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ISTAR 08
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[1]) 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 e.g. 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[2] (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[3] 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[4]. 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, i.e. 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
[1] 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. [2] There is no Class B airspace established in the UK. [3] Beyond line of sight is considered to be a range exceeding 500m from the operator and/or > 400ft above ground level. [4] Latest estimates, although not guaranteed, for a "sense and avoid" system range from 2012 to 2014. |