European Drone Forum - What we take away

The EU drone forum, organized by UAV DACH in collaboration with EASA, took place on Monday and Tuesday, November 07 and 08, 2022 in Cologne. Numerous experts from the drone industry, operators and manufacturers alike, as well as EASA and more than 15 national civil aviation authorities, made the trip to the western German city. While the first day was dedicated to the operational side of the specific category, the forum concluded with a second day focused on the future of digital airspace, called U-Space. Present at the event, the following lines reflect the important points retained.

The discontent of operators

Let's say it straight forward, after a high-level introduction of EASA on the SORA methodology, the floor was left to smaller operators and the associations who listed the irregularities, open points and disappointments with regard to the european regulation and more particularly the SORA.

Amongst others, there was a study of the 'TUM Institute of Flight System Dynamics' presented by Jackie Banas on behalf of the UAV DACH exposing the satisfaction of the SORA methodology from the user perspective. We learnt that for the majority of the requests, being in SAIL II, the most criticized point was the waiting time before obtaining feedback or an authorization. The length of the whole process varies on average between 4 and 6 months, but can exceed a year in some cases in Switzerland and Austria. There is also dissatisfaction with the clarity of the requirements and the quality of the feedback.

It is also worth noting that 51% of the applicants surveyed have no (20%) or little (31%) experience in aviation, safety and the inherent manuals, proving once again the diversity of the market players, yet governed by a real aviation authority.

JEDA, the Joint European Drone Associations, reported the results of a survey conducted among its members that exposes the lack of homogeneity between CAAs across Europe, especially regarding pilot training and certification. As these points have often been addressed in the latest AMC amendments, we wonder if it is not simply a matter of time before they are applied and harmonized in a more adequate way.

With these points recorded by a somewhat perplexed audience, one may wonder whether the figures collected mainly through civil drone associations, which are still struggling to form a common front and find their role in the market, actually reflect the expectations of a majority of perhaps more experienced operators. In any case, this is the impression given by the following speakers, such as Joschka Hoefling of UMS Skeldar. Not without difficulty, but with their experience in aviation, the company holds numerous international and BVLOS authorizations for a helicopter weighing several tens of kilos.

Petr Placek, from the Czech Civil Aviation Authority, came to the hearing to show the granting of almost 1000 authorizations for flights in specific categories, by 400 operators, of which only one was by a PDRA. Thanks to the complete translation of the documents by the CAA and their downloadable templates on their website, the operations are in full swing. However, the operators in the Czech Republic admittedly had the advantage of possessing a regulation very similar to the EU regulatory framework since 2012 and could gain a lot of experience therewith. Not to mention that most of the operational authorizations issued by Czech CAA under (EU) 2019/947 implementing regulation covered operations over controlled ground areas.

Although one can always wonder about the degree of control of some CAAs issuing such a flow of authorizations when others announce months of waiting to process requests and do not accept any "self declaration", the SORA methodology is indeed presented here as a process allowing relatively safe and complex operations. It still has its share of flaws and especially of interpretations that can be frustrating for avant-garde operators, but it has the merit of defining a method that can be applied by all. Built on a base and a structure close to aviation, it particularly frustrates operators not coming from the field who are exposed to a new, complex world, where safety and its description on paper are king... often to the detriment of short-term profitability. The advantage of consulting company is noted here, leaving the operator to focus on the essentials when beeing accompanied through the processes.?

In order to address some of these shortcomings, the SORA method itself will be amended in version 2.5 where all industry players are invited to participate. However, its content and requirements will not be simplified as desired by those actors using the drone as a secondary means of work.

The SORA 2.5

Natale Di Rubbo presented at the end of the day the changes proposed in the next version of SORA, version 2.5, worked by JARUS and which has been published for external consultation on the 08 of December 2022 on the JARUS website.

The conceptual process of SORA 2.5 does not change from the current version, although there is a minor reorganization of some steps. SORA 2.5 would introduce a phased approach (see below) that would include a preliminary phase including the first seven steps of SORA and the process could step onto phase two only if the competent authority so agrees. It is not beyond doubt whether this may fasten the process as is expected by EASA, amid general shortcomings at competent authorities in terms of human resources.

