Airborne threats of low level Remotely Piloted
Aircraft System (RPAS)
Introduction
The technology and abilities of RPAS are changing fast and the demand of thesector to implement and integrate the systems in the airspace is enormous.1 Most ofthe systems consist at the moment of a light RPA (Remotely Piloted Aircraft, i. e. theairborne part of RPAS) operated in low level airspace and in Visual Line Of sight(VLOS) of the operator. The commercial advantages and possibilities of these RPAS
seem almost unlimited and because of decreasing costs - also the recreational user
will be a new partner in airspace.
Traditionally this lower level airspace (below the minimum height of 500’AGL) is usedby manned helicopters2, commercial general aviation and nearby airports by airtransport. All these users of the airspace are subject to international rules which
ensure the highest standards of safety in aviation and to protect against harm anddamages on the ground and in the air.
ECA is concerned about a potential degradation of the existing high level of safety
when considering the integration of RPAS in the low level airspace. This is due to thelimitations and properties of RPAS and their pilots and especially the widespreadlack of knowledge about the above mentioned manned low level operations.
Also there are concerns about security issues around RPAS.
ECA’s intention is to protect and to enhance aviation safety and security to thehighest standards. This position paper underlines our view as regards the integrationof light RPAS in the low level airspace by both the professional and recreationaluser.

1

An unmanned aerial vehicle (UAV), commonly known as a drone and also referred to as an unpiloted aerialvehicle and a remotely piloted aircraft system (RPAS) by the International Civil Aviation Organization (ICAO), isan aircraft without a human pilot aboard.
2In Germany alone in 2013, 102.497 missions were flown by rescue helicopters (various operators). A mission
includes at least two takeoffs and landings. When transporting a patient, a mission usually consists of threetakeoff and landing operations. Since about half of the flights included a patient-transportation, it can be assumed
that the statistical average is 2.5 takeoffs and landings per mission, leading to an average of five low-altitudeoperations (takeoffs/landings) per mission. This results in a number of more than half a million operations in thealtitude band below 500ft outside of airfields, in Germany alone.

European Cockpit Association AISBL
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At this moment worldwide regulations are created for RPAS on different levels by
several bodies. In Europe, the National CAA’s are currently responsible for RPAS
operations with a weight of 150 kg or less, which leads to diverging rules from state
to state. Hence, a European response is needed, and the first step towards EU-wide
harmonisation has been undertaken by EASA, in March 2015, by presenting its
anticipated regulatory approach and ‘concept of operations for RPAS. 3 ECA willcomment on this proposal separately, although many of the issues outlined in thispaper are relevant for the EASA approach, in particular for the ‘open category’proposed by the Agency.

Safety threats
Even below 500 ft AGL there is a lot of air traffic, e.g. air ambulances, police or firefighting, border control, military and newsgathering, manned helicopters/aircraft
performing their tasks. The same applies to the airspace next to airports, wherelanding/departing aircraft are due. Most of these operations are not predictable intime and place, but all are subjected to the same rules of the air.
Given the shape and size of a RPA, and the fact that it is usually many times smaller
than other, manned aircraft, they might not be visible to the other traffic, especiallywhen the speed difference is taken into account.
Due to weight restrictions, only a very limited or not adequate ‘detect & avoid’ system
could possibly be installed on board of an RPA to replace the traditional ‘see & avoid’system by the pilot.
RPAS, even light ones below 1 kg, can cause significant or even catastrophic
damage to helicopters in case of a collision due to the number of vulnerable, criticalcomponents, such as the tail rotor or main rotor head. In addition, during approachand departure manoeuvres, helicopters have very limited avoidance capabilities,
often exacerbated by the nature of the sites that they regularly operate from.
Several bird strikes have demonstrated that even impact with small birds (below200g) can have catastrophic results for a helicopter.4
The impact of damage to commercial air transport aircraft at nearby aerodromes is
not yet demonstrated and should be evaluated.
Even if RPA-operation is announced (e.g. by NOTAM) it is not possible for a crew ofa Helicopter Emergency Medical Services (HEMS) mission to detect if and where theoperation exactly takes place, since these announcements are usually not precise inrespect to place and time. In many cases, a radiotelephony with the appropriate ATCunit is not possible due to helicopters operating at a low altitude and the aircrew3

See: http://easa.europa.eu/newsroom-and-events/news/easa-presents-new-regulatory-approachremotely-piloted-aircraft-rpas.
4Ambulance helicopters as EC 135 certified under regulation CS-27/FAR Part 27 are not designed towithstand any bird strikes.
European Cockpit Association AISBL
Rue du Commerce 20-22, 1000 Brussels, Belgium I T +32 2 705 32 93 I F +32 2 705 08 77 I eca@eurocockpit.be I www.eurocockpit.be3being unable to verify area and time of RPA operations. This can lead to a delay oreven denial of HEMS operations, as pilots must maintain the safety of their aircraft.
Moreover, since there is no common RPAS-license yet, operators of RPAS haveoften very limited knowledge of the rules of the air, the operating principles of aircraft(especially rescue-, state- and aerial work- flights). Due to lack of knowledge, they
will not understand if and when they are endangering manned aircraft operation.
Another major safety threat is the recreational use of (toy) RPAS with lesssafeguards and operated by people who are many times even less aware of thedangers. Many of these untrained operators have no or limited knowledge about how
and where they can safely operate a RPAS. They might not consider potential
conflicts with aircraft. These types of RPAs can easily penetrate airspace used bymanned aviation.
Standards are required for the systems, as well as for the skills and knowledge of thepilot (and his company) as known in manned aviation today. Without that, especiallyin complex and safety-critical situations where human interaction is essential, the risk
is unacceptable. Because a RPAS is operated remotely this will result in a different
level of situational awareness (e.g. when coping with contingencies) and needs to beevaluated.

