Human Factors and Ergonomics Society

Human Factors and Ergonomics Society Response to FAA Notice of Proposed Rulemaking for the Operation and Certification of Small Unmanned Aircraft Systems April 8, 2015 The Human Factors and Ergonomics Society (HFES) welcomes the opportunity to comment on the FAA Notice of Proposed Rulemaking (NPRM) for the Operation and Certification of Small Unmanned Aircraft Systems. HFES is a multidisciplinary professional association with 4,500 individual members worldwide, including psychologists and other scientists, engineers, and designers, all with a common interest in creating safe and effective products, equipment, and systems that maximize and are adapted to human capabilities. The field of human factors and ergonomics (HF/E) works to develop safe, effective, and practical human use of technology. HF/E does this by developing scientific approaches for understanding this complex interface, also known as human-systems integration. One of the most important fields for HF/E application is aviation. The field allows for the safe development, design, certification, operation, and maintenance of aviation systems, including unmanned aircraft systems (UAS). Human factors practitioners working in the field of aviation are engaged in basic research, advanced system design, and improvement of current operational systems. The human factors practitioner is the primary user advocate during system development, testing, and operation. Regarding FAAs NPRM for UAS (FAA-2015-0150), HFES is concerned with several aspects of the NPRM that deal with the visual line of sight. Specifically, the NPRM states that: 1) the operator must be able to see the UAV with unaided vision at all times, 2) the operator has the responsibility for see and avoid, 3) UAVs can travel up to 100 mph, 4) UAVs must be operated at or below 500 ft, and 5) operations can occur without ATC permission in uncontrolled Class G airspace and in B, C, D, and E airspace with ATC permission. See and Avoid The NPRM states that: 1) the operator must be able to see the UAV with unaided vision at all times, 2) the operator has the responsibility for see and avoid, 3) UAVs can travel up to 100 mph, and 4) UAVs must be operated at or below 500 ft. It is unclear from the NPRM that the see-and-avoid concept and the visual operations requirements summarized above are based on data. It is a difficult task for an operator to determine that a UAV 0.5 miles away and traveling away from the operator at 100 mph will miss an aircraft descending at 180+ mph that is 2 miles away on a different heading. It would be helpful for the FAA to reference the data used to determine these requirements. Airspace Requirement HFES is also concerned about UAVs inadvertently entering Class B airspace. Much Class B airspace is protected by the Mode C veil. However, UAVs apparently are exempt from the transponder requirements needed to penetrate the Mode C veil; there is no mention of a transponder requirement in the NPRM. In cases where Class G airspace underlies Class B airspace, the operator could fly a UAV without ATCs permission or knowledge of the operations in the Class G airspace. It is then up to the operator to avoid the bottom of the Class B airspace directly above the operational area of the UAV. This could be difficult because Class B airspace is often irregularly shaped. In addition, even if the operator knew, for example, that Class B started 500 ft above the ground, how would the operator determine if the UAV had penetrated Class B airspace? Can an operator distinguish 480 ft from 499 ft at 0.25 miles for a moving object? Data examining how accurately an operator can make vertical judgments of a moving object would prove useful. Currently, it is unclear what data were used in determining this requirement. HFES Recommendation HFES recommends FAA develop a study of the see-and-avoid issue for small UAVs. The study should incorporate a systematic, scientific approach to identify the factors that affect an observers ability to estimate the UAVs altitude and attitude. The field of human factors plays a critical role in identifying these factors, and FAA should include its own human factors experts in developing this study and consult with external HF experts if necessary. Thank you for the opportunity to provide comments on behalf of the Human Factors and Ergonomics Society. Please do not hesitate to contact HFES should you require additional information