1 Droning Around: How the FAA’s Lethargic & Haphazard Regulation of Commercial Small Unmanned Aircraft Systems is Obstructing Economic Growth Nathan Charles Pitluk Abstract: The focus of this article is to give an overview of U.S. regulation of unmanned aircraft systems vehicles (“UAS”), commonly known as drones. In addition to generally discussing commercial UAS regulations in the U.S. and its policies, this article will provide a quick overview of other international regulations of commercial UAS regulations. These international regulations will highlight the U.S.’s current standing within the international race to drone supremacy. This comparison will allow us to understand where the U.S. can gain ground and capture what is poised to become an $82 billion dollar industry. Introduction The benefits of drone power can provide a number of creative and efficient solutions for citizens and businesses throughout the country. However, some people fear the rise of the drone. In fact, the word drone has negative connotations, synonymous with terminators flying over us with bombs or spy on our everyday lives. A different picture needs to be painted for the general public, a shifted thinking from a future where a drone’s greatest role is a machine designed to kill and spy. The potential for innovation and economic growth far outweigh any science fiction fears. The potential uses of drones should excite the public and spark the imagination and ingenuity of the American people. Automated machines are already a robust part of the commercial setting, helping manufacture goods and sort inventory for entire warehouses. It is doubtful anyone fears the machine that constructed the car they drive every day, and yet, once the machines become mobile, free to roam the earth, the end is near. These fears must subside. With a drone industry
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
1
Droning Around: How the FAA’s Lethargic & Haphazard Regulation of
Commercial Small Unmanned Aircraft Systems is Obstructing Economic Growth
Nathan Charles Pitluk
Abstract:
The focus of this article is to give an overview of U.S. regulation of unmanned aircraft
systems vehicles (“UAS”), commonly known as drones. In addition to generally discussing
commercial UAS regulations in the U.S. and its policies, this article will provide a quick overview
of other international regulations of commercial UAS regulations. These international regulations
will highlight the U.S.’s current standing within the international race to drone supremacy. This
comparison will allow us to understand where the U.S. can gain ground and capture what is poised
to become an $82 billion dollar industry.
Introduction
The benefits of drone power can provide a number of creative and efficient solutions for
citizens and businesses throughout the country. However, some people fear the rise of the drone.
In fact, the word drone has negative connotations, synonymous with terminators flying over us
with bombs or spy on our everyday lives. A different picture needs to be painted for the general
public, a shifted thinking from a future where a drone’s greatest role is a machine designed to kill
and spy. The potential for innovation and economic growth far outweigh any science fiction fears.
The potential uses of drones should excite the public and spark the imagination and ingenuity of
the American people. Automated machines are already a robust part of the commercial setting,
helping manufacture goods and sort inventory for entire warehouses. It is doubtful anyone fears
the machine that constructed the car they drive every day, and yet, once the machines become
mobile, free to roam the earth, the end is near. These fears must subside. With a drone industry
2
that is projected to earn more than $82.1 billion in the next decade, the U.S. cannot afford these
fears.1 As unmanned aircraft systems take to the skies, accept your new drone overlords and all
they bring to help solve a number of economic and infrastructural issues.
Imagine the possibilities and freedom that unmanned aircraft could bring to the world.
Many logistical hurdles the U.S. faces could be alleviated or cured, including fewer trucks on the
road, greater crop yields, and faster internet. And that is only the beginning. When the Federal
Aviation Administration (“FAA”) pulls back its tenuous rules and haphazard policies and the
public freely gets to use this technology, who knows what innovative uses the general public can
discover. But to get there, the U.S. will need to traverse unstable legal landscapes. The FAA has
been slow to enact regulations that delineate the requirements for operating commercial unmanned
aircraft systems (UAS) in the national airspace system (NAS).2 Because of this lethargic
rulemaking Congress added a UAS section to the FAA Modernization and Reform Act, mandating
that the FAA integrate civil unmanned aircraft systems by September 30, 2015.3 But, the FAA’s
slow and unsteady approach is not the only problem. States have taken matters into their own
hands, proposing regulations aimed at curbing police surveillance and protecting privacy rights.4
While privacy is an important constitutional right, these regulations pose another hurdle for
integration of UAS into the national airspace. The U.S. needs to tread a careful line between
1 Darryl Jenkins & Bijan Vasigh, The Economic Impact of Unmanned Aircraft Systems Integration in the
United States, AUVSI, at 2 (Mar. 2013), available at
f9a4e95d1ef1/UploadedImages/New_Economic%20Report%202013%20Full.pdf 2 See Joan Lowy, U.S. Lags as Commercial Drones Take Off Around Globe, HUFFINTONPOST.COM (Mar.
