UAV's are Coming!
Into civil airspace that is, and much sooner then most people expect. Regulators intend to be ready.
By Anne Paylor
Air Transport World, December 2006, p.51
SOMEDAY IN THE NOT-TOO-distant future, perhaps within the next 5-6 years, unmanned aerial vehicle systems will begin to share the airways with passenger aircraft. Although some have voiced concern about the pace at which this is occurring, a consensus is growing that nothing will stop the march of this new dimension of aviation.
Regulators in Europe and the US are hard at work trying to define the certification standards that will make it possible for airliners and UAVs to operate in common airspace with no impact on safety levels. As FAA Associate Administrator for Aviation Safety Nicholas Sabatini tells ATW: "We are open to accommodating this new aspect of aviation, but we will not compromise the safety of the National Airspace System."
Yet some within the air transport community remain skeptical. In testimony to the Senate Aviation Subcommittee, the Air Transport Assn. said it is "concerned about the aggressive pace of their [UAV] introduction into the NAS." It noted that "UAVs are rapidly being deployed in a variety of nonmilitary surveillance roles" and argued that the current practice of quarantining "large blocks of valuable airspace" for them is "clearly not a viable, long-term solution."
In response to pressure from national civil aviation authorities and industry, ICAO is in the embryonic stages of a process that eventually will lead to publication of guidance documentation that will serve as a global platform for development of appropriate standards and recommended practices for UAVs. Meanwhile, industry is toiling over the technological solutions that will provide the transparency and equivalence to manned aircraft that safety regulators insist are essential for making nonsegregated operations of the two feasible.
Significantly, the march of the UAVs is a phenomenon that regulators clearly see coming and considerable effort is being channeled by the more proactive among them to anticipate and prepare for their arrival. UAVsor UAS (unmanned aircraft systems) as FAA prefers to call themalready are used quite extensively in the US, primarily in military applications. This year alone, FAA has issued some 55 certificates of authorization for public-use UAVs and experimental airworthiness certificates for three civil UAVs. At no time, however, do UAVs and airline aircraft mix in the same airspace; in the event that the former do need to use "commercial" airspace, they are allocated protected corridors at times of the day when the impact on NAS capacity as a whole will be minimal.
Sabatini stresses that the technology needed to make it possible for UAV systems to operate freely in the NAS does not exist and is unlikely to become a reality until about 2011 at the earliest. And this, he believes, is an optimistic timetable.
This month, RTCA was due to present to FAA a roadmap document, "Guidance Material and Considerations for UAS," defining and validating a baseline "to move the community toward a common perspective and understanding." The roadmap also will define follow-on actions leading to development of Minimum Aviation System Performance Standards for UAS; Command, Control and Communication MASPS, and Detect, Sense, and Avoid MASPS. RTCA acknowledges that the three MASPS projects are "larger than expected and complex with both technical and operational implications." When it "became apparent the task was more significant than originally believed," the decision was taken to publish the guidance material as an intermediate measure.
Parallel Lines
While the terminology is slightly different, efforts in Europe are tracking along much the same lines with particular focus on five roughly equivalent issues: Airspace, sense and avoid, airworthiness, spectrum and operator qualifications. Eurocontrol, EASA, JAA and the European Organization for Civil Aviation Equipment all are working on various aspects of UAV certification, contributing to ICAO efforts and coordinating with FAA to ensure there is a seamless global solution.
Although Europe and the US are leading the way in terms of size, variety and sophistication of UAV systems, Eurocontrol estimates that by 2004 at least 32 countries worldwide were developing UAVs for civil and military applications and 41 were known to be operating them. There were then an estimated 200-300 UAV models in existence.
Eurocontrol is eager to get some harmonized certification standards and regulations implemented across the continent because a number of states are believed to be accommodating UAVs outside segregated airspace using rules drawn up on a national basis. Applications include meteorological research, aerial photography, motion picture filming and offshore geophysical surveys.
"We are seeing national regulators responding to that requirement on a limited and specifically domestic basis," says Holger Matthiesen, senior specialist-ATM Procedures with Eurocontrol's Airspace, Network Planning and Navigation Division. In order to preempt a profusion of national rules, the agency has drafted ATM specifications for use of military UAVs as operational air traffic outside segregated airspace suitable for incorporation by member states into their own national regulations. Following a recent Notice of Proposed Rulemaking consultation exercise, it is preparing a response document, with actual specifications due to be presented to the Eurocontrol Provisional Council in 2007.
Matthiesen echoes a common theme among regulators, namely that UAVs "are definitely here to stay, they will not go away, and numbers will continue to grow." He calls them "legitimate airspace users" and insists Eurocontrol is not in the business of creating "roadblocks for important new developments such as UAVs." The agency will, he stresses, "ensure that ATM can accommodate all legitimate airspace users."
UK CAA preparations for UAV use are relatively well advanced and in 2002 it published a guidance document, CAP 722, on "UAV Operations in UK Airspace." Revised in 2004, it covers a wide range of issues including legal considerations, certification, maintenance and inspection, spectrum, security, operator qualifications, cross-border operations, ATM procedures and emergency and accident/incident | procedures.
CAA is one of a small group of experts helping to define ICAO's role in drawing up guidance material and ultimately SARPs for commercial UAV operations. The group includes the German Ministry of Transport, ENAC of Italy, Eurocontrol, FAA, RTCA, Transport Canada and UVS International, a not-for-profit organization based in Paris dedicated to promotion of unmanned vehicle systems. The participating air navigation service providers all have taken a proactive stance on UAV systems at a national level.
