Concept of Operations

for Unmanned Aircraft Systems

in

India

An Interactive Session by iSPIRT Foundation

Team Pushpaka

Amit Garg, George Thomas, Hrishikesh Ballal, Manish Shukla, Sayandeep Purkayastha, Siddharth Ravikumar, Siddharth Shetty.

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Outline

1. Introduction�Speaker: Sayandeep�Applications, evolving regulations, missing pieces and addressing these
2. Concept of Operations�Speaker: George�A piece that should inform policy making, categorisation
3. Implementation�Speaker: Hrishikesh�From concept to practice, short and long term roadmaps
4. Q&A with Pushpaka team�Coordinator: Hrishikesh

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For Q&A

⬆Concept of Operations article

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Drones for the Indian Society

• Geospatial Mapping: Drones can be a decisive force multiplier for resource/ infrastructure planning for India’s growing needs through geospatial surveys. Besides providing enhanced accuracy and safety, drone surveys:
• Reduce the cost and time for a survey
• Provide increased data accuracy
• Provide easier access to hard reach areas
• Enable Automatic pre-programmed 2D and 3D mapping
• Enable specific applications such as mining through special sensors.
• Precision Agriculture: These practices allow fine-scale monitoring and mapping of yield and crops providing more intense and efficient cultivation methods by adjusting fertilizer or pesticide prescriptions. In turn, significant cost and environmental savings can be made making Indian agriculture globally competitive besides enhancing the quality of crops for domestic consumption.

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Drones for the Indian Society

• Efficient Last Mile Logistics: Drones can arguably be considered the best solution for India’s last mile logistics issues given the traffic congestion in our urban areas and limited infrastructure in the hinterland. Cost effective and timely delivery of critical items such as medical supplies, besides the promise of urban air mobility, are veritable boons for India.
• Security Applications and Innovations: India has lagged in defence research and development which has been the driver for many new age technologies through agencies such as DARPA. We are slow off the mark but our technological base is well positioned to provide an ideal launchpad for cutting edge innovations in this field which will help not only address our unique security challenges but also establish market leadership for global sales. 

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Evolution of Drone Regulations in India

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Evolution of Drone Regulations in India

STILL AWAITED after 7+ years!!

• Technical Specifications/Standards
• Reference Implementations

for

• Assembly, Design and Manufacturing
• Pilot Licensing
• Remote ID
• Unmanned Traffic Management ecosystem

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Food for Thought

• Requirement of Type Certificate: Drone Rules 21 mandate airworthiness certification for drones whereas, appropriate standards have not been notified.
• Lack of Airspace Integration Vision: Drone Rules 2021 lack provisions for eventual integration of drone operations alongside manned aircraft.
• Business confidentiality must be preserved: The prescribed rules for access to data are not in consonance with the Supreme Court Right to Privacy Judgement
• Lack of transparent Import Policy: Places severe restrictions on the import of critical components thus disincentivizing indigenous development of drones in India 

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Food for Thought - Continued

• Insurance & Training must be market-driven: Market forces must drive the setting up of specialised training schools & insurance products & once mature they may be mandated & accredited. This will result in the creation of higher quality services & a safer ecosystem.
• Fostering innovation and becoming Atmanirbhar: 
• Encouraging R&D: by earmarking airspace for testing for future drones
• Encouraging the domestic drone manufacturing industry:  through a system of incentives and disincentivizing imports should be inherent in the Drone Rules. 
• Recognition of Hobby flying: Hobbyists are a vital part of the innovation ecosystem; however, they are not adequately recognised and legitimized
• Encouraging A Just Culture: Effective root cause analysis would encourage a safety-oriented approach to drone operations. Penal actions should be the last resort and dispute resolution should be the focus.

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Food for Thought - Continued

• Enabling Increased Safety & Security: Clarity on NPNT operationalisation would enhance safety and security manifold.
• No Clear Institutional Architecture: Like GSTN, NPCI, NHA, ISRO, etc a special purpose vehicle must be created to anchor the long-term success of drone operations based on an established concept of operations
• Lack of a Concept of Operations: Although drone categories have been defined, they have not been used adequately for incremental permissions. Failure to adopt an incremental approach can arguably be considered as one of the root causes of the drone policy failures till date in India as regulations are being framed for too many varied considerations without adequate experience in any. 

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What is a ‘Concept of Operations’?

