“There could be as many as 600,000 unmanned aircraft used commercially during the first year after this rule is in place.” – Michael Huerta, FAA Administrator.
Do you think that Part 107 will spark a 30-fold increase in commercial drone usage over the next 12 months? What will it actually take to go upstream and sell to enterprise? Will a “killer app” emerge to drive broad based adoption?
In this article we’ll look at how and when organizations adopt new technologies. We’ll introduce a model to identify the standards that will be needed. And we’ll talk to a diverse team of experts about some of the issues that must be addressed.
Since the early 1960s people have been trying to explain how and why technologies spread.
In 1993, Geoffrey Moore, a Silicon Valley management consultant wrote a book called Crossing The Chasm. Now in it’s third edition, the book has influenced an entire generation of high technology marketers.
Moore took a widely used version of the technology adoption model, a continuous bell curve, and modified it to reflect what he saw happening in his practice –significant disconnects between each group that negatively impacted sales. He called the biggest one, The Chasm.
Just as individual companies need to cross The Chasm to grow, the commercial UAV industry needs to cross The Chasm.
And while Moore’s work is primarily focused on corporate adoption, I believe that the underlying issues presented here apply equally to all types of organizations including government agencies and NGOs.
Let’s meet the key players.
The Techies are the folks on the leading edge – the geeks who first see how to apply the potential of new technologies. If the technology is awesome enough, they are fierce advocates who are willing to overlook all sorts of shortcomings in the product. In Moore’s words “They make great critics because they truly care.”
Visionaries are change agents who look for opportunities to use technology to create a competitive advantage. While I have not done the analysis, I would entertain the argument that the great majority of organizations (ex drone service providers) that applied for a 333, did so at the behest of Visionaries eager to get an early start assessing the technology.
What makes visionaries unique is their willingness to take bits and pieces and integrate them into something that moves their business forward. They are early adopters who are prepared to go it alone without a supporting ecosystem. They rely on Techies to help them assess the feasibility of new ideas. Then, once they are done developing, they move on leaving implementation to others. Which is the reason that 80% of the market is on the other side of The Chasm.
Where the Visionary is focused on building a technology driven future, Pragmatists are focused on incremental industry improvements.
The first of Moore’s “ahas” was realizing that a start-up’s success with a handful of Visionaries was of little interest to the Pragmatists.
It is the lack of industry specific references that creates The Chasm.
Pragmatists want to buy complete working solutions that have been demonstrated to meet the specific needs of their industry. More importantly, Pragmatists want to buy from proven market leaders that others within their industry have already chosen – a wicked Catch-22.
If it’s not clear from the graphic, Pragmatists are the de facto arbiters of broad based adoption. Together with Conservatives, the two groups make up two thirds of every technology market.
In his excellent new book, Enter The Drones, aviation writer Bill Carey notes that a year after Peter van Blyenburgh’s European RPAS Steering Group submitted its report, “The European Commission signaled its intention to set tough new standards for the safety, security, privacy, data protection and insurance of what is called civil drones.”
The FAA’s authority to make and enforce rules is limited to it’s safety mission. In fact, there is no single agency that has jurisdiction over the rest of these, and as a result there is no entity that is able to address the development of national standards in a holistic manner.
If you’re a Pragmatist, it begs the question, where will the standards come from.
The db.c UAV Industry Standards Stack
The db.c UAV Industry Standards Stack was developed to provide a way to visualize a given market sector. You could think of it as a flight plan for crossing The Chasm.
- The horizontal axis contains the “CORE” building blocks that are used by the commercial drone industry. Few people realize the central role the FCC will play in allocating the spectrum necessary for complex drone operations, as well as determining how drone counter measures will be implemented in the United States.
- The vertical axes reflect the “SPECIFIC” needs of a given organization. Privacy and Insurance are repeated here to reflect unique requirements.
