Insertion of Unmanned in National Air Space – A Formidable Challenge
The Central issue is of course the fact that with the NAS becoming more and more congested with the manned aircraft traffic, there is a looming danger of a collision of the manned platform with the unmanned machine which may lead to catastrophic destruction. The current body of opinion is resident in these apprehensions:-
• Comprehensive and fool-proof rules and regulations have not yet being fully conceived and documented that can ensure safe and secure co-existence and co-habitation of the unmanned vehicles with the manned platforms
• Neither the unmanned machines nor their existing Ground Control Stations (GCS) have advanced to that level of automation, networking, search-and-avoid systems, information management for collision avoidance et al, where the existing Air Traffic Controls (ATCs) can integrate them seamlessly with the ongoing movement of the manned aerial vehicles
• A loose unmanned vehicle is perceived as a threat-in-being (spy, photo recce, terror related…) unless firmly in control
• Besides the ‘collision fear’ there are other issues related to UAVs in the hands of people not one’s own. ‘Privacy’ is one… something that is jealously guarded. People are up in arms against ‘Peeping Toms’ who try to snoop in their backyards with their innocuous little machines equipped with tiny cameras and GPS
• There are hundred other things that come in the way of unrestricted flights of UAVs. People/ governments detest the thought of unmanned machines doing unauthorized photography of one’s private spaces/properties or restricted/classified areas, drones violating voyeurism laws, unkindly intrusion in the Paparazzi by shutterbugs and more.
Besides the hurdles and reservations, there are many other requirements that need to be met before an unmanned machine can be inserted in the air space brimming with manned activity. Just a sample is presented below:-
• Airworthiness Certification of the UAV
• Registration of the machine and display of ATC approved numbers and Markings
• Pre-flight serviceability check report
• Flying restrictions/stipulations :-
• Permissible weight and size of UAV
• Maximum Speed/altitude limits.
• LOS requirements/visibility limit pre condition
• Restrictions/prohibition to fly near a certain designated area/installation (lat/long/altitude).
• Pilot/Operator training requirements and minimum threshold of technical knowledge of the operator
• Exemption to certain class of UAVs to fly up to or above safe altitudes.
The basic point is that it has not been possible the world over to put in place such an all-encompassing regime of regulations that addresses all the above and more though the nations around the world are moving towards it.
What the World is doing?
In Feb 2012 the US Govt enacted a resolution (Modernisation and Reform Act 2012) that tasked it’s National Aviation Authority (Federal Aviation Administration or FAA) to improve aviation safety and the capacity of the national airspace system, provide framework for integrating new technology safely into US airspace, provide a stable funding system and work out a road map of insertion of Unmanned Aircraft Systems (UAS) into the NAS to include Certification Requirements, Control and Communication Requirements for Search-and-Avoid capability and a regime of Air Traffic Interoperability Rules. The work had to be completed from fiscal 2012 through fiscal 2015 (Sep 2012-Sep 2015). Where is it? Some facts:-
• Well past the Sep 2015 deadline, it is still work in progress although several drafts have been prepared and presented
• While the final rules are awaited, interim unmanned aircraft rules (that go by the name of small UAS Notice of Proposed Rule Making or (NPRM) http://www.faa.gov/uas/nprm) have been put out for compliance. Comments from the public are invited on NPRM
• Detailed instructions have been put out effective from 21 Dec 15 for registration of UAVs by the operators (deadline 19 Feb 2016)
• Alongside this, the US Army has put out in open domain their road-map for UAS (development, organisation and employment) in three phases,Near term (2010-2015), Mid Term (2016-2025) and Far Term (2026-2035) (http://fas.org>irp>program>collect).
This brief preview was meant to drive home one point, i.e. even in the US, the complex issue of the insertion of the unmanned vehicles in the NAS is still a work at hand.
Open sources report that in many other countries in the world, efforts are at hand to put out some sort of regulations to permit/prohibit the flights of UAVs in the respective NAS.
• In Australia, the regulator, Civil aviation Safety authority (CASA) has put out a regulation that requires the UAVs to keep a distance of at least 30 m from structures, buildings and people
• In France, flights over nuclear power plants is illegal.
• In Indonesia, the Director General of Civil Aviation has laid out restrictions by the way of altitude and range. In that a UAV is not to fly over 150 m and if it is carrying any imaging equipment it must not fly closer than 500 m from the border. UAVs with agricultural payload (seed spreader/insecticide sprayer etc) should keep clear of the housing areas by at least 500m
• Countries like Ireland, and UK besides other restrictions have laid down weight criteria above and below which, registration requirements apply or are waived, respectively
• In South Africa flying restrictions are applied in flights closer to nuclear plants, prisons, police stations, crime scenes, courts of law and national key points.