• A Concept of Operations (ConOps) is a user-oriented document that describes characteristics for a proposed system from an integrated point of view to stakeholders.
• It is produced early in the requirements definition phase to describe what a system will do (not how it will do it) and the design rationale.
• The purpose of a ConOps is to describe the operational needs, desires, visions, and expectations of the user without being overly technical or formal. 
• It defines any critical objectives and performance requirements.
• ConOps is useful for obtaining consensus among the users and all other stakeholders on the operational concept of a proposed system.

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Why a ConOps for Drones in India Now?

• New field – limited information
• Can have a huge public impact
• Sub-optimal progression of UAS Policy
• No effective operations despite huge market
• Globally, most of the significant policy progress has come based on defined ConOps e.g. FAA, EASA and ICAO
• Help build consensus for policy faster
• Enable simultaneous addressing of multifarious bottlenecks

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A flow that works!

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Concept of Operations

Policy

Technical Standards / Specifications

Reference Implementation

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Drones vs UAS vs RPAS vs Model

• Drones – common/layman terminology for Unmanned Aircraft (UA)
• There are three subsets of Unmanned Aircraft :
• Unmanned Aircraft
• Remotely Piloted Aircraft, and
• Model Aircraft.
• Unmanned aircraft system (UAS) – an unmanned aircraft and its associated elements, operated with no pilot on board. Kept away from manned aircraft by airspace restrictions
• Remotely piloted aircraft (RPA) - unmanned aircraft, actively piloted from a remote pilot station. Can use same airspace but subjected to same safety standards as manned aircraft

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ICAO : UAS vs RPAS

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icao.int/safety/UA/UASToolkit/Pages/FAP.aspx

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Model Aircraft

• Model Aircraft - UA without payload used for educational/ recreational purposes only.
• Generally model aircraft must meet the following criteria:
• Be capable of sustained flight in the atmosphere
• Be flown within visual line-of-sight of the person operating it
• Be flown for hobby or recreational purposes
• Not be flown over people or near aerodromes
• Payload - All equipment on board a UAV that are not needed for the flight or its control. It aims exclusively to fulfill a specific mission. Thus payload has minimal impact on class of drone except that smaller drones can’t carry larger payloads

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UAS in India

• UAS in India are currently categorized in accordance with MTOW (including payload) as indicated below:
• Nano : Less than or equal to 250 grams.
• Micro : More than 250 grams & less than/ equal to 2 kg.
• Small : Greater than 2 kg & less than or equal to 25 kg.
• Medium : More than 25 kg & less than/ equal to 150 kg.
• Large : Greater than 150 upto 500 kg.

However no difference in regulations for Small - Large categories; no mention of RPAS and no provisions for Models or Operational categories

• Use of the terms needs serious review in order to align with the international community and better compliance

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UAS Applications

• Aerial Photography and Videography
• Survey and Mapping
• Inspections of critical infrastructure
• Surveillance
• Agricultural Services
• Cargo Delivery
• Search and Rescue
• Public Security
• Disaster Relief and Disease Control
• Science and Research
• Entertainment

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Majority of these applications can be achieved using small Rotary Wing UASs though some of them may benefit from fixed wing or larger UASs

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Guiding Principles for Developing Regulations

• Efficiency
• Safety
• Security
• Infrastructure Constraints

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Efficiency

• Regulations need to be UAS-centric and not lean too heavily on traditional manned aviation.
• Simple regulations with minimal compliance costs needed in order to
• provide a fillip to the industry
• attract investments 
• encourage legitimate use
• Provide time for evolution of standards and ensuring compliance
• Efficient regulations enable
• development of market capacity and further innovations
• reduced gestation period for SMEs
• *wider spectrum of users

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Safety

• UAS should be progressively integrated into the existing aviation system in a safe and risk-proportionate manner
• UAS Regulations must
• minimize risk to safety of people and assets
• meet India’s ICAO obligations towards safety
• meet the safety and operational standards applicable to manned aircraft when operating in non-segregated airspace
• Alternately, initially, UAS operations must be restricted to
• specific conditions e.g. visual line-of-sight (VLOS); or
• segregated airspace outside the operational ambit of manned aircraft; or
• specific areas e.g. away from heavily populated areas
• Rules must express objectives, complemented by industry standards

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Security

• India has long history of sub-conventional warfare in the form of anti-national activities.
• UAS are ideal tool for disgruntled elements
• Potential saturation of our security establishment in differentiating between the ‘good’ and the ‘bad’ actors
• Use of UAS need initially be limited to categories that are
• easily identified
• incapable of significant harm
• Protection of public interests, such as personal privacy*