- In the absence of national regulation, the oft maligned “patchwork quilt” of State and Local regulations will continue to evolve and impact industry operations in various ways.
Because the Pragmatist is concerned with standards and industry experience, this model makes a strong case for why adoption will be uneven.
- It offers important clues as to why many corporations will field pilot programs before they buy fleets, and why many companies will purchase drone services first.
- It suggests that business opportunities exist throughout the Stack.
Guidelines For Unmanned Aerial Systems Operations Around Vertical Communications Infrastructure developed by The National Association of Tower Erector’s UAS Committee is an excellent example of the type of document that ecosystems will have to develop to define their stack. NATE Executive Director Todd Schlekeway told me that with over 12,000 tower technicians and hundreds of thousands of towers located in all 50 states, NATE is embracing UAS technology as a means to enhance safety and efficiency. They will soon be releasing an updated version of the guidelines which incorporate Part 107.
This leads to a very real question about where 600,000 pilots are going to come from. The vision of a drone in every lineman’s truck is tempered by the recognition that in many industries, not every employee will be able to pass the Aeronautical Knowledge Test. Those who do, will then have to learn to fly and maintain their drones before drones can be fully integrated into the work force.
It will certainly take longer than 12 months to build a skilled pool of pilots, technicians and analysts capable of handling the wide variety of sensors, mission profiles and operating environments that will be required for broad adoption.
The question becomes exponential when you consider the millions of pilots necessary to command the 11 million commercial units the FAA forecasts will be in operation by the end of 2020 – well before any fully autonomous operations will be approved.
Given the number and complexity of these issues, I am inclined to agree with the Gartner Group who forecast broad scale corporate drone adoption to be a minimum of 5-10 years out.
In summary, the FAA has provided a set of minimum standards consistent with its safety mission. It will be up to individual users, industries and ecosystems to develop the rest.
The Experts Weigh In On Adoption
To provide a broad perspective, I spoke with with six industry leaders.
“If you don’t know what the risks of the NAS actually are, what do your standards mean?”
Patrick Egan, the editor of the Americas Desk at sUAS News, has been involved in the effort to develop regulations and standards since 2004 when he began working as a Director of the RCAPA, the Remote Control Aerial Photography Association. Patrick notes that “We could have done this 10 years ago. We had an entire proposal ready in 2007.” (Egan figures prominently in Carey’s book which I was reading when we spoke.)
He has spent years contributing to numerous ASTM International and RTCA (Radio Technical Commission for Aeronautics) taskforces. Both organizations devoted considerable time and resources to come up with UAS certification concepts in areas like aircraft, pilots, communications systems, batteries and command and control software. All of their efforts were scrapped by the FAA, as was a proposed NASA drone matrix test program.
But he keeps trying. “There is a lot of work to be done. I keep talking to the OEM’s encouraging them to move beyond assumptions by funding hard research into the risks of various size drones to non-participants on the ground, to auto glass, to structures and to smaller aircraft which are most likely to be affected by a drone strike.” He adds that understanding the risks would lead to proportional regulation – for example you might not always need ISO 9000 standards. So far his arguments have fallen on deaf ears.
Famously outspoken, Patrick expressed concern that none of the manufacturers who agreed to the idea of self-certification proposed during the MicroARC have any idea of the time and expense involved.
“Companies who don’t think there will be standards are dead.”
Beyond the FAA’s standards for pilots, are standards for the aircraft they fly. Clearly, certification has a lot of benefits. It is an assurance that an aircraft is airworthy. That a maintenance protocol has been defined. And that there are trained mechanics to maintain and upgrade the craft.
To no one’s surprise, the idea of certification is anathema for manufacturers whose product development model is based on constant iteration, and whose retail strategy is based on the next big price drop.
Mike Blades is an industry analyst covering the global UAS market for Frost & Sullivan. He is a retired USAF command pilot and instructor. I asked Mike for his thoughts.
