Proceeding Paper

A Quantitative Approach to Air Traffic Safety at Very

Low Levels †
Xavier Olive 1, *,‡ and Patrick Le Blaye 2, *,‡

1 ONERA DTIS, Université de Toulouse, 2, avenue Édouard Belin, 31055 Toulouse, France
2 ONERA DTIS, BA 701, Salon CEDEX Air, 13661 Salon-de-Provence, France
* Correspondence: [email protected] (X.O.); [email protected] (P.L.B.)
† Presented at the 10th OpenSky Symposium, Delft, The Netherlands, 10–11 November 2022.
‡ These authors contributed equally to this work.

Abstract: A safe integration of drone operations at very low levels, especially for beyond visual
line-of-sight operations, must come with proper modeling of the mid-air collision risk at lower
altitudes. In this paper, we present a state-of-the-art quantitative model for the air risk assessment of
unmanned aircraft system (UAS) operations and illustrate how cooperative technologies such ADS-B
and FLARM, together with networks of compatible ground receivers, are crucial to provide the traffic
data required to support this model. An application over an area of Southeastern France is presented.
The results suggest that the collected traffic data allow accurate analyses of the spatial and temporal
variation of traffic types and density at lower altitudes, and can thus support an objective assessment
of the risk of collision of UAS with manned traffic.

Keywords: ADS-B; FLARM; General Aviation; UAS; air traffic, flight safety; collision risk modeling

1. Introduction
Collision risk modeling at lower altitudes is a key topic to keep the skies safe for all
actors of General Aviation, including private jets, ultralights, gliders, and helicopters. Low
Citation: Olive, X.; Le Blaye, P. A
Quantitative Approach to Air Traffic
altitude activities also include those of armed forces, firefighters, or search and rescue
Safety at Very Low Levels. Eng. Proc.
operations. The matter is also of particular interest to define subsets of airspace and time
2022, 28, 1. https://doi.org/10.3390/
intervals when unmanned aircraft systems (UAS), also known as drones, can safely operate.
engproc2022028001 The European Commission issued Regulation 1207/2011 mandating the Single Euro-
pean Sky [1]. As part of this, ADS-B usage is mandated on an aircraft built after 8 January
Academic Editors: Michael Schultz
2015, and for all aircraft by 7 December 2017. Regulation 1028/2014 later modified this,
and Junzi Sun
pushing the deadline to June 2020 [2]. Later, the deadline was pushed back again by Regula-
Published: 13 December 2022 tion 2020/587 [3], adding a transitional period and exemptions for older aircraft, up to 2023
and 2025, respectively. The European Commission’s mandate applies to most commercial
Publisher’s Note: MDPI stays neutral
aviation (with maximal take-off mass exceeding 5700 kg or maximal cruise speed greater
with regard to jurisdictional claims in
than 250 knots) but many light or slow aircraft remain unequipped. From a surveillance
published maps and institutional affil-
iations.
point of view, the common practice is to distinguish two types of traffic: cooperative aircraft
are equipped with electronic means of signaling and identification (Mode A/C or Mode S
transponders, ADS-B, FLARM or equivalent, Wi-Fi for drones) and non-cooperative traffic,
unequipped or stealth, only visible with a primary radar, camera or directly.
Copyright: © 2022 by the authors. The recent development of beyond visual line-of-sight (BVLOS) drone operations poses
Licensee MDPI, Basel, Switzerland. a new risk to the legacy users operating at low altitudes. These drones typically operate at
This article is an open access article very low levels (VLL), e.g., below 120 m above ground level, where manned aircraft may
distributed under the terms and also occasionally fly (e.g., for take-off and landing, training exercises, medical evacuation,
conditions of the Creative Commons or aerial work). Electronic conspicuity has been mandated for drones primarily for security
Attribution (CC BY) license (https:// reasons (police control) and will be mandated for manned aircraft willing to operate within
creativecommons.org/licenses/by/ a U-space airspace [4].
4.0/).

