MATT (AMA): Hello again, everybody. Welcome to another episode of the AMA podcast.
My name is Matt Ruddick, your host, as always. Coming up today we’ve got a really special interview that I’m excited to bring you guys. You know last week we had a conversation with our Government Affairs director, Tyler Dobbs, who told us a little bit about the recent letter that was sent by the AMA, EAA, AOPA, and Wing to the FAA to kind of tell them what our thoughts about – what our thoughts are, rather, about remote I.D., and we’ve got Tyler back on the show with us this week, as well as a couple other special guests that I’m really excited to talk to. First of all, Tyler, thank you for joining the show. We’ve also got on the line with us Adam Woodworth who is the CTO from Wing, and we also have Ben Brooks who’s from the public policy department there at Wing. Ben, Adam, thank you guys so much for coming on the podcast.
ADAM (WING): Thanks for having us. You know I think that this is a really important conversation to have. Happy to kind of share our experience and share our perspective on this journey we’re on.
MATT: Yeah, absolutely. There’s a lot of questions and we’ve gotten a lot of feedback over the last week. We talked pretty in depth last week about what our, from the AMA’s perspective, how the importance of that letter that was written up and sent was. I wanted to bring you guys on to kind of get a sense from your guys’s perspective because you have a different perspective although I think we share a lot of similarities. I’m excited to kind of get your message out about what that means from your guys’s world. But first, before we get to that, I wanted to see if you guys could give us a little perspective for those that might be unfamiliar with Wing. Can you talk a little bit about what this company is – what your guys’s mission is and how it relates to the world of model aviation?
ADAM: Sure. I would probably add as a start to this – I’m also an AMA lifetime member. I’ve been involved in the modeling community since probably before I can remember. Model aviation plays a big part in my personal life and my professional life. So Wing, at the core, we’re an aviation company that’s focused on enabling delivery of goods with drones. Wing has existed as part of the Alphabet family of companies since around 2012 when we started out as a project within Alphabet’s r and d unit called ‘X’. We’ve worked to mature the technology, to mature the operational use cases, and to bring drone delivery to reality. About two years ago, Alphabet created us as our own standalone company, so we became Wing. Since then we’ve been operating delivery services with aircraft on three different continents. We have a delivery service in two cities in Australia. We have a delivery service running in Helsinki, Finland. We have a service running in Christiansburg, Virginia. Throughout all of that, our overarching goal has been to make delivery safer, faster, more accessible, and generally more sustainable than it is by driving packages around on the road, by leveraging the technology of autonomous flying aircraft. We partner with a range of local businesses to deliver food and pharmaceuticals and household goods. The ideal scenario for us is, if you have an immediate need for pretty much anything, whether it’s toilet paper or toothpaste or Advil or a package you just ordered. We will develop a system that brings that to you with an airplane almost instantaneously. Right now in these these three regions we’re operating, we’re doing commercial delivery. So, the exchange of money for goods beyond line of sight over people and structures and real delivery operations day in day out. So I think, at this point, we’ve done in the tens of thousands of commercial deliveries. That’s backed up by hundreds of thousands of test flights that we do at our facilities and across the world. Wing sits at this intersection of this drone space that’s been evolving over the last couple decades to bring that technology to everyone’s daily lives and we’ve seen some really powerful use cases as a result of the impacts that COVID has had on communities. We’ve seen people ordering goods that they otherwise would have to leave their house to go to a store to go get. We’re starting to see the kind of realities of this whole industry take off. So that’s the kind of core business side of it. But within all of that, Wing has a core operational tenant that we want to be good stewards of the airspace. We want to be cooperative players in this industry and cooperative users of this amazing resource that is the national airspace. So wherever possible we focus on bringing collaborative solutions where we can work with both industry partners and partners throughout the aviation world to make sure that everybody has equal access to the sky. And I can’t [unknown] enough that that’s one of our core company beliefs that everyone should be able to operate things in the air. We want to provide solutions and we want to be good partners in that conversation to make sure that’s an outcome that’s sustainable.
