworthiness or the notion of configuration control, or some of the record keeping. It actually kind of negatively trained some in the industry, in a sense, and I mean, I’ll keep my frustration at a limit. But from somebody who’s in the airworthiness business, to trust the system, you have to have some mechanisms in place to know that what you’re flying is, in fact, part of the design, and is suitable for operation. Ultimately, it’s the maintenance and airworthiness team’s responsibility that flight crews, dispatchers and others know that the equipment they are operating is going to be able to do the mission safely.
Alex, in what ways are Matternet’s operations similar to a “real airline”? How does a type certification for drones look like today?
Alex: John already covered a lot on the part 135 side nicely, and as you might know, we are not part 135 operator ourselves in the US – we have UPS operate our drones, for example. But that’s just one side, right.
Our airline is actually much more active on the European side and Europe, or EASA more specifically, has taken a little different approach than the FAA, which I think is very interesting. And that’s taking the learnings from existing manned aviation. There’s a lot really a lot of, I would say, carryovers.
But there’s also now something called the LUC, a light unmanned operator certificate – that’s kind of the pond on to the AOC. That gives you the operational certification to be allowed to operate drones. And it takes a fundamentally different approach because it goes away from the, let’s say, more conventional TC type certification, and then goes through an equipment certification – so that’s what we’re currently doing in the US with the FAA. What Jon mentioned also, we are following the durability and reliability testing there as a core principle of obtaining that certification.
And in Europe, or on the EASA side, it really depends on what you want to do. It depends on your type of risk that you’re running into. We’re differentiating there between air and ground risk, and you can find all the details there in the SORA, that Stefan mentioned earlier. Depending on your operation and the maturity of your system, you reach a certain level that you target, called the safety and assurance integrity level that you need to reach. That defines what your aircraft system needs to be able to do essential oil requirements, and much more, not only the system but also your operation, which is an important piece. It covers also your operating procedures and things like this. And that’s essentially where all of this comes back together and where for example, standards that are used by manned aviation are very helpful and seen as an applicable means of compliance to some of these requirements that are being put forth then by a process like the SORA.
What’s nice about this is, especially in this new but also very diverse industry, you don’t have just the same type of aircraft, you have very different types of aircraft and very different types of operations. You have inspections of bridges, underground inspections, and things like this, and you start to realise that, it doesn’t make sense to apply the same regulations to all of these different types of operations. So that’s why I think the asset approach is very interesting, and definitely opens up even more opportunities for the industry, in my opinion.
How does Airhub’s system work with airspace and traffic management? How do you see unmanned and manned aviation merging in the safest way possible?
Stephan: We really think that combining manned and unmanned aviation in the same airspace will be one of the main challenges for the industry in the coming years and especially once when we come to the point where large numbers of drones will be entering the lower airspace.
And this system, what they call unmanned traffic management in the US or U-space as they call it in Europe, will be the answer. It will basically be the air traffic management system for the lower airspace of unmanned aircraft. Near airports there will be a combination of what they call UTM and an ATM.
So what we already did in our software, the operations platform, is an integration with two of these UTM or U-space service providers, which is Altitude Angel. They’re more focused on Europe, with the exemptions for Switzerland. And Airmap, which is one of the bigger players in the States. What this integration actually does is that it allows our customers to basically get clearance from air traffic from an airport, harbor, city, or any entity that wants to regulate their airspace. It will also separate drones, not only from drones but also from manned aircraft. And of course, in the long run, it will provide capacity management, especially once these guys start flying their drones on a large scale with deliveries.
Zipline has grown and scaled fast, what processes do you have in place to prevent incidents?
Jon: Where we operate today, we do have processes in place operationally – the technical capability of the system, what features and functions are available on the device, or as part of this integrated system. Then, you have kind of the traffic management element and some integration there. Then, you have the operational aspects, the things you do in the course of your business before you launch a mission and how you evaluate your routes, and how you mitigate operationally.
