Your Order is Delayed
How Commercial Drones Can Offer Sustainable Goods Delivery & Why Regulatory Blunt Instruments Keep Your Environmental Footprint High
by Lindsey Hover
Photo Collage by Jonathan Zisk, Images from unsplash
Recent sustainability literature maintains that to achieve environmentally sustainable global practices, affluent individuals in the wealthiest, most developed countries of the world would have to reduce their consumption by somewhere between 40% and 90% [1]. By virtue of the fact that goods delivery contributes significantly to an individual’s personal environmental emissions impacts, and compounded by the fact that companies like Amazon continue to invest in freight to buttress their capacities at 2-day and next-day delivery [2], some literature puts the onus on wealthy individuals to reduce their demand for immediate goods delivery.
Lobbing a consumption reduction imperative of this scale upon the world’s wealthiest households will be about as successful as drawing blood from a stone. A culture of instant gratification and the omnipresent imperative of GDP growth render well-meaning consumption reduction initiatives unlikely to meet our climate goals and to keep our planet habitable.
Robust and immediate intervention to stem the environmental devastation wrought by modern goods consumption practices is needed. Given that carbon dioxide emissions from goods delivery—more precisely, freight transport—are expected to surpass the emissions levels of passenger cars by 2050, it’s time to get serious about immediately actionable ways to reduce the environmental impact of the goods freight industry [3]. Technology can play a more active role in moving freight transportation towards net zero global emissions. Flighted drones, known as unmanned aerial vehicles (“UAVs”), can minimize the damage of consumption patterns and the commercial shipping/logistics sector in the United States. Mammoth companies already cite their potential environmental and fiscal benefits: Amazon shook the world in late 2013 when it announced its Amazon PrimeAir initiative, “a delivery service that uses unmanned aerial vehicles (drones) to deliver lightweight packages to customers in thirty minutes or less.” [4] Likewise, DHL has developed a drone fleet and assessed the feasibility of replacing its entire capacity with drones, including international flight transportation of parcels and autonomous shipping and storage. [5]
These fleets could have enormous effects at reducing the environmental impact of goods delivery worldwide. But, in the United States, we are waiting for the blind tortoise of regulation to catch up.
Given that carbon dioxide emissions from goods delivery—more precisely, freight transport—are expected to surpass the emissions levels of passenger cars by 2050, it’s time to get serious about immediately actionable ways to reduce the environmental impact of the goods freight industry
My research on drone freight delivery is guided by a few initial questions: Is drone freight or distribution an environmentally responsible substitution for the modern truck-dependent freight delivery model? Is there a posited future anticipated use for drone-based freight? Are there scalar components related to the built environment that influence drones’ best environmental applications? And, can drones displace truck-based goods distribution in urban environments?
Scholarship shows that the potential environmental harm reduction from replacing fossil fuel and electric road vehicle delivery could be enormous. However, this transition is blocked by incongruent federal regulations. Likewise, the current patchwork of regulation presents significant safety and security risks that could be alleviated by leveraging geospatial mapping techniques that planners and spatial analytics professionals already have in their digital toolkits. The policy community needs to provide a pathway for the environmentally beneficial applications of commercial drones, which includes preparing for the eventual realities of airspace congestion by drones and their labor implications, which could jeopardize job stability for any the 3.5 million truckers employed in the United States.