“Certification standards are simply too expensive and won’t be put in place until the FAA is forced to do so. An autonomous UTM that is fully integrated with the NAS is likely to be the catalyst. All sorts of standards will need to be in place from the platform to communications protocols to battery life to redundant systems to obstacle clearance performance.”
Both Mike and Patrick wondered if the FAA will apply the DO-178B standard to small UAS. DO-178B is a de facto standard for developing avionics software systems that the FAA uses to determine if the software will perform reliably in an airborne environment. This seems particularly likely with use cases involving a high degree of integration with the NAS such as delivery, long distance BVLOS and higher operating altitudes.
“How many disasters are we going to be allowed?”
Beyond image capture, commercial demand will initially be driven by the 4 Ds – dirty, dull, distant and dangerous. It should not come as a surprise that an environment that is dangerous for humans is also often dangerous for UAVs.
Frank Mellott is a retired US Navy Commander who spent his career flying jets mastering the fine art of Naval Aviation Carrier Safety. Now a safety consultant, Frank is quick to point out that since Part 107 does not include any skills testing, a prospective employer has no idea if an applicant is capable of carrying out the operations they are hiring for.
He told me that “I would never hire a pilot without a check flight during which the applicant shows me that they can execute the exact maneuvers required for the specific mission. That demonstration should take place in an environment as much like the real job site as possible.”
This emphasis on real world scenarios come from his experience with the Navy’s Naval Air Training and Operating Procedures Standardization (NATOPS) program.
He explained that the idea behind NATOPS is to “Train the way we operate. Operate the way we train. Standardize and hold people accountable.” To which he added “The idea is to create a continuous improvement process. So you have to constantly update the training to reflect changes in operating procedures.”
Like Mike, Frank notes that aviation is data driven. Lessons learned, particularly accident investigation, will be essential to the FAA’s evolution of Part 107. (Accident reporting is a requirement.) “Data is the key to identifying the operational areas where there are problems. If you can identify the problem and break the causal chain, you can avoid the next accident.”
“The main goal of any remote sensing software is to detect something in time to make a correction.”
In his four-part series, The Truth about Drones, Colin Snow of Skylogic Research makes the point that “Drones equipped with sensors acquire data, not information. Whatever data the drone captures, needs to be converted into useful information.”
An analyst with a strong background in enterprise IT, Snow spends much of his time digging into the big vertical application areas: agriculture, construction, inspection, mapping and public safety.
There are also questions about precision, one of the keys that differentiate prosumer and high end solutions. Colin points out “Application and data requirements vary with the industry. For instance, in surveying and mapping the end customer usually has stringent accuracy requirements defined by contract. Let’s call this ‘Survey Grade’ accuracy. Unfortunately, most drone software by itself can’t meet this.”
Furthermore, despite widespread corporate acceptance of open source solutions from Red Hat and others, Colin has found “Highly integrated software trumps open source in commercial use. How many surveyors, photographers, inspectors, police, firemen, farmers want to be configuring code every time they swap a sensor?”
Sorting the wheat from the pretenders is exactly why Pragmatists look to their peers.
Data collection is not innovative. What is new is the ability to do it in house for a low cost.
David Kovar of Kovar & Associates, specializes in UAS cyber security and digital forensics. He advises that UAS data should be managed the same way as other sensitive corporate data. “That means including UAS data within the larger data environment. It needs to be part of threat intelligence, security monitoring, incident response, vulnerability management and audit programs. Perhaps most important, clients need to have a plan in the event of a breach.
I asked David why. He pointed out that large companies are not in the habit of collecting useless information. Instead they are deploying UAS’ to document their secrets and intellectual property. “Every mission is planned to support a corporate objective, so even something like a flight plan can tip a competitor off to an area of interest or concern.”
“We’re taking a fairly liberal approach to cover.”