I take inspiration on all this from programmes that once again, back to conventional aviation, you have programmes like ETOPS, and RVSM, and RNP. And all the programmes that exist out there, you know, really were the marriage of those two different aspects – the sort of technical capability and the operational requirements that you have. And so, once again, I think that, in this case, we will end up in a similar place.
I mean, it’s really effectively how we operate today, where we don’t have maybe as much technical capability in certain ways, then we can’t buy down risk – back to the SORA concept, we can’t buy down risk to a low enough level. So now we have to input operational mitigations. Over time, I think you’ll see more technical capability, making the operational integration challenges easier and easier. I just see this graduation, you know, basically like two inclines, opposing inclines, where we phase in more technical capability, and we phase out more, you know, rote manual operational, thou shalt thou shalt nots. And, and then that way, in the end, you know, we’ll, arrive at a point where it’s just kind of the way things are. It’ll be a gradual process, and we’re gonna learn a lot.
Is a completely safe integration of drones possible?
Alex: I would also add, that actually, conventional aviation needs to be more open to change. We see that there’s a lot of requirements put on the new industry and everything that we’re trying to put out there but we also need to recognise the fact that even though manned aviation has been around much longer, it’s very important that there is a certain openness. For example, it may be installing a new type of equipment that allows for better tracking of the aircraft in low altitudes to really create this U-space. I like that nomenclature a little bit better than UTM because it will be different than the normal ATM system – there will be much more automation.
Also to take this question maybe a little bit in a different direction, I think what’s also very important, especially for this new industry is, as we already mentioned, there is a lot of really good and proven practices for manned aviation, such as the safety management system, or quality systems that are in place. Because it doesn’t matter, we will always have humans somewhere, they are not in the aircraft anymore, but they are somewhere else and we’re building the systems. So it’s very important that we ensure a good safety culture as we develop these systems. And especially as we go to more automation, it’s even more important to have this at its core. To make sure to build robotic systems that are safe in it’s core, really taking this from the OEM to the operator. More and more, we will see that it shifts towards the OEM. I think a safe integration into the aerospace is building on that concept.
Drones fly close to normal people. How can violence from these people to the drones be prevented?
Alex: I can take that since we are flying very much in cities, and really in urban areas, that’s definitely on our minds. And it’s violence, obviously, if you think about GPS, spoofing, and things like this. So we all do think a lot about this and how we can solve it. Obviously, what has to be clear, is that, at that point, it’s a criminal act. We’re entering an area that really is problematic on so many different levels. What I can say immediately about our system is that it’s designed in a way that if something like this would occur, it fails in a safe way where you have a parachute or some system that actually prevents a further secondary issue.
When phasing out operational procedures and more into technology, where do you see Web Manuals as a software evolving? Is there any use of that type of system?
Jon: There still has to be somebody to maintain the robots. So most of what we’re talking about on autonomy is air operations being autonomous and less humans involved on the ground side. However, in preparation for those activities and those flights (until we have robots taking care of the robots), we’ll still have people to take care of those robots. So at some point, it becomes a ‘turtles all the way down’ problem for robots, where there’ll be one person standing there fixing the master robot – “I don’t know how he escaped”, you know, something along those lines.
There will always be a need to understand the system at some level and communicate the allowable configurations and conditions and service requirements of those devices. So to that extent, there’s a place for Web Manuals product line. Now, how that integrates, and how that evolves over time so that we can keep the configuration close to the information, there’s a lot of challenges. Information science-type topics around what the right level of documentation and where that lives and how it’s reviewed, approved and released, and how that’s incorporated into your operation. There’s a whole long line of topics to think about in the future of what we could do to improve that. But you also see that happening in the airlines, I mean, augmented reality, and stuff I was playing around with Alaska Airlines 15 years ago, as a ‘this will be interesting kind of hack project for a few months with the early provider’, didn’t really bear any fruit, but it was a kind of a glimpse into it. We we’re trying to put that information at the fingertips of the people doing the work. And they’ll continue to be doing the work there, like I said, until the robots are taking care of the robots. So, um, I see there’s a need that does not go away, maybe there’s something way out there, but I don’t see it going away anytime soon.