The remaining main changes are addressed in each particular step; the ERP logically loses its place as mitigation and joins the list of OSOs, the ground risk class is treated more quantitatively and above all, the contingency measures and the determination of adjacent airspaces are completely reworked and will probably allow a simplification of this dreaded step.

It is also worth mentioning – as Natale di Rubbo stressed in his presentation – that SORA 2.5 would get rid of "ground risk operational scenarios" and rather focus on population density when determining intrinsic ground risk class. Let's see how the legal text that still prescribes concepts like controlled ground area or assembly of people but not urban and suburban areas as SORA 2.5 does will adapt. This is crucial as, over the first two years of EU-wide application of SORA, multiple interpretations of the above notions have evolved without EU-wide consent and this change might lead to further discrepancies.

Far from summarizing the SORA 2.5 here, the main concerned are however invited to participate in the EASA Workshop on February 09 and 10 in Cologne.

During the questions of the day, we notice that some operators are often waiting for answers from CAAs, sometimes forgetting that they are also evolving in an innovative and disruptive market in the process of conception. This point was raised by Rob Akron, B.Eng EMBA ATPL(A) CPL(H) FI-I , from the European Cockpit association, who emphasized that the effort should be joint.

CAAs are mostly understaffed in dealing with the issue of drones and must not only deal with a growing demand for flight authorizations but also devote resources to meeting the expectations of operators and the shortcomings of new regulations.

Dieter Klein , from Wingcopter, raises the point that the main effort to unlock the authorisations should perhaps be put on the certification of the technology, which will allow safer operations and a certain facilitation of the process for the operators. These shortcomings lead us to the lack of standards on the market, which will also bring more clarity to the famous SORA requirements. However, standards are not developed by the authorities, but mainly by the industry, a subject addressed by antonio marchetto of EASA in his presentation "status of development standards".??

Development of standards

The SORA is a process for coming up with a list of prerequisites to prove to the authority. However, the SORA does not prescribe a recipe on how to do it. It is sometimes difficult to precisely understand what is expected, from the operator's side. With the experience of each CAA and operators, these requirements evolve rapidly and are different from one authority to another. To respond to this frustration raised by the operators in the morning, standards must therefore be developed.

But the development of standards are time consuming and the result of a complex collaboration between authorities who advocate safety and the industry who wants to see the emergence of standards that benefit their systems. It is therefore necessary to join these working groups and make these expectations known in order to see them reflected in the documents published by ASTM, ASD-STAN, ISO, EUROCAE and many others.

Arguably SORA did not take testing and prototype drones into account to the desired extent. Now, this would change as a new PDRA for testing is on the agenda. So were the swarms not handled by SORA so far, which led to a gap in law enforcement and among the different interpretations thereof. As both issues are being included in PDRAs, the situation might benefit.

The testing goes hand in hand with (the lack of) standards. The delay in this area leads to an undesired situation where most operators are forced into SAIL II without standardised drones, which hinders the spread of drone services as low SAIL induces operational restrictions in terms of the overflown area and used airspace too. Even the lack of CE marking under EN 4709 standards and the class marking (CIL) means a big problem because the OPEN category cannot exploit its potential either.

However, small and medium-sized industries are still not sufficiently represented in these working groups, as Antonio Marchetto points out in this slide of his presentation (see below), which is mostly due to a different prioritisation of resources among those companies.

If the European Drone Forum was partly organized to freely exchange the operators' difficulties with the authorities, there is an aspect that subtly emerges from the exchanges; the companies expect answers from the authorities, the authorities expect a joint participation in the elaboration of laws, AMC/GM and standards.

For small companies, mostly start-ups that have a significant place in the market, this requires too many resources; they have neither the time nor the personnel to place in these groups says Thomas Markert of Flying Basket. The answer of Antonio Marchetto sums up the overall situation: to represent these values against the industry giants and to assert these rights before the authorities, small companies have no choice but to join forces and contribute to the various international working groups through their collaborations. A collaboration often between competitors that sometimes turns out to be complex and that is still awaited on the market.