Eng. Proc. 2022, 28, 1. https://doi.org/10.3390/engproc2022028001 https://www.mdpi.com/journal/engproc

Eng. Proc. 2022, 28, 1 2 of 10

In this paper, we address the topic of safety at lower altitudes with the aim to character-
ize the traffic and to assess the collision risk. Section 2 describes a state-of-the-art model for
collision risk applicable to UAS operations and illustrates how cooperative technologies are
crucial to ensure proper detection of surrounding traffic without delay. Section 3 attempts
to give an overview of all that can be visible with cooperative traffic in Western Europe with
data collected through the OpenSky Network [5], including ADS-B and FLARM. Section 4
focuses on a case study over an area of Southeastern France covering a wide variety of
landscapes (plains and foothills) and aircraft activities (Marseille–Provence airport, military
air bases, firefighting activities, and local flight clubs) and using ground receivers of ADS-B
and FLARM signals, before a conclusion in Section 5.

2. Collision Risk Assessment

2.1. Qualitative Risk Assessment with SORA Methodology
Drone BVLOS operations at VLL most often present a moderate level of risk and thus
belong to the “Specific” category under the European regulation [6]. These operations are
subject to approval by the authority based on a risk analysis performed by the operator
using the Specific Operation Risk Assessment (SORA) methodology [7]. This methodology
consists of a step-by-step parallel assessment of ground and air risks, the latter being related
to the collision with a manned aircraft or another UA. The SORA was initially developed
by JARUS based on an air risk collision model which has been submitted to consultation in
2018 [8] but remains unpublished at this time.
The air risk collision model of SORA is primarily qualitative and relies on an initial
risk classification using a decision tree (Annex C in [7]), depending on the environment
(airport/heliport), the altitude (e.g., VLL), the airspace class (controlled/uncontrolled),
and the type of area (urban/rural). The classification is based on a ponderation of three
variables (proximity/density, geometry/structure, and dynamics) and results in 12 airspace
encounter categories (AEC) with associated air risk class (ARC) ranging from no risk to
high risk. The operator may claim for a lower ARC by demonstrating that the actual traffic
density is lower than assumed. The final air risk is determined in the next steps after
consideration of strategic and tactical mitigation measures.
This qualitative approach aims to facilitate the risk assessment by the operator, as its
only input is the concept of operation, with no consideration of the actual traffic within
the operational volume. It relies to a large extent on subjective assessments, and studies
are needed to assess whether it correctly captures the actual level of risk [9–11]. However,
SORA leaves to the competent authority the possibility to “directly map the airspace
collision risks using airspace characterization studies”, which indeed requires an extensive
collection of actual traffic data over the foreseen operational volume and its surroundings.
Moreover, the recent European regulatory framework for the U-space [12] specifies
that the designation of U-space airspace shall be supported by an airspace risk assessment,
taking into account “the type, complexity, and density of the traffic, the location, altitudes, or
heights and the airspace classification”. Capabilities and performance requirements for the
UAS shall also be determined based on this assessment. This regulation is complemented by
requirements for the manned aircraft willing to operate in such airspace to be electronically
conspicuous to the U-space service providers [4]. Acceptable means of compliance and
guidance have been proposed regarding the assessment process [13], recognizing the value
of both qualitative and quantitative analysis and the need for iteration considering the
achieved and perceived risks, including hazard mitigation.

2.2. Quantitative Risk Modeling

Hereafter, we focus on collision risk between unmanned and manned aircraft, which is
actually the prominent issue for UAS air traffic integration. Collisions between UA can be
considered of a differing nature, as they involve risk of fatalities or damage on the ground.
The objective of the air risk assessment is to ensure that the risk of mid-air collision
(MAC) for a particular operation is below a target level of safety (TLS), which for General
Eng. Proc. 2022, 28, 1 3 of 10

Aviation is generally determined as 10−7 per flight hour. We adopt the approach of SORA,
where the overall risk depends on the initial “ambient”, unmitigated, collision risk rate and
on strategic or tactical mitigations when required to reach the TLS.
The collision risk rate is typically decomposed as follows [14,15]:

MACrate = p(MAC | NMAC) · p(NMAC | Enc) · Encrate (1)