Alex: What I think is very interesting about Web Manuals to us especially is that we were trying to evolve and improve fast. As john mentioned, it’s all about continuous improvement and a tool like Web Manuals allows us to do that much more efficiently. And if they managed to get the FAA brought into using Web Manuals yet, once the regulators start to use that there, I think there would be a much better pace in getting improvements out than what we have today. So I think definitely, to support that pace, Web Manuals is definitely very important.
Stephan: Fully agree on that we, actually this last week, had a discussion with CAA here in Europe and showed them the system – they were completely blown away on how easy it is for them to approve even minor adjustments to… this was an operations manual we were talking about. I think there’s still a long way to go there at the CAA, they’re really used to the old paperwork and highlighting stuff and then sending it back and then waiting again for a couple of weeks. But this is really, for them as well, such an improvement to work much more efficiently to get the operational approvals out. Especially for the CAA in the drone industry, it really caught them basically by surprise, because it’s not only a few airlines anymore that they need to work with. It’s now 1000s and 1000s of operators from very small to really large, with various kinds of drones. There’s a lot of room for improvements there as well.
What are finals words in regards to this emerging industry and the unmanned and manned coming together?
Jon: I think I’ll reiterate my point that what we’re doing is new and novel in many ways, but there’s also so much that we are learning and leveraging from what’s already come before us. And I think as the industry evolves, and these different models that are being tested, in terms of like some of the comments from Alex about how EASA is approaching this versus the FAA approach. We’re gonna learn a lot as an industry and really see what those outcomes are. And my hope is that the industry continues to work in good faith so that the public continues to trust the products we’re putting into the air. By doing that, we will be able to advance the industry and show how we’re not trying to sneak one past anybody or do anything underhanded, we’re really trying to work through some really difficult challenges to integrate this into the end world because the benefits are huge. Ultimately, I think we’ll be safer, in many respects, if I don’t have to drive down to the store like Alex was talking before about the traffic and the roads and so forth. I think we can actually produce a safer and more accessible world with this technology and I’m excited to be part of it.
Stephan: I think actually a merger between the manned and unmanned aviation in the next couple of years and decades ahead, especially when we talk about Urban Air Mobility – I don’t know if maybe everybody knows the concept already but it’s the transport of people and cargo, by unmanned aircraft systems in between cities and within cities. This is really the last step between drones as we know them today and the aviation industry, as we know them today. And, of course, airports will be working with these clients with increasingly complex operations. And, as Jon and Alex already mentioned, there will be a higher level of automation and fleets of drones flying around, so it’s very exciting to see the future.
Alex: First of all, I want to encourage especially the innovative industry here to make safety one of their priorities, if not, obviously the priority. And, and then I know this is not something easy, right? It requires a lot of resources and perseverance. But in the end, especially having strong processes in place, and, for example, an SMS or a CAST, even if it’s not ultimately required, especially in Europe depending on your operation needed, I think it’s it’s still something that we should strive for across the industry to really show what we can do and that we can integrate drones safely. And really build the trust that you also mentioned, I think it’s really important that right now, we, as an industry show that we can build to a level of safety that is acceptable.
My other thing would be really also with the people here from the manned aviation side. I would plead for a certain openness to change as well, to welcome the new industry rather than condemning it. Some people are very focused on their own kind of operation in the end. I understand that obviously, there’s costs involved everywhere but I think it’s very important that we work together here and and find a solution that works for everyone. We have made really, really good progress here in Switzerland. We work very closely with some of the hams operators, for example, that’s usually the ones that we meet in our airspace. And if there is willingness and collaboration, it’s really amazing what you can do and and I think that’s where we should take this and really collaboratively together to integrate drones safely into our airspace.
Louise: We’re very, very happy that all three of you are paving the way and showing that it’s possible and showing all the good with drones. Thank you for being such big role models in the industry and thank you for as you said putting safety first. The fact that you’re using Web Manuals is really showing your commitment to safety, to processes, to the right kind of documentation. And we’re very, very grateful for that.