Insights from the Nogales Predator crash for the integration of UAVs into the National Airspace System under FAA interim operational guidance 08-01

In April 2006, an Unmanned Aerial Vehicle (UAV) crashed near Nogales, Arizona. This incident triggered one of the most sustained studies into the causes of failure involving Unmanned Aerial Systems (UAS). The National Transportation Safety Board (NTSB) together with the US Customs and Border Protection (CBP) agency under the Department of Homeland Security identified many lessons from this mishap. The following pages use the insights provided from the Nogales crash to support a critical review of the most recent FAA guidance on the integration of UAS into the U. S. National Airspace System. The existing version of FAA’s Interim Operational Approval Guidance 08-01 addresses many of the problems identified in the NTSB report into this incident. However, we conclude that greater oversight is needed to support the exemptions that are permitted for the provisions within this document. In particular, our analysis questions whether a process that enables the same agency to act as regulator and operator of a UAV can be justified within the National Airspace System especially when Federal Agencies delegate operational responsibility to sub-contractors. It is also argued that the Nogales crash illustrates the need for greater coordination between UAS operational staff and Air Traffic Management in order to improve mutual situation awareness under normal operations but also to support coordination under degraded modes. Finally, it is argued that the existing requirements for the certification of maintenance technicians and of maintenance management processes under FAA 08-01 should be strengthened <i>beyond those for conventional aviation</i> to avoid the sense of complacency that undermines the safety of UAV operations within the National Airspace System