• MACrate is the number of MAC per flight hour, expected to be lower than the TLS;
• p(MAC | NMAC) is the probability of MAC given that a near mid-air collision (NMAC)
occurred. NMAC refers to a situation when two aircraft come closer than 500 feet hori-
zontally and 100 feet vertically. p(MAC | NMAC) reflects the role of (lack of) providence
in collision avoidance. It is estimated at 10−2 , taking into account the small dimension
of the UA compared to the typical dimensions of manned aircraft [16].
• p(NMAC | Enc) is the probability of an NMAC provided an encounter has occurred;
• Encrate is the number of encounters per flight hour.
The two former parameters depend on the encounter definition. An encounter can be
described as a situation where two aircraft come as close as to potentially pose a collision
risk, such as the case where a manned aircraft flies into the vicinity of the drone operational
volume and can be considered as an intruder, requiring attention from the remote pilot.
For the purpose of risk modeling and traffic data collection, we consider an encounter
as the situation where surrounding traffic enters a surveillance volume spatially defined as
a cylinder. The larger this volume, the higher is the encounter rate and correlatively, the
lower is the probability p(NMAC | Enc). The definition results from a compromise, i.e., the
choice of an adequate granularity for traffic data collection. If it is chosen too large, the
encounter rate may not adequately represent situations particular to the intended operation,
and if it is too small, some relevant traffic patterns (e.g., high speed) may not be captured.
For a given surveillance volume, p(NMAC | Enc) can be estimated through geometric
calculation and further refined by means of numerical simulations [14], while Encrate
depends on the traffic density which can be derived from actual observations of the traffic,
as described in the next sections. Note that an alternative form of Equation (1) can be
used considering well clear violations (WCV) instead of encounters. In particular, the SORA
refers to work by MIT [16] regarding the well clear definition for small UAS, weighting
less than 55 pounds and operating below 1200 feet AGL at a maximum speed of 60 knots,
which recommended a well clear volume of 2000 feet horizontally and 250 feet vertically,
providing a value of p(NMAC | WCV) equal to 10−1 .
When it comes to collecting traffic data relevant to UA operations below 500 feet AGL,
the following assumptions have been made based on experience reported by UAS operators
and observation of flight profiles of General Aviation aircraft:
• Maximum ground speeds are assumed to be 60 knots for the UA and 250 knots for the
manned aircraft (maximum allowed speed below FL 100), with 95% below 170 knots.
• A minimal look-ahead time of 30 s before loss of separation is considered necessary
for the UA to detect and avoid a possible loss of separation with an incoming manned
aircraft, considering the need to not scare the pilot of the manned aircraft. As a
reference, the maximum time for the first level of alert of a FLARM device is around
25 s before collision [17] and TCAS alerting time is 25 s below 2350 feet AGL and
20 s below 1000 feet AGL [18]. Note that the trajectory prediction of GA aircraft is
complicated by the uncertainties due to lack of inertia and the possibly high turn
and vertical rates, so that predictions with a look-ahead time higher than 30 s are
considered unreliable.
• In the worst case of a head-on conflict, the relative closing speed is thus 310 knots (or
230 knots at 95%). Adding the resulting distance flown in 30 s and the recommended
separation of 2000 feet, the required horizontal distance for considering surrounding
traffic as an intruder is about 5000 m.
Eng. Proc. 2022, 28, 1 4 of 10

The vertical dimension is particularly determining for VLL operations, as the manned
traffic density increases rapidly with altitude (see Figure 6 in Section 4). Manned traffic
usually only transits through the low altitude levels, with moderate vertical rates. Con-
sidering a continuous climb or descent at a gradient of 5% over the horizontal distance
of 5000 m, the possible altitude variation is 250 m (820 feet). Adding the recommended
separation of 250 feet gives a relative vertical distance for the surveillance volume around
1100 feet. When it comes to collect traffic data for VLL operations limited to 500 feet AGL,
the manned traffic may thus be considered relevant when it flies below 1600 feet AGL.

