Simulation Was Staged Faster Than Both Maximum Possible Speed And FAA Guidelines
October 19, 2018 – DJI, the world’s leader in civilian drones and aerial imaging technology, today demanded the University of Dayton Research Institute (UDRI) withdraw a misleading video and blog post which claim to depict a collision between a DJI Phantom 2 drone and the wing of a small airplane.
UDRI staged its video to create a scenario inconceivable in real life, at a higher speed than the combined maximum speed of the drone and airplane, which is also faster than U.S. Federal Aviation Administration (FAA) testing guidelines. UDRI has not disclosed its testing methodology or the resulting data, and while it acknowledged that a similar test with a simulated bird caused “more apparent damage,” it has only promoted the video showing damage from a DJI drone.
In a letter to the lead researcher involved in the video, DJI’s Vice President of Policy & Legal Affairs said UDRI “recklessly created and promoted a video that falsely claims to depict a dangerous condition posed by one of our products. … Your public comments deliberately present an entirely improbable, if not impossible, event as a commonplace risk routinely faced by airplane pilots.”
The full text of the letter is reproduced below, and a pdf of the letter as delivered is available at this link.
October 19, 2018
Via Electronic Mail
University of Dayton Research Institute
300 College Park
Dayton, OH 45469
Dear Mr. Poormon:
I represent DJI, the world’s largest manufacturer of small unmanned aircraft systems, commonly known as drones. We lead the industry in developing systems to help ensure drones continue to safely share the airspace with traditional air traffic. DJI takes aviation safety seriously. It is integral to who we are as an organization and as aviation professionals. We have proactively incorporated dozens of safety features into our products, including altitude limitation, airport geofencing, return-to-home failsafe systems, computer vision anti-collision sensors, and pilot knowledge testing. We also support research professionals who work alongside the industry and regulators to provide academic grounding to aviation safety efforts.
It is thus distressing to see how the University of Dayton Research Institute has recklessly created and promoted a video that falsely claims to depict a dangerous condition posed by one of our products. Your “Risk in the Sky?” video, blog post and media tour created a collision scenario between a drone and an airplane wing that is simply inconceivable in real life:
- Your video assumes a Mooney M20 light aircraft is flying at its maximum possible speed of 200 mph, and encounters a drone apparently flying faster than its maximum possible speed of 33.5 mph. The plane could only achieve such speed at full cruise, typically more than a mile above ground. At the altitudes where that plane would conceivably encounter a Phantom drone, it would fly less than half as fast — generating less than one-fourth of the collision energy.
- Your video was created contrary to established U.S. Federal Aviation Administration (FAA) crash test parameters, which assume a bird striking an airplane at its sea-level cruising speed — which is typically 161 mph to 184 mph for Mooney M20. Your video deliberately created a more damaging scenario, and was widely cited as evidence for what could happen to a large commercial jet — even though the Mooney M20 is a small plane with four seats.
- Your video was not created as part of a legitimate scientific query, with little description of your testing methodology and no disclosure of data generated during the test. Your blog post describes a similar test performed with a simulated bird that caused “more apparent damage,” but your decision not to post or promote that video indicates your bias toward sowing fear. This contrasts with the reputable research performed by the Alliance for System Safety of UAS through Research Excellence (ASSURE), the FAA Center of Excellence for Unmanned Aircraft Systems, which meticulously tests a variety of impact scenarios in order to provide the public, the FAA, and the UAS industry, with supportable conclusions about risk. You have done nothing of the sort.
Given UDRI’s wide-ranging publicity efforts in print, broadcast and online media, it seems clear that your misleading video and incendiary blog post seem designed to generate paid research work for UDRI at the expense of the reputation of drone technology broadly, and DJI’s products specifically. Your public comments deliberately present an entirely improbable, if not impossible, event as a commonplace risk routinely faced by airplane pilots.
To elaborate on the points outlined above, the impact velocity tested, 238 mph, far exceeds any conceivable collision speed between a Mooney M20 and a DJI Phantom 2. The M20J Pilots Operating Handbook lists the maximum structural speed of a Mooney 20 at 174 knots, which is 200 mph. Cruise speed will typically be 140-160 knots (161-184 mph), more than a mile above ground. The Phantom, and our other drones, have built-in altitude limitation features. Thus in the altitudes no higher than several hundred feet above ground where a drone is likely to operate, the Mooney M20 would be taking off or landing at speeds between 70-88 knots (81-101 mph).
As for the other aircraft in this scenario, DJI has not manufactured the Phantom 2 drone for years, but its published specifications indicate a top speed of 15 meters/second, or 33.5 mph. In other words, it is virtually impossible for these two aircraft to encounter each other at the speed of your test. Given that kinetic energy, and therefore resulting damage, increases by the square of velocity, the arbitrary increase in your test velocity results in dramatically more damage.
