Concept of Operations

ID: I01
Status: PUBLISHED Aug 7, 2021
Version: 1

Authors

  • Amit Garg (corresponding)
  • Sayandeep Purkayasth
  • Hrishikesh Ballal
  • Siddharth Shetty
  • Manish Shukla
  • Siddharth Ravikumar
  • George Thomas

Outline

Background

Civil aviation has, traditionally, been based on the notion of a pilot operating the aircraft from within the aircraft itself and more often than not with passengers on board. Rapid technological innovations have enabled pilotless aircraft which can be designed for specific applications that require precision or long duration which have been considered near impossible hitherto. These aircraft also enable applications considered dull, dirty or dangerous, in other words, tasks that entail monotony or hazard for the pilot of a manned aircraft. Such pilotless aircraft make use of a ground based or pre-programmed automatic controllers to manoeuvre the aircraft in flight and are generically termed as drones, although a better term is Unmanned Aerial Systems (UAS).

Traditionally, drones had been limited to military use due to high costs and technical sophistication. However, there is a far broader scope for UAS use, including, inter alia, commercial, scientific and security applications. These potential applications have driven innovations in UAS technology; especially in areas of control, navigation and energy storage; which have provided consumers with suitably small-sized cutting-edge products that are easy to operate and maintain at affordable prices. Today, due to economies of scale, consumers can purchase drones for less than a thousand rupees. Even sophisticated drones with advanced cameras and sensors are available for under fifty thousand rupees. On the other end of the spectrum, large aircraft manufacturers such as Boeing and Airbus, are spending billions of dollars developing pilotless aircraft considered safe enough for long-range intercontinental flights by passengers.

Applications

Unmanned Aircraft Systems thus offer immense opportunities for economic growth and employment generation across a very wide range of applications based on their size and design. Whilst the large drones are currently being used exclusively for governmental purposes, significant economic activity using small civil UAS has already attained acceptance in many countries.

The main civil applications of drones which are already well established are as follows:

Aerial photography & video

With a drone that is equipped with an HD camera, one can take fascinating photos and shoot footage of great quality from the sky. Often the live video is used to provide coverage to important events, especially sports and entertainment events and/ or for tourism promotion.

Surveying & Mapping (GIS)

Using multi-spectral cameras and laser scanners, drones are able to create high-quality 3-D maps. Therefore, they have found applications in various areas, including remote sensing, surveying & mapping, photogrammetry, precision agriculture, and more.

Inspections

Many systems such as power lines, railway lines, wind turbines, and pipelines can be checked by drones. This can avoid the hassle and safety issues involved with sending a human to check things out. Inspection of ships and larger aircraft, where human access is time consuming or impossible, is also being undertaken by drones.

Surveillance

A drone allows recording and monitoring from the sky, and therefore, they are suitable for monitoring sensitive infrastructure/ areas, large factories, public events, or any activities of concern to law-enforcement with fewer personnel on the ground. A great tool for the police to monitor a large area with a flying camera from overhead!

Agricultural services

Drones are very useful for enhancing agricultural productivity through applications like crop dusting, pest control, seeding, survey, etc. Drones can be programmed to provide accurate amounts of pesticide or fertiliser significantly improving not only the crop yield but also the quality of produce.

Unmanned cargo system

Drones also serve in delivery of lightweight packages and bundles of all sorts. This method enables safe, environmentally friendly and fast transport of goods by air.

Search and rescue

Drones are very useful in searching and rescuing operations. For example, they are used in firefighting to determine the amount of the certain gasses in air (CO, CO2, and the like) using the special measuring equipment. Drones can often safely enter a space that humans cannot.

Security

Many authorities use drones to protect people. For instance, they are able to help coordinate a variety of security operations and can preserve evidence alike. They are also used for specific security applications such as coast line inspection, preventive border surveillance, drug control, anti-terrorism operations, avalanche prediction and control, hurricane monitoring, forest fires prevention surveillance, etc.

Science & research

Unmanned aerial vehicles help scientists a lot in research work to observe different occurrences in nature or a particular environment from the sky. For example, drones are used to document archaeological excavations or in glacier surveillance and more. They are also a very useful tool in STEM activities in education.