Scholarship shows that the potential environmental harm reduction from replacing fossil fuel and electric road vehicle delivery could be enormous. However, this transition is blocked by incongruent federal regulations. Likewise, the current patchwork of regulation presents significant safety and security risks that could be alleviated by leveraging geospatial mapping techniques that planners and spatial analytics professionals already have in their digital toolkits. The policy community needs to provide a pathway for the environmentally beneficial applications of commercial drones, which includes preparing for the eventual realities of airspace congestion by drones and their labor implications, which could jeopardize job stability for any the 3.5 million truckers employed in the United States. [6]
Differing Best Environmental Use Cases for Commercial Drones
Studies demonstrate that a business’ model and the context of the built environment can yield differing spatial best-applications for drones as an environmental alternative to conventional delivery methods. Planners note that differences in business use cases, built environment factors, and competing modes lead to different optimal environmental applications of drones. In the high-volume package delivery use case, which compares delivery drones to trucks (assumed as emissions standards-compliant FedEx Express Step Van), drones are particularly environmentally advantageous over trucks in high density delivery scenarios over short distances from the depot. Trucks, in this study, are favored in service zones that are farthest away from the depot with the most recipients[7]. While with lower-volume pizza delivery, drones win out compared to fossil-fuel-based motorcycles and electric motorcycles in both environments, they demonstrate significantly less emissions and particulate matter in the lower density, more geographically disparate scenario, than in a dense capital city. [8]
Although these studies do not point to an optimal blanket use case for delivery drones, they show that drones have the potential for environmentally sound function in either depot-based distribution models or in tackling the last-mile problem. Pivotally, the assumptions shared by the studies speak to drones’ freight sustainability potential. These studies assume uncongested traffic conditions for delivery trucks and motorcycles, that all deliveries of goods would be made on first attempt, with vehicle drivers routing correctly and over the most efficient routes by distance traveled with no detours. [9] Even when motor vehicles stack up against drones in ideal, vacuum scenarios, they still cannot win out on environmental metrics.
What these studies make clear is that there are environmentally net-beneficial applications of commercial delivery drones compared to the status quo. Businesses would need only to be enabled to crunch the numbers to determine their most optimal drone-based use case.
Even when motor vehicles stack up against drones in ideal, vacuum scenarios, they still cannot win out on environmental metrics.
Federal Regulatory Hurdles to Commercial Drone Applications (and Missteps) in the United States, 2022
Federal regulations to enable commercial drones have emerged at a detrimentally sluggish pace. The FAA, which aims to be the primary body regulating the use of UAVs, has done very little to regulate the use of drones, especially for commercial use, and the body’s hesitation is disruptive to existing scholarship on the benefits of drone tech. The FAA may be reticent to permit commercial drone usage primarily for privacy and security concerns. As of December 2019, 22.7% of all scholarly pieces published about drones were concerned with protecting the privacy of people in the properties over which drones may fly. Another 22% were concerned with safety issues of drones, a plurality of the same were concerned with cooptation of drones by terrorists. However, at the same time, 23.9% of articles were concerned with adjusting current regulations, [10] which are few, conflicting, and counterproductive.
Unsurprisingly, the FAA has applied the most stoppage power to commercial drone usage. Beginning in March 2012, a Silicon Valley startup named TacoCopter announced intentions to deliver tacos within San Francisco using UAVs. In response, the FAA signed a national moratorium on commercial drone activity. [11] The potential applications for commercial drones broke into the larger public consciousness beyond the radius of Silicon Valley on December 1, 2013, when Amazon announced its development of Amazon PrimeAir. [12] In 2015, in response to private sector pressures eager to explore the applications of drone technology, the FAA caved and provided some legal authorization for commercial drone experimentation. [13]
Existing Regulations – Prerequisites
FAA regulation on drones is scant. Most regulations focus on the operator’s credentials (have they sat through the required TSA-written and FAA-proctored exam to gain licensing to operate a drone?), the shape of the drone, and how the operator can fly the drone. Current FAA regulations on commercial drones are limited to drones weighing less than 55lbs. 55lbs represents the upward cumulative weight limit of the drone plus its parcel load. In order for companies to operate drones commercially, they must apply for a permit—i.e., use of drones by companies is not as-of-right in the United States. [14]
Existing Regulations – Use of Drones
Once approved, drone operators “must observe the safety regulations restricting the flight area of drones to be away from private property, and at least six miles away from the airport.” [15] Commercial drone operators must adhere to “line of sight” regulations, outlined in the regulations referenced unaffectionately throughout the lexicon by its section name, Part 107. Part 107 maintains that a drone operator cannot allow a UAV to fly beyond the operator’s line-of-sight boundary, which is “usually not more than a few hundred yards.” [16] This regulation applies even if an operator is using First-Person View (“FPV”). Even if the operator is using FPV, the drone may not go beyond the line-of-sight boundary “at all times with unaided sight (e.g., no binoculars).” [17] Other regulations prohibit commercial drones’ flying “at night,” “above 400 feet,” “faster than 100 miles per hour” and “over crowds of people.” [18] Likewise, as with recreational usages, all drones must be registered with the FAA, but the registration thereof only collects the operator’s personal information. All drones, likewise, must be compliant with the FAA’s restrictions on no-fly zones. But, as authors note, no-fly-zones change frequently (one sites the example of having the President in town for a parade).