SMEs Crystal Gaze Future Scenarios
Some Subject Matter Experts (SMEs) are painting ‘Future scenarios of integration and operation of the UAVs along with manned platforms. For this, it is assumed that the ATCs of tomorrow will be fully enabled with such Information Management Systems (IMS) which will permit seamless communication capabilities across the manned and unmanned platforms. Accordingly the future UAVs will be fully loaded with transponder systems and network communication capabilities to communicate with their respective GCSs as well as ATCs seamlessly. Once such communications and connectivity are achieved, any one or more of the following can unfold with relative ease and safety:-
• e -filing of 4D (three spatial dimensions plus time stamp) flight plan by the UAV operator to ATC and its future re-configuration in near real time.
• Achievement of Full Vehicle Autonomy over time, wherein, a ‘fully loaded and programmed UAV’ becomes nearly independent of its GCS and has a capability to interact seamlessly with ATC and other manned platforms. In this role, it behaves as if it were a manned platform.
• With the above capability achieved, following is likely to become possible:-
• Auto-Managing flights of UAVs on any of the multiple-possibility missions transiting through the manned airspace making use of time and/or height band separation and stationing/parking/hovering the unmanned machines into slots unfrequented by manned platforms.
• Taking single machines or groups through a highly congested air space and positioning them in the same airspace for station-keeping (Gorgon Stare/surveillance mission/photo-recce/investigation of reported suspicious activity, et al) through dynamic and minute-to-minute control of airspace ensuring optimal usage, for both the manned and the unmanned at the same time.
• Capability to dynamically re-configure the 4D flight plans of both the manned, as well as, the unmanned vehicles in order to deal with an emergent entry/exit of either platform from/to a specific location (crises management/accident sites/disaster relief etc).
What is the Emerging Position
From the foregoing, the following trends emerge:-
• Insertion of the unmanned platforms into the NAS is essentially a work-at-hand the world over
• With the ever-growing potential uses of the UAVs the compulsions and inevitability to implement the above insertion is a need whose time has come
• The issues involved in the said insertions are many, the safety of the manned platform being the kernel though there are other concerns on privacy intrusion, violation of voyeurism laws and more
•Essentially, there are two levels of insertion strategies, the current one and the futuristic one
•As regards the current strategy, appreciating the inevitability and the urgent need of unmanned insertion in the NAS coupled with what is the state of technology that the UAVs possess today, the countries around the world are laying down practical set of rules that specify one or more of the following:-
• Limiting Speed and altitude for the unmanned operation.
• Earmarking safe areas for the unmanned and deliberately keeping the manned vehicles clear of it.
• Ensuring safety of peoples and structures by laying down restrictions on the minimum distance, the unmanned need to maintain clear of them.
• Ensuring accountability by laying down regulation requirements for the registration of the machine (including exemptions) and for minimum threshold of training for the operator.
• Laying down legal regulations to protect people’s privacy and guard against voyeurism law violations or anti piracy norms etc. In essence, the legalese to guard against the ‘Peeping Toms’.
• For the future, the SMEs are conceiving scenarios in which the technology would have advanced to such a threshold (and counting) where the future ATCs dully equipped with the technologically enabled IMS, would be able to interact seamlessly and in real time, with the ‘equally evolved UAVs’ which will be either fully independent of the GCS or will have the networking capability for a full-spectrum patch up with the IMS, as well as, the GCS.
• Once the above is achieved, any permutation/combination of operations involving the manned with the unmanned will be feasible with the latter acting no different than the manned vehicle.
What is Indian Position?
Against the backdrop of the aforesaid, let us see the Indian position.
DGCA Regulation, the Indian civil aviation regulator (Director General Civil Aviation) has issued a Public notice on 07 Oct 14 (file No 05-13/2014-AED) on the Use of Unmanned Aerial Vehicle (UAV)/ Unmanned Aircraft Systems (UAS) for civil applications. The operational portion of the notice states the following:-
• DGCA is in the process of formulating the regulations (and globally harmonise those) for certification & operation for the use of OAS in the Indian Civil Airspace. Till such regulations are issued, no non government agency, organisation, or an individual will launch a UAS in Indian Airspace for any purpose whatsoever.
