Aleks Kowalski – Consortiq
Does future regulation spell the end for drone training?
In the first article of this series, we looked at the background to where we are today and that commercial and economic drivers, from both industry and government, demand drones to be operated beyond existing legislative capabilities.
In the next 2 articles, we consider a controversial viewpoint, namely, to achieve any of the above do we need a formalised drone training programme at all, and we approach this from a number of angles. However, at the outset, we must be clear that the goal of increased drone operations must not be at the sacrifice of safety. This is the core around which everything else revolves,
CAP722 dictates a documented trail of self-examination when making an OSC (Operational Safety Case) application which is the kind of format that one would expect to be required for BVLoS and reduced distance operations. This is critical for meeting the ‘Claim, Argument, Evidence’ methodology and establishing a Safety Management System (SMS) which is required for regulatory oversight. Does any of this require a regulated flight training system?
In this article, we look at the regulatory approach to drones in Europe and the USA.
The main contributory factor to the decline of training are proposed regulations, most notably by the European Aviation Safety Agency (EASA) which are expected to become law by 2019 1. The distinction between commercial and recreational operations will no longer exist and it will be purely a functionality issue as to what is required.
Figure – Proposed EASA Legislation
Some of the methodologies, as indicated in Figure 1, including reducing the physical flying assessment to a simple online assessment that covers the basic aviation laws. Even within the most challenging aspects, only a Theoretical Test is as far as is required. This has echoes of Part 107 in the USA. One thing we can take away from this is that it seems the physical requirements of being able to fly a drone is of less importance to the regulatory bodies, that EASA believes that automation of UAVs can be developed to an extent that the physical requirements of being able to fly a drone are sufficiently reduced that training is no longer required.
Figure – Summary of UK, EU and USA Legislation
So, does this mean that the future of drone flight training is effectively redundant? At the smaller recreational granular level at least, there seems to be little other option.
Consider the EASA Opinion, “The minimum distance from uninvolved people to be maintained when conducting a UAS operation in subcategory A2 has been reduced to 5 m when a low-speed mode function is
installed on the UA”. According to the feedback from some manufacturers, the economic impact of this is very low, since it could take around 10–20 man-days to develop a low-speed mode.”
A number of Operational Safety Cases have involved proving to the regulator the ability of the pilot to operate at closer distances. This has meant the Standard CAA Permission of 50m from any uninvolved persons was reduced to typically 20-30m – this is now almost also redundant, except for certain scenarios within the specific, which are still to be defined.
If we even consider existing UK regulation which still requires a Flight Assessment and drones such as the DJI Mavic which cannot be operated in any other mode than GPS; the skill factor required to complete a flight assessment is significantly reduced.
In the USA as indicated in Figure 2, the situation is even more clear cut. Prior to June 21, 2016 all applicants to operate drones commercially were required to obtain a Section333 exemption which took a lot longer and a more involved case to the authorities. Since the Part 107 (14 CFR Part 107) was introduced the requirements for simple commercial and recreational operation only preclude the need for an initial aeronautical knowledge test at an FAA-approved knowledge testing centre.
In summary, the current and proposed legislative landscape places a greater emphasis on technology and only a rudimentary understanding of the drone regulatory landscape needed to pass an online exam.
As someone who sat my Airline Transport Pilots Licence (ATPL) exams in 2006 and witnessed students able to complete 960 practice online questions in less than one hour with a 90%+ success rate – there is a degree of concern about how robust and effective such knowledge verification really is. From having delivered our existing ground school and flight assessment training to more than 1000 students since our inception – the type of students attending are less motivated than the early adopters and individuals with an interest in aviation. As a result, the Flight Assessment failure rate has also increased. What will be the check and balance be when this part of the industry is not mandated?
So how does the training aspect of the industry adapt to stay relevant and agile within an overall strategic framework? In Part 3 we look at how other aspects of industry are developing that further remove the need for any formal drone training.
Consortiq are a UK National Qualified Entity (NQE) and the training lead on the USA AUVSI Trusted Operator Program (TOP) Committee, alongside their CQNet software and consultancy services. If you would like to explore what they can offer to your organization, email: [email protected]
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