TYLER (AMA): Well, Adam, in our early conversations I think we started, maybe, on a flight line in California at Expo, and we were discussing remote I.D. coming soon and it was refreshing to hear that we understand what Wing is looking to do and what their overall goal is and it was certainly refreshing to hear that, hey, we have a mission that we’re driving towards but we understand that we can do what we’re going to do and still allow the the hobbyist and modeling community to continue doing what they’ve been doing for 80 plus years. We just had to work on a solution that made that viable for everyone and early discussions with you and with Ben sharing language and being collaborative on that was certainly helpful and we appreciate all your help with that.
ADAM: I think part of the reason why we have that core belief is that so many of us came from from so many different parts of the aviation space so if I look at any of my colleagues at Wing or any of the colleagues that I’ve had throughout my career in aviation, there’s always some tie to – either they flew model airplanes as a kid or they hung around at the the local airport and flew or they got their first experience with aviation because their uncle had a piper cub and they, like, flew around the farm. There’s just aviation in the recreational forum, whether it’s G.A. or whether it’s – model aviation is the gateway to the aerospace industry and I think that there’s a lot of really famous examples. I think we point at Neil Armstrong a lot as with his background in model aviation and we point to [unknown] we point at all these huge figures in the aviation world but most folks I’ve interacted with over my career in this space have some tie back to this. It’s so pervasive that the thought that we might be shutting off the next generation of engineers and pilots and scientists and just people who when a plane flies over, looks up at the sky and gets excited. We have to preserve that. We have to try to protect it. So that’s why I think that that’s why it’s become such a central part of our business to be responsible, cooperative, and helpful actors in the space wherever we can.
MATT: Yeah, absolutely. Now when you guys recently joined forces with us at the AMA with the AOPA and the EAA as we mentioned to write this letter to the FAA about remote I.D., I’m curious if you guys can talk about making that decision and why you thought it was important to help support the modeling community. Adam, you kind of touched on that a little bit right now but specifically going this far to actually reach out to the FAA and say “Listen, you know this is what can’t happen and this is what we think should happen,” and that sort of thing.
ADAM: Yeah. I’ll tee that up a little bit and I’ll let Ben dive in because I’ve been hogging all the conversation. I think that, as we discussed, this is a process and the process involves a dialogue and information sharing and I think within hours of seeing the notice of proposed rulemaking over the holidays we had a variety of conversations and we started reading the rule looking at the parts that made sense and looking at the parts that didn’t make as much sense and formulating evidence-based arguments to both address the challenges in the rule and provide alternate means of compliance to that. And that’s where it becomes, like, you have to share that, you have to share that position. We can’t – it’s very easy just to kind of read the document, get mad about it and, like, stew on that anger, but sharing actionable recommendations is the path towards cooperative change. I think that one of our central tenants provides kind of reasonable suggestions and reasonable pushbacks when pushback is required on concepts that may or may not make sense. I think that there is this element where there are parts of remote i.d. that are necessary to ensure that the national airspace is a safe and cooperative environment. That doesn’t mean that everything that’s in that proposal needs to be there to get to that intended outcome.
BEN (WING): I think at a higher level as well we share your objectives. I think we all agree here that safety and security are really important to the future of drone integration and the integration of UAS generally. Now to that extent I think we also agree that in the right hands with the right safeguards in place, remote id can be one tool that helps to achieve that aim. I think remote id can help to do things like investigate accidents. It can help to promote compliance and responsible flying. The challenge in our mind is that there are, as i say ‘many ways to skin a cat’ and the rule as it was drafted could have made life very difficult for modellers. More importantly, we didn’t want to be naysayers, and like the AMA we want to show that there is a better way and we think there is a better way we think there’s an alternative. We’ve shown it in practice, we’ve demonstrated it in the real world, and we would like to see some of that acknowledged by the FAA and other authorities in the final rule.
MATT: Are there some ideas that you guys have come up with that you have formulated in your mind what some of those better ways could look like?
BEN: Yeah, there’s a few examples. At the very beginning of the year, we put forward I think it was a 50-page paper in the end to the FAA explaining what some of these examples might look like. One of them of course is to to have a process in place for clubs and schools and other organizations to create now what they’re calling FAA recognized identification areas.