The informal ICAO working group had its first exploratory meeting last May and concluded that although there eventually will be a wide range of technical and performance specifications and standards, only a portion of them need to be included in ICAO SARPs and ICAO therefore is not the most suitable body to lead the regulatory effort.
The meeting agreed that ICAO should coordinate development of a strategic document to "guide the regulatory evolution that, even though nonbinding, would be used as the basis for development of regulations by the various organizations and States." This "umbrella" document would identify the main issues to be addressed from a regulatory perspective and serve as a concept for regulatory evolution, making use of the extensive work already undertaken by states and regulatory bodies. The document would serve both as a basis for achieving consensus and as the foundation for later development of SARPs.
Peter van Blyenburgh, president of UVS International, tells ATW: "We do not want to push for an official working group until we have defined a solid basis for what it should do. Only at that point would we expect ICAO to appoint a fulltime UAV representative." There is general consensus that two issues could yet derail endeavors to enable UAV systems to operate in nonsegregated airspace.
The first is the ability to develop sense-and-avoid technology to make them indistinguishable from manned aircraft both to other airspace users and to controllers. All regulators agree that in terms of technology, there is still a lot of work to be done before any of the potential S&A systems currently under development will be ready for certification. Candidate technologies include electro-optical, infrared, microwave radar and laser radar. Most also agree that ultimately the technology will work.
"So far, we haven't actually defined what sense-and-avoid will be," says Van Blyenburgh. "We cannot produce a sense-and-avoid system if we don't have the operational requirements against which to build it. RTCA and EUROCAE are working on S&A operational standards that will satisfy both FAA and Eurocontrol."
Geoff Bowker of UK CAA's Directorate of Airspace Policy, the point of contact within the agency for all UAV matters, agrees. "We need to finalize the separation and avoidance parameters that will be required of sense-and-avoid. The technology is already there, and once we can agree on those parameters it will happen."
The second key issue, which Bowker describes as a potential "show-stopper," is spectrum allocation. "We will clearly need data link for command and control of UAVs, and because it will be safety critical, it will need to be protected. But at the moment there is no dedicated spectrum," he says. And with ever-increasing demand for this finite commodity from a growing number of global users, he stresses it is essential for the aviation industry to get its bid in for the necessary protected spectrum as early as possible. "We have been trying to get industry to fight for spectrum, but I suspect we are too late for WRC 2007, which means our bid will not be heard until the next spectrum allocation conference in 2010-11."
Van Blyenburgh agrees. "I don't think the industry is ready for WRC 2007. Not enough preparatory work has been done focusing on UAV systems. We have missed a real window of opportunity, but at least we should use WRC 2007 to make sure that UAV spectrum is on the agenda as a big feature at the subsequent WRC."
A key difficulty, however, is anticipating the precise voice and data requirements for UAVs because this is still a new, fast-growing and changing industry. Potential applications for civil systems are emerging all the time, and once they are able to operate in nonsegregated airspace, most industry observers believe the floodgates will open.
Next Big Thing
"We are close to something very big starting," says van Blyenburgh. UVS International has done some initial research to define potential operational scenarios and so far has come up with 55 different nonmilitary applications, but it believes this is just scratching the surface. Some industry commentators think UAVs ultimately will be used in a host of commercial applications, with airlines possibly adopting them for cargo services although the cost benefits are far from clear yet. Other schools of thought believe that in time even passengers will fly in pilotless vehicles, although Sabatini points out this is probably a leap of faith in technology achievable only by future generations in maybe 30-40 years. The present IATA position largely echoes that of the regulators who insist that in order to integrate with other airspace users, UAVs must demonstrate an equivalent level of compliance with the rules and procedures that apply to manned aircraft. They also will have to be fully transparent to other airspace users and ATC in the way they are treated and behave. That means they must be able to comply with ATC instructions and equipment requirements applicable to the class of airspace within which they intend to operate.
"We need to know about the mission, characteristics, requirements and performance of the many, many different models of UAS. For safety's sake, we need UAS operations to be transparent and seamless," Sabatini says. "But first and foremost, we must ensure that UAS operating in civil airspace will have no adverse impact to the thousands of aircraft already operating in the NAS."
Airline pilots believe this equivalence and transparency should apply across the board. The International Federation of Air Line Pilots Assns. believes UAV systems should be "regarded in every way as an aircraft," complying with "all existing certification, licensing and operations rules and regulations that would be applicable to the same class of manned aircraft." This should cover UAV pilot/operator qualifications and operating time restrictions as well as emergency procedures, ATM procedures adherence and so on.
In the US, FAA currently requires any ground-based operator of a UAV to have at least a private pilot's license with an instrument rating. UK CAA says it doesn't want to be prescriptive on personnel licensing at this stage but suggests that a human operating a UAV in the airways probably will need to be trained and qualified to the equivalent level of an airline pilot. At the other end of the scale, if a UAV is operating only in class G airspace, the operator probably only would be required to hold a PPL.
IFALPA insists that "Any UAV or operating system which cannot comply with these rules should be restricted to segregated airspace. Furthermore, the Federation argues that it is not acceptable to alter existing rules and regulations in order to facilitate the integration of these aircraft, although it does acknowledge that some of these rules may be irrelevant to UAVs." But ultimately, "IFALPA does not believe that UAV technology is capable of replacing human capabilities, especially in complex and safety critical situations."