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Infrastructure Issues

• Development of UTM concepts and infrastructure is crucial for large scale UAS use
• UAS Traffic Management based on:
• Each UAS transmitting a unique remote ID with a geo tracking feature
• Unmanned Traffic Management Systems for Very Low Level segregated airspace accommodating exclusive UAS traffic
• UAS in non-segregated controlled airspace need to additionally meet manned aircraft standards
• UAS integration in non-segregated airspace will pose challenges
• Development of the UAS market and related technologies needs to be carefully monitored and the planning adapted, for integration 
• Availability of telecom spectrum is fundamental to UTM infrastructure

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Suggested ConOps for India

• Incremental Approach so that
• Operations commence asap
• Risks minimized
• Growth moderated to manageable limits
• Risk and Capability Based Approach
• Category A – Basic UAS Operations with Least Risk
• Category B – Productive Operations Minimal Risk
• Category C – Advanced UAS Operations posing Intermediate Risk
• Category D – Full Range Regulated UAS Operations with Risk Mitigation

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Category A

• Least risk and require the least infrastructure e.g. small UAS for photography or videography.
• Suggested operational boundaries :-
• Operations in Visual Line of Sight (VLOS) only
• Operations at a safe distance away from people, animals, infrastructure and aerodromes
• ​Operations in segregated airspace only till a specified maximum height above ground level (AGL)
• ​The UAS capability is limited by design within specific performance limits such as mass, speed, ceiling, rate of climb, rate of descent etc
• No UTM support required.

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Category B

• Operations unlikely to result in a fatality or cause serious injury/ damage to persons or infrastructure on ground. e.g. small UASs for survey or agricultural purposes.
• Operations subject to limited regulatory restrictions that protect other airspace users and life/ property on ground.
• Require supporting UTM infrastructure but can be undertaken without UTM in a more restricted way.*

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Category B - Continued

Cat B operational boundaries defined as follows:-

• Operations by a qualified remote pilot only
• Operations in Visual Line of Sight (VLOS) or extended VLOS only.
• Operations at a safe distance from people, animals, buildings and aerodromes.
• ​Operations in segregated airspace only
• Operations not involving carriage of dangerous goods or articles
• ​UAS must have mandatory identification features
• UAS capability limited by design within specific performance limits e.g. mass, speed, ceiling, rate of climb, rate of descent etc
• Only in fair weather conditions and away from security sensitive areas

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Category C

• Operations utilizing larger and/or heavier UAS with more payload capacity but posing no challenge to manned aircraft e.g. BVLOS operations in segregated airspace for package delivery
• Low potential to cause fatality or injury to persons on the ground
• Safety challenges limited by restriction to segregated airspace
• Operations with limits such as payload, pilot qualifications, airspace restrictions, altitudes, airspeed, proximity to aerodromes and congested/populated areas
• Specific Risk Assessment based authorisation, that will lead to specific limitations, adapted to the operation

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Category C - Continued

Operational limitations include:-

• Operations by a trained remote pilot only
• Operations at a safe distance from people, animals, buildings and aerodromes
• ​Operations in segregated airspace only
• UAS should have mandatory safety, identification and tracking features conforming to specified standards
• Enhanced UAS capability but limited by design within specific limits such as mass, speed, ceiling, rate of climb, rate of descent etc
• Operations subject to availability of adequate UTM infrastructure

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Category D

• Advanced applications with negligible restrictions on size, the area or complexity of operation or use of airspace e.g. Air Taxi operations
• Includes, with appropriate mitigations, BVLOS operations within controlled airspace.
• UAS should conform to well established design characteristics
• Would require significant risk mitigation measures

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Category D - Continued

• Operators to have an adequate management structure to ensure safe operations 
• ​Licensed remote pilots who are issued licences after successfully completing practical training requirements, pass knowledge tests, meet specific medical standards and age requirements
• UAS will need to be maintained in a safe state for flight and be subject to design standards or other airworthiness certifications
• ​The aircraft may need to be marked and registered and be able to be tracked continually
• Operational rules applicable to this category of operations could be extensive

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Implementing the UAS ConOps

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Suggested Rules for Cat A Ops

• UA with a gross mass of 2 kg or less, and 
• UA is designed to minimise chances of injury to any person in case of accidental collision; and 
• UA is operated always within VLOS; and
• UA is operated at or below 60 m (200 ft) AGL by day only; and
• UA is operated at a safe distance from a person or animal not directly associated with the operation of the UA; and
• UAS is not operated in a prohibited or restricted area; and
• UA is not operated in an airspace notified for use by manned aircraft without prior approval of the controlling authority for such airspace; and
• UAS is used only for hobby flying or photography/ videography.

