Analysis: Dominos' drone delivery trial is public relations BS
Here's an actual Dominos delivery vehicle:
It's a bit of a heap.
But that’s okay.
If I order a $5.99 pizza, I don’t expect it to arrive via Rolls Royce.
We've all seen those beaten-up Dominos cars in real life. In the media, however, the chain is the home of the pizza delivery robot (what happened to that one?) and, now, pizzas lowered onto front porches by an unmanned aerial vehicle.
Yup. The budget fast-food brand has scored another truckload of publicity for its intention to make the world's first commercial delivery of a pizza (at some unspecified time).
Good on it for a savvy press campaign and the attendant truckload of free advertising. Pay the PR company a bonus.
But could it actually happen?
There are technical drawbacks with today’s drone technology, including lousy battery life (in response to an NBR query, Dominos said a drone would last "one or two flights").
But the main problem is legal. There was a reason Dominos' media publicity stunt was staged in a paddock in the middle of nowhere — because that was about the only place it was legal.
That's thanks to the Civil Aviation Authority's new rules around UAVs, which were introduced in July last year.
Part 101, rule 11, of the government's Civil Aviation Rules states "anyone operating a drone must “have consent from anyone you want to fly above.” That's a deal-breaker in itself.
But Privacy Commissioner John Edwards highlights another CAA drone rule: "you cannot fly a drone over a person’s property without their permission" (part 101, rule 12).
Now let’s assume – for the sake of argument - that Dominos’ has a crack team of drone experts and that, with help from partner Navman, it can programme its drones to only fly over public streets, and negotiate right-of-ways. And that it has some kind of advanced AI that allows it to constantly bob and weave to avoid flying over a person (that doesn’t exist today but who knows what Dominos scientists will come up with in the weeks ahead).
That still leaves the problematic rule 5, or as Mr Edwards sums it up, “You’ve got to maintain visual contact with the drone for the entire flight. And that’s not through binoculars or any technology-aided system; that’s with your own bare eyes. So I’d have thought carrying a pizza 1.5km might present some challenges.”
Part 102 of the CAA rules gives a certified drone operator some degree of licence to over-ride the Part 101 rules described above. But with the Air Line Pilots Association already attacking the drone rules as too flexible, I'm guessing they'll go after the government too if Dominos gets any special exemption (and giving a Part 102 exemption in a crowded urban area would be a much more front-foot move than, say, in forestry or farming).
And what of the disturbance factor? A CAA spokeswoman points out that on top of gaining Part 102 authorisation, Dominos would also have to meet council, Department of Conservation, iwi and NZ Transport Agency requirement.
SIMPLY CHEESE: Transport Minister Simon Bridges; Dominos Pizza Enterprises (Australia-NZ) chief executive Don Meij; and Matt Sweeny, head of technology drone partner, US/Australian company Flirtey, at yesterday's launch event.
Beyond technical challenges, there would be a commercial one. Having a human employee maintain line-of-sight visual contact with every drone delivery would be uneconomic.
And then there’s rule 3: "fly only in daylight."
A Dominos FAQ asks the question will the drones have cameras? Then avoids actually answering it. A rep for the company tells NBR it is “likely.”
Mr Edwards says recording video would be problematic under the Privacy Act. If it’s live streaming video (the norm for drones), it could still cause issues – for example, if the drone’s camera advertently or inadvertently sees into your home’s windows. His office has already had to deal with a complaint from an apartment dweller who feared they were being filmed on their balcony by a drone being used to cover a cricket match (it turned out there was no privacy issue).
Civil Aviation Authority staff were present at the Dominos drone launch. Good on them for supporting innovation. But the CAA has not approved Dominos for drone delivery. And under its present rules, there’s no way it could [UPDATE: The CAA responds: It’s not correct to say that under present rules, there is no way the CAA could approve this application — but we need to be satisfied that the applicant can meet the stringent requirements and demonstrate that it has a robust and comprehensive risk management plan to run this operation safely. We are considering this at present and a decision will be made in due course.]
Philip Solaris, the director of Kiwi drone company X-craft Enterprises, says Dominos would need to avoid “random hazards [such as] power lines, moving vehicles, children in the backyard playing”.
Good luck satisfying the CAA that a minimum wage pizza jockey, under time pressure, can negotiate those safety concerns.
Don't scare the horses
Pizza Transport Minister Simon Bridges was also at the launch, and supported it with a press release noting how the CAA rules encourage trial flights and innovation.
Dominos could lobby Mr Bridges for change, of course. He was, after all, open to Uber’s entreaties and duly liberalised the rules around passenger vehicles.
Uber's efforts to shoot itself in the foot notwithstanding, that one was a vote winner. There was a problem: expensive and inefficient taxis. Uber solved it.
But Dominos already delivers me pizzas at a rapid clip and at low cost. As a customer, I'm already happy. Beyond the Instagram potential of the first drone delivery, having to waddle into the middle of my driveway to pick up a box doesn't hold much appeal.
Mr Edwards also makes the quite valid point that most people would find a fleet of drones buzzing overhead “annoying, disconcerting and worrying.”
He’s right. And there’s no way Mr Bridges will risk the ire of voters by changing CAA rules.
Dominos knows that.
No matter. The drone has already done its PR job. Now it can be parked in the cupboard next to the pizza delivery robot.
POSTSCRIPT: Driver-less delivery vehicles
Transport Minister Simon Bridges says "The government is also continuing to work with Domino’s on the possibility of testing a driverless pizza delivery unit on land."
I'm not sure where that one is at. But Uber is already trialling auto-pilot vehicles in Pittsburg, and Tesla is already selling cars to New Zealanders with an auto-pilot function.
NBR asked the Ministery of Transport if Tesla's driver-less car mode is legal. The surprising answer: yes.
Although MoT general manager Nick Brown qualified, "While the use of the Tesla autopilot feature is legal in New Zealand, all current New Zealand road rules regarding the safe operation of a vehicle must be complied with at all times. This includes obligations on the driver to remain alert. For example, being non-impaired and otherwise legally able to drive – and aware of their surroundings, and to make sure that the vehicle is otherwise complying with the law, for example, the legal speed limit."
Uber's self-drive trial clearly falls within those legal parameters because, for now, there's a human in every test vehicle supervising things.
But of course, to make autopilot Uber cars (or Dominos cars) economic, the companies would have to take the human out of the equation.
Would it be legal then? After mulling the question for a couple of days, the ministry forwarded NBR the statement that: "The government is keen to support the introduction of new technology and explore opportunities for self-drive ride sharing trials with companies. However, the issue is a complex one and the regulatory issues involved would need to be worked through."