CPB

Corporate Partnership
Board(Un)certain Skies?
Drones in theWorld of Tomorrow

Corporate Partnership Board
Report(Un)certain Skies?
Drones in theWorld of Tomorrow

Corporate Partnership Board
ReportAbout the International Transport ForumThe International Transport Forum at the OECD is an intergovernmental organisation with 59 member
countries. It acts as a think tank for transport policy and organises the Annual Summit of transportministers. ITF is the only global body that covers all transport modes. It is administratively integrated with
the OECD, yet politically autonomous.
ITF works for transport policies that improve peoples’ lives. Our mission is to foster a deeper understandingof the role of transport in economic growth, environmental sustainability and social inclusion and to raise
the public profile of transport policy.
ITF organises global dialogue for better transport. We act as a platform for discussion and pre-negotiationof policy issues across all transport modes. We analyse trends, share knowledge and promote exchange
among transport decision makers and civil society. ITF’s Annual Summit is the world’s largest gathering oftransport ministers and the leading global platform for dialogue on transport policy.
Our member countries are: Albania, Argentina, Armenia, Australia, Austria, Azerbaijan, Belarus, Belgium,
Bosnia and Herzegovina, Bulgaria, Canada, Chile, China (People’s Republic of), Croatia, Czech Republic,
Denmark, Estonia, Finland, France, Former Yugoslav Republic of Macedonia, Georgia, Germany, Greece,
Hungary, Iceland, India, Ireland, Israel, Italy, Japan, Kazakhstan, Korea, Latvia, Liechtenstein, Lithuania,
Luxembourg, Malta, Mexico, Republic of Moldova, Montenegro, Morocco, Netherlands, New Zealand,
Norway, Poland, Portugal, Romania, Russian Federation, Serbia, Slovak Republic, Slovenia, Spain, Sweden,
Switzerland, Turkey, Ukraine, the United Arab Emirates, the United Kingdom and the United States.

Disclaimer
Funding for this work has been provided by the ITF Corporate Partnership Board. This report is published under the
responsibility of the Secretary-General of the ITF. It has not been subject to the scrutiny of ITF or OECD member countries,
and does not necessarily reflect their official views or those of the members of the Corporate Partnership Board. This
document and any map included herein are without prejudice to the status of or sovereignty over any territory, to thedelimitation of international frontiers and boundaries and to the name of any territory, city or area.

www.itf-oecd.org

FOREWORD – 3

Foreword
The work for this report was carried out in the context of a project initiated and funded by the International
Transport Forum's Corporate Partnership Board (CPB). CPB projects are designed to enrich policy discussion
with a business perspective. They are launched in areas where CPB member companies identify an
emerging issue in transport policy or an innovation challenge to the transport system. Led by the ITF, workis carried out in a collaborative fashion in working groups consisting of CPB member companies, external
experts and ITF staff. Many thanks to the members of the Corporate Partnership Board companies involvedin this work: Anheueser-Busch inBev, Google Inc., Toyota Motor Corporation, NXP, PTV, Uber.
The report draws on insights from the ITF CPB Workshop “(Un)certain Skies – Drones in the World ofTomorrow” held 14-15th November at Uber Headquarters in San Francisco.
Participants of the workshop included:
Borda Fred, Aerial Innovation
Cary Leslie, International Civil Aviation Organization (ICAO)Davidson Mariko, Microsoft
de la Rosa Sara, United Nations Children’s Fund (UNICEF)
Erlich Justin, Uber
Espahbodi Van, Starburst Aerospace Accelerator
Flood Rob, Air Canada
Grand-Perret Sylvie, EUROCONTROL
Heerkens Hans, University of Twente
Herrera Paul, Los Angeles World Airports
Hourcade Céline, International Air Transport Association (IATA)
Humanes Paulo, PTV Group
Irie Hiroshi, SkyWings Inc.
Koike Ryoji, Aerial Innovation
Kopardekar Parimal, National Aeronautics and Space Administration (NASA)
Koperberg Barry, Wings for Aid
Kubo Daisuke, Japan Aerospace Exploration Agency (JAXA)
Kusajima Takayuki, Toyota Motor Corporation
Makagon Jael, University of California, Berkeley
Mason Travis, Airbus A3
Matyushev Aleksey, Natilus
Morita Naoki, DENSO Corporation
Ohta Hiroaki, Autonomous Control Systems Laboratory Ltd. (ACSL)
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4 - FOREWORD

Prevot Thomas, Uber
Reuter Timothy, World Economic Forum (WEF)
Sayyed Ruby, International Air Transport Association (IATA)
Shiffman Naomi, University of California, Berkeley
Singh Rahul, GlobalMedic
Tomonaga Yukinobu, Subaru Corporation
van Blyenburgh Peter, UVS International
Wylie Allison, Uber
Wynne Brian, Association for Unmanned Vehicle Systems International (AUVSI)Xu Emerson, Land Transport Authority of Singapore
Zubkov Vladimir, International Air Cargo Association (TIACA)
Crist Philippe, International Transport Forum (ITF)
Lumbroso Alain, International Transport Forum (ITF)
Schechtner Katja, International Transport Forum (ITF), Massachusetts Institute of Technology (MIT)Special thanks go to Carine Donzel-Defigier and Pierre Moschetti from Direction générale de l’Aviation civile
who provided insights about the French Drone Council; Ande Monier, Cecilia Paymon and Edwina Collins
from the ITF and Naomi Shiffman from UC Berkeley for notes, support and editing, and Alain Lumbroso,
now Transport Canada, who initiated this project at ITF.
The principal author of this report is Katja Schechtner with contributions from Lorenzo Casullo, Anna
Garbarczyk, Philippe Crist and Jagoda Egeland.
The project was managed by Katja Schechtner and Philippe Crist of the International Transport Forum.
Coordination of CPB activities was carried out by Sharon Masterson.

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TABLE OF CONTENTS – 5

Table of contents
Executive summary……………………………………………………………………………………………………. 6
Introduction………………………………………………………………………………………………………………. 9
Current state of play………………………………………………………………………………………………… 13
Drone design, airspace management and service models…………………………………………. 13
Regulations for drones………………………………………………………………………………………… 15

Scaling up…………………………………………………………………………………………………………………. 21
Passenger drones………………………………………………………………………………………………… 21
Freight drones…………………………………………………………………………………………………….. 25
Drones for support missions…………………………………………………………………………………. 28
Drones for humanitarian aid and development projects…………………………………………….31

Challenges for transport policy makers…………………………………………………………………… 35
Safety and security first……………………………………………………………………………………….. 35
Privacy a close second…………………………………………………………………………………………. 37
Challenges for the overall transport system and their impact on drone policies………….. 38
Drones in urban settings………………………………………………………………………………………. 45

Preparing for tomorrow……………………………………………………………………………………………. 49
Establishing a public-private policy dialogue for drones
as part of the overall transport system…………………………………………………………………… 49
Building regulatory capacity in authorities……………………………………………………………… 51
Development of a well-rounded research and development strategy
and establishment of experiment and testing areas/licences……………………………………. 51
Collecting and sharing data on drones to understand their impact and tailor policies….. 52
Develop visions to integrate drones with transport system………………………………………. 53

Annex………………………………………………………………………………………………………………………… 55
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6 – EXECUTIVE SUMMARY

Executive summary
What we did
This report investigates the role of drones as part of the future transport mix. It specifically addresses theissues policy makers face in engaging with the emerging private drone sector. Drones for recreational
purposes are not part of this study.
Drones are already deployed in the transport sector in surveying and monitoring the condition of
infrastructure. They also promise to provide innovative services in freight delivery, passenger transport anddisaster relief. With the sector developing at a rapid pace, regulators will want to create frameworks fordrone use that allow innovation while ensuring positive overall outcomes.
The potential impacts of large commercial drone fleets are as yet not fully understood. Assessment of thepotential impact on aviation has begun but appraisal is rarely addressed from a cross-sectoral perspective.
Freight drones for urban goods deliveries and, eventually, drones for passenger travel, may have both
positive impacts (e.g. improved connectivity in remote regions, traffic congestion alleviation, reduced travel
times) and negative impacts (e.g. safety, privacy, noise, energy consumption, land use and visual amenity
concerns). We explore how some of these impacts could be anticipated and included in appraisal guidelines
to support the underlying policy goals of efficient, safe, sustainable and equitable transport.
The insights in this report build on expert interviews, a review of published research and a workshop with37 international experts held in San Francisco in November 2017. Attendees included drone manufacturers,
leaders of regulatory, humanitarian and economic organisations as well as representatives of companies
that utilise drones as a central component of their businesses, or are planning to do so.

