Memorandum from the Civil Aviation Authority
INTRODUCTION
1. The Civil Aviation Authority (CAA) is
responsible for the regulation of civil aviation in the United
Kingdom and has specific responsibility for aviation safety, airspace
policy, consumer protection and economic regulation.
2. The House of Commons Defence Committee
has announced that it is undertaking an inquiry into ISTAR (Intelligence,
Surveillance, Target Acquisition and Reconnaissance) and specifically
the contribution of Unmanned Aerial Vehicles (UAVs)[7]
in providing ISTAR capability. The inquiry is examining a range
of issues relating to UAVs, including how the use of UAVs, for
training and on operations, impacts on airspace and air traffic
control. As such, the CAA has been invited to provide a written
submission to inform the Committee. This Memorandum focuses on
the work of the CAA's Directorate of Airspace Policy and Safety
Regulation Group.
STATUTORY AUTHORITY
3. The CAA's statutory obligations are set
out in the Civil Aviation Act 1982 and in the Transport Act 2000.
The CAA's principal duty in respect of air navigation is to maintain
a high standard of safety in the provision of air traffic services
and, as required by the Transport Act 2000, the CAA is the Airspace
Approval and Regulatory Authority for the UK operating under Directions
given jointly by the Secretaries of State for Transport and Defence.
Policy for the use of UK Airspace by civil and military users
is determined by the Director of Airspace Policy.
4. The Directorate of Airspace Policy is
charged with securing the most efficient use of airspace consistent
with the safe operation of aircraft and the expeditious flow of
air traffic whilst taking into consideration the requirements
of operators and owners of all classes of aircraft. Environmental
implications and national security issues must also be considered.
The Civil Aviation Authority (Air Navigation) Directions 2001
lay down the obligation upon the Directorate to develop, promulgate,
monitor and enforce policies for the sustainable use of UK airspace
and for the provision of necessary supporting infrastructure for
air navigation.
5. The CAA's Safety Regulation Group (SRG)
performs the CAA's safety regulatory functions. SRG achieves this,
in partnership with industry, by driving continuous improvements
in aviation safety in the UK and, in partnership with, amongst
others, the European Aviation Safety Agency (EASA), across Europe.
Generally, airworthiness responsibility related to UAVs with a
weight in excess of 150 kg now rests with EASA. Airworthiness
regulation for civil UAVs with a weight below 150 kg (or those
above 150 kg that fall outside of EASA regulation eg customs,
police or similar services and aircraft specifically designed
or modified for research, experimental or scientific purposes,
and likely to be produced in very limited numbers) is the responsibility
of SRG which also has regulatory responsibility for the UK Air
Traffic Services.
UNITED KINGDOM
AIRSPACE
6. UK airspace is divided into various classifications
in accordance with International Civil Aviation Organisation (ICAO)
practice and each class of airspace has different rules and regulations.
Classes A, C, D and E[8]
(Controlled Airspace) place more stringent demands on aircraft
and pilot in terms of equipment and qualification. Access is,
in the main, subject to Air Traffic Control permission thus creating
a known traffic environment affording increased protection for
aircraft operating therein. The remaining airspace categories
(outside Controlled Airspace) are Classes F and G. This airspace
is accessible without permission and, as an Air Traffic Control
service is not mandatory, the responsibility for separation and
collision avoidance lies squarely with the pilot under the principle
of "see and avoid". That said, Air Traffic Control services
are available in Classes F and G airspace upon request, subject
to availability.
7. The long term industry aspiration is
that UAVs will be permitted to fly in exactly the same airspace
as manned aircraft. An essential prerequisite will be that UAVs
will need to meet all existing safety standards applicable to
manned aircraft, which are appropriate to the class of airspace
within which they are intended to operate. However, this will
not be permitted until the UAV industry can demonstrate that UAVs
have an "equivalent" capability to manned aircraft in
a number of respects, including safety. Airworthiness of the aircraft
is an issue being monitored by the CAA's Safety Regulation Group.
In airspace terms, the critical issue will be the development
of a technical solution replicating the ability of a pilot of
a manned aircraft to see and avoid other aircraft. The latter
requirement has yet to be overcome and therefore, for the time
being UAV flights that take place beyond line of sight[9]
are restricted to such airspace as can be segregated from other
airspace users. The operation of UAVs must also be transparent
to the ATC system which means that an air traffic controller providing
a service should expect a UAV to react to control instructions
in the same way as would a manned aircraft. To date, the impact
of UAVs on UK airspace and Air Traffic Control has been minimal;
however, there are clear indications that the demand for segregated
airspace is on the increase, both from UK industry and from the
MOD.
8. In the UK, segregation is achieved by
restricting UAV activity to the confines of existing or newly
established Danger Areas. On a temporary basis, segregated airspace
can take the form of Restricted Area (Temporary), which can be
established under Article 96 to the Air Navigation Order 2005
where it would be in the public interest to do so or in the interests
of national defence; however, the establishment of a Restricted
Area (Temporary), as opposed to the utilisation of existing Danger
Areas, places further restrictions on other airspace users.
UAV ACTIVITY
9. A significant increase in both civil
and military UAV flying is anticipated, most of which will require
access in the future to all classes of airspace if it is to be
operationally effective and/or commercially viable. The CAA is
involved in a number of working groups to ensure the demands and
requirements of UAV operators and other airspace users are met.