Drone displays

Drone swarms are finding increasing use for aerial displays at important events.

Disaster Relief and Disease Control

Drones are especially useful in undertaking surveys of disaster zones and planning and monitoring relief operations in various emergency situations. Similarly, spraying for control of larvae/ mosquitoes or similar disease control agents can also be effectively undertaken for disease control especially in public health crises such as during the COVID 19 pandemic. .

The key common element in all these established applications is that they are most effectively undertaken using rotary wing drones. Further, the bulk of these applications do not need very large sized drones, although certain applications such as logistics and agricultural or medicinal sprays could benefit from larger drones based on the area to be covered.

Guiding Principles for Regulation of the Operating Environment

Efficiency

The economic implications of commercial drone use are undeniable. The FICCI Committee on Drones has said that India's Drone & Counter-Drone market potential up to 2030 is cumulatively estimated to be around INR 300,000 crore (approx. US$ 40 billion) with Defence and Homeland Security accounting for ~50 per cent of it. The major initial applications are expected to be in agriculture and survey sectors, besides security. Due to the ability to cover large areas, drone use in precision agriculture is anticipated to effectively feed and hydrate plants while also limiting exposure to diseases or indiscriminate use of pesticides. Similarly, use of drones for surveys is expected to yield significant benefits in infrastructure project design and management.

On a macroeconomic scale, the integration of UAVs could create a large number of jobs. Job creation from commercial drone use will consist primarily of manufacturing jobs, drone operators and support services such as maintenance and logistics. Likewise, the government will benefit from tax windfalls, stemming from increased economic activity.

However, all stakeholders viz the drone industry, manned aviation, regulators and law enforcement, etc. need to evolve and embrace necessary fundamental changes for this sunrise sector of the economy to play out its potential. Specifically, the regulatory regime needs to be designed with drones in mind and not lean too heavily on traditional manned aviation. Further, regulations need to be simple with minimal compliance costs in order to provide a fillip to the industry and attract investments.

Simpler compliance also provides benefits in terms of encouraging legitimate use rather than operators resorting to illegal imports which will, in turn, prove a challenge to compliance. Additionally, since the industry is evolving very rapidly technologically, it is more likely than not to be a matter of time before more implementable compliance standards are developed.

Efficiency in regulations will enable development of market capacity to encourage fresh investments and further innovations. It will also enable reduced gestation period for SMEs and even individual service providers such as videographers who are possibly at the bottom of the industry’s economic pyramid.

Safety

India is a signatory of the Convention on International Civil Aviation (also known as Chicago Convention) and is therefore required to undertake steps for implementation of the provisions of this Convention.

Article 8 of the Chicago Convention entitled “Pilotless aircraft” provides that:

No aircraft capable of being flown without a pilot shall be flown without a pilot over the territory of a contracting State without special authorization by that State and in accordance with the terms of such authorization. Each contracting State undertakes to insure that the flight of such aircraft without a pilot in regions open to civil aircraft shall be so controlled as to obviate danger to civil aircraft.

The Convention mandates that an aircraft shall be operated in such a manner as to minimize hazards to persons, property or other aircraft. These hazards relate to all aircraft operations irrespective of the type of aircraft or purpose of the operation. Thus, there is a need to regulate drone operations in a manner such that risk to safety or security of people and assets is contained.

In order for UAS to be widely accepted, they will have to be integrated into the existing aviation system without negatively affecting manned aviation (e.g. safety or capacity reduction). It is, therefore, essential to ensure that the UAS intended to operate into non-segregated airspace, meet the safety and operational standards applicable to manned aircraft.

If this cannot be achieved (e.g. due to intrinsic limitations of UAS design), the UAS needs to be accommodated by being restricted to specific conditions or areas (e.g. visual line-of-sight (VLOS), segregated airspace (i.e. airspace outside the operational ambit of manned aircraft) or away from heavily populated areas).