What we foundDrones, the technologies that enable them and their potential applications within the transport sector are
already diverse and are evolving rapidly. Future use cases range from on-demand passenger drone services
and fleets of freight delivery drones in urban areas to fully automated drones carrying large payloads andconnecting continents in an airborne “conveyor belt”. Drones also offer many promising support functions
for transport systems. For instance, sensor-equipped drones can help to plan, maintain and managetransport infrastructure and traffic flows more effectively.
The current regulatory focus with regard to drones is on safety and interaction with manned aviation.
Regulatory bodies have generally focused on the allocation of airspace for testing and on creating aframework for the licensing of commercial drone operations. The national and international civil aviation
authorities driving this work currently prioritise the safe integration of drones with the existing manned
aviation regulations.
The potential for disruption by drones extends beyond the aviation industry. The large-scale deployment ofcommercial drone fleets will challenge the transport system as a whole, for instance due to the potentiallyunlimited proliferation of “drone ports” for take-off and landing.
What role drones will play in future transport systems depends on the ability of this new “mode” to gain thesocial licence to grow. To build trust and public support, questions of safety will require answers together
with a wide range of concerns traditionally associated with transport, including noise, emissions, energy
consumption and social equity. However, novel challenges such as privacy and considerations about thevisual amenity of cities and landscapes will also come to the fore. The aviation sector will provide significant(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

EXECUTIVE SUMMARY – 7

input to tackle these questions, but experts from the wider transport policy community will also need to beengaged in the conversation.
The rise of drones provides regulators with an opportunity to foster an emerging market. Faced with
disruptive technological change, regulators may support, hinder or act neutrally in the development ofinnovations. The key challenge is to test the suitability of existing regulatory frameworks for mitigating
possible adverse impacts whilst allowing drone services to develop. Drone regulation will need to address
the standard public concerns of efficiency, competition and sustainability.

What we recommend
Develop a vision for drone services integrated with the transport system as a whole
Drones could play an important part in creating an efficient, safe, sustainable and equitable transportsystem. The real value of passenger and freight drones is generated when and where they touch ground.
Policy makers need to focus on the impact of the potentially millions of “drone ports” and their integration
into the transport system, cities and society as a whole.
Include experts from outside aviation in the policy debate on drones
Several countries have established joint public-private discussion fora that bring together different parties
interested in the development of a market for the use of civil, commercial drones. These “drone councils”
are an excellent starting point for policy makers to develop a vision for drone services that are integrated
with the transport system as a whole. They benefit from the inclusion of experts with a diverse set ofbackgrounds, including digitalisation specialists, transport economists and urban planners.
Explore the significant potential of drones for regional connectivity in thin markets
Many regions lack adequate surface access to potential markets. Particularly in developing and emerging
countries, regional connectivity could be significantly improved for both for freight and passenger transport
once reliable and efficient drone services are available. Such services could be a substitute for investment
in infrastructure for surface transport networks. This could also benefit the connectivity of remote regions indeveloped countries to global markets.
Consider how drone services could become part of future urban transport
Drones present cities with a number of opportunities. They can alleviate pressure on ground transport andenhance emergency services. They can also make the work of different city departments safer and morecost efficient. Yet drones also present new challenges for cities, including questions of safety and security;
the allocation, design and regulation of “drone ports”; the relation between drone services and existing
ground transport services and questions of privacy, visual amenity and noise. Therefore city authorities
should start to include drone transport into their urban development plans.
Mayors could use zoning powers to designate take-off and landing locations and set other operational
criteria for drones. However, devolved regulatory authority could create fragmented and conflicting
regulations.
Deploy drone services in a phased way that maximises public acceptance
Trials with drones have shown that public acceptance is high if the value proposition is clear to the public,e.g. for medical or humanitarian support. At the same time, increasing unease about safety, privacy andaccountability can become a barrier to the introduction of drone services. Policy makers can alleviate theseconcerns by developing a vision for different use cases and a phased introduction supported by aprogressive opening of markets for drones. The initial focus should be on use cases that provide clear value
to society, such as emergency support or improved maintenance of transport infrastructure.

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8 – EXECUTIVE SUMMARY

Mitigate innovation risk through coordinated research and development, tests and regulations
In order to create a market for efficient, safe and sustainable commercial drones, novel aircraft designs andair traffic management systems have to be developed. Significant public funds and large-scale test sites
have been provided for drone development in many countries but further investment is needed andinternational coordination could save expenditure and accelerate progress.
Policy makers must also ensure that research programmes and funds will not look at technologicalquestions in isolation but promote a more pro-active approach towards questions regarding theenvironmental, economic and social impacts of drones overall.

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INTRODUCTION – 9

Introduction
Drones – a conceptual shift from military to civil applications
The public image of drones has undergone a surprisingly quick conceptual shift: while drones were solely
the purview of the military just a few years ago, public discussion now focuses on drones for civil use inleisure and commercial applications.
Until the turn of the millennium, the use of drones had been largely restricted to military operations. The
use of aircraft in a military combat theatre differs in significant ways from operating aircraft underpeacetime conditions. The acceptability of risk is significantly higher, and there are very little, if any, nonmilitary flight operations to take into consideration. Hence, the rules and procedures for separating aircraftfrom one another as well as the threats drones pose to people and objects on the ground are radicallydifferent from during civil flight operations.
The military has historically been a catalyst for the development of drone technology, absorbing many of
the technological development costs but enabling technology transfer to civilian unmanned aircraft andoperation systems. This has allowed drones to become cheaper, lighter, more sophisticated and easier to fly
than a conventional aircraft, while at the same time paving the way for advanced integration of manned
and unmanned air transport management. Most civilian drones are in fact part of a system that consists of
the aircraft itself, guidance, navigation and control elements like radio transmitters, onboard sensors andsoftware that together form the operation system and a human remote pilot or an Artificial Intelligencecontroller depending on the level of automation of the drone system and the data link communicationarchitecture.
In some ways, the potential of drone transport was anticipated by the 1944 Chicago Convention, whichstates in Article 8: “No aircraft capable of being flown without a pilot shall be flown without a pilot over the
territory of a contracting State without special authorization by that State and in accordance with the termsof such authorization. Each contracting State undertakes to insure that the flight of such aircraft without apilot in regions open to civil aircraft shall be so controlled as to obviate danger to civil aircraft.” (ICAO,
1944)
Recent market growth of commercial drones
Drone market forecasts vary considerably as they define the market boundaries differently e.g. military
versus civil or commercial versus leisure use cases, but all agree that drones will be a multi-billion dollar
market within the next five to ten years. A 2016 PriceWaterhouseCoopers (PwC) global report on thecommercial applications of drone technology estimated a volume of USD 127 billion for a civil-drone
powered solutions market for addressable industries (measured by cost of labour and services that have ahigh potential for replacement by drones) (PwC, 2016). Goldman Sachs projected a global market size of
USD 100 billion for the period from 2016-2020, which included a USD 13 billion forecast forcommercial/civil operations and an estimated total spending on drones (both military and civil) of USD 17.5
billion in the United States, USD 4.5 billion in China and about USD 3.5 billion in the United Kingdom(Goldman Sachs, 2016). A 2018 global survey by Blyenburgh, (2018) identified an expected three-foldincrease in missions for the transport of goods between 2017-18 (albeit starting from a very low base). It
also identified passenger drones as a growing, but miniscule market and projected the outlook for the useof drones for market sectors such as construction, maintenance and remote sensing as stable.
Regarding the number of drones, a 2016 report by Gartner projected that there will be ten times morecommercial drones than manned aircraft by 2020. This would mean about 230 480 commercially operated
drones around the globe in 2020, when compared with the statistics for manned aircraft fleets provided by(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

10 – INTRODUCTION

Boeing for 2016. These numbers are dwarfed by the projected global leisure drone fleet, which Gartner
calculated at three million operative units in 2017. The firm also projected that the personal andcommercial drone markets will increasingly overlap as technological breakthroughs allow the use of cheaper
leisure drones for commercial applications.
Why now? The Fourth Industrial Revolution driving drone technologies.
The recent proliferation of drones is an early signifier of the impending “Fourth Industrial Revolution”. Thisextension of the digital revolution involves the fusion of technologies, blurring the lines between thephysical, digital, and biological sciences. It is generating the technological capabilities to conceptualise andmanufacture radically different airborne vehicles, tailor them to very specific mission parameters, takeadvantage of the economies of scale from standardised building blocks and integrate drones with existing(air) transport systems. (Schwab, 2016) Suddenly, use cases that were either impossible or economicallyunsustainable for human-piloted aircraft are becoming technically possible and economically feasible.
While the Third Industrial Revolution (1980s until today) saw digitalisation permeate “just about
everything”, the Fourth Industrial Revolution is characterised by a fusion of technologies and accelerates its
velocity, scope and systemic impact. This is particularly obvious with the accelerated development of drones
and the development dynamics of related operating systems. The breakthroughs are more rapid than everbefore, as reflected by the almost daily reports of new drones moving beyond concept stage and taking
their first successful flights.
Concurrent advances in engineering and manufacturing technologies are pushing the pace of change andfuture drone capabilities and costs. These developments include sophisticated simulation models, newmaterials, dispersed battery storage, 3-D printing of large (metal) parts, biomimetic 4D printing methods
for optimised elastic surfaces. They also include novel software tools and ICT technologies such as artificial
intelligence, wireless 5G communication and the miniaturisation of electronics. All of these, and others still,
have created opportunities for drones to vastly expand into the civil aviation sector with new use cases thatare hard at present to anticipate.
Finally, the depth and breadth of simultaneous changes brought on by highly automated and autonomous
forms of transport herald the disruption of entire systems of production, operation as well as thegovernance of transport infrastructure, vehicles and services. Overall developments of artificial intelligence(AI) and automation are at the core of the challenges posed by drone operations. Martini et al. (2016) gives
a comparative review of the emerging drone laws, best practices and policies in this regard.
Looking at the long-term impact of the Third and Fourth Industrial Revolutions and plausible technology
pathways, it seems likely that unmanned vehicles will partly address future mobility needs, replacing
services on the ground, on rail, on water or in the air. The level of integration between the different typesof vehicles involved and between these vehicles and their manned counterparts and with infrastructure iscurrently open for debate, but at a minimum, there will have to be some kind of integration between
manned and unmanned vehicles in and across all modes.
Moving from science fiction to real world applications
The general population may not be ready yet to fly on a pilotless aircraft (though much of current flight isalready automated), but as with technological advances in self-driving cars, buses and trucks, drone
technologies are quickly moving from science fiction to providing services in the real world.
There is a growing interest in developing drones for a variety of mission types from start-ups to the largest
global aircraft manufacturers. In experimental situations, drones can already carry packages, transport
people, deliver humanitarian aid, inspect infrastructure and support a variety of other transport-related
uses cases.

