IAOPA Comments Regarding ICAO Draft Circular 328

-- Unmanned Aircraft Systems (UAS) --

IAOPA agrees in principle with the contents of the Circular. I wish to thank my follow UASSG members for their diligent efforts in producing a good initial guidance document for the emerging UAS movement.

As with so many beginnings our efforts are largely broad and general, providing baseline comments and guidance for UAS. It is the detailed future directions emanating from this document that will provide detailed guidance to States and operators alike. For this reason I would like to add a few comments that may be considered points of emphasis from the standpoint of the worldwide general aviation community. These items should be considered by ICAO and States when implementing actual standards and regulations:

  • Operating rules for UAS must take into account their potential impact on general aviation aircraft operating in un-segregated airspace. While segregated airspace contains operations subject to air traffic control, un-segregated airspace depends almost entirely on certain Annex 2 cruising altitude conventions and mutual self-separation methods. Because self-separation methods for UAS are still in the conceptual stage and will likely require some time to perfect, there will be a temptation to impose un-segregated airspace restrictions on manned aircraft to accommodate RPA. Since un-segregated airspace is almost entirely the domain of general aviation, we do not want this to occur.
  • State or military UAS must abide by whatever UAS operating rules are devised to ensure safe, hazard-free operations. Because non-civil UAS operations may wish to use lower altitude un-segregated airspace, there could be a tendency for States and the military to pre-empt conventional flight rules in these areas, either on a temporary or permanent basis.
  • The concept of visual line-of-sight (VLOS) control appears to be a reasonable short-term solution to UAS operations within a limited area. However, the term “VLOS” must be better defined to establish practical limits for range and altitude separating operator and RPA, regardless of size.
  • There is an emerging trend in certain States to classify RPA by weight and/or size with apparent intent to reduce operating limitations on the devices. We perceive this as a dangerous trend since the combined kinetic energy generated between even a 2-3 kg. RPA and a light aircraft can easily cause catastrophic collision damage.
  • State and operator Safety Management Systems must serve as the ultimate guide for individual UAS operations. Without employing risk assessment and mitigation techniques for each operation resulting safety margins may easily prove unacceptable.
  • Although consideration of Human Factors is contained within the Annexes, specific mention of human factors should appear in Cir 328. The interaction between pilots and non-pilot RPA operators should be explored as part of the UAS.
  • Finally, sense-and-avoid systems for RPA will provide the key for safe operations, especially in un-segregated airspace. These must be independent, stand-alone systems that do not rely on an SSR transponder or ADS-B device carried by manned aircraft, since many general aviation aircraft do not carry this equipment and would have difficulty doing so.

I look forward to working with my UASSG colleagues on future issues regarding UAS.

Frank Hofmann
12 August 2010

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