In the unforgiving world of aviation safety, the opportunity for low-cost and rapid innovation afforded by drones can lead to prohibitive costs in the form of damage to manned aircraft and loss of lives. Therefore, safety demands that a phased approach be adopted in enabling large scale drone operations, even at the cost of artificially slowing down the growth of the drone industry. Infact, the current state of India’s drone industry can arguably be attributed to an over cautious approach. Justifiably, the past approach needs to be shed but safety demands dictate a measured and nuanced approach in order to take into account the many lessons learnt during the growth of manned aviation.

Drones should be integrated into the existing aviation system in a safe and risk-proportionate manner and this integration should foster an innovative and competitive drone industry, creating jobs and growth, in particular for MSMEs. The proposed regulatory framework should set a level of safety and of environmental pro- tection 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.

Security

Another significant challenge for regulating drone use is the security conundrum arising from illegitimate use of drones. Whilst rogue operatives will always pose a challenge to every technological advancement, given the long history of sub-conventional warfare in the form of terrorism from particulary hostile neighbours, India has to factor this challenge more critically.

Ideally, legitimate use of any technology should not be restricted especially if it has significant economic benefits as in the case of the drone industry. However, in India’s context, a secondary impact of drone proliferation would be the potential saturation of our security establishment in differentiating between the ‘good’ and the ‘bad’ actors. Till such time that suitable technological solutions are not put in place to safeguard vital national infrastructure, more rudimentary controls in the form of limiting legitimate use of drones to categories that are easily identified and incapable of significant harm may need to be adopted.

Protection of other public interests such as personal privacy and security entailed by drone operations will also need to be addressed. The regulatory framework would eventually inescapably need to envisage provisions to reduce those risks.

Infrastructure Issues

The ATM/ ANS aspect of the concept of operation will need to be further developed. Several concerted efforts are underway globally to address these issues. However, unless radically new concepts emerge, there appears to be convergence on several key aspects : each UAS transmitting a unique remote ID with a geo tracking feature; and having a separate Unmanned Traffic Management System for Very Low Level segregated airspace accommodating exclusive drone traffic.

UAS in non-segregated controlled airspace adhering to manned aircraft standards and being under active control of remote pilots able to comply with ATS instructions. Currently, there is negligible development of UTM concepts or infrastructure in India. The further development of drones and their integration in non-segregated airspace will pose new challenges and a significant amount of further research and infrastructure would be needed. Also the development of the drone market and the development of the technologies need to be carefully monitored and the planning adapted. Finally the harmonization of regulations and availability of telecom spectrum is fundamental to the success of drones.

Suggested Concept of Operations

Given the significant economic benefits it is imperative that notwithstanding the challenges arising from safety and security concerns, India’s drone industry is allowed to ‘take-off’. However, any attempt to rush headlong into permitting complicated drone operations especially in non-segregated airspace may lead to catastrophes which may actually force a policy regression thus harming the fledgling domestic drone industry.

It would, therefore, be prudent to have an incremental approach in drone regulations rather than proposing comprehensive regulations for the complete range of drone operations right from the start. This incremental approach is based on an identification of the needs and associated risks of each category of operation based on the guiding principles identified earlier. The categories can subsequently be the basis for defining the ‘rules of business’ or operational boundaries which enable safe and efficient operations for the applications of drones, both current and potential.

The suggested categories based on this technique are as follows:-

Category A (Least Risk)

The first category comprises drone operations that pose the least risk and require the least infrastructure. A typical example of these least risk operations is the use of small drones for photography or videography. The operational boundaries could be defined as follows:-

  • Operations in Visual Line of Sight (VLOS) only
  • Operations at a safe distance away from people, animals, infrastructure and aerodromes
  • Operations in segregated airspace only till a specified maximum height above ground level (AGL)
  • The drone capability is limited by design within specific performance limitations such as mass, speed, ceiling, rate of climb, rate of descent etc

Category B (Minimal Risk)

This category comprises drone operations that would be unlikely to result in a fatality or cause serious injury to persons or infrastructure on the ground. An example of such operations could be use of small drones for survey or agricultural purposes. These operations would be subject to limited regulatory restrictions that would be required to protect other airspace users and life on ground. Such operations would require supporting UTM infrastructure but can be undertaken without the service in a more restricted way. The operational boundaries could be defined as follows:-

