7 Key Considerations and Recommendations for UAS Safety
Insights from 383 ARC
The full report from the Federal Aviation Administration’s (FAA’s) recently concluded Aviation Rulemaking Committee (ARC) focused on UAS Detection and Mitigation Systems, also known as 383 ARC, was recently published. Echodyne has participated in previous ARCs and is grateful to have been asked to co-chair (with RTX) the working group on systems and technologies for the 383 ARC.
Under the direction of the FAA’s UAS Security office, AUVSI, and Airports Council International – North America, the ARC convened representatives from industry, academia, public safety, and government to tackle the thorny issues arising from securing key assets and locations from unauthorized or malicious drone flights. Drones represent a considerable escalation in the threats to national security and critical infrastructure. Establishing and maintaining proper tactics, techniques, and procedures (TTPs) for airspace situational awareness requires expertise and advanced capabilities. The Echodyne focus was and is to ensure that radar can be part of effective, multi-layered counter-drone solutions.
The approach of the ARC was unique, in that the primary consideration was the impact of detection and mitigation systems on the National Airspace System (NAS). In some ways, the approach allowed systems and technology discussions to gracefully end – the consideration was not good or bad counter-UAS, but the impact good or bad CUAS might have on risks to safe and predictable operations in the NAS. Complicating all of this was the lack of definition of what constitutes “good” drone behavior – how does one describe how to safely police airspace operations that today are few and generally undefined?
With “thou shalt do no harm to the NAS” as primary guidance, the group approached the challenge from four perspectives:
- the community in which these systems would operate
- airports
- other critical infrastructure
- systems and technologies
The full 383 ARC Report provides all the details and you are strongly encouraged to read it cover-cover, and here is a summary of seven key considerations and associated recommendations:
1. INTENT
It is extremely challenging to identify the intent of a drone operator. This makes every drone a potential intruder. Flight plans and flight operations data made available to security teams would alleviate the pressures arising from volumes of unknown and unexpected drone traffic.
Strong recommendation: Support UAS Traffic Management (UTM), UAS Service Suppliers (USS), and other data sources and exchanges of data related to current and planned drone operations. The more data available for security operations, the lower the risk of unintended incidents.
2. EFFICACY
There is little expertise for counter-drone outside of small groups in Federal agencies and pockets across industry. The subject of security is serious enough that we can ill afford equipment or systems purchases that look good on paper but perform poorly or, worse, inadvertently.
Strong recommendation: Independent 3rd party(ies), such as FFRDCs or UAS test centers, should be funded to thoroughly test performance characteristics and publish performance data for approved public agencies and critical infrastructure owner/operators. If the equipment works as advertised, there is no reason for industry to hide this data in the face of such grave risks.
3. MINIMUM PERFORMANCE STANDARDS
Related to Efficacy, the idea is to create a baseline set of requirements that any approved equipment or system must meet. While interesting, the high level of variation in security planning from location to location for similar industries makes this quite challenging.
Recommendation: Put more emphasis on Efficacy. Certainty in knowing how equipment or systems will perform allows security professionals to adapt to site or mission requirements.
4. RISK
The subject of risk is tricky. CI owner/operators are not being pushed by insurance underwriters to enhance security against drones. And if there were such a push, the solutions would largely be illegal. Granular assessments of risk allow for facilities that pose the most danger, either to national security or the general population, to receive more attention, better equipment and systems, and the training to conduct the work properly.
Recommendation: Establish a national framework to assess Risk by CI category, akin to the Security Coordinating Councils (SCC) within the Cybersecurity and Infrastructure Security Agency (CISA).
5. AIRPORTS
There is an expression the airport community loves – if you’ve seen one airport, you’ve seen one airport. That is, each airport is sufficiently unique to resist templates and models. Fair enough and true enough across all critical infrastructure. Airports remain the only place where interaction of crewed and uncrewed aircraft is expected to happen, which does make these locations altogether unique.
Recommendation: Empower airports to do what is best at each location. Where compelled by wider community interests, federal funding should be provided for airports.
6. PRIVACY
When remotely piloting a drone, should the operator be able to maintain privacy? Identifying and tracking piloted aircraft is relatively straightforward but, as uncrewed aircraft volumes increase, should the equivalent remain?
Recommendation: Privacy should be secondary to security. We may not be able to know contents of an aircraft but knowing the identity of the aircraft owner and operator helps mitigate risk.
7. MOBILE/CELLULAR
Much of today’s counter-drone capabilities arise from an early design choice by drone manufacturers to use unlicensed spectrum, such as Wi-Fi and other frequency bands that do not require licenses. Using this spectrum for communication made it incredibly simple for consumers to interact with their drone from distance, as well as making it easy for industry and authorities to build and use Radio Frequency (RF) tools that can easily interrogate and potentially intercept the communication between operators and drones. As the wireless operators create programs for drones, more communication will move to licensed spectrum that will be outside the technical and legal capabilities of these RF tools.
Recommendation: Multi-layered, multi-sensor counter-UAS solutions are essential for robust security.
It was a pleasure to meet counterparts from industry, academia, public service, and government during the ARC work. Echodyne is committed to working with Federal, State, and Local authorities, with Industry, and with Academia to find creative ways for technology to solve our most important security challenges, especially security from rogue drone operators. Please reach out if we can be of assistance in your efforts to design and operate airspace security solutions.