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INTRODUCTION – 11

Eventually fully automated drones could replace manned aircraft, especially for the transport of passengers
or freight along already established routes – much like airborne fixed-route shuttle services or aerial“conveyor belts”. In other cases, they could provide new mobility options to serve remote areas, disasterstricken zones and very thin markets that, to date, have not been economically feasible to serve. Finally, in
addition to the ability to carry passengers or freight, unmanned aircraft operating as aerial sensor platforms
will soon be able to support transport and other sectors by carrying out a wide variety of missions.
The rapid proliferation of drones for leisure use can serve as an early indicator for the readiness of markets
to embrace drones for commercial transport services. However, it also serves as a reminder that large-scale
deployment of drone fleets may be slowed down by growing public concerns.
Gaining social licence for the large-scale deployment of drones
Drones are already widely available for a broad variety of use-cases, ranging from leisure uses tocommercial applications like precision farming. Indeed, the enthusiastic uptake of leisure drones across theglobe point towards a growing acceptance of drones overall.
Alongside the proliferation of leisure drones has been a growing use of drones serving transport purposes.
The latter are on the verge of scaling up from experimental use cases to potentially large, commercially
viable fleets.
With the private sector driving the development of new technologies to manufacture and operate drones
and experimenting with novel service applications, public authorities face the question of how to best
support the emerging drone market such that society benefits as a whole.
What is a “drone” in the context of this report?
The term drones is used in public discussion as an umbrella term for airborne vehicles without a pilot onboard. Other, more technical terms are also used to discuss drones in many countries and in aviation. The
most frequently used terms are Remotely-Piloted Aircraft Systems (RPAS) and Unmanned Aircraft Systems(UAS). Literature also refers to Unmanned Aerial Vehicles (UAV), Autonomous Aerial Vehicle (AAV),
Remotely Piloted Aerial Vehicle (RPAV) etc.
In this report, the term “drone” encompasses all flying vehicles without a human operator on board.
Unless otherwise specified, a distinction is not made between the different levels of automation. Theselevels range from a drone remotely piloted from the ground (within or beyond the visual line of sight [VLOS
and BVLOS]) to a fully autonomous drone requiring no human intervention in carrying out its mission.
This less technical definition is used in order toencompass a wide variety of current and emerging concepts,



encourage a view of drones as a new part of the transport system, rather than an extension ofexisting air traffic system; andbe more readily understandable for the general public.

Furthermore this report addresses drones:

Irrespective of their size and weight. This includes drones small enough to just be equipped with asensor e.g. for construction site monitoring up to full sized airplanes that carry hundreds ofpassengers or many tons of freight.



Irrespective of the altitude at which they are able to operate. This includes all classes of navigable
airspace excluding space travel.

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12 – INTRODUCTION

Irrespective of their design layout or engine type. This includes drones with a varying number ofrotors, e.g. quadcopters with four individual rotors to tilt and fixed-wing drones or combinations
thereof and powered by different engines ranging from electric to combustion and hybrid engines.



That are used to either transport a) passengers, b) freight or c) supports the performance of thetransport system. While the use of passenger and freight drones as part of the overall transportsystem is clear, support drones can be used for a wide variety of use cases for the transport sector,
e.g. drones to collect data for the better planning and maintenance of transport infrastructures, tomonitor construction sites and traffic flows as well as to guide emergency operations and otheremerging (cross)-sectoral support functions.

When employed in a commercial context. Policy and regulatory concerns for leisure drones are also
important questions and can inform guidelines for the commercial use of drones. In this report we
will focus exclusively on the commercial use of drones.



As part of a larger operational system. The term drones thus refers to both the aircraft itself andthe systems required to operate it.

This report outlines the principal policy considerations associated with the large-scale deployment ofdrones, with a focus on the next five to twenty years.

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CURRENT STATE OF PLAY – 13

Current state of play
Drone design, airspace management and service models
Drone designs vary widely depending on the missions for which they are intended. They include, but are notlimited to, quadcopter drones able to carry small payloads such as the heavily publicised pizza delivery
drones of recent years. Hassanalian and Abdelkefi (2017) present an extensive overview of drones andvarious current categorisation methods. Most common among these are categorisations based on theweight, wingspan, payload capacity or flight range and flight endurance as well as classifications based on
rotor, wing , fan or hybrid design, the selected propulsion system or mission capabilities, e.g. whether they
are capable of vertical take-off and landing (VTOL) or horizontal/conventional take-off and landing(HTOL/CTOL). Other classifications look at the type of application a drone might be used for, e.g. military
vs. civil, or passenger vs. delivery drones.
The heterogeneity of drone designs is driven by the large variety of potential drone use cases. Specific use
cases serve to specify drone mission parameters. These include at a minimum the intended payload (weightand dimensions), range, altitude and speed, but may be much more detailed in order to tailor drone design
to a specific use case, e.g. a 4-6 passenger drone operating in a dense, quiet urban area with a large
proportion of high rises and constant high temperatures.
Drones are one part of the airspace management system. The defining quality of drones, regardless of theirvehicle design or mission, is that there is no human operator on board. Accordingly, the operating system
must be able to perform all necessary tasks to fulfil a mission. The operating system includes on-board
systems and ground based control systems, ranging from a pilot within the visual line of sight of a drone to
fully automated drone control systems integrated in an artificial intelligence (AI) based air traffic control
centre with little to no human oversight. The technological advances of recent years had a significant
impact on the guidance, navigation and control (GNC) systems of drones (see Kendoul, 2012).
A major technological challenge in every day operations of unmanned aircraft will be air traffic management(ATM). A recent Single European Sky ATM Research Joint Undertaking (SESAR JU) “Roadmap for the safe
integration of drones into all classes of airspace” (SESAR JU, 2018) expects that large drones using ATM
services will be piloted remotely in a one to one relationship, while drones using U-Space services will behighly automated and supervised. U-space is a European concept for “a set of new services relying on ahigh level of digitalisation and automation of functions and specific procedures designed to support safe,
efficient and secure access to airspace for large numbers of drones. As such, U-Space is an enabling
framework designed to facilitate any kind of routine mission, in all classes of airspace and all types ofenvironment - even the most congested – while addressing an appropriate interface with manned aviation
and air traffic control” (SESAR JU, 2018). Similarly, in the USA the National Aeronautics and Space
Administration (NASA), Federal Aviation Authority (FAA) and industry are working on technologies that will
enable a UAS Traffic Management system (UTM). They envision UTM as an air traffic management
ecosystem for eventually fully automated drone operations that is separate but complementary to the FAA's
Air Traffic Management (ATM) system. The current research and development efforts will ultimately identify
services, roles/responsibilities, information architecture, data exchange protocols, software functions,infrastructure, and performance requirements for all kinds of drones services. In China there are already
UTM/U-Space systems operational on regional and national levels, which will be further strengthened
according to the China Civil Aviation Administration (CAAC) which has developed two cloud computing
systems — U-cloud and U-care — for UAV flight registration and monitoring (Zhang, 2016).

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14 – CURRENT STATE OF PLAY

The integration of current ATM systems with drones will be an iterative process: the regulatory frameworkand the operational parameters allowing unmanned traffic management systems to coordinate withconventional air traffic management will ideally continue to co-evolve progressively.
Service models and business models
The business models that will drive drone deployment and widespread up-scaling are in flux and thiscomplicates the regulatory task. As with any new technology deployment, the initial focus is often on howtechnologies can beneficially replace current ones – e.g. what can drones do that is already being done? An
immediate and related focus is how well new technologies can do better what is already being done. These
two uses are relatively easy to anticipate, but not always. For example, drone inspection of infrastructure
and the built environment is one way in which drones can be used to substitute existing practices.
Arguably, because of the characteristics of drones, these inspections can be more thorough, faster and lessexpensive to carry out. Nonetheless, when advanced sensors, including cameras, are deployed in places
where they were never expected (e.g. over private property, at the level of upper-storey windows), and thesensor platform allows persistent storage of the sensor input, new privacy-related challenges emerge.
The third category of use cases is more problematic. This is the broad category of new uses that emergethat simply were not thought possible or feasible before. By their very nature, these uses are hard to
anticipate and, when they are deployed, their potential for disruption may be high as is the uncertainty
around their staying power.
Two examples of these potential use cases outline the type of challenges that may emerge as new uses
become possible.
While the use of drones for freight and parcel delivery, especially for the last-kilometre, is foreseeable (andis currently being trialled in a number of instances) the potential for direct-to-consumer delivery, whereverthat may be, are use cases that will prove to be highly problematic from a policy perspective. If windows,
rooftops, yards or public space like sidewalks all become potential droneports, zoning, construction, building
regulations, property law (including air rights), private contract law regarding the use of shared spaces ofcollective dwellings, and laws regarding noise and visual amenity will all come under pressure. The risk ofunwanted outcomes through poor, or inexistent, coordination across these regulatory spheres is high.
Large-scale, persistent, and ubiquitous surveillance is a task that military drones already routinely
undertake in conflict zones. These create high-definition, multi-spectral, nearly complete records of “reality”
that are useful for both incident prevention and post-incident forensic investigation (e.g. tracking
movements of people and vehicles backwards in time). These surveillance capabilities are starting to be
deployed by law enforcement agencies for event-related use or, more broadly, for persistent surveillance on
the basis of existing laws relating to video surveillance. It may be that commercial operators soon leveragesuch capabilities to provide new services based on (even more) ubiquitous location and tracking-based
capabilities to public authorities and, ultimately, to consumers. Combined with new data analytical
capacities, like vehicle, facial, gait or audio recognition or with motion pattern recognition (e.g. remote
identification of pedestrians, cyclists, older or younger people, etc.), a raft of new services become possible- as do a range of potentially privacy-abusive practices. (see section “Safety and Security first”)
The intrinsic and unplannable nature of these, and other, hard-to-anticipate use cases, make it even more
important to agree robust principles to frame drone deployment going forward. No general classification ofdrones and operating systems exist due to rapidly evolving technologies and missions.