17, 2014), http://www.huffingtonpost.com/2014/03/17/us-drones-_n_4978768.html. 3 See FAA Modernization and Reform Act of 2012, PL 112-95, 126 Stat 11 §323 (2012). 4 See Allie Bohm, Status of Domestic Drone Legislation in the States, ACLU (last updated June 30,
drones/dscS47PsQdPneIB2UQeY0M/singlepage.html; see also Jenkins & Vasigh, supra note 1. 12 Facebook wants to fly huge unmanned aircraft for months or years at a time that beam down faster
internet than satellites higher above. These planes would fly higher than commercial passenger aircraft.
Connecting the World from the Sky, FACEBOOK (last visited Oct. 22, 2014), available at https://fbcdn-
tion/feis/appendix/media/Appendix_A-National_Airspace_System_Overview.pdf. 16 Richard Whittle, DON’T SAY ‘DRONES,’ Beg Drone Makers, BREAKING DEFENSE (Aug. 14, 2013),
UAS is the neutral term Congress and the FAA selected to use for the more colloquial, all-
encompassing drone.17 However, “drone” has negative connotations.18 The Association for
Unmanned Vehicle Systems International (AUVSI) and the military would have us believe drone
needs to be avoided because of the negative connotations connected to the Predator drones and the
deadly strikes drones carry out.19 While it can be difficult to rehabilitate an image once sullied, the
word drone is not going anywhere.20 As this article will highlight, the true potential of DRONES
has not been tapped and their contribution to society will far outweigh their use in war. Hopefully,
its future successes will define its image. For the remainder of this article, UAS and drones will be
used interchangeably.
The focus of this article is small unmanned aircraft systems (sUAS), which are UAS below
55 pounds.21 Small unmanned aircraft are, as the FAA acknowledges, the fastest growing sector
of UAS in civil markets and commercial industries “because of their versatility and relatively low
initial cost and operating expenses.”22 One of the biggest areas of potential growth is the delivery
industry; Google, Amazon, and delivery companies like FedEx, UPS, and DHL are currently
17 E.g., FAA Modernization and Reform Act of 2012, PL 112-95, 126 Stat 11 §333 (2012) Unmanned
Aircraft Systems, FED. AVIATION ADMIN. (Sept. 25, 2014), http://www.faa.gov/uas/. 18 See Konstantin Kakaes, Banishing the Word Drone Won't Solve the Unmanned Vehicle Industry's Real
with trespass and nuisance claims.27 U.S. courts scrambled to piece together a coherent legal
framework to tackle these novel legal issues.28
Congress responded in 1926 with the Air Commerce Act (“ACA”).29 The ACA’s purpose
was to “encourage and regulate the use of aircraft in commerce and for other purposes.”30 Although
private rights and safety were a concern, the ACA focused on economic growth in a young
industry, specifically “[t]o study the possibilities for the development of air commerce and the
aeronautical industry and trade in the United States.”31 The FAA can learn from the ACA. The
ACA expressly stated that all “interstate or foreign air commerce” meant air commerce between,
within, and through the airspace of any state, territory, or place outside.32 Congress did not coddle
or suppress the expansion of the aviation industry, but welcomed the industry by opening the door
and learning from and fixing mistakes along the way. Through the ACA and later amendments,
the United States established “complete and exclusive national sovereignty in the air space . . . .”33
The ACA did not define the scope of air rights, which forced the Supreme Court to define
them in United States v. Causby.34 The issue presented was whether the landowner’s property was
taken under the Fifth Amendment by frequent flights of military aircraft over the landowner’s
property at low altitudes.35 These planes took a path over his home, flying only about 60 feet above
27 Id. at 198. 28 Id. 29 Id. at 199 (much like Congress’s recent action ordering the FAA to integrate UAS). 30 Air Commerce Act of 1926, 69 Cong. Ch. 344, 44 Stat. 568, (1926). 31 Air Commerce Act §2(c). 32 Air Commerce Act §1. 33 United States v. Causby, 328 U.S. 256, 260 (1946) (internal quotations omitted). 34 328 U.S. 256 (1946). 35 Id. at 258.
