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Navigating Regulations for DFR

Posted Sep 27, 2024 | Views 310
# Regulatory
# Remote Operations
# DFR
# First Responders
# Drone
# Patrol-Led DFR
# Public Safety
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Jakee Stoltz
Sr. Regulatory Program Manager @ Skydio
SUMMARY

Unlock the future of drone operations with Skydio's groundbreaking approach to Beyond Visual Line of Sight (BVLOS) operations. As the utility sector rapidly adopts drone technology, mastering aviation regulations is crucial to fully realizing the benefits of autonomous operations.

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TRANSCRIPT

Alright.

Let me get the slides up again here. There we go.

Okay. Well, welcome to the last breakout.

I know the room's gonna be a little sparse because we have our our DFR program manager training going on, but, I know there's could be a big, big virtual audience. So, yeah, thanks for those of you that that are here. Thanks for joining online.

So I'm gonna cover some regulations for DFR, basically. And I'll kinda use this first slide just to introduce myself. I'm Jakey Stoltz, director of aviation regulatory affairs here at Skydio.

I have the privilege really of working with a small but experienced team here on the slide.

And, you know, between the three of us, like, we're we're really just aviation professionals at the end of the day, and we've been working in this industry for a long time. So, me personally, I'm a a commercial pilot, a CFI, remote pilot.

We got other pilots on the team as well.

And, I got my first experience actually flying drones, back in twenty fifteen. So, the image on the right here is actually a Christmas card from a regional UIS team that I was part of.

So, you know, kinda going way back, this was before point one zero seven. It's kinda in the three thirty three days, but even a little before that.

And you had to have a, a private pilot certificate or or more to even fly small drones. So, this law enforcement team, and the lead there, I mean, he's he's kind of thinking way ahead of the curve, but they couldn't require their officers or or deputies to go get pilot's license. That was just way too cost prohibitive. And, so instead, they hired some, students and staff out of the university there, and I was fortunate to be one of them. So I spent a couple years flying with them, and we were basically an on call unit. We'd go fly.

Things were quite basic at that time. We didn't even have photogrammetry, so we would just take pictures of, incidents, crime scenes. We'd do some search and rescue or search for fugitives.

Yeah. It was amazing. And so it was a really good experience. It helped me, you know, get some experience in what you all do every day in public safety, and and the importance really of the job and the mission.

And and, again, kind of fast forwarding a little bit. So I I I spent a number of years at an FAUAS test site, and and my colleagues have as well before joining Skydio. We've spent a lot of years, thinking about, you know, aerospace awareness and aviation safety and how do we use these these technologies to go beyond visual line of sight and fly remotely.

And so kinda between the three of us, we've we've used just about every type of technology out there, radars and the electro optical systems, the acoustic systems, and so on.

Kinda one of my favorites was, in the upper left picture, on the slide here.

It's a picture with me and colleagues in front of an m q one predator, so, you know, a bigger surveillance drone.

And, it it's a little crazy, but they actually had to have a chase plane, you know, follow them around whenever they would fly this thing in the national airspace. So they were doing, like, training training flights and and training missions in the US before, selling units overseas or or operating overseas. And and so that had to be done in accordance with, like, the same regulations, you know, we're we're all kind of flying under today. And so they had to have a chase plane following this thing around with a pilot in it and a visual observer, so kind of a two person crew, and that that chase plane would be the eyes for this drone, as it flew around.

So, obviously, very, like, cost prohibitive and and cumbersome, and so they they kind of brought our you know, got our help to get them a, Beyond Vision on-site approval, and we used an FAA radar to do that. So kind of the big radar is the same radar that air traffic is looking at. We were able to get that data and and visualize it and use that for collision avoidance and and ultimately remove that that chase plane. So, but, yeah, a lot of experience with it.

And all this experience has really driven our our strategy at Skydio and and how we look at, you know, getting Beyond Vision ISO approvals and helping customers do that. And so, we'll hit more on that. But, it wouldn't be a regulatory presentation without our arc of autonomy, so we we always do show this. It it's really like, our regulatory road map at the company.

So, and we've been working at it for many years, and there's more to come. So, at this point, we've we've achieved stage stage three at scale. So this stage is characterized by remote operations now where the pilot no longer has to be with with the drone, but it's in a one to one ratio. So it's still one pilot flying one drone, but remotely.

And so we do have you know, there's work going on, with stage four, which is, what we call multi mission or where one pilot can start to fly multiple drones simultaneously.

And you saw, kind of what what that looks like with DFR command yesterday, which we're really excited about.

