Need for a New Class of Drones

Technology advancement continues at an ever increasing pace and Aerial Cameras have overtaken the classification of aerial vehicles.  . . New flight rules from Transport Canada and the FAA are based on  the old technology and need updating. I have recently put forward an official request for consideration by the Canadian board or committee that is finalizing the CARs UAV Proposed Amendments. Particularly PART V and PART VI. (6.37 Collision avoidance). So I thought I'd capture that process here in the BLOG.

There is enormous commercial market and need for aerial photography, surveillance and security that can be effectively accomplished with palm size UAVs weighing <1kg that carry sufficient communications and sensors to be operated safely beyond 200 meters or so where they cannot be seen because of their small size. Right now SMALL means <25kg.
 
The case of very small, light weight UAVs ( ie Low Energy RPA . . in my case <1kg all up weight and ~150joules maximum total energy <3 joules /sqcm) the missions are extremely low risk with SFOC qualified pilots. Therefore, (UAV_REPORT -1 PART 2 of the Terms of Reference) deserves further consideration now that accurate positioning and reliable collision avoidance has been miniaturized.

Definitions:
RPA - Remotely Piloted Aircraft
UAV - Unmanned Aerial Vehicle
Low energy RPA - means an RPA that has been analyzed and/or demonstrated, for the case of an uncontrolled impact, to not impart a peak energy of more than 12 Joules /cm2 on a stationary person or object in the most unfavourable of circumstances.
Small RPA - means an RPA with a maximum permissible take-off weight of 25 kg (55 pounds) or less, not including low energy RPA.
SFOC Special Flight Operations Certificate. This is how UAV/RPAs/Drones are currently regulated for commercial use in Canada.
VLOS - within Visual Line of Sight - Can be seen by the naked eye.
BVLOS - Beyond Visual Line of Sight - Can't be seen without aides. NOTE: The location of a UAV BVLOS is still known as accurately as within VLOS and displayed for the operator.
 
RECOMMENDATION:
I recommend a class of VERY LOW ENERGY RPAs and VERY SMALL RPA/UAV class (PART V RPAS), of <2kg with a total energy of <150Joules, and <5 Joules/sq cm. that can be authorized to fly BVLOS out to at least 50% of the demonstrated telemetry range when flown by a qualified/authorized pilot, from surface to 300ft, while maintaining 2 way communications and a listening watch on the low level frequency appropriate to the class of airspace it is authorized to operate in.
 
Technical Rational and EXAMPLE

The KE (Kinetic Energy) is 1/2 Mass x Velocity Squared and for current commercially available technology (eg Mavic Pro) that is 0.5 x 0.743 x 424.4 = 157.65 joules of energy. If you divide that by the cross section of a head-on MavicPro ( 8.3 cm x 8.3 cm) doing 20.6 m/s then the maximum impact energy / sq cm is 2.29 Joules. According to Transport Canada's PHASE I REPORT, this is less than a baseball (3.9) or tennis ball (3.1) These balls weigh much less than a UAV but they can go more than 2-3 times as fast. . . which is called  "NOT lethal" in the report. A golf ball imparts 8.4 joules/sq cm. and the report states this is "NOT lethal but getting close".

So by this reasoning, the Class of VERY SMALL UAVs like MavicPro carries a maximum 157joules of energy while a baseball is comparable at about 140 joules. Yet we still allow people to stand around stadiums right next to the foul line and get hit now and again. In the worst case scenario of a flyaway (uncontrolled/uncommanded flight), I submit that there is no difference in risk from VERY SMALL UAVs flying BVLOS. The risk is identical and just because you can see one within VLOS you still cannot do anything about it if it fails and the injury risk is identical. Also, to be noted that Mavic's 157joules is only at top speed in "SPORT " mode flying in forward orientation, otherwise it's less. At normal maximum transit speed of 32mph (14.4m/s) it's less.

The RISK when flying BVLOS with VERY SMALL CLASS Drone then a 3 part problem.
1. You might hit someone and hurt them. (chances are extremely low comparable to hitting someone while playing baseball, unless you intentionally aim at a victim or become incapacitated and the UAV is uncontrolled in a mode that can reach >20m/s speeds, approx 40mph) Here is a quick reference point for <1kg Class RPAS www.youtube.com/watch?v=FY2eCvuHflA
2. You might hit an obstacle and damage it or cause a fire. (except that you can see and avoid where you are going (Forward Camera) and you have reliable collision avoidance, including 4 more automated cameras and GeoFencing that will stop flight into prohibited airspace and also inhibit active command attempts to do so.)
3. You might get in the way of a commercial or recreational aircraft and cause damage, injury or death. (except airplanes/helicopters and hot air balloons are easy to spot and avoid with the unaided eye at a range exceeding the practical range of the UAV. In addition you know exactly where your UAV is (GPS map display heading, altitude and ground speed) despite not being humanly able to see Mavic's (.02 sqm cross-section) unaided only 200m away. . More importantly, there are already airspace restrictions for all types of air vehicles to avoid such conflicts and situations, and proper GeoFencing along with responsible, qualified and authorized pilots will prevent unwanted or illegal deviations.

So for VERY SMALL/VERY LOW ENERGY UAVs then( <1kg <.02sqm profile machines especially), the risk of accident or serious personal injury is lower than a baseball and normal eyesight combined with current rules of the air mean the likelihood of being in the same airspace with commercial aircraft (that you CAN easily see) is highly unlikely with qualified responsible pilots. There is no safety rationale to restrict VERY SMALL/VERY LOW ENERGY UAVs  from operating  BVLOS.
 
As seen by the new MavicPro, technology continues to change at an increasing pace but proposed regulations do not consider the positive impact of miniaturization (pun intended). The Transport Canada Terms of Reference from 2012 said, they "expected that the availability of reliable detect, sense and avoid technology is likely to be a significant number of years away, therefore, some of the work in Phase 2, which is dependent on the availability of sense and avoid technology, may be delayed." I think both the technology and the reliability has already arrive nearly a year ago (Mavic predecessor Phantom 4) and we should revisit Phase 2 work now and create a VERY SMALL and VERY LOW ENERGY class of Unmanned Aerial Vehicles..