Small UAS (< 150 kg) regulations in various countries

Correspondence concerning the activities of this Special Interest Group will be posted here, with the most recent correspondence first. The name of the contributor and the date of the contribution is in the header.

Consistent with the EUROCAE WG 73 ToRs, EUROCONTROL will develop ATM issues (rules, procedures, airspace requirements) for both small and large UAS in coordination with its Member States and stakeholders. In that respect I would suggest that information collated in your work be submitted to EUROCAE, (EASA) and EUROCONTROL. ICAO coordination would follow. As a function of the EUROCAE MASPS/MOPS for small UAS, the ATM requirements will be developed for harmonious application across Europe and hopefully globally.

EUROCONTROL will develop its work programme on UAS this autumn which will also include ATM guidelines for small UAS (not necessarily certified).

My suggestion would be to therefore submit the work of this special interest group to WG 73 from which point in time WG 73 could continue the development of small UAS guidelines and standards. In that way we ensure consistency with: EUROCONTROL, EASA, FAA, ICAO and importantly the EUROCONTROL safety regulation commission. (the 150 kg split is strictly an EASA split which should be, in my view, transparent to operations).

On this understanding I would be happy be an advisor. My immediate view is that this work should include regulators and standards organisations on UAS so I didn’t see the immediate link to EDA. Certainly Dan Hawkes and as Chairman WG 73 and Doug Davis should be able to provide valuable advice. I will be seeing EASA shortly (Yves Moirier) and will bring up this work to enquire his views. I will let you know on that outcome.

Following discussions with key partners, I am pleased to inform you that a Small UAS Focus Group has been formed within WG-73. This group will operate under the EUROCAE mandate and its members will be invited from the volunteers who, at the UAV2007 conference, supported the concept of a Small UAS Special Interest Group. Joe Barnard has accepted to lead this group and will join the WG-73 Leadership team.

A first draft Work package is attached for your consideration. Any comments should be sent to Joe for consideration and revision of the Work Package. Other affected papers have been updated and copies are attached.

This integration into WG-73 of the interested parties offers the best route to publication of guidance material and recommendations for small UAS that can be endorsed by EUROCAE leading to their recognition by the international aviation community.

I propose to invite registration of the people named in the Work Package later next week and I would welcome your agreement to this action.

Thanks for your interest in this issue and for your comments. Both are much appreciated.

It is very pleasing to hear your endorsement of an official route for recommendations in respect of small UAS's.

The coordination between EUROCONTROL and the FAA is another very welcome development on the road to realizing a global set of rules for small UAS's.

Colleagues:

In the context of the EUROCONTROL UAS activities, I would like to offer that EUROCONTROL undertake the assessment of the ATM integration issues (including safety) of UAS <150 kg, as a function of the operational deployment concepts which your work will define. The means by which such ATM issues would be addressed would be considered by State airspace authorities through the EUROCONTROL working arrangements as a means of achieving consensus and buy-in.

Furthermore, you may be aware that EUROCONTROL is in a position to coordinate with the FAA, in the frame of the EUROCONTROL-FAA MoC, on these issues.

Ultimately, I feel that it should be our intention, given the civil/commercial market for small UAS, to generate a global guidance document on certification and operations of small UAS. Such guidance could be promulgated, for example, under cover of an ICAO circular which could be developed by the (about to be established) ICAO Study Group, where EUROCONTROL also expects to be active.

Hopefully this work on small UAS can be integrated into the EUROCAE WG 73 activities as a means of mitigating against risks of fragmenting the UAS certification frameworks.

With best regards

H. Matthiesen

EUROCONTROL UAS

At the 4th meeting of EUROCAE working group 73 in Brussels in May, the subject of guidance material for UAS <150 kg was raised. It was recognised that the initial focus of the working group had been directed to the larger UAS taking account of the EASA rule-making activity. Subsequently, at the WG-73 leader's meeting and taking account of the groups’ terms of reference which do not specify a 150 kg boundary, the need for a work package for small UAS was identified. Cliff Whittaker of the UK CAA and a member of WG-73, accepted provisionally to coordinate this activity.

A workshop at the UAV2007 conference in June, identified a group of volunteers, referred to as an international special interest group, who wished to pursue the subject but without an official mandate. Joe Barnard, a member of WG-73, is currently coordinating this activity. The attached e-mail gives details.

Taking account of these activities, it would seem logical that the work of the informal group should either be integrated with the activities of WG 73, or its output routed through WG-73 and the EUROCAE consultative process leading to publication of a EUROCAE report for small UAS. A schedule in which a draft outline report could be offered to the WG-73 meeting in October 2007 followed by a final report in February 2008 would seem achievable.

Your views as to which is the best way forward will be welcomed. In the meantime a work package for small UAS will be defined by WG-73.

