EASA Concept of Operations 12-03-2015
EASA Concept of Operations 12-03-2015
EASA Concept of Operations 12-03-2015
EXECUTIVE SUMMARY
Drones should be integrated into the existing aviation system in a safe and proportionate manner and this
integration should foster an innovative and competitive European drone industry, creating jobs and
growth, in particular for SMEs. The proposed regulatory framework should set a level of safety and of
environmental protection acceptable to the society and offer enough flexibility for the new industry to
evolve, innovate and mature. Therefore the exercise is not simply transposing the system put in place for
manned aviation but creating one that is proportionate, progressive, risk based and the rules must express
objectives that will be complemented by industry standards.
Considering the broad range of operations and types of drones, it is proposed to establish three categories
of operations and their associated regulatory regime: Open, Specific and Certified. The Open operation
category of drones, should not require an authorisation by an Aviation Authority for the flight but stay
within defined boundaries for the operation (e.g. distance from aerodromes, from people, etc). The
specific operation category will require a risk assessment that will lead to an Operations Authorisation
with specific limitations adapted to the operation. The certified operations will be required for operations
with a higher associated risk or might be requested on a voluntary basis by organisations providing services
such as remote piloting or equipment such as detect and avoid.
Protection of other public interests such as privacy and security entailed by drone operations will need to
be addressed at the same time as the safety risk and will be dealt with at National Level. The regulatory
framework may envisage provisions to reduce that risks. The developing regulations needs to be
complemented by safety promotion actions to support the Member States.
The further development of drones and their integration in non-segregated airspace will pose new
challenges and a significant amount of further research needs to be performed. The ATM/ ANS aspect of
the concept of operation will need to be further developed. Also the harmonization of regulations and
availability of spectrum is fundamental to the success of drones. Finally the development of the drone
market and the development of the technologies need to be carefully monitored and the planning adapted.
Background
Unmanned aircraft systems (UAS) are an aircraft and its associated elements which are operated with no
pilot on board. Remotely piloted aircraft systems (RPAS) are a set of configurable elements consisting of a
remotely piloted aircraft, its associated remote pilot station(s), the required command and control links
and any other system elements as may be required , at any point during flight operations. RPAS are a subset of UAS. These terms that are coming from the ICAO circular 328-AN/190 are replaced in the common
language by the word drone and this document will accordingly use drones to speak of UAS and RPAS. A
drone operator is a person , organization or enterprise engaged in , or offering to engage in a drone
operation. It should be noted that this concept in most of its paragraphs except in the outlook paragraph
assumes drones to be remotely piloted and with no people on board
Page 1 of 8
TE.GEN.00400-003 European Aviation Safety Agency. All rights reserved. ISO9001 Certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.
An agency of the European Union
Drones are not a new phenomenon as they date back to the mid-1800 but their development in the civil
market is relatively recent. 2013 has been qualified by some as the year of the drones.
Indeed, the use of drones is developing at a quick pace worldwide and in particular in EASA Countries. The
use of drones is extremely varied. Some examples are: precision agriculture, infrastructure inspection, wind
energy monitoring, pipeline and power inspection, highway monitoring, natural resources monitoring,
environmental compliance, atmospheric research, media and entertainment, sport photos, filming, wildlife
protection and research, hunting and anti-hunting monitoring, disaster relief. Experiments to carry small
cargo are on-going in Germany and France. Size, configuration and complexity of drones are also extremely
varied. They are developed by not only classical aviation companies and but also by non-aviation
companies, usually Small and Medium-sized Enterprises (SME)
Some numbers may testify of this development. In EASA countries, there are 2495 operators and 114 RPAS
manufacturers of very small to small RPAS with a maximum take-off mass (MTOM) up to 150kg. This
compares to 2342 operators in the rest of the world (2000 in Japan only)[1]. Concerning RPAS with a MTOM
above 150 kg, 76% of the respondents to a survey conducted by the European Commission last year
indicated that they thought a swift development of such drones was likely in the coming years.
Concept of Operation
The operation of drones should be regulated in a manner proportionate to the risk of the specific
operation. Considering the broad range of operations and types of drones, it is proposed to establish 3
categories of operations and their associated regulatory regime: Open, Specific and Certified.