And then stage five, a little more future looking and and kinda visionary, but we believe at some point, you know, we'll be able to make the pilot optional. So imagine for for drone's first responder, the drone is able to at least, deploy based on sensors or different inputs and just deploy autonomously and and start to go to that call. But then as it arrives, you know, a pilot can kinda jump in and maybe start to move it around, get the angles they need, and and the the data they need for that that particular call. So alright. And, kinda turn that into a little bit more of a metaphor here now. So, I this idea came to me, you know, earlier this year of, you know, how do we explain what we do really internally and and externally to customers?

So the idea of, mountaineering came to me, and and there's some similarities to what what we do, and I'll kinda call out three things. So firstly, it takes patience, and so this is something we, again, been working at for many years.

And we're not to the summit yet either, so we're gonna keep working that. But it does take patience, and it's just incremental steps as we go.

The next thing is it does help to have a guide, and so that's really what we hope to be is kind of your guide as you're, you know, trying to work up this mountain as well. We we know certain paths and and, you know, strategies to take, along that that journey.

And then finally, you know, safety, safety matters for both these things. So climbing a mountain can be dangerous, so you wanna you wanna take safety precautions.

But flying a drone remotely and beyond visualized sight, if not done correctly at least, can also be dangerous. And so, we care deeply about that, aviation safety. So so come along the journey with me a little bit. So twenty twenty one, the FAA, Trula Vista and Skydio's partnership to, unlock what we now call tactical b v loss. So this is really a a beyond visual insight for a kind of short range, low altitude flying, and it just allowed officers to fly drones in areas where they couldn't see them or or still be behind cover where while they're flying the drone.

And that's now been issued to over five hundred agencies. So it's it's really, you know, just taken off. And and if you don't have it really at this point, there's no reason not to. So and you could think of this as like there's a little bit of a base camp.

Right? So we're we're going up the mountain towards the autonomous summit here, and and that was one of the first base camps. Then in twenty twenty three, you know, Jonas first responder really took off again with Chula Vista, and, the concept, you know, from that point really to today is that there still had to be a visual observer, watching the drone and and scanning the airspace around the drone during flight. So, so, you know, we have many agencies doing this today, doing drones first responder, but it's all characterized by, you know, a VO standing on a rooftop or, still maybe on the street.

But there's always somebody scanning the airspace. And that has, you know I think it's clear now, like, the value of DFR and and a lot of this work has has shown us that and proved it out, but, it's also been hard to scale because of that requirement. So, not every agency can can put personnel up on rooftops, or they have the budgets to hire contractors to do that job. And so, so it's been really great, but it's also been limited a little bit in scale.

So this year, we're really excited now to be breaking some new ground and and getting some new pathways to no visual observer DFR. So the first one, was a no VO part one zero seven waiver that went to Pasco County Sheriff's Office earlier this year.

And then, on Monday, just very recently now, we announced that New York City Police Department also received a Novi OCOA to do DFR in their city. And so I'm gonna kinda spend the rest of, the presentation talking really about those two and and these new pathways here.

So firstly, for Pasco County, so they received a waiver to one zero seven dot three one. That's the visual line of sight rule.

And today, that enables them to do training and testing at their first facility.

So it's a super cool facility they have there in the county where they do, a bunch of different work, but that includes some of their drone, where they do testing, they do training, they bring agencies in, share tactics, and so on.

And it also allows them to do drone as first responder at their school properties, and really across most of Pasco County.

And so they're they're looking at the schools as kind of that launch point. So the drones can be at the school and respond to any incidents right there at the school themselves.

But importantly, this will kinda serve as their launch point for more of a full county implementation of DFR in the future, under one zero seven.

And so really quickly, kinda what this allows them to do, sort of operationally, it it allows them to do what we call shielded DFR operations.

And so that's operations up to two hundred feet AGL, kinda generally, throughout these areas. Or if there are structures that are higher than two hundred feet, they can, go up and over those, and we call that fifty foot shielding. So it kinda combines both of those two things, that's depicted on the the graphic at the top there, and kind of that, in green area. It looks a little bit different color on my screen, but the green area is kinda what I'm talking about here.

And the great thing about it is it it doesn't require VO's, and it only requires ADS B and technology. So there's no other technology that's required here. There's no radars or electro optical systems, or anything like that. So just ADS B and technology.

And I'm gonna hit on that again, so I'm gonna kinda keep moving here.

So New York City Police Department now, they got a slightly different kind of approval. So it's a waiver to ninety one one nine one thirteen and one nineteen, or, this is kinda commonly referred to as ACOA.