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Suggested Rules for Restricted Cat B Ops

• UA with a gross mass of 25 kg or less; and 
• UA uses primarily vertical axis rotors to generate its propulsion; and
• UA is designed to minimise chances of injury to any person in case of accidental collision; and 
• UAS is operated by a remote pilot authorised for the operation; and
• UA is operated always within VLOS or enhanced VLOS; and
• UA is operated at or below 120 m (400 ft) AGL by day only; and
• UA is operated in suitable weather conditions; and
• UA is operated at a safe distance away from people, animals, buildings and aerodromes; and

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Suggested Rules for Restricted Cat B Ops

• UA is not involved in the carriage of any parcel or jettisonable load in excess of 5 kgs; and
• UAS is not operated in a prohibited or restricted area; and
• UA is not operated in an airspace notified for use by manned aircraft without prior approval of the controlling authority for such airspace; and
• the remote pilot is able to access web-based updates on any flying restrictions that may have been imposed over the intended area of operations before commencing the flight; and 
• UAS is not operated within 25 kms of India’s international borders or 5 kms of India’s coastline without the prior sanction of the appropriate law enforcement authority.

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Suggested Rules for Design and Manufacturing

• DGCA / QCI follow design standards for UAS in the micro, small, medium and large categories.
• Standards for micro and small UAS operations in Cat A or Restricted Cat B on immediate basis
• UAS incapable of infringing stipulated height and permanent geographical restrictions by design.
• UAS manufacturers, domestic or foreign, to prove that their UAS conforms to stipulated design and equipment standards for marketing their UAS.
• Manufacturers accountable in case of any manufacturing or design defects.
• Manufacturers to imprint a unique ID to ensure traceability of the UAS.
• Manufacturers and traders to maintain record of every transaction of UAS or components to ensure UAS traceability given our security paradigm.

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Suggested Regs for Remote Pilot Authorisation���

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• No requirement of remote pilots to undergo any other formal training for Category A or Restricted Category B operations – immediate.

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• Online examination conducted at authorised centres through professional organisations with desired level of quality in the process.

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• Need to rationalise training needs and costs based on risk assessment.

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Suggested Regs for Remote Pilot Authorisation���

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• Practical training under own arrangements for Category A or Restricted Category B operations. E.g. Online videos etc.

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• Category B operations require pilot to obtain authorisation after undergoing an online DGCA/ QCI certified course. The course followed by an online examination enables authorisation – to be developed in short term.

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• Category C and D need specific training and licensing – to be evolved in medium term.

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Action Plan: Enabling the Ecosystem - Immediate�

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• Airworthiness Compliance requirements be removed till published
• Operations be permitted for Category A and Restricted Category B
• Remote Pilot training requirements be simplified for Cat A and B as a priority

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Action Plan: Enabling the Ecosystem - Immediate�

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• Guiding principles for Import policy formulation be laid out to incentivise import drone parts and de-incentivise drone models
• Insurance be not mandated for any drone categories
• Enhanced privacy be applied for DigitalSky data access that restricts abuse technically
• The provision for setting up the Drone Promotion Council be subsumed by a SPV

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Action Plan - Setting up the Long Term Ecosystem

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• NPNT be re-notified as a bedrock requirement for operational control
• An SPV outside of entrenched institutions be set up with a charter to
• Envision India’s concept of aviation operations for the next few decades
• Formulate Future Policy including: 
• Maintenance / Development / update of ConOps
• Track / develop / customize International standards
• Establish Standards for Airworthiness and Flight Training
• Develop & operationalise DigitalSky in an open, collaborative fashion
• Establish an Advisory Committee with equitable membership of stakeholders
• Address all charter items of the Drone Promotion Council
• Lay a legal framework for drone data privacy

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Q&A

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References

• Concept of Operations Version 1: https://sayandeep-ai.github.io/pushpaka/work-items/i01�Published Aug 7, 2021 by Pushpaka group�
• Commentary on the Draft Rules 2021: https://pn.ispirt.in/ispirt-response-drone-rules-2021�Published Aug 7, 2021 on iSPIRT Blog post: pn.ispirt.in

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