The Open operation category of drones, should not require an authorisation by an Aviation Authority for
the flight but stay within defined limitations for the operation (e.g. distance from aerodromes, from people,
etc.).
The specific operation category will require an Operations Authorisation by an Aviation Authority with
specific limitations adapted to the operation.
Certification will be required for operations with a higher associated risk due to the kind of operation or
might be requested on a voluntary basis by organisations providing services such as remote piloting or
equipment such as detect and avoid...
This concept has been developed to address two main goals:
a) Integration and acceptance of drones into the existing aviation system in a safe and
proportionate manner .
b) Foster an innovative and competitive European drone industry, creating new employment, in
particular for SMEs.
To achieve both goals simultaneously, the regulatory regime needs to set a level of safety and of
environmental protection acceptable to the society as well as provide protection of other public interests
such as privacy and security on the one hand, and to offer enough flexibility for the new industry to evolve,
innovate and mature on the other hand. The regulatory framework should not simply transpose the system
put in place for manned aviation but must therefore be proportionate, progressive, risk based and the
rules must express objectives that will be complemented by industry standards. Only this way can we
address the challenges posed by the wide variety of drones and their operation and support SMEs to learn
and progress from simple operations to higher risk operations as they gain experience allowing them to
increase the range of operations and application. The regulatory framework must be an enabler and not an
impediment; hence striking the right balance between innovation and the societal concerns about safety,
environmental protection, privacy and security. With this approach mentioned above the regulatory
[1]
framework will render obsolete the limit of 150 kg included in Annex II of the EASA Founding Regulation
separating drones regulated nationally and those regulated at European level. Furthermore, this approach
will allow to put on equal footing commercial and non-commercial operations (including classical aero
models or toys). This concept focuses on safety risks but recognises the importance of risks to privacy and
security. These subjects are briefly addressed at the end of the paper.
The safety risks considered must take into account:
Mid-air collision with manned aircraft,
Harm to people, and
Damage to property in particular critical and sensitive infrastructure.
Page 3 of 8
TE.GEN.00400-003 European Aviation Safety Agency. All rights reserved. ISO9001 Certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.
An agency of the European Union
Page 5 of 8
TE.GEN.00400-003 European Aviation Safety Agency. All rights reserved. ISO9001 Certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.
An agency of the European Union
Developing regulations needs to be complemented by safety promotion actions that EASA could initiate to
support the Member States. Three proposals could be made all for the open category:
Develop a leaflet listing dos and donts for drone operators. Such leaflets have already been
developed by some Member States. They could be published on EASA and Member States
websites and with the support of the RPAS community be distributed when drones are bought.
Such leaflet should be translated in all EU languages and cooperation from Member States would
be needed.
Video campaigns could also be organised.
As the police and other enforcement Agencies are expected to play a key role in the oversight of
the Open category, consideration should be given to provide them with an information manual and
a training syllabus after coordination with Member States. There again it would be necessary to
translate such manuals in all EU languages and cooperation from Member States would be needed.
Help and advice could be sought from the Federations, clubs and associations of model flyers throughout
Europe.
This concept paper has concentrated on the safety aspects which is a top priority for Aviation. However the
risks entailed by drone operations will need to be addressed at the same time as the safety risk.
The privacy risk/ data protection will be dealt with at National Level. The regulatory framework may
envisage provisions that could reduce that risk and also the security risk. For example, the risk regarding
privacy (data protection) could be mitigated through the operators self-registration in a web based
application maintained by the local authorities. Another solution would be to install chips/ Sim cards in
drones. Such a web based application or chip/ Sim cards could also contribute mitigating the security risk
It should be noted that operators may use the same process for safety, privacy and security risk
management by taking an integrated approach
To be able to endorse the regulations for the open category and to give information to the operators on
applicable local regulations and restrictions, a standardised web portal could be established. This portal
could inform about local regulations and temporary restrictions e.g. due to security issues.
A registration of operations could solve some privacy, security and enforcement issues. For example a
requirement in certain areas could be to have signed print of the registration with the applicable
conditions.
