NAAA Comments on Petition for UAS Package Delivery Reporting Relief

On December 30, NAAA submitted comments on a petition for Zipline to make several amendments to their Part 135 UAS package delivery exemption. These amendments would collectively absolve the petitioner from having to submit service difficulty reports (SDRs), mechanical interruption summary reports, conduct pre-employment and random drug testing of its employees, conduct random alcohol testing of its employees and report pilot records to FAA’s Pilot Record Database. 

NAAA’s comments centered on ensuring robust safety data reporting channels with FAA are maintained. While the petition made claims that some procedures were redundant by reporting similar information to multiple FAA offices, NAAA pointed to a recent DOT Office of Inspector General report which highlighted major deficiencies in interorganizational data visibility within FAA. Put simply, while data submissions may be duplicative to the petitioner, the separate recipient FAA offices independently rely upon those separate submissions. 

More troublingly, the petition stated “in highly-autonomous operations, determining whether an interruption or diversion to a flight was the result of mechanical difficulties as opposed to a change in environmental conditions, avoidance of crewed aircraft, or other non-mechanical reason is not readily apparent and requires time-consuming review and analysis.” 

NAAA expressed concerned with this rationale as a basis for the requested relief. While it may be inconvenient for the petitioner, it should remain incumbent upon them first and foremost to continue spending “time-consuming review and analysis” to identify whether interruptions/diversions are due to avoidance of crewed aircraft or mechanical/software malfunctions and report accordingly to FAA.