Required safety level – consequences for manned aviation
Due to the characteristics and limitations of RPAS - all risks shall be mitigated toachieve at least an equivalent level of safety to the one in place before integration ofRPAS with manned aircraft in low level operations. Where necessary, the rules
should be amended, and should be proportional to the classification and place ofRPAS operation.
When integrating RPAS in common airspace, the new rules should not put additionalburden to manned flight operations. As a general rule, the operation of RPAS should
neither deny airspace nor require additional procedures or equipment for manned
aviation.

Requirements for RPAS
ECA calls for a minimum of standard European rules for commercial RPAS
operations to ensure safety in lower level airspace when integrated with other traffic.5
Hereby:a) The responsibility to see and avoid manned aircraft must be placed solely on thepilot of the RPAS under all circumstances.

5One set of rules in Europe also for smaller RPAS is crucial, as users near the border are likely to use 2countries’ airspace. Also it reliefs the NAA’s from doing extensive research to the rulemaking as all aspects ofRPAS operations would be regulated in one European body.
European Cockpit Association AISBL
Rue du Commerce 20-22, 1000 Brussels, Belgium I T +32 2 705 32 93 I F +32 2 705 08 77 I eca@eurocockpit.be I www.eurocockpit.be4b) Even basic separation which is ruled by level/altitude restrictions (i.e. level
restriction of 400ft AGL for RPA) does not guarantee deconfliction, due to thenature of helicopter operations below this altitude (HEMS, fire fighting, police,rescue, agriculture, and military). It should be noted that these operations
frequently take place away from aerodromes and outside controlled airspace.
c) Standardization is required for altimeter readings (barometer or height).
d) Maximum altitude of the RPA is limited technically (or at the very least indicatedto the RPAS pilot).
e) The visibility of RPA should be at a maximum level achieved by lights and/orcolours and required for certification.
f)Special weather minima should be developed for RPAS operations dependingon the classification of operation.

g) Extended Visual Line Of Sight (EVLOS) and Beyond Visual Line Of Sight(BVLOS) operations should be only performed under conditions where conflictwith other aircraft is not possible (NOTAMS are not sufficient).6h) The observer has at least the same medical and knowledge status as the pilot.
i)Approved automatic detection and avoidance equipment should be implementedand mandatory as a mitigation means in case the RPAS-pilot cannot avoid dueC2-linkloss during EVLOS and BVLOS concept operations.

j)

No operations are allowed near to areas (within 1000m), where suddenly
appearing air traffic has to be expected (e.g. hospitals, landing fields, farm strips,
barracks, in the vicinity of exercises, or areas where rescue and/or emergency
operations are in force etc.) unless properly qualified and under positive controlof ATC.

k) No RPAS operations nearby (controlled and uncontrolled) airfields, including
heliports.7l)

Data of accidents and incidents are compulsory to report and gathered in one
database in a ‘Just Culture’ and SMS environment.

m) A safety assessment with target levels of safety proportional for the classificationof operation must be proven to the certification authorities and maintained.
Human factors shall also be considered.
n) RPAS-pilots must be trained and licensed in a way that knowledge and skills –but also awareness and airmanship – are on a comparable level as manned
aircraft pilots, in order to guarantee a safe cooperation with each other. 8o) All RPAS must be registered.
6As long as RPAS for EVLOS / BVLOS operations are not equipped with an approved detect and avoid system,
operation in non-segregated airspace is not possible.
7
The impact of damage to (commercial) manned aircraft is not demonstrated yet and should be evaluated.
8
Periodical recurrency training and proficiency checks are required to maintain practical and theoreticalproficiency. Training organisations have to use standard training programs and have to be approved and audited
regularly.
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Additional requirements
There are already accidents and incidents where even recreational RPAS haveinterfered with air traffic and people on the ground. The public is not conscious of thedangers of RPAS to other people and to air traffic, and not aware that one has tocomply with the respective national regulation for model aircraft. ECA urges
therefore the authorities and RPAS industry:a) to inform the public about the dangers of recreational RPAS, whereby in mostcases one is not insured (in case of incidents/accidents),b) to inform them about do’s and don’ts (e.g. commercials on TV and aplacard/information leaflet in the box),c) to standardize the national model aircraft regulation with a maximum safealtitude,d) to limit (technically) the maximum height of flight of recreational RPAS,e) to implement safeguards in the design of recreational RPAS,f)

to assist with a proper education, training and licensing for the recreational andhomebuilt user,g) to create methods to increase the level of law enforcement regarding to RPAS.

Security
Security of RPAS operations is a vital issue, with characteristics and considerations
that are both similar and unique when compared with manned aircraft. RPAS could
be hijacked and used as a weapon against other airspace users (e.g. by exploiting
data (e.g. ADS-B9 signals)) or targets on the ground. Terrorists could use their own
RPAS. One could also jam or spoof the RPAS, thereby seriously compromisingsafety.
Elaborated standards are in place for manned commercial aircraft operations
considering many factors. For RPAS, due to their characteristics, more factors haveto be considered to guarantee security. ECA has concerns to achieve a same levelof security with RPAS operation, already with today’s affordable RPAS designed tofly in low levels. Extensive research has to be done on this subject leading tosafeguards against security threats.10***
24/03/2015
9

Automatic dependent surveillance – broadcast (ADS–B) is a cooperative surveillance technology in which an
aircraft determines its position via satellite navigation and periodically broadcasts it, enabling it to be tracked. The
information can be received by air traffic control ground stations as a replacement for secondary radar. It canalso be received by other aircraft to provide situational awareness and allow self separation.
10See also ECA position paper; “Secure Skies”.

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