Letter to the Hon. Daniel K. Elwell, Federal Aviation Administration Acting Administrator, Steve Bradford, Office of the Chief Scientist for NextGen - Congresswoman Claudia Tenney Sends Letter to FAA in Support of UAS Traffic Management Pilot Program in Upstate New York

Letter

Dear Administrator Elwell and Chief Scientist Bradford,

We write to you in support of the application by the New York UAS Test Site (NYUASTS) and Texas UAS Test Site (TXUASTS) (the "Team") for the Federal Aviation Administration Unmanned Aircraft Systems (UAS) Traffic Management (UTM) Pilot Program (UPP) Demonstration. Through this program, these test sites will leverage their significant experience of almost five years collaborating with NASA, the FAA, and UAS industry stakeholders in the development of a UTM Research Platform (URP) and further exploration of how an operational UTM system can enable access for sUAS into the Very Low Level (VLL) airspace in a safe, efficient, and effective manner.

As put forth in the proposal, operations and testing will take place at both the New York and Texas UAS Test Sites and will include:

Testing and evaluation of situational awareness data between the FAA, state entities, and UTM operators and vendors;

Multiple vendors supporting UTM initial operations; and
UAS operations with information sharing between other UAS operators and the FAA.

The three scenarios proposed include:

Use Case #1: Visual Line Of Sight (VLOS) and Beyond Line of Sight (BLOS) Operation in Uncontrolled Airspace -- three entities over two events, being an off road race and cattle operations
Use Case #2: Dynamic Restrictions in Uncontrolled Airspace -- four entities operating small Unmanned Aerial Systems (sUAS) and manned aircraft for four different mission intents, with the airspace cleared for purposes of finding a fictional lost hiker.

Use Case #3: Dynamic Restriction in Controlled Airspace: four entities operating sUAS and manned aircraft for four different missions, with cleared airspace for the purposes of fighting a fictional brush fire.

Building on extensive NASA experience, this team will develop performance requirements and support industry consensus standards for UTM implementation. The team leads in both air traffic management (ATM) and UTM airspace integration research activities as shown by:

Significant aviation flight test experience -- among the first to measure UTM performance with the NASA UTM solutions; and
Proven experience with FAA, NASA, and FEMA with the team's demonstrated efficiency, safety, and success of UTM research activities.

Congress recognized the impact that the UPP will have in operationalizing UTM. Achieving this means fielding systems on a path to certification and commercialization, with commercial potential to perform with civil aircraft. The team's depth of experience supports "operationalizing" -- and identification of services, roles and responsibilities, information architecture, data exchange protocols, software functions, infrastructure and performance requirements for UAS operations in uncontrolled Very Low Level airspace.

These testing capabilities are supported by the states of New York and Texas, and are strategic to accelerate the use of commercial sUAS. Building upon significant state investments into both tests sites, this important research and development will create substantial commercial opportunity.

The proven track record of the New York and Texas test sites in concert with the significant State investment in building and creating the assets and facilities the UPP UTM project requires, the diversity and broad range of research, industry leading private sector partners, and diverse geography distinguish this application.

The New York and Texas UAS Test Sites are ready and fully capable of successfully executing the mission of the UPP. The New York Test Site has flown over 3,100 test flights of which 199 were part of NASA's UTM test flights and the remainder were with Fortune Top 50 companies. The FAA has granted Special Airworthiness Certification (Experimental) to the NUAIR team. The combined research experience and capacity of Syracuse University and Texas A&M University further enhances the strength of the proposal.

The NUAIR Alliance, which operates and manages the UAS Test Site at Griffiss International Airport in Rome, New York, is a key partner in this initiative. Winning the designation for the UPP will directly strengthen our ability to attract new jobs to New York and further incent resident firms to expand.

We respectfully and enthusiastically recommend that the New York -- Texas proposal be given due consideration and successful selection for the UPP program.

Sincerely,