And, this really enables them to do citywide DFR operations. And, the image here, the green is really where they they have approval now to do this type of operation. So it's it's most of the city. The only areas that really aren't included are the areas right around, the two major airports there, JFK and LaGuardia. So, very wide scale approval, and it allows them to do similar operations. So if this slide looks familiar, it's because it's exactly the same slide. So they are also able to do shielded DFR operations up to two hundred feet, just kinda broadly across the city in those green areas that you saw before.

And then, you know, maybe unlike Pasco County, New York City does have some some taller buildings in it. Right? So, when they do encounter those, if, you know, there's a building along their flight path as they're responding to calls for service, and just kind of pop that altitude up, and get over that building and back onto their call. So it's not just limited to two hundred feet.

And again, it only requires them to use ADS BN technology, so there's no visual observer on the rooftop. There's no pilot on the rooftop at this point. It's just remote operations, and it's really safe, simple, and scalable with ADSB.

And interestingly enough, this approval actually gives New York City Police Department a second type of operation. I'll just call this kind of a second con op concept of operation. So, this approval also allows them to fly up to four hundred feet AGL, again, broadly across the city.

But in that case, they're required to have a d s b and technology and a noncooperative detect and avoid system. So they have to have additional airspace awareness technology that's looking out for aircraft and and providing that information back to the pilot.

So we'll kind of talk about, like, the differences between these two, and and there's there's pros and cons, and I'll I'll sort of compare those. But for now, we'll just kind of, leave it at this, and there's two types of con ops that they're able to do.

Okay. So next the next few slides here, I'm gonna kind of go, like, a a a level deeper here that we we usually don't, but, we wanted to kind of, you know, give a little peek under the cover and and talk about the safety case and some of the, you know, the overarching themes and and the the things that we did to, help these two customers get these approvals. So, so when we when we help a customer get approval, we think about two things, and and these are the two things that the FAA is most concerned about when they're evaluating these requests and deciding to approve or or ask questions.

And so those two things are airspace safety and citizen safety.

And so we'll we'll kinda focus first on airspace safety. So kind of the overarching question here is just how does the pilot avoid collision with other aircraft? So if you're not there, and you're not scanning airspace and and looking for helicopters or or low flying aircraft, how how do you, you know, see those things? How do you give way to them?

How do you use the technology to do that? And you have to think about it in two ways too. So you have to think about it when, you know, things are going well. So the missions are going well, everything's performing correctly, but there's a low flying aircraft. What do you do? And you also have to think about them in what we call, like, off nominal situations. But if something doesn't go well, you know, if you, lose link, for example, what how do you still avoid an aircraft in that situation?

Okay. So first, just the goal. So what is the goal of airspace safety? It's to keep the drone away from other aircraft or a more technical term, it's to remain well clear of other aircraft.

And the New York City Police Department approval actually gave us kind of an updated definition of this. So when you're flying visual on a site, you know, you're you're just kind of making a judgment call and, you know, you're you're looking at, you know, an incoming aircraft and your drone, and you're probably just taking kind of a a big action to either maybe land it or, you know, maybe it's it's still far off and not not converging. But, you know, it's it's not really based on, like, numbers. You can't tell if it's five hundred feet away or a thousand feet or a mile. You're just making a judgment call. But when you're flying beyond the line of sight and you're starting to use technology to avoid aircraft, you actually can start to use some numbers.

And so kinda interestingly, the the the actual numbers, like how far away you have to keep drones from aircraft, are on the right side here. And, under two hundred foot, we really only have to give aircraft, give way a hundred foot vertically and five hundred foot to the side. So it's quite a small sort of, we call it like a hockey puck around the drone that you have to keep aircraft out of. When you start flying higher, that number gets bigger.

So there there's kind of perhaps one advantage to flying lower is that, you you kinda have a smaller area, that you have to maintain, clearance from aircraft.

And so okay. So that's that's the overarching goal is just to keep aircraft, you know, in our case, flying below two hundred feet, hundred foot vertically away from from the drone. And so to do this, we use, two types of mitigations, so strategic and tactical. So strategic things are like just flying in kind of the right time or place, and then tactical is like using more of the sensors and actually, you know, taking actions, maneuvering based on some sensor technology that you're using.

Okay. So firstly, you know, we'll kinda talk, like, about strategic mitigation. So, it's a little bit counterintuitive, actually, but flying, you know, you'd think New York City, it's it's this super busy airspace. There's aircraft just all over the place at any given time.

And it's true. Like, there are a lot of aircraft, but when you look closely, it's actually not as chaotic as it might seem. So things are are pretty predictable. There's helicopter routes. There's the airports.

And, you know, aircraft generally fly along these kind of consistent places at at certain altitudes.

And so it becomes quite predictable. And that's, you know, kinda shown in the graphics here. So if you just look, at all aircraft, you know, flying in and out of that area, at a thousand feet AGL, like, there's aircraft kinda everywhere, especially along the rivers and around the airports.