U-space and its forecasted implementation

U-space, the European version of UTM, a collection of digitised and interoperable processes and functions aimed at safely integrating an increasing number of complex drone operations in a common airspace with manned aviation, was the focus of the second day. Some private companies demonstrated their partial solutions, but what really caught our attention was the current state of implementation of U-space, and its interpretation, by some national authorities.

Germany, which implements U-space through the "Bundesministerium für Digitales und Verkehr", and Switzerland, through the civil aviation authority, the Swiss Federal Office of Civil Aviation, have presented their U-space implementation project. It is obvious that the two countries have chosen a different approach.

Germany opts for a centralized system where the data provided to the USSPs goes through a "single common information provider" (SCISP), giving a certain monopoly of some information. The USSPs, on the other hand, obviously provide U-Space-specific services for drone operators.

Switzerland proposes a bottom-up approach, directly involving the industry, operators and future USSPs in the joint development of a U-space solution. As explained by Amanda Boekholt , Switzerland, in order to keep market entry barriers low, preferred not to use the possibility of having a single SCISP. Indeed, the data forming part of the CIS will be provided, as indicated by the Implementing Regulation (EU) 2021/664, directly by the relevant data providers, namely the ANSP Skyguide, FOCA and the USSPs.?USSPs will therefore have direct access to CIS data relevant to the provision of U-space services, without going through an intermediate provider. This architecture has many advantages but can be more complicated to implement as the data comes from several entities.

After assessing the interest of the U-space market, including that of becoming a USSP. FOCA was able to establish that approximately 5 organisations with their principal place of business in Switzerland could potentially be certified by the FOCA to be a USSP. Before the USSP can actually provide U-space services in Switzerland, the FOCA will verify that the USSP in question is in possession of the USSP certificate (issued by the FOCA or the competent authority of its Member State). In addition, the USSP will have to demonstrate that it complies with the standards on which U-space services are based by means of automated verification. This automated verification, developed on the InterUSS open source platform, enables the USSPs to continuously test their ability to meet the requirements set in the standards that shape the framework for the implementation of a U-space services. The FOCA wishes to harmonise this automated solution across all EU Member States in order to facilitate access to the European market for all USSPs.

Indeed, the U-space regulation ?and its standardization still leave a lot of flexibility, leaving the challenge of an interoperability and European standardization surely even more complex than the SORA itself.

Two different interpretations of U-space and opposing approaches, but the involvement of the operator centric approach chosen by Switzerland caused a sensation for both the participants on site and the online community.

Conclusion

We are seeing a shift in the industry towards standardisation, professionalization and an approach with aviation practices. It is time to accept that companies building or using drones are evolving in an aviation market, regulated by the corresponding authorities, with the safety constraints that this represents. The days of the technology company offering its flying data sensor with a simple CE mark on the market are over, as is the small company using a drone in the specific category as a sporadic work tool. The operators allowed to operate in the specific category are professionals and need to prove their maturity to develop their business around the drone. This approach with traditional aviation, with its 100 years of experience in safety, does not please most users from other sectors who see their business models being shaken up. After having surfed on a technological wave for several years, the market is now facing the bottom of the hype curve and wants to professionalize, consolidate, and standardize itself throughout Europe. The very basic aim of the EU regulatory framework – beside the integration with manned aviation - is to build up a single European market for drones and services that cannot be achieved without uniformed interpretation and application of the rules. Participant agreed that the first two years of entry in force had provided the greatest evidence how truth this is. However, this takes time, and not everyone has the same patience or the resources to invest, for fear of seeing their business based on drone technology sink.

UAV DACH succeeded to bring the industry and national authorities with EASA together. The European Drone Forum provided an unprecedented assembly of the European drone ecosystem and the importance thereof cannot be overrated. UAV DACH represents 255 market players from 10 different countries and numerous segments of the drone industry. Such an organisation can help in cumulating demands of the operators and forward them to decision-makers. However, the data coming from members shall be authenticated or collected in a standardised way in order to increase the accuracy and usability of the survey’s results. The planned cooperation between JEDA, UAV DACH and EASA expresses this intent too, allowing a common front and direct access to the authorities to emerge.

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