9
his home and barn, affecting the use and enjoyment of his land.36 The Court knew that landowners
were entitled to full use and enjoyment of their lands, stating they were entitled to at least the
“exclusive control of the immediate reaches” of their airspace.37 The Court held that the flights
constituted a taking because flights over private land may constitute a trespass if they are “so low
and so frequent as to be a direct and immediate interference with the enjoyment and use of the
land.”38 The Court reasoned that because continuous invasions of one’s airspace immediately
above the land could “limit the utility of the land and cause a diminution in its value,” the full use
and enjoyment of that land could not be realized and a trespass occurred the same as on the surface
of the land.39
The Court in Causby balanced the interests of property owners and the rights of public
airspace use granted by Congress. In the end, the Court protected real property rights, but the Court
also defined practical limitations of those rights, restricting landowners to the airspace they could
actually “occupy or use in connection with the land.”40 The Court declared that the immediate
reaches above the land are properly part of the landowner’s rights, but the airspace above that is
basically a public highway that is part of the public domain.41 Causby clarified the right to public
use of airspace while still carving out some protection for landowners.
The Creation of the National Airspace System
36 Id. (the landowner brought the complaint because multiple aircraft would pass over his property
causing noise and glare from lights. The family living there lost sleep and their farm suffered, losing
about 150 chickens that died from fright). 37 Id. at 264. 38 Id. at 266. 39 Id. at 262, 265. 40 Id. at 264. 41 Id. at 266.
10
In 1958, the Federal Aviation Act established the FAA and delegated the authority to
regulate the use of the U.S. airspace.42 The FAA started by creating the National Airspace System
(NAS) to build a safe and efficient airspace for civil, commercial, and military aviation and protect
the public and property on the ground.43 The NAS created classes of airspace, which the air traffic
control is required to maintain;the controlled airspaces are A, B, C, D, and E regulate the airspace
between 60,000 feet and 700 feet.44 Below 700 feet is uncontrolled, class G airspace.45 Class G
airspace is not under air traffic control’s authority, but is still within the authority of the FAA.46
Class G airspace, especially under 400 feet, is the regulatory battle ground for sUAS operation and
use.47
FAA UAS Policies, Rules, and Regulations
The FAA’s 2007 Notice of UAS Policy
In 2007, the FAA issued a notice of their policy regarding clarifying the classification of
different UAS uses and declaring the operational requirements under those classes.48 The policy
discusses three types of UAS uses: public, civil, and recreational use of model airplanes.49 This
policy was the first time the FAA acknowledged the growing UAS industry.50 However, that
acknowledgement was the extent of the FAA’s contribution to UAS growth. The FAA went on to
42 National Airspace System Overview, FED. AVIATION ADMIN. (last visited Oct. 22, 2014, available at
http://www.faa.gov/news/fact_sheets/news_story.cfm?newsId=14153 (“UAS must be flown . . . less than
400 feet above the ground . . . inside Class G (uncontrolled) airspace and more than five miles from any
airport or other location with aviation activities.”). 48 Unmanned Aircraft Operations in the National Airspace System, 72 FR 6689-0, at 6690 (2007). 49 Id. 50 Id. at 6689 (“[Civil UAS] is a quickly growing and important industry.”).