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Due to the rapidly evolving technologies and expanding scope of missions, there is currently nointernationally agreed categorisation method for drones available. Despite the ongoing work e.g. at Joint
Authorities for Rulemaking on Unmanned Systems (JARUS) and the Aviation Safety Agency (EASA) it seems
likely that a definitive, all-encompassing, globally accepted categorisation method may not emerge for quite
some time, posing additional challenges for regulating authorities and standardisation bodies.
For this report we included a wide variety of drone designs and mission types when analysing which policy
areas could potentially be affected by the large-scale deployment of drones. Some more detailed examples
of current and future drone designs and service models and the questions raised when envisioning theirlarge scale deployment are described in the section “Scaling up”.

Regulations for drones
The commercial use of drones represents one of emerging challenges for regulators linked to disruptive
technological changes. As a critical tool in the hands of government to influence behaviour, regulation may
support, hinder or act neutrally in the adoption and development of new technology. When new products
and technologies emerge, the adaptability and suitability of existing regulatory frameworks is put to thetest. The twin challenge for regulators is to ensure that innovation can flourish while at the same time
mitigating potentially adverse economic and societal impacts that arise from disruptions
Current and emerging challenges
As drones are the latest addition to objects flying in regulated airspace, existing regulatory frameworks forthe aviation sector tend to apply to commercial drones (Jones, 2017). However, regulatory regimes
designed for different and older technologies are in many instances not adapted to many drone use cases,
e.g. leveraging the safety benefits of being able to let a drone in distress crash in a safe place as there is nocrew to protect. In some cases, drones may be in a regulatory void with very little control over their
particular conduct. As a result, aviation standards, laws and regulatory approaches require constant
updating (Clarke and Bennett Moses, 2014).
At the national level, the rationale for updating and even introducing regulations when dealing withcommercial drones is mainly underpinned by public safety and security concerns (Stöcker et al., 2017).
Similarly to existing aircraft, drones can pose threats to people and property in the case of technicalfailures, collisions or hijacking. However, in contrast with manned aircraft, drone activity is moreheterogeneous and is therefore harder to anticipate. In addition, the costs of detecting drones violating
rules and related investigations are higher (Clarke and Bennet Moses, 2014).
National regulations have to date displayed a wide range in their level of restrictiveness of drone activity,
going from effectively banning commercial drones licensing to promoting very permissive regimes. Despite
this diversity, meta-reviews (Jones, 2017; Stöcker et al., 2017) of recently approved drone regulations
identify some common elements across most jurisdictions:

Administrative rules (e.g. pilot’s licence and training, aircraft registration, insurance requirements)



Operational limitations (e.g. maximum weight, flight altitude restrictions, VLOS)Airspace management rules (e.g. flight authorisation, restricted flying zones, maximum altitude).

Flexibility is also an important characteristic of emerging drone regulation, in two ways. First, requirements
across administrative, operational and airspace rules are modulated based on the different characteristics ofcommercial drones. These encompass size (weight), flight altitude, the role of the pilot (if any), the degreeof autonomy and the purpose of the drone operation. The pervasive growth of commercial drones also leads(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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to a blurring of the traditional administrative boundaries. Michel (2017) found that 133 communities, home
to 30 million inhabitants in 31 US States have some kind of regulation pertaining to unmanned aircraft.
At international level, this translates into the need to develop international standards and principles for theuse of drones as advocated by the ICAO, the UN agency for aviation. In addition JARUS (Joint Authorities
for Rulemaking on Unmanned Systems), a group of experts from the national aviation authorities in chargeof designing a set of common technical and operational requirements for the integration of drones in theairspace and at aerodromes, has been set up. Efforts in this area are ongoing at the time of writing and are
not included in the review.
A second challenge linked to the blurring of administrative boundaries at subnational level deserves further
attention. When drones are allowed to operate in urban areas, the higher the number of permitted
movements and/or deliveries is, the higher their operational benefits and competitive advantage will be(SESAR JU, 2016). At the same time, public safety concerns are most prominent in cities. Hence, withurban operations the trade-offs between more permissive and more restrictive rules become mostapparent. A more detailed analysis of urban questions can be found in the chapter “Challenges for policy
makers”
Therefore, our report identifies the development of commercial drone operations in and around urban areas
as one of the greatest challenges for regulators and policy makers over the coming years. Regulatory issues
are inevitably linked to infrastructure development questions in this realm: Whose responsibility is it todevelop ‘safe’ landing zones for drones? Should these designated aerodromes be regulated differently fromexisting airports? Heavily preoccupied with airspace interactions (and rightly so) regulators may beoverlooking the question of land-use interactions.
Emerging national regulatory frameworks for commercial drones
The regulation of commercial drones at national level has typically begun with the extension of existing
regulatory frameworks for the aviation sector to commercial drone operations, given the similarities
between manned and unmanned aircraft.
An example (Masutti, 2016) is offered by the Italian Navigation Code, which extended the definition of
aircraft to include drones. In 2005 and 2006, the Italian legislature proposed a new definition of aircraft
and, as a consequence of this decision, Article 743 of the Navigation Code now states: “Also consideredaircraft are remotely piloted aircraft systems, as defined by specific laws and regulations issued by the CAA
and for those military ones as defined from the decrees issued by the Ministry of Defence” (Navigation
Code, 2006). The consequence of this decision is that all rules established by the Code for manned aircraft
are, as far as is possible, applicable to unmanned aircraft.
Similarly, insurance and liability requirements have been extended to commercial drones across the EU
based on the existing framework of Regulation 785/2004 which defines third-party liability insurance
requirements for aircraft based on their mass. However, applying Regulation 785/2004 to drones has
required a number of clarifications and may need further adjustments. For instance, the European
Commission clarified that rules do not apply to model aircraft and hobbyist drones; national legislators (e.g.
the House of Lords in the United Kingdom) called for the minimum amount of liability to be raised;independent studies (Steer Davies Gleave, 2014) raised warnings about the costs of enforcement and therisk of accidents involving uninsured drones. Hand in hand with these issues, the certification procedures ofsafety-critical products and systems will bring significant challenges to both suppliers and regulators toenable commercial services.
While they represent a good starting point, existing regulatory frameworks may be insufficient to deal withthe complex and specific challenges raised by commercial drones, and further technological developments
such as collision avoidance systems could soon render them obsolete. There are parallels here with the(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

CURRENT STATE OF PLAY – 17

need to update regulatory frameworks ahead of the introduction of automated vehicles such as driverless
trucks on public roads (See Box 1 “The regulation of self-driving trucks”).
Disparate national regulations
The proliferation of national rules and laws in recent years also highlights one of the main issues that
regulators are grappling with while they try to promote the safe use of commercial drones: that thepotential damage of incidents involving drones is also largely unknown given the absence of historical
records. The weight of commercial drones may be only one of the criteria determining their potential
damage and hence appropriate insurance requirements, for example; other factors such as speed, thematerial and characteristics of the airframe and the presence of parachutes also play a role.
This diversity also reflects the reality that there are various categories of commercial drones, differing insize (weight), flight altitude, the role of the pilot (if any), the degree of autonomy and the purpose of thedrone operation. The requirements across administrative, operational and airspace rules are modulated
based on the different characteristics of commercial drones in most national regulations. A crowd-sourced,
constantly updated “Global Drone Regulations Database” can be found online (UAViators, 2014). An
overview of the detailed provision in the United States, the European Union and China is provided in the
Annex.
For a global summary, the most comprehensive review of national regulations carried out to date (Jones,
2017) identifies a handful of countries where outright bans (e.g. Argentina, India, Morocco) or effectivebans due to very restrictive regulations (e.g. Chile, Colombia, Nigeria) are in place and no commercial
flights have been approved. Next, around 20 countries permit drone use for commercial purposes under therequirement of VLOS and a limit of one drone per pilot. Population restrictions often accompany VLOS andexperimental BVLOS operations – these are allowed in 11 countries, including the United States, on a caseby-case basis. In France, Canada and Poland drones cannot fly over heavily populated areas and are only
allowed in certain zones. Towards the more permissive end of the spectrum, in China, administrative rules
vary significantly depending on the mass and type of drones but operations including BVLOS are authorised
once all requirements are complied with. Drone delivery is explicitly banned, however. National regulations
are in constant flux, resulting in most recent changes across the whole spectrum from abolishing flight bans(e.g. in India) to establishing procedures to allow flights over heavily populated areas, e.g. for France.