But if you start to fly at low altitudes that we'd like we do, I mean, we fly at two hundred feet or below, that's the image on the bottom. There's far less aircraft, and you can start to see that they're in kind of just predictable areas. They're all along the East River, the Hudson River. They're doing tours of the Statue of Liberty.

They're flying in and out of the two airports, or they're flying along the shoreline, for example, to kinda come into the rivers.

So if you if you know these things, you can start to kinda plan around it. And, when when you run some math, actually, the the just general risk of colliding with an aircraft is very low. So, we've done some math, but there's the probabilities, are the same for two things. So being dealt the royal flush in poker, it's the same probability as having a major collision in controlled airspace.

So has anybody been dealt the royal flush in here?

Yeah. So not not very good chances.

And then so that's just the general risk. If I just, like, closed my eyes and and flew through Manhattan, that would that would sort of be the probability. But we can further decrease that by avoiding some of these areas. So if we avoid flying over the East River or near the airports or along the shoreline, that number goes even lower. So, so that's one kind of big part of it. It's just the the risk of collision, and flying in the right time and place is just very low.

K. So now, so that can't be the only mitigation. Right? We can't just, you know, sort of hope that that there won't be that one in a million chance, because, you know, if if you do fly enough hours and there's enough years that go by, you know, that that probability might be realized at some point. So we do have additional mitigations, and now we're kinda talking tactical. So for both of these approvals, for both Pasco County and New York City Police Department, they're located in what's called ADS B out airspace. So in this airspace, aircraft, other aircraft, so crewed aircraft are required to, have ADS B transmitters.

And this means basically that they're broadcasting once a second their altitude, their position, and and a bunch of information about, about their aircraft. And so we can use that information then to make decisions and and avoid void them.

It's not a perfect you know, it's not a hundred percent compliance, so we do know there's about two percent of operators, that either, you know, receive approvals to turn it off for security reasons, or, you know, maybe it's the equipment is just not working correctly that that happens.

But the percentage is is very high, as high as ninety eight percent. So and then even outside of ADS B airspace, so these two approvals, are are are based on ADS B airspace. But even outside of that and this kinda goes into, you know, some of the things we're gonna continue to be working on. The estimates now are as much as ninety percent of aircraft are equipped with this technology, and and they're broadcasting. And so that just means generally that, like, we we receive this data.

It's kinda the next thing. So, with our x ten and and our docs, we have ADS B receivers that collect this this data and and put it right on remote flight deck, for the pilots to make decisions on. And that's a key thing. So, both both approvals require the AD speed to be a local sensor. So, it can't be like an Internet service like flight radar twenty four or flight aware or some of those other systems that agencies might have used in the past. This has to be a local receiver, right there at the operating area.

And by doing that, we we kinda guarantee two things. So we guarantee that the we have very good low altitude coverage, and that's the area that we care most about. So everything below, you know, say a thousand feet, particularly five hundred feet, we can just make sure that any aircraft that are broadcasting, will be able to receive, and display that data.

And it also guarantees that, we have kinda high performance, so we don't have to worry about latency.

That data is all kinda passed through the same link as as the drone, and so it's it's very accurate, very low latency data.

And we make it we take this data, and we make it easy for pilots to, basically kinda know when there's low flying aircraft near them and if needed, take action. So firstly, we we filter the irrelevant data. So you don't really care, about an airline, you know, flying overhead at thirty five thousand feet. It might be cool to know, but it has no safety impact on your operation. So we filter out a lot of that data and just don't we don't show it effectively so that, you don't get kinda overloaded with, you know, ADSB traffic on your map, and and it becomes hard to pick out what's a, you know, what's a hazard and what's not. So we just filter a lot of that away, make it really clean.

And then when a low flying aircraft does get close enough, we'll alert you, and that's kinda what you see in the graphic, on the top. So, there's alert in remote flight deck. It's both visual and audible, so it's pretty hard to miss. And that just directs the pilot to, you know, hey. Pay attention. There's something low nearby, and then the pilot, makes a decision, at that point.

Alright. And now, you know, kinda just switching gears a little bit, to noncooperative detecting avoid sensors. So, the this kinda goes into reasons, you know, again, I I mentioned why we've chosen this the strategy that we have. So, the other sensors, you know, radars, camera rays, etcetera, those can be used to detect aircraft that are not broadcasting ADS B out. So, you know, in in these particular air spaces of Pasco County and New York City, you know, this would be like the two percent of aircraft, right, that don't have it or have turned it off, for security reasons.