Over time we should see more of these areas. There should be a process to renew them. That’s one way that hobbyists can continue to fly. We also care about the local park flyer. We care about people being able to go into their backyard to the local park, take out a model and start flying. One example of an alternative here is to declare your flight intent so in other words you as a hobbyist will be able to pull out an app on your phone you’ll be able to say ‘I’m going to fly here for a certain period of time up to a certain height,’ and that information can effectively be your remote identification information. Now we’ve shown this in practice – we held a demonstration even before the rulemaking came out late last year in San Bruno, California, so near San Francisco International, complex airspace, a busy part of the bay area. We showed that a hobbyist flying a home-built model can pull out an app to tell us where their flight area is. if they don’t have the internet they can do it well in advance of their actual flight. That information can then be visible to the FAA and other authorities on an as needed basis.That’s just one example of how there is a better alternative and it’s an alternative that still meets the FAA’s objective of safety and security.
TYLER: Sure, and that’s why I think it’s so important that we came together on this.
AMA had been pushing that message for quite a while. Obviously we pushed we would like to be exempt from remote id rules for for line of sight operations but we understand there’s some big players in this discussion the FAA and security agencies like the D.O.D and others and so if we’re going to get forced down the road of remote id then those those types of solutions the fixed flying sites, the marking your location if you’re flying outside of one of those flying sites through an app based solution – we felt like that made the most sense. That was something we were pushing to the FAA and to the appropriate members of congress. When we got the support of an organization like Wing hen we can show that, hey, not only is this a solution, it can be done. Here’s some others from the industry who says it can be done and standing united on it really put some force behind that proposal.
BEN: No, no, absolutely and I think what AMA members should be confident that this isn’t just words on a page. I’m not just having discussions that industry is trying to demonstrate a lot of this in practice. There’s a standard actually from ASTM International –
BEN: – So we have a technical standard already that tells us how we could implement something like this today. There’s a lot of work behind the scenes to help validate this in the real
world. That said, look, you know we do want to give credit where credit is due. The FAA has a really tough job. They have to balance these concerns from law enforcement which are in many cases legitimate. They have to ensure safety, they have to promote compliance. They have to do all of this while they have congress and local authorities across the country breathing down their neck. So it’s a really difficult job and we acknowledge that and we respect that and I think as we’ve seen with with some of our work, Tyler, we’re trying to find a path forward that satisfies everyone and ticks their boxes while continuing to keep the airspace open to all.
ADAM: Yeah and one of one of the things that we’ve really leaned in on over the past half decade of this project is standards and rule making and process which are aligned with the risk and aligned with a set of performance based standards. And we take that approach on the design of our aircraft and the surf bases for our aircraft and the kind of use case for the aircraft. We think that there’s a similar approach that is warranted on kind of any of these rule making efforts where is the solution that’s being proposed commensurate with the risk that exists and is the burden of that solution commensurate with that risk as well. I think to Ben’s point, the FAA has a very complex charter that there’s a lot of players, there’s a lot of voices. They have a pretty hard job to do to preserve the safety and security of national airspace. At the end of the day I think it’s about are there ways to meet the intent of the rule. And I use the word intent like very specifically the intent of what the desire to have a remote identification capability is so that you can identify aircraft where they’re not supposed to be or, as Ben said, investigate accidents after the fact meet that intent without imposing specific parts of the rule that cast out a lot of model aviation. So when reading through it, there were a lot of elements around the level of automation that’s kind of implicit in some of the technologies that are required. So distance limiting of the aircraft and connection of the remote id solution into the flight control.
If I have an old GWS Pico Stick, right, like it doesn’t, like, I don’t know how I’m gonna tie in to a flight controller that’s not there. Some of the tamper proofing requirements, if folks are building their own airplanes on the kitchen table, I think it’s hard to meet some of those bits. Some of the manufacturing requirements and the cert requirements, as Ben mentioned, some of the expiration dates on the authorization areas – all those elements are things that I think go a bit beyond the intent right. They’re means of getting to the outcome, but I think there are alternate means that can be equally as effective in delivering the intended outcome for the regulator without the collateral damage to the community.
TYLER: While not exact, there is precedent to this declaration to fly. We see that with LAANCE and all in controlled airspace. You log on to your LAANCE app and you request authorization through it. And this would be a similar type process, not exact but similar.
