[EDITED] Regulation of autopilot

[Orcatortugs]

Category: Regulation
Area of effect: transportation

The World Assembly,

NOTING the fast paced expansion of the aviation industry as well as the evolution of autopilot

REALIZING the need to put regulations on this technology

Hereby,

1. Defines autopilot as a device that keeps aircraft moving in a particular direction without/ or with minimal human involvement

2.Defines the airplane manual as the operation instructions of that airplane.

3.ILS as the landing system equipped in different airplanes with varying strengths and accuracy measuring between I and III.

4.Controller as the main traffic guider of airports and airspaces responsible for keeping the skies safe

5. Go around as a failed landing where the pilot rapidly gains altitude because he doesn’t feel safe landing

Autopilot may be used in all circumstances EXCEPT:

1. In takeoff and initial climb. No person may use an autopilot for takeoff or initial climb below the higher of 152 meters or an altitude that is no lower than twice the altitude loss specified in the Airplane Flight Manual

2. No person may engage an autopilot during a go-around or missed approach if the values are not already entered.

3.Below 15 meters

4. For Instrumental landing systems (ILS)
If aircraft and airport is equipped with ILS I visibility needs to be > 60m
If aircraft and airport is equipped with ILS II visibility needs to be > 45m
If aircraft and airport is equipped with ILS III A visibility needs to be >= 30m
If aircraft and airport is equipped with ILS III B visibility needs to be >= 15m
If aircraft and airport is equipped with ILS III C these is no visibility limit

4.During taxi to the runway and back to the gate

For flight planning:
1.All flight plans must be submitted and approved by the controller and only the operational flight plan may be entered into the Flight computer

2. For any changes to the flight plan the controller must be informed and must approve before changes are applied to the Flight computer

Overseeing autopilot:
1. There must always be at least two observing pilots in the cabin while autopilot is engaged one to monitor readings and the other to monitor potential inclement weather.

Feel free to add suggestions

[Kenmoria]

“This looks good. On a general point, I recommend using the reasons why your number-based restricts exist, rather than the numbers themselves, in your mandates.”

[Excidium Planetis]

A weary looking Cornelia Schultz stumbles onto the drafting chamber. She glances around nervously to make sure there are no Excidians in the room, when her eyes settle upon the draft of a Transportation Regulation proposal. Her instinct to offer advice cannot be suppressed, and she picks up a copy and begins to read it.

NOTING the fast paced expansion of the aviation industry as well as the evolution of autopilot

"Is it really expanding at a fast pace? I'm not so sure about that."

Hereby,

1. Defines autopilot as a device that keeps aircraft moving in a particular direction without/minimal human involvement

"Firstly, I'm not entirely sure if there is a current definition of aircraft in World Assembly law. I would find out myself but I've been preoccupied with other things. You may want to run a search through our records, and if there's no definition, define what an aircraft is here.

"Secondly, the wording here is a little clunky. 'Without/minimal human involvement' should be 'without or with minimal human involvement'. You should probably also say 'any device' rather than just 'a device'."

Autopilot may be used in all circumstances EXCEPT:

1. In takeoff and initial climb. No person may use an autopilot for takeoff or initial climb below the higher of 500 feet or an altitude that is no lower than twice the altitude loss specified in the Airplane Flight Manual

"What is this Airplane Flight Manual you refer to? I've never heard of it, and it doesn't appear to be in this proposal. Also, using feet as a measurement? Can't we just use meters, which are pretty standard throughout the Assembly? Or better yet, figure out a way to word the regulation so that nations can determine their own safe altitude at which autopilot should be used. Not every nation has the same geography or even gravity, and what's safe for autopilot in one land may not be so for another."

2. No person may engage an autopilot during a go-around or missed approach below the minimum engagement altitude specified for takeoff and initial climb. An autopilot minimum use altitude does not apply to a go-around/missed approach initiated with an engaged autopilot. Performing a go-around or missed approach with an engaged autopilot must not adversely affect safe obstacle clearance.

"Maybe it's because I never took any piloting lessons, but what exactly is a go-around? This whole section reads like it was copied from your nation's aerospace laws."

3.Below 50 feet

"Again with the feet?"

4. For Instrumental landing systems (ILS)
If aircraft and airport is equipped with ILS I visibility needs to be > 200ft (60m)
If aircraft and airport is equipped with ILS II visibility needs to be > 150ft (30-60m)
If aircraft and airport is equipped with ILS III A visibility needs to be >= 100ft (30m)
If aircraft and airport is equipped with ILS III B visibility needs to be >= 50ft (15m)
If aircraft and airport is equipped with ILS III C these is no visibility limit

"But now you switch to using both feet and meters? Just use the meters. Or better yet, don't use such specific and narrow regulations. GA law has succeeded in governing so many varied nations in part because the laws of the GA are applicable to many nations and stretch to fit the peculiarities of those nations.

"Additionally, what is an ILS, and and what is the difference between ILS I and II and III and III C and all these? None of this is defined in the text and you just expect people to know what you're writing about?"

