On March 9th the Federal Aviation Administration requested comments from the public on drone test sites.  On May 8th, lengthy comments were submitted by Not 1 More Acre! and Purgatoire, Apishapa & Comanche Grassland Trust.  The FAA asked all the wrong questions, but still got a lot of the right answers.  When the drone accidents start, and you’re told “Nobody could have known,” refer them here: PDF.

Photo by Charles McCain

I would have asked “Should weaponized drones be permitted to exist on earth?” and “How can surveillance drones possibly comply with the Fourth Amendment?”  The FAA asked:

“The Congressional language asks the FAA to consult with and leverage the resources of the Department of Defense and NASA in this effort.  Since many public operators already have access to test ranges and control the management and use of those ranges, should the management of these new test ranges be held by local governments or should private entity [sic] schedule and manage the airspace?”

Not 1 More Acre! replied:

“Neither.  Although the pilot UAS [Unmanned Aircraft System] program is a Congressional mandate, and the timelines are accelerated, the complexities and potential dangers of integration of UAS into civilian airspace must not be delegated to local governments or private organizations in the name of expediency, entrepreneurship, or profit. . . . The wording of Question A suggests that the FAA is contemplating abdicating its inherent authority to manage the NAS [National Airspace System] by ceding broad discretion over UAS flight operations. . . .

“. . . The primary driver of the move to integration has clearly been contractors funded by the DOD, working in concert with the secretive Joint Special Forces Operation Command, the Department of Homeland Security, and the CIA, among others. . . . Private defense [sic] contractors increasingly woo local law enforcement agencies and other community groups with grants to help fund the purchase of new UAS.  The FAA should not allow any other federal agency to usurp its authority over the NAS or circumvent the pre-decisional public disclosure requirements of NEPA [National Environmental Policy Act] including agencies like the CIA, NASA, and JSOC which are not transparent or accountable to the public.”

Of course, there’s a catch.  Even the accountable agency has, naturally, ceased to be accountable:

“However, the FAA has never conducted any NEPA review related to UAS.  The agency has never prepared an Environmental Impact Statement or Environmental Assessment to disclose the potential impacts of UAS to the public and agency officials, despite issuing hundreds of Certificates of Waiver and Authorization to some 60 public agencies.”

Have you heard about the 51st State for Armed Robotic Drones?

The 63 drone sites in the U.S.?

The 30,000 drones planned for U.S. skies?

The habit drones have of crashing even on their own?

While initially cheaper than manned planes, unmanned drones of the sort used now tend to require many more personnel: 168 people to keep a Predator drone in the air for 24 hours, plus 19 analysts to process the videos created by a drone.  Drones and their related technologies are increasing in price rapidly.  And to make matters worse, they tend to crash.  They even “go rogue,” lose contact with their “pilots” and fly off on their own.  The U.S. Navy has a drone that self-destructs if you accidentally touch the space bar on the computer keyboard.  Drones also tend to supply so-called enemies with information, including the endless hours of video they record, and to infect U.S. military computers with viruses.  But these are the sorts of SNAFUs that come with any project lacking oversight, accountability, or cost controls.  The companies with the biggest drone contracts did not invest in developing the best technologies but in paying off the most Congress members.

What could go wrong?