ADAM: Yeah, and I think LAANCE has been somewhat of a marquee program in that it shows
the ability for industry to come and deliver solutions. i think there’s, what, Ben, 20 plus –
BEN: 21, 23.
ADAM: LAANCE providers in the U.S have it be standards based have it be performance based. It’s all the elements of what I think, like, modern rule making and solutions development
look like and it’s largely successful and it has huge value to everyone. It lets people fly in places that they weren’t allowed to fly before with a process that I think – I don’t even remember what the on paper LAANCE authorizations used to be. If you filled out the form and sent it in, I think it was like a 90-day or it was either 30 or 90 days, I forget which one, but now it’s you pull your phone. you look at the grid, it says ‘okay I can fly up to 200 feet, here you go,’ you click the buttons and within sometimes a matter of seconds you get authorization to use that airspace.
I think that that’s a – it’s an awesome proof point. Again, it’s it’s one of a variety of ways that you can get to the desired outcome of providing some level of identification in a way that’s very low burden to the average operator. I think on the very best day you want no additional steps from somebody who goes to their local club and pulls out their – I don’t think they make tower trainers anymore – but pulls out their entire trainer and fires up and goes to fly. That experience should be largely the same. In the practical case, one or at most two steps additional and, ‘Okay, I pull up my phone and I say, yep, I’m flying.’ Making it easy to comply. It’s important it’s important to everyone. Frankly, I think it’s important to the regulator. Having it be easier to comply means that more people will be in compliance.
BEN: It’s important to note that even with something like LAANCE, which, to Adam’s point, is a very safety and security sensitive function flying into controlled air space. We’ve got these 20 – I think it’s closer to 27 – LAANCE providers and a number of them offer these services for free to hobbyists. In our mind, when you have a vibrant and competitive network of these providers, there’ll be something for everyone. There’ll be options for the complex commercial operators who, under remote id, will have to do a much more precise remote identification, but there’ll also be options for hobbyists as well. That’s the kind of outcome we want. I think the precedent to your point, Tyler, on LAANCE is that when you have that ecosystem, when you have that network, there will be nil cost, low cost, very accessible options which, to Adam’s point, will help to maximize compliance in the community.
MATT: Yeah, absolutely. Because if people don’t comply at the end of the day it’s no good. Either the whatever regulations they put out, if nobody uses them it’s not going to do them any good. It’s not going to improve safety in the airspace. It’s making it so the people will be willing to comply and that means, as Adam, as you mentioned, making the barrier to entry far lower than what they originally were proposing. Bringing up the LAANCE idea is a, per in my opinion, is a perfect analogy. I’ve used LAANCE in the past. It is – it seems like that would be the perfect way to do this because it’s simple, it’s easy, it’s no cost to the end user. It seems like a – it seems like a no-brainer in my opinion, but you know that’s why I host a podcast and not do all that other stuff.
ADAM: Yeah and, again, I think that it’s a complex challenge and complex challenges rarely have simple answers associated with them. I think when you provide a variety of means of compliance. It always makes the problem a little easier to digest. I think that our comments that we put out back in March that – Ben wrote a pretty epic novel there – our comments in March highlight a lot of these pieces. I would encourage anybody who’s listening to us to go to [unknown] and pull those up. I think it lays out a lot of the benefit of challenges, the complex space that this is – it’s a long read but I think it’s a useful read. In this letter that we joined you all with highlighting the challenges in proposing solutions, I think that that’s always the the best way to approach these things. I looked at the response from the community on the NPRM during the comment period – I think it was, what, close to 60,000 comments. I went in and I read a lot of them. I definitely didn’t read 60,000. A lot of it was describing the real challenges that this proposed rule has on the individual and on everyone’s story. It’s the stories that are so powerful, and sharing that experience is so powerful. I look at a lot of my colleagues and I think about what if the scenario where, we rewind the clock 30 years and none of us had the experiences we had with model aviation. I think this would be a very different looking industry. I even look at a lot of the technology that we’ve built this industry around. Small business motors, lithium, polymer batteries, chip scale IMUs – all these pieces have been fueled in large by a very vibrant hobbyist community. For me, to look at myself in the mirror at the end of the day, I need to be able to say I’ve done as much as I can. Wing collectively has done as much as we can to try to fight for this community that’s helped so many.