3. Cooperative Aircraft Detection at Very Low Levels

3.1. ADS-B
ADS-B (Automatic Dependent Surveillance—Broadcast) is a technology based on
transceivers, electronic on-board devices which help to identify aircraft on air traffic control
(ATC) radars. Alike to transponders, transceivers produce signals on the 1090 MHz fre-
quency but do not require interrogations. The FAA and the European Commission issued
regulations to mandate aircraft to be ADS-B compliant, but these mostly apply to large
aircraft flying in designated airspaces.
ADS-B data collection for en route commercial aircraft is usually rather easy to achieve
with proper receivers, which are at best limited by the radio horizon and yield a coverage
range of about 400 km. Coverage usually decreases with altitude and is affected by sur-
rounding buildings and mountain relief. Figure 1 shows a correlation between low altitude
coverage, receivers’ locations and mountains over Western Europe. Low altitude coverage
in France is therefore limited to densely populated (more chances to get a potential feeder
there), lower altitude or flat areas (fewer chances to be affected by surrounding mountains).
Low altitude ADS-B coverage is also affected by the very low equipage rate for General
Aviation aircraft, as we documented in [19]: as a result, even a decent receiver with a good
low altitude coverage will not provide any trajectory information for a significant part of
General Aviation aircraft.

Figure 1. ADS-B coverage (minimal altitude detected) below 10,000 ft for aircraft with a non-
commercial callsign over Western Europe (left) with mountain relief (right). Red dots match the
location of receivers actively feeding the OpenSky Network on the same day.

3.2. FLARM
FLARM is, with TCAS [20], one of the most widespread technologies for traffic aware-
ness and collision avoidance, initially designed for gliders, light aircraft, rotorcraft, and
drones. FLARM obtains its position and altitude readings from a GPS antenna and an
internal barometric sensor, then broadcasts these together with forecast data about the
future 3D flight track. At the same time, its receiver listens for other FLARM devices within
range and processes the information received.
Eng. Proc. 2022, 28, 1 5 of 10

The wireless nature of FLARM allows for the reception of signals in a crowdsourced
fashion. Although the FLARM radio protocol features message encryption in order to
ensure integrity and confidentiality, implementation and encryption keys are available:
the Open Glider Network (OGN) maintains a tracking platform with the help of many
receivers, mostly collocated with flying clubs operating light aircraft at local airfields. The
OpenSky Network (OSN) also collects FLARM raw messages, with data accessible to
institutional researchers. Despite fewer receivers currently feed OSN, access to historical
data is possible, allowing for proper analyses. Figure 2 plots the low-altitude coverage for
the OpenSky Network and the Open Glider Network in Western Europe: it is similarly
affected by surrounding relief and receivers’ location.

Figure 2. FLARM coverage (minimal altitude detected) for equipped aircraft. Red dots match the
location of receivers feeding the OpenSky Network (left) and the Open Glider Network (right).

3.3. Mode A/C and Mode S Transponders, Multilateration

The transponders equipping most General Aviation aircraft are Mode A/C transpon-
ders only: they reply to Secondary Surveillance Radars (SSR) with squawk (Mode 3/A) and
altitude information (Mode 3/C), by increments of 100 ft. Mode S is a further extension of
Mode A/C where queries are addressed to specific aircraft (S stands for selective).
All ADS-B receivers, including those feeding the OpenSky Network decode and record
the raw messages associated with squawk and altitude information which can further be
related to the flight logs of any airborne aircraft within range (cf. Section 4). Even without
any precise localization information, receivers receiving squawk and altitude messages
from any aircraft equipped with a transponder can relate that piece of information with
probable activity in the neighborhood and around the air field where the aircraft is based.
When an aircraft is within coverage of at least four synchronized receivers, multilater-
ation is a technique designed to estimate the localization of the aircraft. Multilateration is
based on the optimization of a quadratic problem relating the differences between times
of arrival of messages to the differences between distances between the aircraft and all
receivers within range. Provided that clock drift is properly estimated, clocks with a
nanosecond precision (GPS clocks) may reduce the uncertainty to the order of magnitude
of a meter in the estimation of the aircraft’s localization.

4. Case Study
In this section, we focus on data collected between 15th and 30th June 2022 by our
ground receiver located on the Salon-de-Provence Air Base (BA 701), collecting ADS-B and
FLARM data and feeding the OpenSky Network. This area in Southeastern France, near
Marseille, is of particular interest for this study as it hosts a wide variety of landscapes
(plains and foothills) and aircraft activities are displayed in Table 1.
Eng. Proc. 2022, 28, 1 6 of 10

Table 1. The case study spans over many airfields and covers a wide range of aeronautical activities.
Flights with ADS-B coverage and tagged as landing or taking-off from these airfields were counted in
the appropriate column of the table.