In the absence of what would have been an unprecedented FAA insurance mandate, states are free to legislate their own requirements. A move that some industry players are actively opposing. It actually doesn’t matter much for the commercial UAV market because a basic truism in the insurance industry is that it is the client’s requirement for indemnification that drives demand.
As is the case in manned aviation, many observers expected insurance underwriters to establish their own additional requirements. So I was eager to chat with Chris Proudlove, Senior Vice President of Global Aerospace and the point man for their global UAS initiative.
Chris told me “When Part 107 was on the horizon, our team was looking at traditional underwriting –pilot hours, the type of craft being flown and the mission. Ultimately we made the decision to cover any operator who passes the Knowledge Test and operates under Part 107 guidelines. Over time we’ll take a look at the data and adjust as needed.”
A significant benefit to this strategy is that Global can scale quickly. Since Global was a pioneer in offering drone cover, I wondered how their experience shaped their approach. Chris sounded relieved when he explained that “We’ve had a good number of hull claims but only a couple of minor liability claims.”
Asked about the future Chris told me that he is “Watching to see who survives the next couple of years. I think that a lot of the forecasts are exaggerated and the weeding out is going to happen swiftly.”
“People are captivated by the limitless possibilities unmanned aircraft offer, and they are already creating business opportunities in this exciting new field.”
So said a justifiably proud Anthony Foxx, the Secretary of the Department of Transportation, when he announced that Part 107 was open for business. “These new rules are our latest step toward transforming aviation and society with this technology in very profound ways.”
Part 107 makes it apparent that the FAA has concluded that if people fly under 400’ AGL, stay away from airports and keep the drone in sight, commercial drone operations can be conducted in a manner that poses little danger to the NAS.
I think that Visionaries must be largely gratified by the progress. By eliminating the requirement for a manned license and an observer, Part 107 makes it easier and less expensive to field a workforce. And the recently passed FESSA (2016 FAA Reauthorization) bill ensures ongoing government investment in critical areas like UTM.
On the other hand, I don’t think that the Pragmatists got everything that they needed.
It is important to understand that the Pragmatist does not want to take on this workload.
Given the growing pressure that the FAA has been under since 2012 to integrate drones into the NAS, Part 107 was a smart strategic move. Clearly promoting business is not an FAA mission. But without an FAA imprimatur, there is nothing like a Good Housekeeping seal of approval to encourage implementation.
Unlike manned aviation, the FAA has left it to the customer to determine if a pilot (or service provider) is qualified to meet the needs of their mission. It will also be up to the organization, together with the pilot, to determine what “ensuring a drone is safe before flying” means, as well as how to maintain it and who should do it.
As the db.c UAV Industry Standards Stack suggests, the FAA knows that there are other forces at work. State and local legislatures will deal with issues like privacy and insurance. Employers – oil fields and towers and bridge owners and movie producers and farmers – will enforce their own performance standards. Attorneys will demand insurance. And as the market grows and segments, underwriters will set additional standards for high risk operations.
As a result of a wide variety of initiatives, different verticals will fill in their stacks at different rates:
- Waivers will define the rules for more types of missions.
- Standards and best practices will evolve as ecosystems gain experience.
- An experienced pool of pilots with specific skill sets will emerge.
- Metrics will be developed.
We already know that the Visionaries are willing to take it on.
The Technology Adoption Curve makes it clear that the Pragmatist is the key to the growth of the commercial drone business. The real question for anyone trying to forecast the rate of adoption and so the growth of the industry is “What will it take for an organization to decide that the benefit is great enough to overcome the lack of specific standards and solutions?”
Someone recently asked me if I was bullish. I am – that’s why I am here. But I am not irrationally exuberant. The careful reader will see that there are opportunities everywhere, as well as red flags.
The very brightest part of the future will belong to those who can fly across The Chasm. Which makes it appropriate to give Geoffrey Moore the last word:
“A successful crossing is how high-tech fortunes are made; failure in the attempt is how they are lost.”