And so each one of these sensors, you know, if you're an agency kind of thinking about, purchasing, deploying these sensors, you know, there's some things you should think about as you're you're doing that. So each one kinda has some unique things.

There's different installation requirements, environmental considerations, range, costs, and so on. So, so this this picture actually here on the bottom is is a picture from, years ago when we were deploying some, some of the small panel radars, that are common in systems out there.

And and the picture, it might be a little bit hard to see, but the picture actually shows, one helicopter, that we knew about. So we were testing this out, so we we were typically, like, standing there and looking as well as using this this technology to to kinda see how it performed. But, this sensor shows one helicopter in this kind of frame, but you can see two targets, and what might what might not be so clear because it's small is that one target has a confidence of twenty percent, one has a confidence of a hundred percent, and really the only information that you're the useful information that you're getting out of this is kind of the location. So, it doesn't give you altitude.

And so if if you're a drone pilot, you're you're out there doing a mission, responding to a call, this could be, you know, difficult to use. Right? So you have to interpret this. Like, do I do I avoid the both targets or or just one of them? You know, is the twenty percent one actually something I need to care about, or is or is it not?

I don't know what altitude it is because, the sensor just doesn't have that capability. So it could be co altitude. It could be the same altitude as me. It could be a thousand feet in the air.

And so these are these are just the things that you have to kinda think about with these sensors.

And, the the complexity is again just reasons why we have, at least today, chosen not to to deploy those for these two approvals that we got, but it is an option. So and and there's another thing too. So, you know, think about, a city like New York City. So it's a little over, you know, I think four hundred fifty square miles, so just an expansive city.

And if you had to deploy sensors across that whole city, let's say you wanted to get a hundred percent coverage of your city with a with a sensor like this. So, a lot of these sensors, have limited range, and I'll I'll just use one example.

You know, some of these small panel radars or the electro optical systems, they see about a mile, maybe a mile and a half.

So and you typically need, for, like, radars, you need four of them to see in a three hundred sixty degree view. So, you know, imagine a city of four hundred fifty square miles, and your one sensor sees about a mile radius.

You know, you can kinda do the math. It ends up being, a lot of sensors, and then you have to install them. You have to find rooftops or or water towers or some kind of tower to put these things on, you know, all over the city.

And so the the cost and the complexity just, like, really ramps up if you wanna start, covering your city with sensors like this.

Or if you don't do that, so let's say you don't, you know, cover do full coverage of your city with the sensors, and you maybe just have one sensor at the takeoff and landing point, that then starts to limit your operational capabilities. So if the sensor can see a mile and a half, you can't operate that far. You have to kinda operate within that that volume so that you can see something and have time to react.

So if you just deploy one, now you're limiting, like, your operational distance that you can respond to calls and and the effectiveness of your system. So, so with with the shielded DFR operations and just ADSB, we don't really, you know, kind of run into those problems. Like, we don't have to install infrastructure all over the city to collect this data. It's just on the x ten.

It's very easy to use, so, there's no confidence intervals or anything. It comes directly from a GPS source, so it's very high quality data that the pilot can use to make decisions.

And so that's kind of just reasons why we've chosen our strategy. So the last thing here is that okay. So you've deployed these sensors, or you're using ADS B to see aircraft.

And so now, you know, if one does fly low in in near your area, you might have to take an action. And so, low flying aircraft, you know, just because there are low flying aircraft nearby doesn't mean you always have to take an action.

And so, you know, just for illustrative purposes, we kinda created three scenarios. But, this goes back to that well clear, definition that I shared earlier. So if a helicopter is flying overhead at five hundred feet a g l and you're flying at two hundred feet a g l, you know, by by those numbers, you actually don't have to maneuver to give way to that.

So, so we've chosen to make these decisions at least for now, you know, just pilot decisions and based on training and and understanding of the system.

It's not an automated avoidance maneuver, because, you know, if you start to build in some some rules about, you know, just do an automated avoidance maneuver if anything is within a mile, you could be doing unnecessary maneuvers, that actually add some risk potentially to your to your operation. So, so, yeah, based on our alerts, the pilot just looks, makes the decision, you know, what altitude is this aircraft at, how far away is it, and then if they need to, they take an action.

Okay. So that was all the airspace side of it. So now kinda switching gears to the citizen safety side. So the question here now is how do you avoid injuring somebody on the ground?

And this is mostly in the cases of our off nominal situations. So, if you have to do an emergency landing or for some reason, something like that. So the goal here is just, you know, don't injure somebody. So it's in some ways, it's a little more simple than than the airspace side of it.

And so we've we've got kinda three different strategies for how agencies can, achieve this and and what we use for Pasco County and and NYPD.

So firstly, the the first thing you can do is just kind of avoid it.