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Box 1. The regulation of self-driving trucks.
Driverless vehicles already operate in controlled environments like ports or mines, and trials on public roads areunder way in many regions including the United States and the European Union. Within the next ten years, vehicle
operators and fleet managers will likely accelerate the adoption of these vehicles due to the considerable labour
cost reductions that they bring. Other benefits of automation to society include lower emissions due to more
efficient routing and better safety by reducing the incidence of human error. At the same time, the transition toautomation presents a number of political and regulatory challenges that the governments will have to address.
The adoption of driverless vehicles in freight transport will carry profound impacts on employment. There will be
job losses among drivers while other jobs will be created, especially linked to the support and maintenance of newvehicles in operation. Potentially, some on-board tasks will also be required. The challenge for policy makers is to
mitigate the negative social impacts of driver job losses, whilst balancing the social status of the newly createdjobs with the efficiency opportunities of the road transport industry.
The current regulatory framework in road transport (which in the European Union includes e.g. EC Regulation No
561/2006 on working time, EC Directive 96/53/EC amended by Directive 2015/719/EC on the weights anddimensions of vehicles) has been developed and implemented for a situation in which the driver is present in thecabin of the vehicle. To reach the underlying policy goals of economic efficiency, equity and sustainability, all roadtransport legislation will need to be adapted to support the implementation of driverless vehicles. In order toensure the highest safety standards during the introduction of driverless vehicles on public roads, standardisationof vehicle technical characteristics at the international level will also be required, and work is ongoing at the
UNECE World Forum for Harmonization of Vehicle Regulations (WP.29).
The lack of drivers on board automated road vehicles presents an enforcement challenge too, because the current
paper-based control procedures cannot be carried out in the absence of personnel on board. This calls for thedevelopment of completely new data-driven enforcement procedures, which would enable checks and inspections
to be carried out without hindering the flow of goods and undermining the efficiency gains of driverless vehicles,
possibly even without stopping the vehicles.
All of these challenges will require new and enhanced approaches for data collection, sharing and analysis. Further
cooperation will be necessary between public authorities, transport operators and vehicle manufacturers. Datadriven regulation based on live feeds and digital inspections should therefore become the norm. Greater dataneeds will also raise challenges with respect to issues of ownership, storage and dissemination of data.
Sources: ITF (2017a), ITF (2017b)

Cloud technology to monitor drone operation in China
To better monitor whether or not unmanned aircraft violate these regulations, China has created an
unmanned aircraft cloud that monitors the activities of all unmanned aircraft in that country (Wei et al.,2016). The cloud is usually passive, collecting data on location, speed and altitude. However, China has
geofenced certain areas where unmanned aircraft operations are prohibited. Unmanned aircraft weighing
more than 4 kg empty or more than 7 kg with payload are also required to have “geofencing” software on
board that would sound an alarm to the operator should the unmanned aircraft enter a prohibited area.
The unmanned aircraft cloud is a cornerstone of how China intends to manage the operation of the over
20 000 unmanned aircraft currently flying there. The cloud is not intended to be a monopoly as multiple
providers can each offer their own version of the cloud. Chinese regulations specify the requirements of acloud provider, who must meet the requirements of the civil aviation authority of China as well as local
authorities and the military. Cloud providers are also required to supervise, record, and monitor the pilots
and operators of unmanned aircraft and must report the following to the civil aviation authority every six
months:numberofunmannedaircraft

using

their

systems,

numberofoperators,

technology

improvements, difficulties, accidents and incidents.

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Several countries including Sweden and the United Arab Emirates have adopted the most permissive
approach to drones and have designed licensing regimes to accompany the use of experimental BVLOS
operations.
The potential for international harmonisation
Currently aviation is built on the development of international standards, translated into national laws thatenable such a global industry to operate in a very similar fashion around the world. The fragmentation ofnational regulations clearly reflects different sensitivities to the public safety risks posed by drones.
However, it may also slow down the uptake of drone technologies in countries with the most restrictive
regimes and could render operations economically unviable in countries with very high regulatory
requirements.
The benefits of an international regulatory approach to commercial drones may not be as clear as for themanned aviation sector (since commercial drone operations are not yet international in nature) but there
are multiple benefits of international regulatory cooperation in this field too, not least the ability to update
safety standards at the global level based on the most recent evidence. First examples of governmental
international co-operation for cross-border drone operations in Europe are trials by the European Maritime
Safety Agency (EMSA) and FRONTEX, the European Border and Coast Guard Agency to surveil maritime
borders. Moreover with introduction of large, long haul freight drones the need for internationallyharmonised regulation will become even more apparent.
Global players driving the commercial drone industry
The industrial configuration of the commercial drone sector is increasingly international. Existing
multinational companies active in digital, aviation, distribution and delivery services already operating inseveral countries are entering the market. Both drone manufacturing and ancillary services (e.g. softwaredevelopment, insurance) are carried out by global companies. In addition, the sector is consolidating
through a number of mergers and acquisitions as well as the rise of system operators similar to Uber that
operate under a ‘Drone as a Service’ model striking contractual arrangements with individual operators.
For all these companies working across national boundaries, greater harmonisation translates into lower
administrative barriers and costs when entering new markets. Therefore the industry itself is likely to put
continued pressure on harmonisation and will certainly continue to provide insights to regulators in order tostreamline new rules and laws. Most future scenarios also foresee the rise of international drone operations.
The prospects for international harmonisation are highest in the field of technical and safety standards, andcooperation in R&D for technologies also looks promising. Cooperation is likely to intensify in the field ofairspace management too, building on the increased success of joint airspace management initiatives formanned aviation and the need to integrate larger drones with existing air carriers. In this field, concepts
such as low-level dedicated airspace for small commercial drones may also be adopted in a relatively
uniform way internationally, should trials lead to positive outcomes.
ICAO will play a key role for international regulatory harmonisation. It is currently backing the creation of asingle global drone registry, as part of broader efforts to come up with common rules for flying and tracking
unmanned aircraft. The single registry would eschew multiple databases in favour of a one-stop-shop thatwould allow law enforcement to remotely identify and track unmanned aircraft, along with their operator
and owner (Creamer, 2017). ICAO has also been working with its member countries, industry andstakeholders to develop single registry standards. It issued the Unmanned Aircraft Systems circular (ICAO,
2011) which sought information on the application and usefulness of unmanned aircraft in order to develop
a regulatory framework and guidance material that would enable unmanned operations to take place in a(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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similar fashion around the world. ICAO is also working on amending 18 of the 19 annexes of the Chicago
Convention in order to account for unmanned aircraft.
At the European level, member states are cooperating on the issue of drone standards and regulations witha view to establishing a comprehensive regulatory framework for all drones operating in the European
Union in 2018. The European Commission’s efforts are supported by the Aviation Safety Agency (EASA) andbuild on the work of JARUS, a group of experts from the National Aviation Authorities in charge of designinga set of common technical and operational requirements for the integration of drones in the airspace and at
aerodromes, as well as ICAO.
However, harmonisation of operational and administrative rules is a much greater challenge. In the spaceof a few years, the different national regulations adopted across the world have shown considerable
divergence as discussed above. The main areas of dissent have emerged around:

BVLOS operations: “Beyond visual line of sight” means flying an unmanned aircraft without thepilot having to keep the unmanned aircraft in visual line of sight at all times. This means that thedrone’s remote pilot must be able to respond to or avoid other airspace users by visual means as
the safest way to reduce the risk of collisions and other accidents. The number of countries offering
derogations and allowing BVLOS under special permits has increased in recent years, but the basic
requirement of VLOS has remained in place in most countries.



Flying over populated areas: the second most common restriction to commercial drones is theoperational ban over populated areas, usually cities and large public events. While it is not difficult
to understand why such restrictions are in place, they also limit drone operations where theirbenefits may be highest: in urban settings.

A more detailed discussion about drones in urban environments follows in the section in “Challenges fortransport policy makers”.

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Scaling up
How far citizens are willing to go to accept the deployment of drone fleets will depend on theirunderstanding of the balance of benefits and disbenefits that may result from scaled-up use of drones. It
will also depend on the successful mitigation of potentially adverse effects via the development ofappropriate regulations.
Looking at the many different designs of drones and emerging specialised use-cases, it is intuitively obviousthat a framework to assess the benefits and challenges for the overall transport system must be introduced.
At the same time, it is essential to understand that new players are entering the “aviation market”, e.g.
electronic retail companies, new emerging B2B and B2C service providers, telcos and other advanced
system providers who perceive new business opportunities. Different business and operational cultures
between those new players and the established aviation community – particularly their contrasting businesstime frames between 5-10 years for the former and 20-40 years for the latter – need to be understood,
addressed and balanced by the involved communities and the regulators. Moreover as regulators are facedwith similar, digitally driven disruptions for surface transport modes (e.g. automated ground vehicles,
shared an/or on demand transport options, etc) the large scale introduction of drones will benefit from closeinteractions between all involved transport policy makers to create more systemic and co-operative multimodal transport solutions.
Three different use cases are presented below. They examine drones used for a) passenger transport, b)
freight transport and c) drones to support the better management of the overall transport system.
Future visions for scaled up drone fleets are analysed vis-à-vis the technology currently available, service
models, regulatory status and the envisioned benefits and challenges. Finally, drones to support
humanitarian missions are examined to understand a possible pathway for the introduction of drones for
specific missions and how drones can gain social licence to grow.