and found that the FAA’s 2007 Notice of Policy was not a valid rule implemented through notice
and comment rulemaking.64 The ALJ found that Congress – through the FAA Modernization and
Reform Act of 2012 – expressly tasked the FAA with making rules for UAS, and Congress did not
recognize the FAA’s 2007 Notice of Policy as an effective rule.65 Additionally, the ALJ found that
Pirker’s UAS was not an aircraft, but instead, fell under model aircraft and was “subject only to
the FAA's requested voluntary compliance with the Safety Guidelines stated in AC 91-57.”66
The FAA is currently appealing the decision, but this decision sent ripples through the drone
industry and muddied the skies even further.67 As far as this decision was concerned, there are no
rules governing UAS operations and class G airspace is now the “Wild West.”68 The decision blurs
the line between what qualifies as a recreational sUAS use and what is commercial, and it gives
little reasoning as to why UAS are not aircraft. The purpose was commercial, but the model used
in these flights was relatively small. Did the size factor into the decision,69 and if so, would a
heavier weight factor into another ALJ’s decision? This uncertainty will keep the drone industry
in limbo until the FAA promulgates final rules for UAS that Congress mandated under the FAA
Modernization and Reform Act of 2012.FAA Modernization and Reform Act of 2012
Five years after the issuance of the 2007 Notice of Policy on UAS, Congress ordered the
FAA to promulgate a workable framework and final rules for commercial drone use.70 The FAA,
is tasked “to safely accelerate the integration of civil unmanned aircraft systems into the national
airspace system.”71 This effort was not to be undertaken alone though, and Congress wanted the
FAA to consult with representatives of the aviation industry, Federal agencies that employ
64 Id. at *4 (“Notice 07-01 does not, however, meet the criteria for valid legislative rulemaking, as it was
not issued as a Notice of Proposed Rulemaking (NPRM), and if intended to establish a substantive rule, it
did not satisfy the requirements of 5 U.S.C., Section 553(d), which requires publication of notice not less
than 30 days before the effective date.”). 65 Id. 66 Id. at *5. 67 See Bart Jansen, Federal appeal may define FAA authority over drones, USA TODAY (July 2, 2014),
http://www.usatoday.com/story/money/business/2014/07/02/ntsb-drones-faa-appeal-pirker/11793203/. 68 Id. 69 Pirker Decision, supra note 58 at *7 (Attachment 2: the UAS Pirker used weighed 41lbs 7oz). 70 FAA Modernization and Reform Act of 2012, PL 112-95, 126 Stat 11 §332(a)(1), (2012). 71 Id.
unmanned aircraft systems technology in the national airspace system, and the unmanned aircraft
systems industry.72
The Act directs that the FAA rulemaking must give specific recommendations on minimal
“standards for operation and certification of civil unmanned aircraft systems;” require that “civil
unmanned aircraft systems include[] a sense and avoid capability;” and “establish standards and
requirements for operators and pilots,” including registration and licensing.73 In the plan, the FAA
must develop “the best methods to enhance the technologies and subsystems” so that civil UAS
will be operated in a safe and routine manner in the national airspace system.74 The FAA must
develop certification, flight, and air traffic control standards and create airspace designations for
simultaneous and cooperative manned and unmanned flight operations.75 The FAA must
implement its final rule and requirements in a “phased-in approach.”76 These requirements show
that Congress is seeking a comprehensive framework from the FAA.
Congress also wants the FAA’s UAS plan to be incorporated into the NextGen
Implementation Plan (NGIP).77 The NGIP is the FAA’s plan to upgrade the current aviation
methods of guiding and tracking aircraft to be more precise and offer more direct routes for aircraft
traveling from terminal to terminal.78 NextGen claims it will enhance flight efficiency by
improving safety, reducing delays, saving fuel and reducing the number of aircraft.79 However, the
72 Id. at §332(a)(2)(A). 73 Id. at §332(a)(2)(B). 74 Id. (Congress failed to clearly define what “methods” entail, especially confusing when it pertains to
technology and subsystems). 75 Id. at §332(a)(2)(G)-(H). 76 Id. at §332(a)(2)(C). 77 Id. at §332(a)(2)(I). 78 NextGen Update: 2014, FED. AVIATION ADMIN (Aug. 2014), available at
provided a frame work to get approval for civil UAS operations, two years after the FMRA
passed.93 First, the new guidelines state that civil UAS operators have the “option” to obtain an
FAA airworthiness certification by applying for a SAC, but are not required.94 According to the
guidelines, the application must meet the requirements of 14 C.F.R. § 11.81.95 Pursuant to. §11.81,
the petitioner must include statements about which 14 CFR sections the petitioner wants exemption
from, the extent of relief sought, why granting it would be in the public interest, how public safety
would not be affected, and granting the FAA right to publish a summary in the Federal Register.96
The guidelines also set forth what information will be considered in the exemption
evaluation, including safety characteristics of the UAS and the operation/flight.97 This safety and
operational information must include information about: (1) design and operational characteristics;
(2) pre-flight inspections, maintenance, and repair; (3) the radio frequency to be used; (4)
qualifications required of any pilots in command, including their required certifications and
amount of experience; (5) the actual flight plan, including the proposed maximum operating speed
and altitude, minimum flight visibility, weather conditions, and proximity to airports; (6) “[t]he
UAS must be operated within visual line-of-sight (VLOS),” pursuant to FMRA § 333(b)(1); (7)
internal procedures requiring notification to the Flight Standards District Offices (FSDOs) prior to
2014) (these guideline likely only pertain to small UAS because large UAS will need to be fully
integrated into the other classes of the national airspace with manned aircraft). 93 Public Guidance for Petitions for Exemption Filed under Section 333, FED. AVIATION ADMIN (Sept.
