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What is Happening?
With the recent introduction of Federal Aviation Administration (FAA) Small Unmanned Aircraft Regulations (Part 107), the U.S. has paved the way to manage and license drone operations for commercial use (Trip Report: 3 Enterprise Takeaways from InterDrone 2016, 6 Ways Drones Mean Enterprise Business, Now).
One of the core features of Part 107 is the rule governing drone usage outside of visual line-of-sight operations – namely, they are not permitted without a specific exemption. Multiple companies, including Google, Amazon, BNSF Railway, and several oil companies have operated with exemptions to the previous Section 333 rules, and are likely to continue to secure waivers to continue operations.
The focus of the FAA’s regulations on drones has so far been targeted at how commercial operators can continue to use drones safely. Limits on weight, line-of-sight, flights over people, and permitted cargo are all designed to reduce the risk of drone operations. But as the FAA begins to weight the possibility of controlling drones over LTE, then they necessarily run into issues of net neutrality.
Why is it Happening?
Traditional radio controls have limited ranges, which can suitably manage drone control up to distances of several miles depending on the hardware. However, these radios tend to operate on unlicensed spectrum (most commonly 2.4ghz, the same as WiFi, Bluetooth, cordless phones, and domestic microwave ovens), and as a result are vulnerable to signal interference that can reduce their range. Additionally, the range is further limited by the exact control frequency’s ability to penetrate solid objects, which comes into play immediately when operating a drone outside of line-of-sight. To combat this limited range, there are really only three options when flying outside of line-of-sight or manual control range, and the most potentially beneficial approach opens a can of worms when it comes to Net Neutrality challenges. The three options are as follows:
- Fly Autonomously. Because advanced commercial drones have onboard GPS and flight computers, operators can generate a flight plan and transfer all the necessary instructions to the drone, which can then follow them even if interference or distance limits the drone’s ability to communicate with its controller. However, this approach is not yet fully vetted. Most flights that rely on uploaded flight paths are still done within line-of-sight, with the autonomous aspect typically operating as a way to ensure full coverage of imagery for mapping, or to enable the drone to follow precise instructions for the purpose of capturing specific footage for film or photogrammetry purposes.
- Fly Autonomously + Sense-and-Avoid. This is a second-generation approach to the above technology. Drones in this category will need to have different hardware to allow them to not only follow a predefined track, but also to take evasive/avoidance action in order to avoid collision with objects that may end up in their path. This technology is still mostly in proof-of-concept and trial phases. However, for long distance delivery, and autonomous flight, this “remote sense-and-avoid” technology will likely be the gold standard for achieving the FAA exemption. However, again, this does not cover all use cases, specifically those that do not necessarily follow a predetermined flight path like inspections, exploration, search and rescue, and flightpaths in cities where GPS becomes significantly less reliable.
- Get a better radio. This is likely to be used in conjunction with number 2 above for certain flights, and also as a replacement for existing remote controls for drones designed for long distance operations. And the obvious choice due to the bandwidth and coverage needs is to use existing LTE networks to control the drones via internet.Currently, Intel and AT&T are working on chips that will bring LTE to drones to enable this kind of control. In areas with LTE signal, this network should allow drones to be remotely piloted well beyond visual line-of-sight while maintaining connectivity to the pilot.
The big issue is this: LTE bandwidth and frequency is already limited in/near major metropolitan areas such as San Francisco and New York, and in more rural areas can be limited by the hardware available on each cellular tower. Additionally, because spectrum is allocated in the U.S. by auction from the Federal Communications Commission (FCC) on a per region basis, there is little uniformity in the quality of internet from a given provider across different geographic regions.
In June of this year, the FCC won a court case that affirms its ability to both regulate and enforce Open Internet rules (a.k.a. “net neutrality”) rules that it passed last year (No Net New for Net Neutrality). The FCC had previously ruled that providers are not allowed to differentiate between different uses of bandwidth, and that all traffic must be treated equally. Carriers – specifically mobile carriers like AT&T – objected to this change on the basis that they had difficulty meeting demand and that by limiting high-bandwidth traffic, they could provide better service to all of their users. To achieve and sustain commercial viability at a large scale with safety, net traffic controlling drone activity will need to be prioritized over other forms of traffic. Drones, and other autonomous vehicles, must be able to send and receive signals as continuously as possible – which implies some form of network traffic prioritization.
Market Impact
In a world of purely digital-to-digital communication, Net Neutrality rules seem to be oriented toward consumer protection, preventing carriers from creating fast and slow “lanes” for different types of content, or differentiating commercial vs consumer users. However, as technology increasingly incorporates more digital-to-physical systems including drones and other autonomous vehicles which will depend on Internet access to operate, it raises the question whether all use cases really are equal. We think they are not.
Drone operations serve a legitimate commercial and public purpose—facilitating inspections, public safety, and operator safety (Quick Take @ Interdrone 2016 – Drone Safety and Risk) —and being able to operate them is aligned to the public interest. As a result, if drones and other autonomous vehicles are to be controlled using public networks, governments must guarantee adequate bandwidth to control drones to ensure safe operations. This will likely include prioritization of bandwidth for situations where Internet access is necessary for real-time remote control. Because low-bandwidth conditions cannot be predicted, it will be difficult to mitigate issues arising from bandwidth limitations ahead of time, especially as flight (or drive) times and distances increase.
At present the issue of adequate bandwidth is still speculative, and has not been challenged by providers or drone operators. But we think the growth of drones and other devices using that part of the spectrum will challenge the infrastructure. There may yet be permissible technical solutions to mitigate when drones lose connectivity, such as auto return-to-home or auto-landing features. Eventually, long-distance unmanned flights will likely become fully autonomous and rely on no continuous control – so that bandwidth and connectivity issues become significantly less important. But in the meantime, issues remain.
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