• To support the above, DGCA states that since the International Civil Aviation Organisation (ICAO) is yet to publish Standards and Recommended Practices (SARPs) as far as certification and operation of civil use of UAS is concerned and due to uncertainty of the technology, UAS poses threat for air collisions and accidents since the airspace over cities in India has high density of manned aircraft traffic.
• Use of UAS besides being a safety issue also poses security threat.
• Civil operation of UAS will require approval from Air Navigation service provider, defence, Ministry of Home Affairs and other concerned security agencies besides the DGCA.
Is it right to put such a blanket ban as stated above or is there any other way? Instead of a binary yes/no let us analyse further:-
• This is the personal experience of the author as an SME in the field of unmanned, as well as, supported by the open source data that the Indian unmanned industry has not seen the type of growth it could have seen. Except for Seminars and academic discussions on the need for an exponential growth in the multiple-use scenarios in the country, the real hard core business growth of UAVs and associated control systems/payloads etc, has largely remained stunted, grossly under utilising the tremendous wealth of talent and expertise available indigenously.
• There are many other issues that pain them, which go beyond the blanket DGCA ban. Some of these include lack of test ranges, lack of clarity on demand, a near total disconnect with the defence users as to what are the current and possible future areas (demand generation) the forces are looking at where the local MSME industry can chip in with Make-in -India initiatives. Experience has it that the seminar circuit where the industry has a first-hand representation, the decision makers are conspicuous by their absence.
• There have been several calls by the SMEs in the open media making a strong pitch to the government to open the Indian skies for drones. Some of the arguments put forward are:-
• A Report by the Association for Unmanned Vehicle System International (AUVSI) a non-profit trade organisation that works on “advancing the unmanned systems community and promoting unmanned systems” states that by 2025 the commercial drone industry would have created 100,000 jobs with an economic impact of $ 82 Billion in US alone.
• Countries around the world are contributing immensely to national economies from the drone export activity (Japan, China, South Korea to name a few).
• Whether it is to assist fishermen with finding shoals off the Indian coastline or conducting rapid anti-poaching patrols in protected areas across the country, mapping refugee settlements in Assam, assessing the quality of National Highways, lifting a marooned people from disaster hit areas, doing a hundred and one jobs in the agricultural domain, or simply to feed the ever un-satiated fashion and entertainment industry with many an un-experienced goodies (selfies being the least of it) drones are required in the Indian skies. A blanket ban is not in our best national interest.
• The Unmanned System Association of India (USAI www.usai.in) which came up in Sep 2012 is also engaged effectively in generating a collective voice and representative interface with the Indian government and Indian Airspace Regulators. Bringing together a community of UAV frame constructors, payload and system manufacturers, data capture processing services providers, UAS trainers and operators, it is trying to push the best interest of the unmanned community.
Can the DGCA Do it
Can the DGCA follow the existing best practices in the world? The one word answer is a plain yes, though it will require a considerable amount of pre-work and a possible policy change. Let us examine how:-
• Level 1 integration mentioned earlier is very much a possibility
• There is a possibility and an urgent need to move beyond 07 Oct 2014. Open sources suggest that the ICAO initial SARPs are expected only by 2018 with the overall process taking up to 2025. Waiting that long is not in our best interest, especially when options are available. In any case, the front-runners countries are not lying in wait, they are going ahead in whatever they can do to promote the unmanned industry in pursuance of their national interests
• For starters, an upfront a licensing regime in the form of QR for drones to be air-worthy can be put out (size, weight, wing span, speed and altitude capability, minimum electronics and communication package, GCS requirement, pilot/operator knowledge requirement and training threshold etc could be some of the factors built in).
• Given the level and state of automation available in the country today, it should be possible to build an on-line permission/approval seeking portal that covers multiple authorities viz, MHA, MoD, DGCA and others.
• With the data base captured as above, it should be possible to gradually open the Indian Civil Airspace to the unmanned, initially with full and positive control (flights only in designated volumes of space confined by a 4D defined air space that is kept clear of manned traffic) to be eased out slowly as the technology grows.
• There are also some other urgent requirements which need to be addressed:-
• Provide Test Ranges to the industry (either designate remote areas or have a sharing arrangement with the defence services).
• Build a connect between the industry and the prospective users. (Institutionalised forums, as well as seminar circuits).
• Build visibility of the industry especially as related to multiple private users, para military forces, the youth and fashion world.
• Explore export avenues (unmanned industry leaders to also be included in the delegation of business leaders accompanying national leaders in their visits overseas).