And so for Pasco County, what that looks like, at least for now, is that they're they're operating within the boundaries of of the school at the at these properties.

And they're using things like flight planning, you know, flying over rooftops, flying over tree tops where there's heavy vegetation, and if there was somebody under, they'd be kinda sheltered.

Be again, like time and place, so, you know, maybe don't fly during recess, fly between recess, whatever. So they can use all these strategies. There's no, prescriptive method there.

But the the goal is just avoid flying over people. And so we know that's not really tenable for for DFR where you're responding to calls for service. You don't have that luxury. But again, this is just kinda one one option if you're doing more of, like, a fixed site deployment. You know, in this case, it's schools, but, jails as well, different types of sites where, maybe you're just concerned with responding to events, you know, at that property.

So then the next thing, and still under part one zero seven here would be to add a parachute recovery system or some other way of mitigating the the energy of the drone as it comes down. And, so, we are developing an attachment for x ten, that will enable operations in category three of part one zero seven. So that would allow momentary flight over people and moving vehicles.

So again, I mentioned, you know, the the Pasco County approval, it's it's really just a stepping stone, for them. So they're able to to do response at their schools, at least for now, and then, you know, when the parachute coverage system comes online, we expect that approval to expand to kind of a full county deployment.

And then for NYPD, the path there is actually operating under a COA. So COAs allow operations over human beings when necessary to safeguard human life, so that's kind of the exact words that the FAA uses.

You know, gets in into technicalities here a little bit, but part ninety one, unlike part one zero seven, actually doesn't prohibit flight over people. So it doesn't expressly prohibit that.

You know, this the set of regulations was designed more for crewed aircraft flying at higher altitudes, and they had airworthiness certificates. So, you know, flying over people was really not a consideration when part ninety one was originally, developed.

But it does prohibit you from flying below five hundred feet unless you have a, like, a safe area to land. So, it's just technicalities, but it's kind of a different approach. So because partnering with one doesn't prohibit you from flying over people, the the FAA has kind of chosen to compromise on this a little bit. So, it's not a a carte blanche approval to to fly over people all the time or, like, large gatherings of people, so the CoAs even, prohibit some of those types of things.

But they understand that, you know, there are certain calls for service, the benefit of of getting to that call, and and helping people potentially saving their lives just outweighs the risk of, you know, flying over a person or a moving vehicle on the way to get there. So, so they've recognized that and and kinda found a balance. So, so when you need to under this COA and and for New York City, when they need to, they're they're able to just respond to the call for service and fly over our people and and just kind of accept that risk, along the way.

Okay. So yeah. So that that's kind of a, you know, deeper dive into, like, the safety case for both these approvals, and those two things combined have have really created these paths forward for doing drones first responder without VO's. And so, this next slide here is is a little bit of an eye chart, but it really just kind of shows these pathways opening up now. So on the top line at least, that really represents the the NYPD approval and and sort of the precedent and the blueprint that that sets, further agencies moving forward.

So you have the ability to fly, you know, shield the DFR operations with ADSB only, to do DFR or if you have the need to fly over two hundred feet.

It gives the ability add an airspace awareness technology to do that.

And then for waivers to part one zero seven, we have basically with the the Pasco County approval where you can do shielded DFR operations, with a parachute that kinda gives you full ability to to do, a citywide or countywide deployment without it. It's more fixed site.

And then I don't have enough time really to to kinda dive into it today, but, there also is now, a second waiver option called public safety organization, shield at ops.

And what the FAA is doing for that type of approval is kind of expanding, tactical b v loss into part one zero seven.

So happy to talk to anybody, you know, after this about that, but, just kinda running out of time today to hit them all.

Alright. Okay.

And so, you know, these pathways are now, you know, kinda opening up, and we're really excited to keep working with these two agencies, to make sure, you know, these safety cases are effective.

We made the right assumptions along the way, but we're also not done yet. So, like, the work isn't done, just because we got, you know, the VO removed for for one Koa. So, we're gonna continue to climb this, you know, summit, the autonomous summit here.

The things that are kind of on my mind, in the future are certainly enabling that, multi mission operation, the DFR command demo you saw yesterday.

We call that one to many, but, but, yeah, our our minds are certainly on unlocking that. So giving, agencies the ability to fly multiple drones simultaneously to respond to calls, whether that's, you know, doing, like, an on station handoff or, possibly responding to more than one call at one time in the future.

You know, it's also the the zero grids, what we call them, but essentially flying in those areas close to the airports. So if you remember back to the graphic with with them, New York City, the only areas that can't really fly today, at least routinely, are right around those major airports.