Flights Airport or Airfield

LFMA 223 Aix-Les Milles General Aviation, Guimbal (helicopters)
LFMI 263 Istres Le Tubé (BA 125) Military activity, flight test center
LFML 4120 Marseille Provence Commercial hub, Airbus Helicopters
LFMV 94 Avignon Caumont Low-cost seasonal hub, General Aviation
LFMY 39 Salon-de-Provence (BA 701) Military, aerobatics, gliders (receiver location)
LFNE Eyguières General Aviation, gliders, ultralights
LFNT Avignon Pujaut General Aviation, parachute drop-out
LFNR Berre-la-Fare General Aviation
LFNZ Saint-Rémy-de-Provence Gliders
LFTW Nîmes-Garons Low-cost hub, Sécurité Civile (firefighters)

Table 2 decomposes all the detected traffic with ADS-B and FLARM data: most ADS-B
traffic comes from commercial activity at Marseille–Provence (LFML or MRS); most FLARM
data stem from gliders operating at LFMY (military school) or LFNZ (local civil gliding club).
Visible military activity comes mostly from air tankers taking off from the LFMI air base
and heading for in-flight refueling training in designated areas. Remaining trajectories are
mostly helicopters commuting with hospitals heliports, performing firefighting activities
or manufacturers tests (Airbus Helicopters).

Table 2. The ADS-B and FLARM datasets cover a wide range of activities: commercial, military,
test flights by manufacturers, ambulance (Life and Rescue), firefighting, General Aviation including
ultralights and gliders. Four aircraft have been detected in both datasets.

Flights Aircraft Category

5766 1111 ADS-B dataset
4546 866 commercial mostly operating to/from LFML
161 26 military FAF callsign, air tankers, etc.
106 13 test flights (F-W*) Airbus and Guimbal helicopters
134 10 Sécurité Civile (fire) MILAN, DRAG, BENGA callsigns
72 4 Life & Rescue SAMU callsign helicopters
895 247 General Aviation
650 128 FLARM dataset
99 19 Aircraft
93 15 incl. also equipped with a transponder
40 4 incl. also ADS-B compliant
418 105 Glider
114 38 incl. also equipped with a transponder
76 5 Tow-plane
48 1 Parachute Drop-Plane around LFNT in the north
9 5 Helicopter also equipped with a transponder
1 1 Paraglider

We found that even local flight clubs showing good will in investing for safety may
lack technical background and mistakenly think their aircraft is ADS-B-compliant after
they equipped it with a transponder. Even though Mode A/C transponders do not send
positional information (other than barometric altitude and callsign), detecting a signal from
a known aircraft from a local flight club is precious information about traffic density in the
neighborhood. Figure 3 compares the data detected for one aircraft with the flight logs kept
by a local flight club at Eyguières LFNE: apart from UTC vs. local time (UTC+2) confusion
in the keeping of the flight logs by different people, our receiver detects and correctly logs
local activity (discovery flight, local flight, school flight) of the aircraft.
Eng. Proc. 2022, 28, 1 7 of 10

June 17 June 18

log
dataflight
June 19 June 20

07:00 09:00 11:00 13:00 15:00 17:00 07:00 09:00 11:00 13:00 15:00 17:00

Nature of the flight

data discovery local navigation private school

Figure 3. Comparison of detected activity based on Mode A/C data with flight logs for a private
aircraft based at Eyguières airfield LFNE nearby our LFMY receiver. In spite of no ADS-B-compliant
equipment, it is possible to detect a local activity of the aircraft.

Figure 4 reflects the difference in philosophy between ADS-B and FLARM technologies:
ADS-B is a surveillance technology where aircraft broadcast their current position; FLARM
is a collision avoidance technology where aircraft estimate their future position. Reported
GPS altitudes (FLARM only reports GPS altitude, using the metric system) may not match,
as they do not represent the same estimation.

GPS altitude (in ft)

2,300

2,200

2,100

2,000

1,900

1,800

14:03 14:04 14:05 14:06 14:07 14:08 14:09 14:10 14:11 14:12

Source of information
ADS-B FLARM

Figure 4. Aircraft F-JVZB (identifier 394f3c) is equipped with both ADS-B and FLARM. Different
GPS altitude data are however emitted: ADS-B broadcasts the aircraft current position, while FLARM
estimates the position of the aircraft two seconds in the future for collision avoidance purposes.