4.During taxi

"Like, the cab? Just kidding, I know this refers to aircraft moving on a runway. Still, you should probably elaborate more here."

For flight planning:
1.All flight plans must be submitted and approved by the controller and only the operational flight plan may be entered into the Flight computer

2. For any changes to the flight plan the tower must be informed and must approve before changes are applied to the Flight computer

"This looks like a lot of stuff that hasn't been defined."

Overseeing autopilot:
1. There must always be at least two observing pilots in the cabin while autopilot is engaged

"But why?"

Cornelia Schultz glances at her datapad. "Oops, got to go," she says, before swiftly exiting out a side door. A moment later, two Excidians Guards burst into the door, glance around, note the absence of the ex-Ambassador, and leave the room.

[The COT Corporation]

"I mean, I'd support this... I suppose. But why?"

[Terttia]

OOC: This is from the Civilian Aircraft Accord:

6. Leaves to the individual member state all authority regarding regulations pertaining to equipment or training in regards to the operation of civilian aircraft.

This resolution tasks leaves responsibility to member nations to regulate autopilot (I think that autopilot would be considered equipment), not the WA. I think this entire proposal is illegal for contradiction on that basis.

Also, from the “Repeal: Protection of Airspace” draft, I meant that you should affirm that member nations have the right to protect themselves from automated/autopilot-controlled aircraft. (Oops. I should have worded the recommendation better in that thread).

[WayNeacTia]

Really, what is the point to any of this? The IACO doesn't even regulate the usage of autopilot.

[Verdant Haven]

EDIT: I got suspicious about some of the wording here, like significant misuse of highly technical terms, and inconsistencies between sections. Turns out the legislative portions are significantly plagarized from 14 CFR § 121.579.

Author - be aware that the mods look with extreme displeasure on plagiarizing content. It is explicitly prohibited.

OOC:

I’m torn on this. I am interested in the topic of aviation safety and regulation, and believe the WA has plenty of room for sensible expansion in this regulatory space, but I don’t know that this is the topic most in need of pursuit at present. It is focusing on creating and setting permanent regulations for a rapidly-changing technology, and the mechanics of the WA and the game mean that this would not be able to be updated and modified over time with anything beyond repeal and replace. Furthermore, I feel like there are a significant number of fairly major errors that render the present draft unusable.

I’ll leave the question of if this is worthwhile or appropriate for the WA to the voters, should it make it that far, and will do my best to focus on feedback geared towards making it a presentable/sensible draft. Hopefully that will be useful for the author regardless of if this proposal continues, or if a different topic is later selected.

Disclaimer – I am not a pilot or an ATC. I welcome corrections from anybody who is.

Category: Regulation
Area of effect: transportation

The World Assembly,

NOTING the fast paced expansion of the aviation industry as well as the evolution of autopilot

REALIZING the need to put regulations on this technology

What is the justification for the declaration that the aviation industry is expanding at a fast pace? Remember that real-world references are not valid in NationStates.

“Evolution” is an unusual word choice to use in a legal document to refer to an automated control system with, presumably, no AI elements. Development or Implementation might be better word choices.

The simple fact that something exists doesn’t strike me as triggering a need for regulation, and I don’t think autopilot poses sufficient self-evident danger to go by without comment. Why does autopilot need regulation? Explain the decision.

Hereby,

1. Defines autopilot as a device that keeps aircraft moving in a particular direction without/ or with minimal human involvement

Autopilot is a hell of a lot more than that – just going a certain direction would be useless. Autopilot needs to maintain heading, yes, but also altitude, and can encompass airspeed, pitch, roll, etc. Without at least the first two things functioning, you get Air France 447.

Also, due to the assorted non-human RP’s present in NationStates, it is presently trendy to refer to “sapient” involvement, or one could simply use “pilot intervention” to avoid the question.

2.Defines the airplane manual as the operation instructions of that airplane.

This is a self-evident definition, and I don’t think needs to be included. If you choose to keep it in, I’d probably swap to the term Aircraft Flight Manual.

3.ILS as the landing system equipped in different airplanes with varying strengths and accuracy measuring between I and III.

ILS (Instrument Landing System) does not generally refer to the system built in to airplanes. While commercial aircraft carry ILS receivers, ILS generally refers to the ground-based system of transmitters that guide aircraft in safely via Localizer and Glide Slope.

The levels I, II, III etc that you mention, while dependent in part on suitable receiving equipment on the incoming aircraft, are also a part of the overall ground system as well, with heavy reliance on the ALS – Approach Light System. They do have varying strengths to be sure, but they’re all accurate within their limits.

If you’re talking about the landing system installed on some new aircraft that interacts with an ILS to permit landing automatically, that’s usually called Autoland.

4.Controller as the main traffic guider of airports and airspaces responsible for keeping the skies safe

Another self-evident definition. I think it’s safe to assume one can reference Air Traffic Controllers without further definition. The act of engaging in basic ATC functions is already required in GAR 342 Civilian Aircraft Accord, so we can assume such command and control is present.