More to the point, a test deliberately designed to generate the worst conceivable outcome is contrary to the FAA’s established testing parameters, which seek to measure the risk that an aircraft is most likely to encounter. The relevant Federal Aviation Regulation states an airplane must be capable of successfully completing a flight despite striking a bird at the equivalent of the aircraft’s cruise speed measured at sea level, which as stated above is 161-184 mph for the Mooney M20. Your test was thus performed at a speed 54 mph to 77 mph faster than a responsible collision test would require, creating a case that is unrealistic and damaging to the reputation of our company’s products.
Reputable testing institutions have meticulously tested a variety of impact scenarios in order to provide the public, the FAA, and the drone industry with supportable conclusions about risk. ASSURE has set the standard for this work by releasing detailed reports with careful documentation of their testing methodology and hundreds of pages of data. By contrast, the limited information available about your demonstration prevents anyone from determining other flaws in your methodology and conclusions.
Your video and blog post have been promoted in media around the world, yet nowhere in any of your print or television appearances have you qualified the limited and unrealistic nature of your test. As a safety researcher, surely you understand the detrimental impact on public perception when purported scientific research is not presented with appropriate caveats and with an opportunity for peer review and alternative views.
Unbalanced, agenda-driven research does substantial harm to our industry and to our company. Policymakers at all levels of government have responded to sensational media coverage by proposing and enacting new restrictions on drone ownership and use. These limitations prevent people and businesses from using drones safely for beneficial purposes, such as performing hazardous inspections or finding missing people. At least 195 people around the world have been rescued from peril by drones, many of them saved by small drones such as DJI Phantoms. By misleading the public and promoting fear about drones, you are undermining their benefits and encouraging restrictions on their lifesaving uses.
We respectfully demand that you withdraw your research, remove the alarmist video from circulation, and issue a corrective statement to the public and to all of the media outlets you have appeared in, acknowledging that the configuration of the test was invalid given the flight envelopes of the two aircraft tested, FAA testing standards, and the limited value of a single test.
Yours very truly,
Brendan M. Schulman
Vice President of Policy & Legal Affairs
Dr. Allan Crasto, Director, UDRI
Mary Ann Poirier Recker, Vice President and General Counsel, University of Dayton
Published at Fri, 19 Oct 2018 20:20:51 +0000
Today EU Transport Commissioner Violeta Bulc launched the European network for drone demonstration projects. The network will become a forum to share knowledge on how to keep drone operations safe, secure and green. It will focus on the so-called U-space: a system that connects all drones flying in the air and that makes all drones visible for authorities and citizens.
Commissioner for Transport Violeta Bulc said: “Drones are a key part of the future of aviation and will become part of our daily lives. All players can mutually learn from practical expertise on how we can keep drone traffic safe, secure and green in the public space. That exactly is the purpose of this EU wide network.”
Already today, drone and U-space projects deliver concrete results on how to fly drones safely and how to make the developing U-space system more reliably robust. Yet these U-space projects are only sustainable and will only attract additional investment if the proposed solutions are compatible with the European framework. That is why the Commission has taken the initiative to establish a European Network of U-space Demonstrators to support these projects.
The network is a cooperation of the European Aviation Safety Agency, SESAR Joint Undertaking (SJU) and EUROCONTROL and will focus on promising projects that still need some further operational and regulatory demonstrations before starting commercial operations. The network will focus specifically on projects with a clear business case that builds on mature technologies but need some further operational and regulatory demonstrations before starting commercial operations.
The network would also support the competent authorities in processing the numerous applications that can be expected once commercial businesses will be started.
Erwin Verstraelen, Chief Digital and Innovation Officer, Antwerp Port Authority: “Innovation and digitization are crucial if our harbour is to stay sustainably competitive in the long term. Drones will become indispensable in the near future, not least in our port, to support our role as operator and regulator. Furthermore, in our role of a community builder, we facilitate the use of drones as much as possible for all stakeholders. Given the particular nature of our port, this has to be done in a safe manner. Through our participation in this network, we are confirming our pioneering role and ambition to be an open and innovative hub that institutionalizes new technologies.”
Marc Kegelaers, CEO of Unifly: “This European Network of U-Space demonstrators is a first: all stakeholders of this new industry are invited to work with the regulator to explore how a solid regulation can be built to enable the European drone services market. We are excited about the prospect of contributing our international experience to this initiative. The safe integration of drone traffic is crucial.”
Johan Decuyper, CEO Belgocontrol: “The drone sector is making us re-invent ourselves as airspace manager, and deal with new types of airspace users. Rather than standing on the sidelines, we believe it is important to be a driving factor in this evolution. Yet we cannot and will not ignore the safety challenges that go along with it. The only way of dealing with this properly is to innovate, to adapt and to pave the way towards automation where we can, and in a safe and secure way. This includes also the drafting of new EU laws on the use of drones. Therefore we welcome initiatives like the platform that is announced here today. We are looking forward to fully collaborate to the platform and the drafting of EU regulation.”
Published at Fri, 19 Oct 2018 19:44:49 +0000