National Aviation Authorities’ Conference
Presentation by Director of Aviation Safety John McCormick, 28 February 2011
Unmanned Aircraft System developments in civil airspace and the way ahead
I would like to thank you for coming to this event, and look forward to your input and perspectives on Unmanned Aircraft Systems (UAS) in your own countries.
The aim of this conference is to
- Establish contact points with our colleagues in other National Aviation Authorities
- Seek mutual agreement to co-operation on sharing information on UAS developments, and
- Work towards a common framework for harmonisation of regulations that cover UAS.
Like other safety regulators, CASA faces a number of challenges responding to a changing aviation environment, a dynamic international and domestic industry and the need to ensure that safety related considerations are at the forefront of our thinking. One of the key challenges is the rapid pace of development in the UAS sector.
A significant area of innovation and development in the aviation industry is being directed towards Unmanned Aircraft Systems. The UAS sector is potentially the most innovative sector of the aviation industry. The development of the potential of unmanned aircraft systems is a key future challenge to which CASA, other regulators and The International Civil Aviation Organization must respond.
There are currently 13 holders of Operators’ Certificates in Australia who operate UASs for commercial purposes. All of these operate aircraft in the ‘small UAS’ category - Large UASs are generally only operated by the Australian Defence Force, however, we can expect the technology, scope of operation and size of unmanned aircraft to increase as technology is developed in the civil sector.
The number of enquiries being made to CASA relating to UASs strongly suggests interest in this sector will grow rapidly over the coming years – we are receiving approximately 15 enquiries a month from organisations exploring the possibility of operating UASs.
Globally, while assessments indicate that 45 per cent of the civil market will be made up of Government operators, there will still be significant growth. In the US, it is anticipated that by 2017, there will be 2,900 UASs – the majority of which will be small low altitude systems, and in Europe there will be significant growth in the next ten years.
I would expect that similar levels of growth will be seen through-out our region.
In responding to these demands, it is important to highlight that CASA is not an economic regulator. We have no authority to allow economic or commercial considerations to influence the safety-related decisions we are obliged to make.
It is only after all relevant safety-related factors have been considered with due diligence that the economic or commercial consequences of that decision might be taken into account. Where a less onerous, but equally safe, alternative is allowed by the law, CASA will certainly entertain that option. But in every case, commercial and economic considerations will be subordinated to safety-related matters.
In this regard there is a clear distinction in the design of UAS for the civil and military market. Aerospace Industry’s design of military UAS is ‘application driven’ – What does the UAS need to do? While the aerospace industry’s design of civil UAS must necessarily be ‘safety driven’ – How safe does it have to be to comply with applicable regulatory requirements?
Where more than one course of action is equally acceptable to CASA to achieve the required safety outcomes, then those options should be considered. And as I have said, where an available alternative is financially or commercially less onerous CASA can and should allow for that—so long as there is no compromise of safety.
A key challenge for the safety regulator is how to develop and maintain expertise in such a rapidly changing field. Events such as this one are an important step – for regulators to share developments and experiences, and to collectively consider strategies to ensure the safe development of the sector. It is important that we all hear the different perspectives of the organisations and countries represented and to learn what access has been permitted, lessons learned, how operations were controlled, rationed, or constrained, and what benefits have resulted from our respective efforts.
Internally, we have established a UAS Steering Committee and UAS Working Party. The terms of reference for these groups include:
- overseeing the development of UAS policies and procedures
- assessing the priorities for oversight of UAS activities within CASA’s overall strategic program;
- advising and making recommendations on the management, budgeting and performance of CASA’s UAS program of work;
- informing the processes governing the safety regulation of civil UAS operations;
- supporting the development of CASA’s policies and procedures with a view to strengthening the organisation’s capabilities in UAS; and
- fostering an awareness within the wider aviation community of the importance of UAS safety and compliance with relevant legislation
Importantly, these groups draw together experts from across CASA, such as our UAS specialists, Flying Operations Inspectors, Airworthiness Inspectors, Airspace experts and others to ensure a wide range of skills are brought to bare to respond to UAS developments.
I am proud to say that Australia has led the world in civil regulation of UASs and was the first country to have developed regulations—CASR Part 101, Unmanned Aircraft and Rocket Operations.