Spatial mapping—or “geofencing”—of no-fly zones is an exciting issue where planners and spatial analytics practitioners can engage with drone policy. Unfortunately, debates on the authority of geofencing within public or private spheres have largely shrouded the fun and nerdy brainstorming on to how to design and regulate drone lanes in airspace.
Regulations requiring avoidance of public property complicate and disrupt the environmental benefits of drone delivery, which operates efficiently and nimbly in linear flight paths.
Conclusions and Labor Concerns
In an absence of federal leadership and increasing proliferation of drones consumer and commercial use, states have taken to regulating drone usage themselves, dispelling any hopes for uniformity in drone aerospace regulation. [19] These disparities and lack of any intestate oversight conduit has caused over 700 near misses between drones and manned aircraft—and that frightening statistic comes just from the first eight months of 2015. [20] In 2022, despite the fact that drones and aircraft each contain sensors that send identical signals between vehicles and ground controllers, there are no regulations requiring that they communicate in the air. [21]
The current state of US regulations regarding commercial drones undermines the environmental harm reduction potential incumbent in commercial drones’ numerous use cases. Regulations requiring avoidance of public property complicate and disrupt the environmental benefits of drone delivery, which operates efficiently and nimbly in linear flight paths.
Likewise, the line-of-sight regulations currently crush the practical commercial drone application of package delivery. Consider this in contexts when obstacles like trees or buildings would hinder flying drones very far, or when landing in urban or vegetative areas, drones have significant potential missed applications. Environments with these features constitute a huge portion of the United States’ land area use case for commercial drone delivery, and are where the majority of our population lives and consumes goods.
Currently, spatial regulations prevent drones from going places on a heuristic basis to protect against privacy violations and physical safety concerns. However, privacy and safety concerns can be mitigated by leveraging the geospatial data which planners and spatial analytics professionals have at their disposal.
Lastly, I would be remiss to mention that I hoped to complement my exploration of drones from an environmental and regulatory perspective with a third eye on labor economics. Anyone can infer that the proliferation of commercial drones will have some effect in forcing the obsolescence of trucking and other professionals in the logistics and supply chain sectors. Regrettably there is nothing discussing skills transferability between trucking to drone operation in the academic literature. What is clear is that a commercial transition to drone-based goods delivery renders human-labor undesirable, and will be a cost which goods shipping companies can look forward to cutting if and when commercial drone use becomes permissible.
Cutting human labor costs in favor of automation is often a managerial no brainer. However, an August 2022 article by Bookertrans, a consortium of independent owner operator trucking companies, found that only about half of the nation’s 1.8 million truckers, are employees of trucking companies. The other 1.7 million are owner operators of their own trucking businesses, a number that has grown over the last decade as online retail put a premium on reliable shipping. These owner operators often work as contractors for shipping companies. Their rates are more expensive than traditional employees—typically more than double that of an employee truck driver, at $180,000 a year—but are generally more willing to work through hours that enable fast goods delivery. [22]
It is not clear from the scholarship—or really, the lack there of—whether employee truckers or independent operator-contractors are most threatened by commercial drone proliferation. Most scholarship takes for granted that drones can operate without human intervention, while regulation currently assumes one human operator for one drone at a given time. The existing scholarship makes no exploration of the skills transferability or potential jobs creation paralleling commercial drone rollout. Whether commercial drones roll out as fully autonomous or not, considerate and equitable attention needs to be expended to find a place for truckers, the primary employment group that the sustainable technological innovation of commercial drone delivery threatens to make obsolete.
Photo by micah epstein
About the Author: Lindsey Hover
Lindsey M. Hover is a graduating Master of City and Regional Planning candidate at the Weitzman School of Design at the University of Pennsylvania and a candidate for the Kleinman Center for Energy Policy’s Professional Certificate in Energy Management and Policy. Lindsey specializes in economic development projects and research that advances macro-level sustainability policy and equity.