Figure 5 shows that on a relatively short time period and despite the lack of an extended
network for FLARM data collection, traffic is very likely to operate at low altitudes (i.e.,
below 1200 feet AGL) over a large share of the covered area. The possibility of interference
with VLL UAS operations cannot be ignored. The resolution of traffic data visualization is
high enough (the grid creates 100 points per latitude and longitude degrees) to reveal local
traffic patterns and to allow for a precise analysis of possible encounters along the planned
UAS trajectory. The figure also confirms the complementarity of FLARM and ADS-B data:
both technologies cover different types of traffic and different regions. Moreover, aircraft
equipped with FLARM constitute a significant part of traffic at lower altitudes.
Figure 6 highlights the variation of traffic density with AGL altitude layers over the
same day of two consecutive weeks. As expected, coverage below 500 feet is limited to the
immediate surroundings of the receiver located at LFMY and only local traffic for take-off
and landing is visible, together with some glider activity over the hills between LFNE and
LFNZ. On the intermediate altitude layer (500 to 1200 feet), particularly relevant with regard
to UAS operations, patterns of VFR traffic are visible even far from the receiver. More IFR
traffic appears on the third layer. Discrepancies between the two days suggest that traffic
density should be considered over time, rather than through a maximal or mean value.
Eng. Proc. 2022, 28, 1 8 of 10

Figure 5. This minimal GPS altitude coverage map shows the importance of FLARM receivers
when detecting traffic at VLL, especially near General Aviation airfields. VLL traffic (ambulance,
firefighting) is also highlighted along the littoral, near downtown Marseille in the southeast.

Figure 6. Density maps on various days (or various hours of days) reflect different levels of activity,
even on the same day of the week (Wednesday). Activity above 1200 ft may look similar on both
days, but activity below 1200 ft looks denser on 29 June 2022.

In contrast with the SORA qualitative approach, data reveal that local variations of
traffic density at low altitudes have to be accounted for air risk assessment. A drone
inspection mission of the TGV fast train line, in double lines on the figure, is a very realistic
use case: between LFMA and LFMV, the area close to LFMY will be most critical, crossing
an area of possible low-altitude flights. Moving the surveillance volume along the line,
the number of aircraft which may be encountered can be calculated along the UAS flight
trajectory leading to the encounter and NMAC rates, as described in Section 2.

5. Conclusions
This paper describes a possible path for air risk assessment using traffic data at lower
altitudes. The feasibility of the approach is shown at a regional scale. Some gaps are also
identified before the approach can be further extended and formalized. In particular, the
number of receivers feeding the existing networks with FLARM data is still small and,
as a consequence, low-altitude traffic data are not available over large portions of the
Eng. Proc. 2022, 28, 1 9 of 10

European territory. Hopefully, the coverage will expand in the future in relationship with
the development of surveillance technologies and services associated to the U-space.

Author Contributions: Conceptualization, X.O. and P.L.B.; methodology, X.O. and P.L.B.; software,
X.O.; validation, X.O. and P.L.B.; formal analysis, X.O. and P.L.B.; investigation, X.O. and P.L.B.;
resources, X.O. and P.L.B.; data curation, X.O.; writing—original draft preparation, X.O. and P.L.B.;
writing—review and editing, X.O. and P.L.B.; visualization, X.O. All authors have read and agreed to
the published version of the manuscript.
Funding: This research was funded by the French Directorate General for Civil Aviation (DGAC) in
the context of the research partnership PHYDIAS for safety improvement of UAS.
Institutional Review Board Statement: Not applicable.
Informed Consent Statement: Not applicable.
Data Availability Statement: Data used to support this research and the visualizations are for the
most part available from the OpenSky Network historical database.
Acknowledgments: The authors would like to thank the aero clubs of LFNE for providing informa-
tion on their activity and the flight logs used to build Figure 3. Giorgio Tresoldi also provided great
assistance in processing and understanding collected FLARM data on the OpenSky Network database.
Conflicts of Interest: The authors declare no conflicts of interest.

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