Passenger drones
Imagine travelling downtown from an airport in San Francisco, Tokyo or Dubai in a convenient 5-seater
passenger drone in a matter of minutes instead of being stuck in traffic for hours. Imagine reducing youraverage commuting time by 80% facilitated by a flying taxi service operating in your region. Imagine
travelling from Seoul to Paris in an airplane carrying hundreds of passengers without a pilot on board.
Why passenger drones?
Since the 1950s, civil helicopters have been flown over (peri-)urban areas and many cities have dedicatedplaces at which helicopters can land. Commercial passenger-carrying operations have largely been confinedto the corporate or charter markets, however, transporting just small numbers of passengers.
There are five major arguments put forward to invest in passenger drones capable of ferrying from a single
traveller up to hundreds of passengers: First, drones provide enhanced connectivity to remote regions.
Second, scheduling and routing becomes more flexible. Third, drones may contribute to congestion
reduction. Forth, drone services reduce infrastructure investment costs and, lastly, they address thepotential shortage of pilots.
Apart from high volume passenger transport with rail, light rail or metro lines, a large share of passenger
urban and inter-urban transport today relies on an extensive road network in combination with cars or bus
services and is often subject to significant congestion at peak periods. A 2014 INRIX study calculated that
Americans spend 6.9 billion hours per year stuck on congested roads. It also put the total economy-wide(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

22 – SCALING UP

cost in France, Germany, the United Kingdom and the United States combined, at USD 200.7 billion in2013, and expected it to increase by 46% by 2030.
Shortening intra-urban and intra-regional commuting times and relieving some people from the daily stopand-go traffic of (sub-)urban transportation is therefore one of the most cited reasons for starting to invest
in the development of a passenger drone service.
Moreover, as traffic growth is outpacing investment in infrastructure building and maintenance, congestion
could become an even bigger drain on further economic growth. Even more so in countries that currently
lack adequate surface transport networks and regional connectivity. The Asian Development Bank in a 2017
study projected that USD 8.3 trillion would be needed for transport infrastructure investments in Asia’s
developing countries alone from 2016-2030 to enable continued economic growth. That is an annual
average of USD 520 billion needed to mostly maintain existing transport infrastructure and continue toconnect to yet inaccessible regions. Passenger drone services might help to connect to remote, often
indigenous communities, with reduced impact on the existing habitats.
Opening up another, less congested travel path in the air that is currently either entirely unused or servedby only a few helicopter companies by introducing passenger drone services seems a compelling proposal toa) connect underserved regions and cities, b) alleviate surface transport congestion and c) significantly
reduce transport infrastructure investments.
From the service operator point of view two major factors drive the business viability of passenger dronescompared to the already available helicopter services. First, cutting the pilot and crew staffing cost toalmost zero (depending on the degree of automation of take-off/landing and cruise) and, secondly, thereduced per vehicle manufacturing, maintenance and operation cost due to novel designs and economies ofscale.
When discussing regional or long distance drone travel the already high automation level of existing
passenger aircraft is often cited as an excellent starting point for a fairly quick transition to remotely piloted
or fully automated distance air travel. Referencing the imminent introduction of automated surface vehicle
automation and the simpler navigation demands in the relatively less crowded navigation space, at least
during cruise, SESAR JU (2016) suggests that long distance passenger transportation without pilots onboard could be introduced from 2030 onwards. This is also an increasingly attractive prospect for anindustry facing a dearth of pilots, underlined by the 2017 Boeing pilot study that projects that thecommercial aviation industry will need 637 000 new airline pilots worldwide between now and 2036. That is
an average of 87 new pilots graduating per day, or almost four pilots every hour.
For the congestion mitigation potential of passenger drone services to be realised, travellers must feel thatthe safety, accessibility, quality and affordability of the services provided are sufficient for them to forego
the use of cars for certain trips – especially during peak hours. To significantly decrease infrastructure
investment spending the long-term reliability, availability and affordability of drone services between
sparsely connected regions must be guaranteed. There are important equity considerations to address froma public policy perspective, however.
One of these is the degree to which drone passenger traffic will truly alleviate congestion for the overallsystem (and thus benefit all) or simply enable some, more affluent, travellers to avoid personallyexperiencing congestion. These considerations should not influence whether or not such a use case makes
sense – it may very well be a commercially attractive proposition – but it will impact the extent to which
public authorities should go out of their way to facilitate it via investments or permissive regulatory
treatment.
Another fundamental point to consider for passenger (and freight) transport drone use cases that are
predicated on congestion alleviation (or travel time savings) is that drone technology deployment is only

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one of a set of co-mingled and co-evolving technology changes within and outside of the transport sector.
Where these are likely to have an impact on congestion or travel times, they will also have an impact on
the viability of or benefits from specific drone use cases. For instance, a city that moves to a unified trafficsystem based on self-driving fleets and high-capacity public transport may not experience congestion thus
eliminating one of the principal selling points for drone services. From a public policy perspective, it isimportant to keep in mind that system-wide efficiency improvements remain a fundamental policy objective
even as the system itself changes.
Moreover, the energy consumption and emission profiles per passenger kilometre travelled and thus theeffect of the introduction of drones to the Paris Agreement, reached at the 21st United Nations Framework
Convention on Climate Change (UNFCCC) COP 21 remain yet unclear.
Passenger drones today
No regular passenger drone service operates at present. In 2017/18, a variety of passenger drones havemade maiden flights, however, operating under experimental licences in several countries, and many more
prototypes have been tested at various global test sites or showed their capabilities at trade shows.
New helicopter-sized vehicles have been under development since the 1980s, with a focus on developing
aircrafts that are capable of vertical take-off and landing, so called VTOLs. A VTOL is a vehicle that does not
require a runway because it takes off, hovers, and lands vertically thus being better suited for urban
transportation where runways are not available or could only be built at prohibitive cost. Design proposals
are suggesting various numbers of rotors or a combination of rotors and propellers, sometimes attached toshort fixed wings, mainly to improve steering capabilities and forward thrust during cruise. Recognizing theenergy inefficiency and high noise profiles of traditional helicopter engines, a large number of the newly
proposed vehicles include an electric or hybrid-electric engine. The range of helicopter-sized passenger
drones will be about 100 kilometres, according to a study by Deloitte (Lineberger et al., 2018).
The following paragraphs highlight a few examples of the current state of the art for different deployment
scenarios:
Single passenger drone in an urban, sub-tropical scenario
The EHang 184 was developed by Chinese drone manufacturer EHang, based in Guangzhou. Its multi-rotor
design uses an electric engine and is capable of carrying up to 100 kg or one individual passenger withbaggage. It made its first public flight in China in February 2018. It was announced that it could fly at a
maximum of 160 km/h for 23 minutes at sea level, or ten minutes at 100 km/h at a higher altitude. The
manufacturer claims to have conducted over 1 000 test flights with a human on board, including special
tests such as a 300-metre vertical climb, a weight test with an over 230 kg payload, a routed test flightcovering 15 kilometres, and a high-speed cruising test that reached 130 km/h. The EHang 184 was also
flown in a variety of weather conditions including fog, heat and gale-force winds of up to 50 km/h and atnight.
In 2016, EHang, Nevada’s Governor’s Office of Economic Development and the Nevada Institute forAutonomous Systems agreed on a collaboration that would have paved the way for test flights at Nevada’s
FAA UAS Test Site, but so far FAA approval for testing has not been granted.
In 2017, EHang obtained the Special Flight Permit for civil aerial vehicles issued by Civil Aviation
Administration of China (CAAC). The CAAC continues to work with EHang and other Chinese drone
manufacturers to jointly establish relevant airworthiness standards for drones in its UAV Technical Experts
Committee to create systematic industry polices and standards (EHang, 2018).