  • Operations by a qualified remote pilot only
  • Operations in Visual Line of Sight (VLOS) or extended VLOS only. Extended VLOS is attained by means of additional observers in touch with the controller or observation systems providing adequate situational awareness
  • Operations at a safe distance away from people, animals, buildings and aerodromes. However, safety margins need to be increased and/ or operations need to be away from dense population areas
  • Operations in segregated airspace only till a specified maximum height above ground level (AGL) which could be more than the least risk category
  • Operations not involving carriage of dangerous goods or articles
  • Operations using drones that have mandatory identification features
  • The drone capability is more than the Category A but is still limited by design within specific performance limitations such as mass, speed, ceiling, rate of climb, rate of descent etc
  • Operations only in fair weather conditions and away from security sensitive areas till establishing of adequate UTM infrastructure.

Category C (Intermediate Risk)

These are operations associated with a higher risk such as operations utilizing a larger and/or heavier aircraft with more payload capacity and with the potential to cause fatality or injury to persons on the ground or other airspace users. However, in order to limit safety challenges for manned aircraft, operations continue to be in segregated airspace. An example of such operations would be BVLOS operations in segregated airspace with limits on all up weight of the drone. Authorisation of such operations will require a risk assessment that will lead to an Operations Authorisation with specific limitations adapted to the operation. Operations in this category would require more stringent regulatory requirements with a focus on operational limitations such as payload, pilot qualifications, the establishment of airspace restrictions, altitudes, airspeed, proximity to aerodromes and congested/populated areas. The operational limitations would need to include:-

  • Operations by a trained remote pilot only
  • Operations at a safe distance away from people, animals, buildings and aerodromes. However, safety margins need to be increased and/ or operations need to be away from dense population areas based on the specific risk assessment
  • Operations in segregated airspace only till a specified maximum height above ground level (AGL)
  • Operations using drones that have mandatory safety, identification and tracking features conforming to specified standards
  • The drone capability is significant but is still limited by design within specific performance limitations such as mass, speed, ceiling, rate of climb, rate of descent etc
  • Operations only subject to availability of adequate UTM infrastructure

Category D (Regulated Increased Risk)

These would include the more advanced applications of drones with negligible restrictions on size, the area or complexity of operation or use of airspace. This category of operations would include, with appropriate mitigations, BVLOS operations within controlled airspace. Such operations would need to conform to well researched/ established design characteristics that would assure the desired level of safety. These operations would require significant risk mitigation measures, for example:

  • Operators to have an adequate management structure to ensure safe operations
  • Licensed remote pilots who are issued licences after successfully completing practical training requirements, pass knowledge tests, meet specific medical standards and age requirements
  • UAS will need to be maintained in a safe state for flight and be subject to design standards or other airworthiness certifications
  • The aircraft may need to be marked and registered and be able to tracked continually
  • Operational rules applicable to this category of operations could be extensive

All successful global regulations have followed an incremental risk-based approach to drone regulations. In fact, ICAO had adopted the European concept of graded regulations nearly three years back and even published a toolkit to help nations develop incremental regulations. The ICAO approach also mandates that UAS intended to operate into airspace meant for manned aircraft should also meet the safety and operational standards applicable to manned aircraft.

Suggested Implementation

Implementation Schedule

The suggested implementation approach for India, based on an incremental risk-based technique, should fall broadly under the following steps: -

Short Term: Define rules for permitting operations in Category A and restricted Category B categories. The restrictions in the Category B would be transient till the establishing of the UTM policy and infrastructure for which actions would need to be initiated immediately. This operation category of drones should, therefore, not require any specific authorisation by the government for the flight but stay within defined boundaries for the operation. This phase is expected to last for one year from the acceptance of this policy.

Medium Term: Remove restrictions on Category B as also permit the Category C operations in segregated airspace. Alongside, actively pursue steps for laying down standards for the design of advanced drones and integration of the UTM infrastructure with established ATM procedures. Hold public consultations and publish policy documents for enabling the long term integration of drones into the complete airspace. This phase is expected to last between one and three year.

Long Term: Establish the infrastructure and standards for enabling the full range of drone operations including air taxi, large scale cargo and passenger services. This phase would be after the Category C operations have stabilised and requisite infrastructure has come up.