SOURCES
1. Weidmann, Thomas, Manfred Lenzen, Lorenz T. Keyßer, and Julia K. Steinberger. “Scientists’ Warning on Affluence.” Nature Communications 11 (June 19, 2020).
2. Clark, Dave. “Introducing Our First Airplane: Amazon One.” About Amazon (blog), August 4, 2016.
3. Guerra, Erick. “Urban & Global Freight.” Class Lecture at the University of Pennsylvania, November 15, 2022.
4. Chen, Gina Y., “Reforming the Current Regulatory Framework for Commercial Drones: Retaining American Businesses’ Competitive Advantage in the Global Economy,” Northwestern Journal of International Law & Business 37, no. 3 (Summer 2017): 513-538.
5. Park, Jiyoon, Solhee Kim, and Kyo Suh. “A Comparative Analysis of the Environmental Benefits of Drone-Based Delivery Services in Urban and Rural Areas.” Sustainability 10, no. 888 (2018): 1–15.
6. Bookertrans. “What Percentage of Truckers Are Owner Operators.” Bookertrans (blog), August 6, 2022.
7. Goodchild, Anne, and Jordan Toy. “Delivery by Drone: An Evaluation of Unmanned Aerial Vehicle Technology in Reducing CO2 Emissions in the Delivery Service Industry.” Transportation Research Part D: Transport and Environment 61, no. A (June 2018): 58–67.
8. Park, Jiyoon, Solhee Kim, and Kyo Suh. “A Comparative Analysis of the Environmental Benefits of Drone-Based Delivery Services in Urban and Rural Areas.” Sustainability 10, no. 888 (2018): 1–15.
9. Goodchild, Anne, and Jordan Toy. “Delivery by Drone: An Evaluation of Unmanned Aerial Vehicle Technology in Reducing CO2 Emissions in the Delivery Service Industry.” Transportation Research Part D: Transport and Environment 61, no. A (June 2018): 58–67.
10. Kellermann, Robin, Tobias Biehle, and Liliann Fischer. “Drones for Parcel and Passenger Transportation: A Literature Review.” Transportation Research Interdisciplinary Perspectives 4 (December 9, 2019).
11. Koiwanit, Jarotwan. “Analysis of Environmental Impacts of Drone Delivery on an Online Shopping System.” Advances in Climate Change Research 9, no. 3 (September 2018): 201–207.
12. Chen, Gina Y., “Reforming the Current Regulatory Framework for Commercial Drones: Retaining American Businesses’ Competitive Advantage in the Global Economy,” Northwestern Journal of International Law & Business 37, no. 3 (Summer 2017): 513-538.
13. Koiwanit, Jarotwan. “Analysis of Environmental Impacts of Drone Delivery on an Online Shopping System.” Advances in Climate Change Research 9, no. 3 (September 2018): 201–207.
14. Chen, Gina Y., “Reforming the Current Regulatory Framework for Commercial Drones: Retaining American Businesses’ Competitive Advantage in the Global Economy,” Northwestern Journal of International Law & Business 37, no. 3 (Summer 2017): 513-538.
15. Park, Jiyoon, Solhee Kim, and Kyo Suh. “A Comparative Analysis of the Environmental Benefits of Drone-Based Delivery Services in Urban and Rural Areas.” Sustainability 10, no. 888 (2018): 1–15.
16. Calandrillo, Steve; Jason Oh; Ari Webb, “Deadly Drones: Why FAA Regulations Miss the Mark on Drone Safety,” Stanford Technology Law Review 23, no. 1 (Winter 2020): 182-251.
17. Ibid.
18. Ibid.
19. Chen, Gina Y., “Reforming the Current Regulatory Framework for Commercial Drones: Retaining American Businesses’ Competitive Advantage in the Global Economy,” Northwestern Journal of International Law & Business 37, no. 3 (Summer 2017): 513-538.
20. Tran and Nguyen
21. Ibid.
22. Bookertrans. “What Percentage of Truckers Are Owner Operators.” Bookertrans (blog), August 6, 2022.