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Two-passenger drone in an urban, high heat scenario
As part of the “Smart Dubai” strategy that also includes a driverless metro, Dubai has been inviting several
passenger drone companies to help achieve the target of 25% of “autonomous journeys” of all trips by
2030.
In September 2017, the first actual test flight with a passenger on board a drone in Dubai took place with
the Volocopter, an 18-rotor drone created by a German start-up of the same name and funded by Daimler.
The Volocopter is powered by an electric engine; the diameter of the rotor rim including propellers
measures just over seven metres. The Volocopter carries a maximum payload of 160 kg, has a maximum
flight time of approximately 30 minutes, a range of 30 kilometres and a maximum airspeed of 70 km/h. It
takes two hours to recharge (Ong, 2017).
Dubai announced that the trial of drone taxi services would be continued for five years. During this time theDubai’s Road and Transport Authority will cooperate with the UAE General Civil Aviation Authority and theDubai Civil Aviation Authority in order to develop requirements for regulations, standards, and certification
requirements (PWC, 2017).
Two-passenger drone for regional service in a temperate climate zone
In New Zealand, a start-up called Kitty Hawk launched its two-person drone Cora for testing in March 2018.
Funded by Google co-founder Larry Page, Cora has a wingspan of 11 metres, but can take off vertically,
then using a propeller at the back for propulsion. Powered by an electric engine, it flies at a maximum
airspeed of 180 km/h for around 160 kilometres at a time up to an altitude of 915 metres (Kitty Hawk,
2018a).
Kitty Hawk was originally launched in California but found it difficult to get approval from US regulators for
an official certification and the launch of a commercial service. Therefore, it moved its operations to New
Zealand, where the regulatory authorities committed to devise a certification process for a drone-taxi
service within the next three years (Sorkin, 2018).
A statement published at the launch in March 2018, by New Zealand Ministry of Business, Innovation and
Employment GM Science, Innovation & International said: “We saw Cora’s potential as a sustainable,
efficient and transformative technology that can enrich people’s lives, not only in New Zealand, butultimately the whole world.” (Kitty Hawk, 2018b)
Other passenger drones at advanced concept stage
Beyond the above examples, many other start-ups and leading aircraft manufacturers are working on
passenger drones. Some have been presented at trade shows, including the Consumer Electronics Show
(CES) in Las Vegas.
Airbus’s Vahana drone, built by the company’s Silicon Valley outpost A3, completed a first test flight at
Oregon’s Pendleton Unmanned Arial Systems Test Range in February 2018. The Vahana is another VTOL
single-passenger drone, but with wings and tail sections that rotate from vertical to horizontal as theaircraft lands and takes off. The battery-powered drone is six metres long and 5.7 metres wide, with aprojected range of 100 kilometres. Airbus’s goal is to bring the Vahana to market in the United States by2020 (Collins, 2018).
Boeing has not publicised civic passenger drone tests yet. In 2017, however, it bought the Aurora Flight
Sciences, a company whose projects include a flying taxi developed with Uber Technologies’ Elevate project(Hawkins, 2017). Aurora's main line of business is the military aircraft sector, where it has won several
contracts from NASA and DARPA, including for a VTOL aircraft. It is unclear whether Aurora will continue towork on civil passenger drones with or without partnership with Uber. While Uber itself is not developing
any drones, the firm is working on design requirements for aerial passenger vehicles and co-operates with(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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several drone manufacturers, with a view to launching an aerial taxi service for five to six passengers and asmall amount of luggage with pilots on board in Dubai, Dallas and Los Angeles by 2020. The company says
it expects to transition to autonomous drone transport by 2030 (Uber, 2016).
Lilium, a German start-up that attracted USD 90 million from investors led by Chinese internet giant
Tencent, is proposing a different aircraft design: The Lilium Jet has a rigid winged body with 12 flaps
carrying three electric jet engines each. Depending on the flight mode, the flaps tilt from a vertical into ahorizontal position. The drone can carry five passengers. Lilium says that wing-borne, electric-powered
drones can travel five or six times the distance of drone designs with rotors (Auchard, 2017).
Workhorse, a US-based manufacturer of electric vans who partners with logistics firm United Parcel Service(UPS) is proposing a drone powered by an electric-gasoline hybrid engine. The vehicle named SureFly
accommodates two passengers and is said to have a range of 113 km. Workhorse plans Surefly to function
autonomously within the near future (Zart, 2018). The company received permission to fly by US regulators
in January 2018; the SureFly’s maiden flight, planned for the 2018 CES in Las Vegas, had to be postponeddue to rainy weather (Lee, 2018).
Passenger drone service models
Currently passenger drones aim mostly at providing unmanned aerial taxi services. These services directly
target an existing (and expensive) niche market currently dependent on manned helicopter-based services
that link airports and central business districts or different parts of highly congested urban areas. These areregulated services that are part of the broad offer of licensed commercial transport operations in cities, but,because of their limited scope and the small niche market they serve, are typically not part of broader
strategic transport policy, including aspects relating to investment or fare regulation.
Open questions for transport policy makers include: will taking the pilot out of the aircraft change this? Will
enhanced and unmanned aerial taxis form an integral part of broader transport policy and objectives? Will
passenger drones soon evolve towards larger-capacity shared aircraft that can move a significant number ofpeople at peak hours in ways that contribute to congestion reduction while meeting other noise,
environmental and equity imperatives?
Aerial passenger drone services will certainly find a market. Yet the extra regulatory space given to suchservices will have to be guided by broader transport policy objectives.
Major policy concerns with regards to passenger drones
The main policy concerns regarding passenger drones are the safety and security of vehicles and of
airspace management systems. Other future challenges centre around the air/ground interfaces and theimpact of future drone ports on noise levels, emission exposures and the visual amenity as well as on thesocial equity.

Freight drones
Imagine getting your pizza delivered right through the window of your skyscraper apartment by a smalldelivery drone. Imagine receiving your weekly supplies needed to run your business in a remote region by adrone that can carry a payload of up to 25 kg - which will also pick up your products and shuttle them tomarket when ready. Imagine large cargo drones delivering tons of freight like an intercontinental conveyor
belt made of drones.

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Why freight drones?
Drones for freight transport have four advantages:


They avoid surface congestion and delays.



They allow faster, customised delivery.

They enable low-cost air cargo services as drones are cheap to operate.



Freight drones improve market access for remote places.

Airfreight currently accounts for about 1% of world trade calculated by tonnage, but roughly 35% of world
trade when calculated by the value of shipped goods. Unmanned freight transport - especially when looking
at drones the size of regional or intercontinental cargo aircraft - may lower the cost per ton significantly.
Hoeben (2014) describes the reasons for cost reduction: lower personnel cost due to a switch to groundbased crews (e.g. remote pilots or controllers), increased flexibility of flight schedules and lower fuel costs.
Heerkens (2017) expects that the majority of advantages will stem from the efficient transport of relatively
small loads, flexibility in scheduling and thus increased productivity for large-scale unmanned freighttransport. The spectrum of drones ranges from those with a 300 kg payload and 500 km range to drones
with a 15 000 kg payload and a range of up to 15 000 km. Suggested commercial business cases include:
flights from the Chinese hinterland to assembly works at the coast, flights from eastern-European
manufacturers to their western-European clients, Intra-continental package transport like DHL and others
presently provided by Boeing 737-sized transport or smaller aircraft such as the ATR42. Van Groningen(2017) analysed the cost efficiency of a long-haul drone transporting a 5000 kg payload weekly between
Stuttgart, Germany and Shenzhen, China and compared it to other possible modes of transport. It
concluded that for this specific scenario and when shipping automotive goods a cargo drone would be morecost effective than a Boeing 777 by 17%, or 35% more efficient than by sea. However, the study also
showed that the achieved efficiency depends largely on the amount of freight demand and its timing, with aminimum of a 1250 kg of high value payload transported between Stuttgart and Shenzhen when competingwith a Boeing 777 or 500 kg when competing with rail.
Thus, SESAR JU (2016) expects that initially drone deliveries will be available in areas with very low
accessibility and generate new growth rather than displacement of surface deliveries.
They also forecast a very low displacement rate for current standard urban freight delivery, but expect a
growth market for premium services and high value goods. Urban premium delivery with goods might becost efficient for suppliers if a single operator can control at least 15 freight drones built for payloads of up
to 2.5 kg. This small scale, (sub)urban business cases have attracted the most media attention due to highprofile experiments by Amazon and other e-commerce companies.
At the same time – or even before drone freight delivery becomes feasible - ground freight transport will
also fundamentally change with the (phased) introduction of automated trucks, which might alter thecurrently projected business cases for freight drones significantly, particularly in areas with establishedsurface networks.
Freight drones today
Currently no regular large-scale drone fleet is operating for freight delivery. But, when compared topassenger drones more freight drone services are already operating for specific use cases. Small freightdelivery drones, for payloads of up to 5 kg are being trialled in various countries in everyday conditions,e.g. by FedEx, UPS, DHL, Amazon and Alphabet and the potential of large unmanned cargo planes is being
explored by the military in several countries and its transfer to civil transport studied by global aircraft
manufacturers.