So we're gonna be working on ways to, get approvals to fly in those areas so they have kinda full coverage of their city or, other metropolitan areas, for other agencies.

And then, you know, there could be more after that. So, we're gonna keep climbing, keep working on this.

But, yeah, that's that's what I've got for today. And I think we've got, yeah, maybe five, six minutes for questions here.

So we'll take some audience questions first. Yeah.

Tommy will run over with the mic. I saw your hand first.

Hey, Jake. I could've texted you this, but I figured I'd put you on the spot.

So first question, are you guys starting with a two to many approach or going straight to one?

Two or one? Sorry.

Two two to many versus one to many. So there was some feedback we got a while back that just on on the multi rotor type ops side, so way more your world.

That, two to many approach initially would make a little bit more sense to get off the ground because if you have a, you know, ten nominal operations going on at once and then an emergency, the second pilot can take care of the emergency while the other nine flights are Okay.

Still being monitored. So are you guys gonna start with a two to many or you're gonna go straight to a kind of a one to x approach?

Got it. Yeah. Yeah. Okay. Yeah.

Yeah. So I think our our approach is is more the latter. So one to many. Right? So, so we believe that, you know, with autonomy, really, we can kind of solve a lot of those, you know, contingency situations.

I think we'll start initially with, like, a low number. So we're not gonna go straight to, like, a hundred or, you know, the drone light show types of numbers. But, you know, we think, one pilot flying two drones maybe is a is a good first step. Right?

Just doing, like, an on station handoff, because some calls for service last more than, you know, the thirty minutes of a battery life. Right? So if we can give that capability where you can just launch a second drone, do a hand off, that first drone comes back, that's a good first step, and then maybe we'll just kind of expand that from there. But, yeah, we believe the autonomy side of it is key to just handling some of those, you know, contingency things, without needing more pilots.

Got it. And as a non related follow-up, any plans to type certify the x ten?

Not today. Got it.

Thanks. Thanks, Jakey.

Who else has questions?

So in reference to your, fifty feet off, hundred feet over, is that preestablished?

Is that being enforced? How are you tracking violations of that? Like, how are what's that look like?

Like, the the fifty feet over structures is kinda thing about it.

Yeah.

Like, is that just pilot, hey, fly that way, or is that actually hard coded in in, like, a geofence type solution?

Oh, I see. Yeah. Yeah. So right. So it's it's two hundred feet AGL, just kind of broadly.

And then, yeah, as if if you need to get over two hundred feet to clear an obstacle or something like that. Yeah. Today, it it's based on the pilot, and so, you know, they're they're increasing altitude and and taking actions.

We are working on some some things to to make that easier, bringing in, like, terrain data, building data. I think you saw, what we call pathfinder, where the drone's kinda navigating through an urban canyon like that. So, yeah, we're we're working on some things to just make that easier and easier, and more automated. But today, it's it's just pilots. Yeah.

Hello, Jakey. Just kind of tagging along that question. As part of those waivers, does the FAA audit the data from all those calls, the DV loss calls, kind of then go back and issue a violation or something?

Yeah. So so for for NYPD particularly, there there are some record keeping and reporting requirements, because it is a new thing. You know, it really represents a major step forward for the FAA, and when typically when they do that, they wanna have kind of a feedback loop, like I mentioned. So are things going well?

Is there anything, you know, any safety things that we didn't think about? Are your mitigations working? So, so for them, there's gonna be a feedback loop. So we're gonna do some reporting back on, certain things related to, like, how many aircraft, did you avoid, you know, during your operations, or, how many connectivity issues did you have, things like that.

So, so, yeah, it's not not really an audit. There's just a feedback loop there, because the FAA wants to learn as well.

But, yeah, to to the question of if if is there some kind of monitoring system going on where they're they're looking for violations, you know, that that's really not, the the FAA's kind of mentality around things. I think they'd rather learn and just have those discussions with operators, versus just this monitoring and, like, violate them the minute they fly over fifty feet. Yeah. So yeah.

It's really it's really a partnership. I mean, to just put a cap on it. Yeah. So, you know, FAA, New York City Police Department, and us, they it's they really view it as just a partnership to to take this step forward.

You know, let's make sure it's safe, and then let's let's scale it out. Yeah.

Thanks. My question is is regarding patrol at DFR where a patrol officer, brings out the drone and it's controlled remotely and the assumption the officers on the scene then become the visual observers.

My question is how strict is it that the visual observers are being visual observers and not police officers? Right? That they've launched it. They become focused on the bad guy, and nobody's really looking at the sky. Can you just talk about what kind of the regulations the expectation is of the visual visual observers during patrol at DFR?