lic_guidance.pdf (starting this article before Sept. 25, 2014, the author has firsthand knowledge of the vast
improvements of this entire process); see Attachment to comment Supplemental Guidance on the
Submission of Petitions, REGULATIONS.GOV (Oct. 15, 2014), available at
http://www.regulations.gov/#!documentDetail;D=FAA-2014-0397-0007. 94 Public Guidance for Petitions for Exemption Filed under Section 333, supra note 93. 95 Id. at 5. 96 14 C.F.R. §11.81 et. seq. 97 Public Guidance for Petitions for Exemption Filed under Section 333, supra note 93 at 5.
operation; and (8) “obtaining a Certification of Waiver or Authorization (COA) from the FAA Air
Traffic Organization.”98 “In seeking authorization, petitioners will require exemptions from
regulations with which they cannot fully comply.”99 The FAA also lists a number of regulations
that may need exemption, most important is the exemption from the Airworthiness Certification,100
but the list is not exclusive and each company must determine if their operations will require
further exemptions.101 After the submitting the petition for exemption,102 the entity seeking
exemption must file a separate COA application.103
The exemption process implemented by the FAA is tedious and uncertain. Hopefully, these
exemptions are not looked at with great scrutiny. Many companies are trying to work within the
national airspace system to test out their UAS, but also help the FAA determine the best course of
action for future regulation. For an example, in July 2014, Amazon petitioned the FAA for an
exemption to conduct research and development.104 The FAA needs to allow companies like
Amazon to conduct these test flights so that commercial integration into the NAS will be smoother
out the gate. The more exemptions the FAA allows, the more data it can gather to help develop its
rules.
98 Id. at 5-7. 99 Id. at 7. 100 14 C.F.R. § 21 et seq. 101 Public Guidance for Petitions for Exemption Filed under Section 333, supra note 93 at 7 (suggested
inspections). 102 Exemptions can be submitted online at regulations.gov. 103 Petitioning for Exemption under Section 333, supra note 93; see FAA UAS Civil COA Request, FED.
vil_COA_Request.pdf (last visited Oct. 22, 2014). 104 Amazon Petition, supra note 24 (Amazon.com’s petition to be exempt from certain FAA regulations to
“conduct additional research and development for Prime Air . . . .”).
When Congress enacted the ACA in 1926, it had the ability to recognize the importance of
aircraft in the future of American industry and commerce, much like Congress did with the FMRA
in 2012. Many of the problems that arose at the birth of the aircraft are again repeating themselves
with UAS. Causby defined the right to public use of airspace while still carving out some
protection and use for landowners.105 The problem with the Causby holding is what happens in the
airspace between the public domain, i.e. the regulated airspace, and the immediate reaches private
property; where do we draw the line now that sUAS will operate mostly within this airspace? The
battle of property interest versus commerce played out in the early twentieth century, and round
two is happening within the sUAS argument. These drones have the ability to take off from any
location, hover over a target, and land almost anywhere, meaning they can easily enter someone
else’s property. This freedom of flight may constitute a trespass if they are “so low and so frequent
as to be a direct and immediate interference with the enjoyment and use of the land,” as the planes
were in Causby.106 The aircraft in Causby were loud enough to scare chickens to death and
continuous because of the property’s proximity to a military airfield.107 sUAS are much quieter –
most only as loud as a vacuum cleaner108 – than full blown aircraft and will likely not frequent
over the same property because of their ability to take off vertically.
