Some Counterarguments to Criticism of the Book

In preparation for publication, the manuscript was reviewed by various professors and, in one case, heavily criticized. Not only was the lack of “scientific depth” criticized, but parts of the book were also presented as incomplete or erroneous. The disagreements were subsequently resolved. However, there are various comments that the author of the book does not agree with and on which he holds a contrary opinion.

Some examples:

Criticism: Organ transport is missing from the discussion

Response: The author refers to the transport of medical samples and blood. Medical logistics transports substances that are 90% classified as hazardous materials (according to S2 and S3 of the BioStoffV). This is the result of an evaluation of thousands of transports. Over the past two years, the author has been able to develop appropriate solutions for the challenges associated with transporting hazardous materials by drone. After intensive discussions with the LBA and the state aviation authorities, the interpretation of the German Aviation Act (Luftfahrtgesetz) regarding a general ban on the transport of hazardous substances by drone was changed by the EASA with the EAR in September 2022, and the transport of hazardous substances was defined as approvable under certain conditions. The transport of organs, on the other hand, is more strictly regulated and, in the majority of cases, subject to conditions that cannot be met by unmanned aviation alone, even in the next few years. Organ transport is very special in terms of organization and technology and cannot be combined with other transport volumes in the field of unmanned aviation. For this reason, the transport of organs by drone is unlikely to be relevant in the coming years.

Criticism: The criticism expressed in the book regarding the ongoing privatization of infrastructure was questioned.

Response: Two examples that confirm this trend:

Drones are usually controlled using signals from the normal mobile phone network via 4G and 5G. It would be important, for example, to set up a backup signal for controlling drones in the 868 MHz frequency range. Since the range in this frequency range is only around 10 km, a radio array would have to be designed for larger flight areas. Ideally, the necessary antennas could be mounted on existing antenna masts belonging to mobile phone providers. I wanted to install the necessary antennas on existing mobile phone towers. However, in Germany, the mobile phone towers have been sold to investors (operators) such as Brookfield Asset Management, DigitalBridge, Telxius, American Towers, and Vantage Towers, for example. This critical infrastructure is mainly in American hands and therefore only to a limited extent within Germany's sphere of influence. The drone operator would have to rent space there. However, as the investors are profit-oriented, the rent for the drone operator is no longer economically viable.
U-Space is a de facto privatization of lower airspace. How can the essence of a U-Space be described in simple terms?

A private operator is commissioned to monitor and regulate the safety of lower airspace.
This means that every flight must be registered and approved separately by this “quasi-authority.”
These U-Spaces should initially only be introduced in urban areas and later extended across the entire country.
The providers are to refinance themselves through “service fees.”
Providers must purchase significant amounts of data from the data provider, generate and distribute their own data, and implement a role model specified by EASA. This involves enormous costs.

At the EASA event in June 2023, the author asked how this system would be implemented in terms of costs. At that time, EASA was unable to answer the question of costs and assigned responsibility for financing to the member states. In the weeks that followed, EASA drew up its first cost estimate, which assumes implementation costs within EASA's area of responsibility of between €7 billion and €9 billion. The author has previously discussed several fee models from potential U-Space providers. The fees calculated there exceed the capabilities of a drone airline operating in medical logistics by a factor of 200 in the best-case scenario! If U-Space is introduced in this way, drone airlines and providers will not be able to survive. The author suggested looking at the American system being discussed at the time outside of a U-Space. However, the issue is much more complex, as the organizational and legal questions surrounding the prioritization of transports and the (partial) transfer of responsibility for the transport of hazardous materials have not yet been sufficiently clarified.

Critique: It has been critiqued that the economic efficiency of drone transport has not been sufficiently recognized.

Response: Although the economic efficiency of transport is not the subject of the book, here are some statements on transport costs and economic efficiency. Calculating the economic efficiency of drone transport is an important issue that must be clarified before implementation. Here is a small excerpt on the associated approach:

Remuneration for transport services in the healthcare sector is regulated in the EBM (old 40100 deleted, now new: 40089–40091: procurement, provision of sampling materials, 40092–40093: digital order/findings communication systems, 40094–40095: shipping materials, transport, transmission of results including costs) at approximately €2.80 (with various small surcharges) per sample. This includes packaging, handling, data management, and transport. It is a simple calculation to filter out the remaining share for transport. This is absolutely not enough to cover the costs of transport by ground or by drone. For this reason, transport services are cross-subsidized by other services. Based on standard drones, the possible payload is usually between 1 and 2.5 kg. If the possible transport weight is reduced by the weight of the prescribed packaging (UN3373 with aviation adjustment of at least 95 kPa), there is not much left for the actual samples. Most drones can therefore currently transport a maximum of 10 to 15 samples (with appropriate packaging). The weight of the prescribed cooling system has not even been taken into account in this calculation. The break-even point will not be achievable with this small number of samples. And one more comment on the cost comparison with helicopters: No samples are transported by helicopter, so the often-made comparison of costs is meaningless. Economic efficiency is achievable (in Germany), but not in the way most providers are currently approaching it. One more note on the military: The military is not tangible in terms of economic efficiency. Based on the available figures, the military spends approximately 1,000 times more (tax) money per drone flight (small drone) than medical logistics.

This is only part of the counterargument to the annotations submitted after the (partial) evaluation.