As we discussed, below is a précis of the aims of the 2007 UVSI Conference, ‘Workshop on Small UAS’:

It was generally agreed that Small UAS (<150kgs) would become a significant sector of the future UAS industry, yet the designers, builders and operators of Small UAS are likely not to be the larger aerospace companies. Therefore these smaller entities are unlikely to be able to benefit from the background experience, respect, economies of scale etc. that the larger organisations have and enjoy. Therefore for the Small UAS sector to thrive in Europe, which is clearly what we want, it is crucial that there is widespread cooperation within Europe, involving regulators, industry and stakeholders, to develop a coordinated way forward with certification of Small UAS for the benefit of all.

The Eurocontrol Experimental Centre will be hosting a follow on workshop in Dec 07 (venue and date TBC), to consider certification for Small UAS. It was hoped that at the Paris conference a small group would be formed to develop thinking/guidance document etc. to take to the Eurocontrol Workshop such that the work can be taken forward by/with Eurocontrol backing. It will obviously be necessary for the group to involve regulators, industry and stakeholders, but be of a (small) size that will allow all issues to be represented efficiently, and not so big that it becomes political and unwieldy. Whilst EUROCAE will be encouraged to pick this work up eventually, there is a real danger that such work could become lost hence it is considered too early to involve them at this stage. Likewise the focus should be on creating a way ahead for the certification of small civil UAS in Europe; therefore it is suggested that the UK military and non-Europeans (US DoD, ASTM, RTCA, and FAA etc.) should only be copied in on work at this stage. However it will clearly be crucially beneficial to include all parties eventually to achieve global harmonisation for the certification and operation of Small UAS.

My suggestion at the conf was that this new Small UAS Group takes an approach to Eurocontrol similar to that taken by States with ICAO. The latter started with ICAO sending out questionnaires to all representative states asking whether ICAO should be taking an interest in UAVs. The answer was yes, and in May 06 a group of states were invited to Montreal (I represented the UK) to develop a way ahead. It was agreed at that meeting that a Global Strategic Document should be created (attached) for the eventual consumption by the ICAO Air Navigation Council. At the second ICAO meeting (Jan 07) it was agreed that the document be accepted, UAV change to UAS, and that the UAV Working Group should become a more formal ICAO UAS Study Group. The recommendation and report were put to the ANC in Mar 07 who agreed to the Study Group status. The ICAO UAS Study Group will now act as the ICAO portal for UAS matters such that UAS development work can be fed in and then filtered down to the various ICAO Panels for them to absorb into their own work/plans. The support for UAS and speed of adoption by ICAO has been astonishing. Hence my suggestion that this new small UAS Group follow that method of working as I firmly believe that everyone involved with UAS should keep an eye on ICAO if we want to create global harmonisation from the outset. Therefore my proposal is that this new Small UAS Group collates a document similar to the attachment but obviously focussing on Small UAS. This way all the issues of who, what, where Small UAS are currently operated and under what rules/guidance/legislation, to quantify what is happening, what could be harmonised and what is missing. I further suggest that a lot of this information was captured in the original ICAO questionnaire and answers? (which Peter may have or is available from ICAO?). So much of the work may already be done. If such a document can be created by late summer there may then also be time for further refinement work to be able to take a consolidated, cohesive and coordinated piece of work to Eurocontrol, who would undoubtedly be very grateful!

Could I further suggest that when you have put the above into your (probably far better!) words that you agree them with Peter and then send it out to everyone who expressed an interest at the Paris Workshop. Maintaining interest and ensuring involvement from regulators, industry and stakeholders will not be easy and maybe Peter can help here with other individuals who may not have been at the conference. Please keep me on your distribution list as I will have an interest in how things develop, and I will help out where I can. As I explained my time is not for me to give away but there are evenings! Also I maybe able to help out with other contacts in UK, particularly in the CAA and some industry.

I am contactable at this email address and at the telephone numbers below. The sasco e-address in the Cc: box above is my work one which I may not be on for much longer!

I wish you the best of luck with this, and please do not hesitate to get in touch if the above requires clarification.

Hi All:

It was good to meet everyone in the Small UAS Group at the recent UAV 2007 Conference.

I have attached scanned copies of all the business cards I collected.

A few introductory words.

This is in essence an International Special Interest Group. Let’s be quite clear: this is not an official group, and we have no government authority or legislative powers of any description.

The aim of this activity is to collect, to distil and to then generate a harmonised set of documentation for small Unmanned Aircraft Systems (0 to 150 kg) covering:

q air worthiness aspects

q operations aspects

q command, control and security aspects

including a view on the application of sense and avoid.

The documentation supplied and developed will be made openly available to the general public, and to official bodies tasked with the development of policy as regards small Unmanned Aircraft Systems. So do not submit any confidential information.

Time wise, the plan as I understand it from Peter van Blyenburgh is to have a draft of the documentation ready for this December.

So, step 1: can you email me any documentation you might have on any of the aspects mentioned above (air worthiness, operations, CCS) as relates to small Unmanned Aircraft Systems in your country, please.

I asked Geoff Bowker, the Chairman at the Small UAS Workshop at the recent UAV 2007 Conference, to email me a copy of his suggestions, as he discussed them during the “round table” session. I will circulate those comments as soon as I receive them.

Best Regards,

Joe.