105 See Generally United States v. Causby, 328 U.S. 256 (1946). 106 Id. at 266. 107 Id. at 259. 108 Sdporchet, DJI Phantom sound levels, YOUTUBE (Mar. 28, 2013),
https://www.youtube.com/watch?v=0WcbyhGjr70 (video with example of the noise level of a consumer
There is also cause for worry given courts could hurt the sUAS industry by finding that
“the airspace immediately above the land would limit the utility of the land and cause a diminution
in its value.”109 Because many sUAS uses will often be within the immediate reaches of one’s land,
0 to 100 feet,110 the FAA needs to comment on the close proximity use to protect sUAS from a
new era air trespass doctrine. The FAA needs to comment on flights within 100 feet of the ground,
but should take a fairly hands off approach, allowing states to provide for stricter standards if they
choose. Close proximity flights should be allowed as long as they are conducted in a safe manner
and away from road and airways. As for direct damage caused by crashes, sUAS are relatively
light and any damage caused by them should be handled with civil claims and not be the subject
of over regulation. If low level flights of sUAS are strictly regulated, the full utility of sUAS will
never be realized.
Safety Concerns
There are two main safety concerns: air safety and link safety.111 Air safety is somewhat of
a concern because a 25 pound printer112 flying at 50 mph113 has the potential to cause serious injury
and property damage. Most sUAS will operate below 400 feet in uncontrolled, class G airspace,
making them a danger to public and property on the ground.114 Therefore, a major concern, and
109 Causby, 328 U.S. at 262. 110 100 feet should be a fair marker of within the immediate reaches of one’s land considering Causby
flights occurred at around 60 feet. Id. at 258. 111 Bennett, supra note 84 at 14-18.This writer refuses to address the ridiculous argument of terrorism by
drone. Model aircraft have been around for decades and any terrorist could have purchase a model aircraft
and equipped it as easy as a UAS. Any regulation aimed at terrorism will likely not help and hamper
industry growth. 112 See Rhett Allain, Physics of the Amazon Octocopter Drone, WIRED (Dec. 3, 2013),
http://www.wired.com/2013/12/physics-of-the-amazon-prime-air-drone (11.43 kg is a general estimate of
the Amazon drone weight). 113 Amazon Petition, supra note 24 at 1 (Amazon sUAS will make deliveries at about 50 mph). 114 National Airspace System Overview, supra note 15; Amazon Petition, supra note 24 at 5 (flights will
detect-and-avoid-demo-.html. 117 Bennett, supra note 84 at 16. 118 Id. 119 Patrick Marshall, The tech that will make drones safe for civilian skies, GCN (Jul. 12, 2013),
http://gcn.com/articles/2013/07/12/drone-uav-sense-and-avoid-technologies-civilian-airspace.aspx. 120 Valerie Insinna, Sense-and-Avoid System for Hobby Quadcopters, NAT’L DEF. MAG. (July 3, 2014),
Overall, UAS have generated a greater interest among states to protect privacy rights. This
has gained traction with the ACLU, which supports state regulations focused on privacy rights.124
However, the main concern here is public use and not civil use, meaning there is a fear that
government agencies will use drones to impermissibly search for information. In 2013, 43 states
considered approximately 96 bills related to domestic drones, the vast majority of which pertained
to privacy.125 Many of these bills “require a probable cause warrant in order for law enforcement
to use a drone to gather evidence in a criminal investigation.”126 These regulations have come in
two main forms: bans on pre-textual flights and limits on data retention.127 Pre-textual flight
protections ban police from using information collected by a drone, absent a warrant or appropriate
exigency, as part of an application for a warrant.128 Data retention limits are imposed on
information gathered that is not evidence of a crime or part of an ongoing criminal investigation.129
The ACLU focuses its anti-drone campaign on law enforcement's use (and abuse) of UAS
technology, although the organization's phobia of police drones overall seeps into its and others’
views on commercial drones.130 State-level politicians, whether legitimately concerned about
social consequences from a new technology or simply gouging drone stigma for votes, have sprung
into action nationwide.131
124 Allie Bohm, The Year of the Drone: An Analysis of State Legislation Passed This Year, ACLU (Nov.
7, 2013), https://www.aclu.org/blog/technology-and-liberty/year-drone-roundup-legislation-passed-year. 125 Id. 126 Id. 127 See Id. 128 Id. 129 Id. 130 Nicholas Ryan Turza, Dr. Dronelove: How We Should All Learn to Stop Worrying and Love