Yep. Yeah. So so yeah. The the expectation is that, they've received some training, you know, what their duties are, their role, phraseology, you know, how to scan airspace, you know, things they can do to help the pilot. So their expectation is there's some training there. And then, yeah, that, you know, even the words kind of out of the co are that it's a dedicated visual observer. So there's certainly an expectation that they are scanning airspace and and acting as a member of the flight crew and, not getting too distracted with other duties.

And so and we we recognize, you know, that that is a hurdle, right, to, like, implementing a patrol IDFR. Like, do you can you really take a guy out of this situation to kinda stand and scan airspace?

So the the ideal situation is, know, just like these two path forward, we just figure out ways to remove that requirement using other technology like ADSB. So that's our ultimate goal is to get rid of the need for that requirement even with patrol ed DFR. Yeah. For that reason.

Yep.

My question kinda goes in line with the gentleman in front there. You had mentioned that the FAA is always trying to learn, and I'm I'm curious as are a lot of other agencies and speaking to people around here, like, why the FAA chose for their first Novo DFR COA to be at, like, one of the most complex airspace areas in the country.

I just it was a little shocking. So do you happen to have any info on that? Yeah.

Yeah. I mean, so it's it's, it's something we've been working on a long time, actually. So this this didn't kind of just materialize overnight. So, it it took over a year of just working with them.

NYPD has been doing operations with a visual observer for a long time, so, so there's there's been plenty of operations going on. There's some level of, you know, trust and professionalism with with an agency like New York, that they're doing it right. And then I think, you know, it kinda goes back to, like, the safety case. So it I'll just say it again.

It's counterintuitive, but it's not it's not as crazy of an airspace as it as it might just kinda seem on the surface when you look down. So, there there really aren't aircraft just kind of all over the place flying at two hundred feet AGL.

All the aircraft there are cooperative, so we see them all with ADS B, and we can, you know, give take maneuvers, give right away if we need to. So, so, yeah, I think it it might be a little bit counterintuitive, but, yeah, it's actually you know, we the safety case we put together was seemed safe. So yeah.

Yeah. Sure. Yeah.

K. I only refresh.

Okay. Sorry. Just reading. But, yeah. So so one question. You know, what was it difficult to get the the one zero seven three dot dot three one waiver, so the Pasco County waiver?

So, I mean, there's kind of there's sort of two answers to this. So, there there's work that has to be done to get the first one. So, you know, for Pasco County, there there was certainly some work done to get that, you know, kind of first precedent setting approval, and work with the FAA on the safety case of that. Like I said, there's a lot of work that went into the New York City Police Department approval, took took over a year to to work with them on that.

So, yeah, the the sort of the first time through, it it is a little bit more difficult.

But then the the idea is that that sets precedent, and as long as the operations, you know, for Pasco, for New York City are safe, and and there is that, like, feedback loop that I mentioned, so they're gonna have to report back, are things going well, as long as everything goes well, and that gives the FAA, you know, kind of confidence to, approve it the next time with a shorter time line. So is the next one that hard to get as the first one? Usually not.

But it is, you know, it's part of our responsibility, part of the operator's responsibility to, to to continue operating safely. You know, you get these waivers, but there are provisions, and so make sure they understand it all and and continue to operate, safely so that we can, you know, we can make it easy to get the next one, so to speak.

And there was one other one, so related to ADS B.

So the question is kinda how are you planning to make that, functional functional fully, automatic. So I kind of interpret it to mean, like, an autonomous, avoidance maneuver, is sort of how I interpret that question. So, so it goes a little bit back to, you know, I was kinda talking about, not not every low flying aircraft nearby requires, an avoidance maneuver.

So, we've been a little careful to to implement autonomous and, like, autonomous avoidance things because, because we don't want to create situations where the drone is autonomously avoiding something it didn't need to, because that creates risk as well. So imagine, if you had to you know, your drone just suddenly descended, and there's a helicopter flying overhead, but that helicopter is, you know, turns at the last minute, and it's not a factor. So there's just there's enough situations where we think with the right training and just kind of the way that we've developed remote flight deck and and the alerting and and the information that's prevent presented, we think, the pilot is gonna make the best decisions for now.

We are thinking about, you know, adding, automatic avoidance, in the future, but just as as a kind of simple way to get started and not add extra risk by, you know, kinda unnecessary maneuvers, That's why we wanted to start at least.

So yeah. I think that's it. So, yeah. I guess I'll just kinda wrap up. I mean, thanks to everybody for coming, and sticking around.

I hope you have all safe travels home. And if you do have questions, I'll I'll be around for a little bit more. I'm gonna kinda wander over to the the program manager training, but I'll be in the lobby, so happy to talk more. So thank you all.

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