The availability of spectrum is fundamental to the success of drones. Spectrum decisions are taken in the
ITU (International Telecommunication Union). The continuation of the active coordination of Member
States already existing in the European Aeronautical Spectrum Frequency Consultation Group (ASFCG) is
strongly recommended so that Europe speaks with a single voice and the necessary spectrum is allocated
to drone operations.
Additionally and similarly to model aircraft flying today in most of the Member States, a third party liability
insurance is foreseen for the 3 categories of operation. Current Regulation (EC) No 785/2004 on insurance
requirements for air carriers and operators does not require insurance for model aircraft of less than 20 kg.
Page 6 of 8
TE.GEN.00400-003 European Aviation Safety Agency. All rights reserved. ISO9001 Certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.
An agency of the European Union
OUTLOOK:
The further development of drones and their integration in non-segregated airspace will pose new
challenges. While today flying a single drone in non-segregated airspace with cooperative aircraft can be
done with appropriate coordination and special procedures, operation of several of them possibly with
non-cooperative aircraft will be much more complicated and will require additional measures. The concept
of operations will need to be further developed to address the issues related to operations of fleet of
drones in the non-segregated airspace. These operations of fleet of drones will pose new challenges not yet
explored with manned aircraft operations. This integration will need to be done in full coordination with
the expected development of the ICAO Aviation System Block Upgrades (ASBU) being implemented in
Europe by the SESAR programme.
The key research areas for the integration in non-segregated airspace are as follows:
Detect & avoid
Human factors
Contingency
Security
Autonomy
This will need a significant amount of further research to be performed in particular by SESAR and the
European Defence Agency (EDA). Cooperation will be necessary to augment synergies and avoid
duplications of work
Factors to be taken into account could be the following (non-exhaustive list):
Transfer of drones from one control station to another: some drones have a significant range and
the transfer from one control station to another needs to be envisaged. The present SESAR
experimentations have already shown that such transfer should not coincide with the transfer from
one ATC sector to another
Operational Control of several drones from one control station: this is a real possibility and would
lead to formation flights, with coordinated flights of the various drones for example to attack
efficiently a fire or for crop-spraying.
ATC and operational control done by the same person: this would be an extension of the previous
case but will entail new risks and pose new liability issues.
Communications with ATC with an acceptable time of latency
Full autonomy and cooperative operations (e.g. operation in swarms; network centric operations)
Extreme endurance (several days even months) at very high altitude (20.000m): how to maintain
the necessary vigilance to face emergencies
Integration in non-segregated airspace will require for the Air Navigation Services and the Operators:
o Minimum Navigation, Communication and Surveillance Performance standards
o Adaptation of the Infrastructure
o New Procedures
o Adapted Training
Page 7 of 8
TE.GEN.00400-003 European Aviation Safety Agency. All rights reserved. ISO9001 Certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.
An agency of the European Union
The ATM/ ANS aspect of the concept of operation will need to be further developed or a separate
ATM/ANS concept of operations will need to be established which should address short, mid and long term
perspectives. However, these perspectives should be based on the development of the drone market and
the development of the technologies. These should be carefully monitored and the planning adapted as a
consequence.
PLANNING:
The planning will reflect a progressive introduction in the non-segregated airspace. The development of the
rules will be market driven so a detailed mid/long term planning is not provided here, however the
following short term actions are identified:
Stakeholder consultation on the regulatory framework taking into account the discussions at the
Riga Conference to be published for consultation by middle of 2015
Stakeholders consultation on concrete regulatory proposal for open category based on the
relevant elements of the regulatory framework and existing National rules to be published for
consultation in June 2015
Draft regulatory framework to be presented to the Commission by end 2015
Concrete regulatory proposals for open category to be presented to the Commission in December
2015
These actions are considered priority actions for 2015, as they address the foundation of the Regulations
for drones and the pressing need to harmonise operations of small drones in Europe. This harmonisation
has been identified as a key priority by operators of small drones.
A communication plan should be developed in coordination with the European Commission and the
Member States to explain and promote the concepts included in the regulatory framework.
Harmonisation of drones rules are a must which is recognised by all parties. This concept for a regulatory
framework will be proposed to JARUS and ICAO as the European input thus contributing to global
harmonisation.
Page 8 of 8
TE.GEN.00400-003 European Aviation Safety Agency. All rights reserved. ISO9001 Certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.
An agency of the European Union