Supported by a useful set of guidance material, these regulations provide the framework within which all classes of UAS may be operated in Australian airspace. Not only will our Advisory Circular be re-written to provide that guidance, but other materials such as operations manuals risk assessments, safety management systems and human factors are required to developed to provide the guidance required.
Australia also has airspace, activated as required for UAS operations including east of Melbourne at West Sale in Victoria, south west of Sydney at Marulan in NSW and north west of Brisbane at Kingaroy in Queensland, and due to this many countries bring their systems here for trials.
Domestically, there is growing pressure in Australia from operators considering the use of UASs for fire-fighting related tasks and there are suitable sensors currently available in the civilian market that may provide the data required for fire spotting and hot spot identification for fire fighting related purposes.
However, this technology has not yet been utilised in Australia for fire-fighting purposes, largely because of our concern about the risk assessment process that the proponents have conducted.
As a result, we are developing an operational risk assessment for UAS, based in the ALARP ISO31000 international standard. This will serve as a standard and consistent basis for our inspectors, as well as the basis for guidance and education of the UAS community.
That way we hope to get the right material that will meet our needs to access the application and hence improve our efficiency of assessment and decision making.
But relating to the fire fighting situation, the scenario that is currently planned as the test case appears to be workable - we just need to work through the prime issue of making it as safe as possible. Other issues like:
- the lack of international airworthiness certification standards for small UAS (less than 150kg);
- UAS operations in differing categories of airspace where regular public transport aircraft may be operating; and
- UAS operations in over populous areas
can be catered for through proper risk assessment, segregation and proper co-ordination and communication. These, and a number of other issues, will require further assessment and resolution before the widespread deployment of UASs in Australian airspace may be safely considered.
In the meantime, however, CASA has been examining submissions and approving limited operations of UASs having regard to demonstrable compliance, or the ability to comply, with the applicable legislation, the areas in which operations are conducted, and the types of operations and vehicles proposed.
CASA is working with ICAO in the development of certification standards for UASs, and continues to evaluate permissions sought under CASR Part 101 on a case-by-case basis. In the assessment of applications for such permissions, the onus is on the operator to prepare a satisfactory safety case/risk analysis. CASA has published relevant guidelines in an Advisory Circular, copies of which we are happy to make available to you.
Australia is fortunate to have one of our own, Jim Coyne, serving as chair of the ICAO Unmanned Aircraft Systems Study Group. ICAO has set up this study group to develop the regulatory framework to integrate it into non-segregated airspace alongside manned aircraft.
As Chair, I expect Jim will be steering the group towards developing a comprehensive package of regulations including standards and recommended practices, advisory circulars and manual of standards.
Currently the group is made up of representatives from Russia, South Africa, Brazil, Singapore, the United States, Canada, across Europe and of course, Australia. I am sure that Jim is keen to hear the views and experiences from NAAs in our region on the development of the international standards.
I encourage you all to provide your input into this conference. Today we will be focusing on setting the scene with updates on the industry’s status, international developments, airspace access and manufacturing and certification issues.
Tomorrow will be more facilitated sessions on training and licencing, cross-border operations, and issues and challenges.
A ‘crystal-balling’ session on Monday afternoon will help to identify the potential issues that we will collectively face around the corner - things like full autonomy, swarming and optionally piloted aircraft may have to be considered and incorporated in the next suite of regulations.
We will prepare conference proceedings and provide them to you, and to those countries that could not be represented here. We look forward to further and continued engagement and sharing information.
I would like to formally launch the new CASA web page on UAS. The page will help us provide better advice to industry and all perspective applicants for Operator Certificates. This has been a void in the access to our documentation, and while this is just the beginning, more information will appear other the next few months
In closing, we have brought together an excellent regional representative group to look at some of the challenges posed by the rapid growth of UAS’ operations. However, as this group is fully aware, it is a rapidly developing and evolving part of the aviation industry.
We will be under increasing pressure to allow greater use of UASs, both from industry and our governments. My own Minister has reinforced to me, through the National Aviation Policy Statement, that he expects CASA to enhance our oversight of the operation of UASs. This only reinforces to me that safety must remain our focus.
It is a big challenge for us to effectively oversee the safe operation of these systems. We need to develop procedures and processes consistently, be mindful of the work of ICAO, and the leading manufacturers of UAS such as in the USA and Europe, and identify training and experience requirements for our inspectors and related staff.
Not a small task, but one I am sure we can step up to as a region.