The CAA is represented on an International Civil Aviation Organisation
(ICAO) Study Group, which is developing international guidance
on the operation of UAS and is also engaged with a major European
body (EUROCAE) which is developing UAV standards. Furthermore,
by ensuring it is at the forefront of this emerging activity,
the CAA has the opportunity to influence other regulators (such
as the European Aviation Safety Agency and the Federal Aviation
Administration) to maintain an acceptable level of safety for
all aircraft and airspace users into the future. The recent amendment
process to update Civil Aviation Publication (CAP) 722: Unmanned
Aircraft System Operations in UK Airspace—Guidance has been
a collaborative approach with significant input from industry
and the MoD. To ensure a co-ordinated approach across all relevant
disciplines, the CAA has established committees to address UAV
issues that involve all relevant CAA departments as well as industry
representatives.
10. In terms of military UAV flying within
the UK, the prime activity is for training, which, at present,
is confined to existing Danger Areas; however, the acquisition
of systems such as Watchkeeper has led to a growth in demand for
airspace to enable UAV training missions to be conducted in a
realistic environment. As previously stated, before UAVs can be
safely integrated with other airspace users, UAV operators would
be required to work within the same regulatory framework as that
of manned aircraft operating in the same class of airspace. As
such, current MoD and industry UAV operations, beyond line of
sight, will take place inside Danger Areas or other segregated
airspace. The following points are of note:
(a) Whilst manned aircraft can utilise the
principles of "see and avoid" to visually avoid colliding
with other aircraft, UAVs do not yet have an equivalent method
of aerial collision avoidance. "sense and avoid" systems
are under development to emulate this manned aircraft capability;
however, it is unlikely that a system which is acceptable to civil
regulatory authorities (and by implication, other airspace users)
will be available for some time.[10]
(b) It is CAA policy to utilise Danger Areas
as a method of segregating UAV activities; however, it is recognised
that this may be misinterpreted to mean that the activity is in
some way dangerous. While the flight may not in itself be considered
dangerous, with the lack of a "sense and avoid" capability
the UAV activity requires an enhanced level of protection from
other airspace users, which can best be catered for by using Danger
Areas.
(c) In all aviation activities, including
UAVs, it is essential that the risk of endangerment to people
and property on the ground, as well as to other aircraft, be avoided.
As such, for a UAV that has not yet gained an airworthiness certificate
or a military release to service, flights may be restricted to
segregated airspace over land or sea that is devoid of people
and property to ensure that third parties are not exposed to any
unacceptable risks. This issue is carefully considered when establishing
segregated airspace and has been a key factor in the development
of the UAV flight test and trials facility at ParcAberporth in
West Wales with its access to Danger Area EG D201.
11. With the future introduction of Watchkeeper,
it was recognised that the size of the Danger Area complex in
the vicinity of Salisbury Plain would not allow the UAV to utilise
its full ISTAR capabilities due to the standoff range required
for its sensors, ie the capability to operate at range from their
intended target. As such, a proposal has been put forward by the
MOD to establish additional Danger Areas to the south of the existing
Salisbury Plain Training Areas. The Airspace Change Process is
being conducted in accordance with CAA policy as set out in Civil
Aviation Publication 725. Whilst this will clearly have an impact
on other airspace users, full consultation will take place with,
amongst others, the aviation community to ensure that the available
airspace can be used in a safe and efficient manner and that the
new Danger Area structure is proportionate to the MOD's needs
and has the minimum impact on other airspace users.
12. The CAA is aware of the UAV industry's
view on the benefits that the operation of UAVs may bring, and
will apply its best efforts to meeting the reasonable demands
of this sector, whilst balancing those against the needs of the
manned aviation industry. It is recognised that the requirements
for UAV operations inside Controlled Airspace, in terms of procedures
and equipment carriage, may differ from operations outside of
that more stringent regulatory environment; however, the basic
remit for collision avoidance is the same in all classes of airspace.
Detailed policy has yet to be established in some areas, which
will be progressed by the CAA with all interested parties playing
a significant role. However, UAVs will be segregated from other
traffic until an acceptable collision avoidance system has been
developed and is in place.
CONCLUSION
13. The CAA is alert to the airspace requirements
of all users, including operators of UAVs, and is working closely
with stakeholders to ensure a collaborative approach in determining
evolving policy related to UAV operations. UAVs are expected to
play a significant role in a number of military and civil areas
and it is important that the abilities of these platforms are
exploited fully. In the short term at least, it is anticipated
that these operations will be significantly different in their
profile and requirements from manned aircraft operations. It is
anticipated that future airspace arrangements will need to cater
for all types of UAV operations and access to all classes of airspace.
The need for safe integration without compromising current levels
of safety is evident. The CAA has played, and continues to play,
a lead role in this regard.
29 April 2008
7 The term UAV refers to the air vehicle part of the
Unmanned Aircraft System (UAS). The UAS also incorporates the
Ground Control Station (GCS) and any other UAV System Elements
necessary to enable flight, such as a Communication Link and Launch
and Recovery Element. Back
8
There is no Class B airspace established in the UK. Back
9
Beyond line of sight is considered to be a range exceeding 500
metres from the operator and/or 400 feet above ground level. Back
10
Latest estimates, although not guaranteed, for a "sense and
avoid" system range from 2012 to 2014. Back
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