5. Go around as a failed landing where the pilot rapidly gains altitude because he doesn’t feel safe landing

Defining a go-around by the rapidity of its altitude gain is inaccurate and unnecessary. A go-around, or missed-approach, is the term for the actions at any time the crew decides to not continue an approach. It can happen at decision height, or after wheels touch down, or any time after the final approach fix. There are reasons other than “pilot doesn’t feel safe” to do it, and we should avoid gendering the pilot.

Autopilot may be used in all circumstances EXCEPT:

1. In takeoff and initial climb. No person may use an autopilot for takeoff or initial climb below the higher of 152 meters or an altitude that is no lower than twice the altitude loss specified in the Airplane Flight Manual

This is an extremely specific set of numbers, and is worded in a very confusing manner. “The higher of… an altitude that is no lower…” What is “Altitude Loss” in this context? You use the term “Airplane Flight Manual” which doesn’t actually match the term you yourself defined (though it is closer to what I suggested above that you use). What are you measuring altitude against? AMSL? AGL? Keep in mind that GAR 88 WA Numeration and Units act guarantees every member nation the right to use their own measurement systems, and the real-world “meters” measurement may be prohibited. Also, nowhere is reasoning given for this restriction.

2. No person may engage an autopilot during a go-around or missed approach if the values are not already entered.

What values? Entered in to what? When must entry be completed?

3.Below 15 meters

AMSL? AGL? What about Autoland systems? What about approaches where either you’re skirting the ground and a computer is a hell of a lot more stable than a person (think of the old approach to TGU). How about a place where the terrain rises sharply to meet the end of the runway (when do you turn it off flying in to a place like LUA?)

4. For Instrumental landing systems (ILS)
If aircraft and airport is equipped with ILS I visibility needs to be > 60m
If aircraft and airport is equipped with ILS II visibility needs to be > 45m
If aircraft and airport is equipped with ILS III A visibility needs to be >= 30m
If aircraft and airport is equipped with ILS III B visibility needs to be >= 15m
If aircraft and airport is equipped with ILS III C these is no visibility limit

The numbers you used here are decision heights for various ILS/ALS approaches, not “visibility.” At aircraft speeds, the different of 15m in visibility means precisely nothing at all. Even having slowed down to around 200mph in preparation for landing, 15m is one sixth of a second. The RVR for a CAT I ILS is 550m, with visibility required to be 800m or better.

4.During taxi to the runway and back to the gate

For flight planning:
1.All flight plans must be submitted and approved by the controller and only the operational flight plan may be entered into the Flight computer

Hang on, how did a proposal about autopilot end up talking about flight plans? This is a separate issue. Flight plans pre-date autopilot, and are used for sapient pilots too.

This may be a fine distinction, but after filing a plan with ATC you receive clearances from them... not so much approval of the plan. Plans (at the commercial aviation level) are generated by trained specialist dispatchers within the company that operates the aircraft, and are submitted to the aviation authorities. ATC does want to know where you're going, but that’s to help them plan so they know what you need in advance.

2. For any changes to the flight plan the controller must be informed and must approve before changes are applied to the Flight computer

You definitely are going to need ATC permission before actually changing course or altitude, but I don't think that's going to involve filing an amended flight plan mid-flight. Flight plans really don't belong in this proposal.

Overseeing autopilot:
1. There must always be at least two observing pilots in the cabin while autopilot is engaged one to monitor readings and the other to monitor potential inclement weather.

This is not reasonable. Many commercial aircraft have only two pilots, and the ability for one of them to, for example, use the bathroom during cruise is necessary. Autopilot makes it easier to have just one pilot on the flight deck, not harder. While it is definitely good practice to have one pilot monitoring instruments while the other is watching out the windscreen (for far more than just weather, which is detected with instruments as much as eyes), you can’t tie both pilots to the flight deck on an absolute basis.

Also, FYI, the “cabin” typically refers to the passenger area. The area the pilots control the aircraft from is the Flight Deck, sometimes called the “cockpit” (though that is arguably inaccurate for large aircraft).

[Kenmoria]

EDIT: I got suspicious about some of the wording here, like significant misuse of highly technical terms, and inconsistencies between sections. Turns out the legislative portions are significantly plagarized from 14 CFR § 121.579.

Author - be aware that the mods look with extreme displeasure on plagiarizing content. It is explicitly prohibited.

(OOC: In this case, Orcatortugs, you need to remove all plagiarised sections of the proposal and write different versions yourself. Make sure to do this before submitting the proposal, as plagiarism is a WA-ban level of offence.

Also, Verdant Haven, you might want to remove the red text, since it’s generally reserved for mods.)

[Verdant Haven]

Also, Verdant Haven, you might want to remove the red text, since it’s generally reserved for mods.)

Thanks for the heads-up! I generally use red to interleave my own comments when providing feedback on issues, to make it easier to distinguish/read, so I just continued that above. Didn't even consider that it might look like I was trying to be modly! I'll plan to swap to another color for commenting.