TYLER: I agree. In terms of AMA and our membership, obviously, as I mentioned, we want an exemption. We feel that the history of the modeling community has shown that we can operate safely. We understand that we’re flying in a different world today than we are years ago and that remote id is going to be part of our future just simply from security agencies and the faa and even congress have stated that remote id is something that needs to move forward. So we wanted, like you mentioned, we wanted various options. If you’re not buying an aircraft this is already put in at the manufacturer’s level, then have that option of an app-based solution. We understand we have a number of members who don’t use computers, don’t use cell phones. We wanted that other option of, okay then, we’re going to have the exempt flying sites around the country. So while it may not be perfect for everyone, we understand that we do want to work to give as many of the best possible options that we can and we feel like this is a good place to land.
BEN: This is to Adam’s earlier point – it’s really important that these authorities, and I’m not just talking about the FAA, we talk about other federal and state and local police departments as well, understands the lived experience of people in the modeling community. You can see if you read the rule making as it came out, almost a year ago, there are assumptions in there about what a model aircraft looks like, what the typical modeler does, and those assumptions aren’t entirely sound. I think what has been very useful, certainly over the past year, what we’ll need to continue doing in the future is telling that story and explaining that this isn’t a one-size-fits-all community. There is a diversity there. The rules need to account for that and to make sure that, to your point, Tyler, that when push comes to shove and a final rulemaking comes out, that there are options that support everyone and help everyone to get into the airspace.
MATT: So I guess the question at this point, then, is what are some of the next steps? We know that the FAA is talking about wanting to have something out by the end of the year. Tyler and I have talked at length, I think, about whether or not we feel like that’s realistic and what we should expect there. But what are our next steps as far as the group that you guys have formed along with the EAA and AOPA? Do you guys have anything planned in the near future to keep pushing this along?
BEN: One of the challenges, of course, is that with the rulemaking on the time frame that it is time is of the essence as the lawyers like to say. We’ve been continuing to meet with as many stakeholders as we can in D.C. and elsewhere to talk about remote id and to talk about some of these alternatives. We’re continuing to, obviously, work to ensure that some of these standards that incorporate these options and these alternatives are adopted by regulators and by industry.
We’re continuing to work there. I think that the question will really be when the final rule comes out – What does it look like? It’s the million dollar question. The response after that will very much depend but I’d certainly come back to the point I made before which is regardless of what happens with this final rule, it’s going to be critically important that the global aviation community continues to tell that story. I think to some extent the community, the industry as a whole was perhaps caught off guard by some of the content in this rule. I think we can help to avoid that in the future by ensuring that all of the stakeholders in this space really understand what the community means to everyday people, but also what it looks like – what these aircraft look like, what these operations look like. So that would be important going forward as well.
MATT: Yeah, and I think having a group like you guys where not only Adam but I know you guys have a lot of other folks on your team that are life modelers and are really passionate about this topic. Having you guys on board and helping to fight that fight, I think is gonna be really important moving forward. I’m sure, Tyler, you probably feel very similarly about that.
TYLER: We do and this letter obviously, we’ll share that with the appropriate members of congress. As you and I have talked, Matt, AMA’s had numerous meetings – too many to count –
with those members and we can continue to do so all the way up until that rule comes out and probably even afterwards. We’ll have to wait and see what’s in it. As Ben and Adam mentioned it’s just crucial that we all collaborate within the industry and we let our officials know how and what will be impacted by these rules as written. So that’s what we’ve been doing and that’s what we’ll continue to do.