In order to achieve the earliest operationalisation of drone operations, albeit limited, it is recommended that the short term measures at Para 14.1 above are adopted at the earliest. Permitting drone operations in the Category A and restricted Category B categories would provide adequate opportunity for the bulk of the current drone applications listed at Para 4 above albeit with some restrictions. Equally, this approach would provide the necessary opportunity for drone operations to kickstart without compromising more pressing requirements of safety or security. It will also provide opportunities for development of efficient regulations and necessary infrastructure for the more complex applications having a higher bearing on safety.

Implementation Approach

The recommended operational limits of the Category A for India are defined as follows:

  • Using a drone with a gross mass of 2 kg or less on takeoff and throughout the duration of each operation under this category, including all items that are on board or otherwise attached to the aircraft; and
  • the drone is designed to minimise the chances of injury to any human being in case of accidental collision; and
  • the drone is operated always within the visual line-of-sight of the person operating the drone; and
  • the drone is operated at or below 60 m (200 ft) above ground level (AGL) by day only; and
  • the drone is operated at a safe distance from a person or animal not directly associated with the operation of the UA; and
  • the drone is not operated in a prohibited or restricted area; and
  • the drone is not operated in an airspace notified for use by manned aircraft without prior approval of the controlling authority for such airspace; and
  • the drone is used only for hobby flying or photography/ videography.

The operational limits of the restricted Category B are defined as follows:

  • Using a drone with a gross mass of 25 kg or less on takeoff and throughout the duration of each operation under this category, including all items that are on board or otherwise attached to the aircraft; and
  • the drone uses primarily vertical axis rotors to generate its propulsion; and
  • the drone is designed to minimise the chances of injury to any human being in case of accidental collision; and
  • the drone is operated by a remote pilot authorised for the operation; and
  • the drone is operated always within the visual line-of-sight or enhanced visual line-of-sight of the remote pilot operating the drone; and
  • the drone is operated at or below 120 m (400 ft) above ground level (AGL) by day only; and
  • the drone is operated in suitable weather conditions that do not pose a hazard to the drone operation; and
  • the drone is not operated at a safe distance away from people, animals, buildings and aerodromes; and
  • the drone is not involved in the carriage of any dangerous goods; and
  • the drone is not involved in the carriage of any parcel or jettisonable load in excess of 5 kgs.
  • the drone is not operated in a prohibited or restricted area; and
  • the drone is not operated in an airspace notified for use by manned aircraft without prior approval of the controlling authority for such airspace; and
  • the remote pilot is able to access web-based updates on any flying restrictions that may have been imposed over the intended area of operations before commencing the flight; and
  • the drone is not operated within 25 kms of India’s international borders or 5 kms of India’s coastline without the prior sanction of the appropriate law enforcement authority.

Design and Manufacturing

The Directorate General of Civil Aviation or the Quality Council of India should additionally specify specific equipment and design standards for approval of the drones in the above two categories. The height and permanent geographical restrictions should also be mandated in these standards, that is to say, that the drones should be incapable of infringing these stipulated limits by design. Manufacturers of drones, domestic or foreign, should be required to prove that the drones conform to all the stipulated design and equipment standards. They should be given design approvals without which they should not be allowed to market their drones. Further, manufacturers should be accountable in case of any manufacturing or design defects that lead to any infringement of the airspace boundary limits for each category. Manufacturers should also be required to imprint a unique ID on every drone to ensure traceability of the drone. Manufacturers and traders should also be required to maintain a record of every transaction of drones or components in order to ensure traceability given our security paradigm.

Remote Pilot Authorisation

Persons desirous of operating drones in Category B should be required to obtain authorisation after undergoing an online course essentially focussed at bringing in an awareness of regulations and a sense of public responsibility. The course should be certified by the DGCA or the QCI and should be followed by an online examination leading to generation of authorisation. The online examination should be conducted at authorised centres through professional organisations with the necessary infrastructure and expertise to bring in the desired level of quality in the process. Any individual desirous of obtaining practical training may do so under their own arrangements and there should be no requirement of remote pilots to undergo any other formal training at any approved organisation for these Category A or B operations.