ADAM: Yeah. I keep coming back to – I look at my own story, I look at the opportunities that model aviation provided me throughout my childhood, throughout my college years, throughout my professional years, the friendships I’ve built. I was lamenting – meet fair in New York was this weekend. It’s the first time in a while I haven’t been able to go. There’s folks that I’ve seen since I was a little kid that these friendships, these connections, these stories last – they truly last a lifetime. It’s not hyperbole. The thought that – I have a three-year-old daughter now and she’s the sort of person that, when an airplane flies over she looks up at it and points at it and gets excited. I need to protect that for her. I need to be confident that there’s a future for her that if she chooses, she can have the same kind of path that myself and a lot of my friends had throughout their life. I think that it’s airplanes are just too cool, right, there’s just something awful about buying stuff. We’re talking about, in most cases, we’re talking about flying chunks of foam. It’s too special to lose and it’s truly a cause worth fighting for. My internal pledge is I will fight for it as long as I can on every front that I possibly can to assure that it’s something that’s preserved, not just preserved but encouraged. Having more kids involved in model aviation, having more careers that lead to the next generation of pilots and engineers is something I’m personally super passionate about. My message to the community is I’m here to advocate and fight for this. I think there’s a lot of voices that are here to advocate and fight for this so don’t lose hope, like, keep telling the story, keep engaging because when you lay it out on a table it’s really hard for anyone to look at and be like ‘yeah, no this isn’t’ – we can’t write this off, this isn’t – it’s okay that this community gets hurt.’ It’s so special that it’s worth protecting.
MATT: Yep. Absolutely. Well, guys, if folks want to learn more about Wing, where can they go to to learn more about your company?
ADAM: So wing.com is the website for Wing. We hopefully – we’re operating in a bunch of places around the world. If you happen to live in any of those places, you can come see airplanes fly around. I think that we’ll continue to try to engage the community more directly over the coming months and years. I think a lot of folks in the modern aviation world reach out to me directly if you want to. I’m talking about airplanes. I’ll gladly talk about airplanes for a couple hours. I think that I want this to be the beginning of a long conversation that everybody comes out on the other side more educated and happier and that’s – it’s the better world.
BEN: We’d also encourage – there’s on our Youtube page there are some great examples of what our operation looks like in practice. It can be hard to visualize sometimes. We’d also encourage everyone to take a look at our careers page as well, particularly over the coming years. There’s going to be huge demand for people who understand the space, understand what the industry needs, how it needs to interact with other stakeholders in the airspace and there’s all sorts of work, technical and otherwise, so take a look out there as well. And Adam’s earlier point, we certainly encourage everyone to read these rule makings as they come out and read what is being said in response. I think they’ll come away certainly understanding the complexity of some of these proposed rules and documents but they’ll also understand what is being said in the space and how they can best contribute to that conversation.
TYLER: Good point.
MATT: Absolutely. Well, Adam, Ben, thank you. I really – I can’t thank you guys enough, not just for coming on the podcast but for all that you guys and the rest of Wing are doing to help support the hobby. It does not go unnoticed, certainly, and I’m really excited about where we go from here. I think you know the future really does look bright to me when we all come together like we’re doing right now and fighting this as one community. We’ve been talking about that internally for the last couple of months. We are one community and doing this kind of thing, it really shows that we are one community. So, thank you guys so much for all that you’re doing.
ADAM: Well, I – Thank you all for continuing to fight on behalf of the hobbyist. I think that everybody’s doing the best they can. I’m personally thankful for it and I think the community is too. So thanks for having us, thanks for listening to me ramble for probably too long, but until next time.
TYLER: Yeah, look forward to talking soon.
MATT: Absolutely. Well, and I want to thank all of you guys out there for listening this week to the AMA podcast. If you haven’t subscribed yet, we’d love it if you do so. We’re on all the major podcasting platforms – Apple podcast, Google podcast, Stitcher, Spotify, and wherever you get your podcast. And of course you can listen right from your browser at modelaircraft.org/podcast where we release brand new episodes every single Monday so make sure you’re subscribed so you don’t miss a single one. If you listen to Apple podcast, we’d love it if you leave a comment there and rate us. That’ll help us move up into their charts and be featured and if you have any questions. comments, or suggestions for us drop us an email at email@example.com. Those come right to my email inbox. I read every single one so keep those coming and of course if you’re not already a member of the AMA, head over to modelaircraft.org. See what the AMA can do for you. We’d love to see you out in one of our flying fields very very soon. And if you are already a member, thank you so much for your support. And with that for everybody here at the AMA, thank you so much for listening. We hope you’ll be right here next week on the AMA podcast,