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Humanitarian services are currently the most prominent use-cases for freight drones in a small to mid-sized
payload category. (see “Drones for humanitarian aid and development projects”).
The following paragraphs highlight a few examples of the current state of the art for different deployment
scenarios:
Food delivery service to end-consumer over difficult terrain in low-density city
AHA, one of Iceland's largest e-commerce companies, started to use drones for regular goods delivery inReykjavik in mid-2017. When launched it operated about 20 flights a day, if weather permitted, along one
route between two parts of the city that are separated by a river, cutting down delivery times by about 20
minutes and transport cost by about 60% compared to regular ground delivery operations.
The drone itself was provided by Flytrex, an Israeli start-up, it has a multi-rotor design, a payload of up to
3 kg, a flight time up to 35 minutes and operates about 50 metres above ground.
The operation was launched following intense public information and community engagement sessions andreceived regulatory approval from the Icelandic Transport Authority (Icetra). AHA and Flytrex continue towork with Iceland’s regulatory authorities to increase the number of routes as well as experiment withdifferent air/ground interfaces for delivery (Banker, 2017).
High value goods delivery with a combined drone/van system in dense city context
A combined drone-ground vehicle delivery concept is currently being tested in Zurich by US drone systems
developer Matternet in conjunction with Daimler and the Swiss e-commerce platform siroop aG. Its goal isto speed up delivery times and create safe air-ground interfaces for drones by using the roof of a van as thedesignated a landing zone.
The employed drone can carry packages of up to 2 kg for approximately 20 kilometres, and it lands on theroof of Mercedes-Benz Vans at four pre-defined drop off points in Zurich, dropping off the parcel at a heightof about two metres, thus ensuring the safety of passers-by. The goods are then delivered to the endcustomer by the van driver. The drone is integrated into the Swiss airspace system using sense and avoid
technologies similar to helicopters (Daimler, 2017).
The trial has been authorised by the Swiss Federal Office of Civil Aviation (FOCA) based on the SpecificOperations Risk Assessment (SORA) methodology developed by JARUS (Joint Authorities for Rulemaking on
Unmanned Systems) and was approved by all relevant Swiss air and ground authorities (Daimler, 2017).
Examples for higher payloads and for longer distances are detailed in the section “Drones for Humanitarianand Development Projects”.
Other freight drones at advanced concept stage
Apart from the examples mentioned above there are many other global companies experimenting withdrone delivery tailored to special use cases, including the development of drones for large payloads, e.g.
the projected deployment of a FlyOx drone by Astral in Kenya with an estimated payload of up to 1200 kg
and a range of 1 800 kilometres.
Two examples supporting other transport modes
Crew support and spare parts delivery to ships: Maersk, a Danish shipping and logistics company, which
operates a fleet about 100 tankers currently employs barges to deliver medicine, mail and spare parts to its
ships. Per trip the barge costs between USD 1 000 and USD 3 000. To evaluate the potential of drones tosubstitute barge transport Maersk in early 2016 trialled a drone developed by French Xamen Technologies.
The drone had a payload of up to 2 kg, and was approved for use in potentially explosive environments.
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distance) drone delivery would be able to substitute three barge transports per year per vessel served.
Thus generating savings of USD 3 000-9 000 per ship or nearly USD 1 million for its whole fleet even forsuch a limited use case. As Maersk pointed out drones could potentially serve more shipping related use
cases, e.g. vessel maintenance or port monitoring and the business case for using drones to support
maritime industries could grow substantially (Paris and Wall, 2016).
Ship and oil rig resupply or supply of semi-dense logistic cluster distribution centres: Boeing has recently
unveiled a cargo drone prototype able to carry substantial loads for mid to long-range supply missions.
Measuring 4.5 m in length, 5.49 m in width and 1.22 m in height, the electric VTOL multi-copter vehicle
weighs 339 kg and will be able to support up to 227 kg of payload (Boeing, 2018a). It is predicted it will beable to fly at a speed of 97 to 113 km/h at a height below 120 metres (Davies, 2018). The first prototype
was able to support 68 kg of cargo for about 15 minutes (Davies, 2018). Boeing’s goal is to mature thealready existing building blocks of autonomous technology for future applications. Although there is noconcrete plan or timeline for commercialisation of the drone, Boeing expects a cargo drone with thispayload and range capacity could be used to replace the use of expensive manned helicopter operations todeliver time-sensitive and high-value goods and conduct autonomous missions in remote and dangerous
environments. Its possible commercial applications include oilrig and ship resupply, port operations, mining,
construction, and logistics (Boeing, 2018b). The drone’s range of operation is ideal for last mile supply or
short-distance deliveries between clustered distribution centres (King, 2018).
Major policy concerns concerning freight drones
The main policy concerns regarding freight drones, beyond the safety and security of vehicles and airspace
management systems are energy consumption per ton of freight delivered, related emissions and theimpact on the workforce. Depending on the location and scale of operation other environmental impacts,
including noise, visual amenity and the effects on land use values close to droneports also need to be taken
into consideration.

Drones for support missions
Imagine a camera equipped drone mapping a port or highway planning site in 3D thus speeding up thetimeline and quality of the design process. Imagine a sensor equipped drone spotting a critical fault in arailway line and alerting the maintenance crew before an accident can happen. Imagine drones inspecting
the hulls of ships, airplanes and difficult to reach sites thus reducing the risk to human workers. Imagine
drones monitoring people flows during large events, helping transport operators to direct capacities wheremost needed or deploying emergency services quickly.
Why drones for support missions?
Some of the first commercial use cases for drones were support missions. Already in the early 1980s,
unmanned helicopters were deployed alongside piloted helicopters to guide them where to spray pesticides
over fields in Japan. By 2018 drones are replacing manned helicopters for agriculture purposes acrossJapan (Thornhill, 2016).
Today, drones designed for support missions for planning, monitoring, maintenance and emergencies are of
special interest to companies and governments that have to manage assets dispersed over large areas or
assets that are inherently hard to inspect. In the transport sector, drones present an opportunity to
improve the quality and efficiency of a large variety of use cases, e.g. railway companies monitoring thestate of their infrastructure, port operators monitoring and guiding incoming vessel movements andinspecting hull stability, logistic providers managing their intermodal hubs or construction companies
constantly surveilling complex construction sites.

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There are three key drivers for the use of support drones within the transportation sector:
1.

Improving safety: Drones can perform hazardous work and thus save human lives, e.g. during theinspection of construction sites, aircraft, ports, railway tracks or auxiliary infrastructure. According
to a recent study (PwC, 2017), the number of life-threatening accidents on an average construction
site monitored by drones could be decreased by up to 91%. Airlines such as Lufthansa and EasyJet(Perry, 2017) are trialling drones to inspect the fin and topside of their aircrafts, thus supporting
the safe operation of manned aviation.
Drones can not only be used to improve the safety of work crews during planning, construction andmaintenance of transport infrastructures, but also quickly assess disaster impacts, guide
emergency support to the locations where it is needed or even deliver life-saving tools.

2.

Reducing cost: using drones to inspect infrastructure can significantly reduce cost. In a test by the
New York Power Authority in 2017, a drone was used to inspect an ice boom near Lake Erie thatwas installed to reduce the amount of ice entering the Niagara River and impeding hydropower
stations located there. Inspections by boat or helicopter cost between USD 3 000 and USD 3 500.
Using drones could halve the costs (NY Power Authority, 2017). Similar savings can be achieved
when inspecting bridges, tunnels and other transport infrastructure where the costs of in-person
inspections are even higher. The labour cost per drone flight in 2017 was already less than
USD 300. A few hundred fixed-wing drones could monitor approximately 200 000 kilometres ofrailways, according to an estimate by SESAR JU (2016).

3.

Improving information: drones can be equipped with a wide array of sensors, thus enabling thecollection of data that has so far have proven to be impossible, or too expensive, to collect. Dronemounted high-resolution image sensors can detect structural faults, enable 3D-modelling ofplanned and existing infrastructure. Therefore, globally operating planning companies for theconstruction industry have been investing in drone companies over the past few years. Drone
imagery can also improve the quality of real-time information for crowd control during large andsmall-scale events, providing a real-time view from above and enabling authorities to address
problems before they escalate.

Drones for support missions today
Drones to map and monitor construction sites
Service providers within the construction industry, including globally operating planning software providers
such as Autodesk have already been investing in drone companies over the past few years. Autodesk
employs drones designed by 3D Robotics in partnership with Sony which carry 35 different sensors and 20
microprocessors on board, can operate in a radius of 1 km from the controller’s standpoint and have a
per trip flight time of 16 minutes. Drones equipped with high-resolution image sensors will continue toimprove the mapping, 3D-modelling and monitoring of planning and construction sites.
The use of drones within the construction sector has also accelerated when in 2016 the FAA released Part
107 of its rules for commercial drone operators (Danielak, 2018). Under the regulatory framework, a
traditional pilot’s licence is no longer required to operate a small unmanned aircraft. Instead, passing aknowledge test is sufficient to obtain a drone piloting certificate. Thus in early 2017, Caterpillar, one of theworld’s largest construction equipment manufacturers acquired the drone company Airwave and alreadyoffers drone services through its regular dealer network in the US (Kolodny, 2017).
The importance of drones in this area is underlined by the 2018 launch of a Grant Call by the Land
Transport Authority of Singapore seeking industry proposals to estimate bulk excavation volumes via
drones equipped with 3D photogrammetry technology.

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Drones for transport infrastructure maintenanceDrones equipped with high resolution cameras and scanners allow for precise inspections of infrastructure
assets. The use of drones improves the infrastructure maintenance process and is a cheaper and often safer
alternative to current monitoring techniques. At the same time, data collected by drones can be comparable
over time, allowing for measurements and forecasts of wear. PwC (2017) puts the total global addressablevalue of the use of drone technology in road and railway segments at an estimated USD 4 billion for
infrastructure maintenance. Alongside maintenance, drones can also be used for otherwise time and labourconsuming stocktaking. PwC (2017) notes a large scope for further application of novel deep learningtechniques to enable fully automated drone services, which would further increase the efficiency ofmaintenance operations at significantly reduced costs.
Transport authorities around the world have been testing drones for use in infrastructure inspections. In
Singapore, the Land Transport Authority aims to deploy drones for maintenance inspection in MRT (Mass
Rapid Transit) and to enhance underground tunnel inspections in order to gradually replace manual effort
within the next few years. As of spring 2018 more than 20 proposals are under evaluation (LTA, 2017). In
India, Zonal Railways are set to procure drones for project monitoring and maintenance of rail
infrastructure (The Economic Times, 2018). With the 2016 FAA commercial drone regulation, the use ofdrones for maintenance is likely to accelerate in the US as well, and projects such as Minnesota Departmentof Transport’s use of drones for routine bridge inspections – where it was found that drones significantly
improve the quality and safety of maintenance activities (Zink and Lovelace, 2015) – are expected toproliferate.
Drones monitoring traffic flows, crowds and providing emergency support
A drone’s bird’s eye view, autonomy from road traffic and ability to access otherwise unreachable or
dangerous areas gives them an edge in traffic surveillance, crowd monitoring and the monitoring of
emergency situations.
For traffic surveillance, drones can provide useful information about vehicle trajectories, and help estimate
roadway usage and O-D (origin-destination) flows (Puri, 2005). However, their autonomy is still limited due
to short battery life and tethered drones – such as the one used by Elistair to monitor a busy suburban
roundabout in Lyon, which is connected to an on-ground electricity supply by a long cable – can be asolution for smaller areas that need to be continuously monitored (Elistair, 2016).
Drones can also be used for crowd monitoring during mass events: the Italian Air Force has teamed up withthe country’s police to use MQ-9 Reaper drones for surveillance during football matches and demonstrations(Kington, 2014). Similarly, in the United Kingdom the West Midlands Police has used drones during footballgames (Todd, 2016). Alongside safety, drones have also be used to ensure security at big events: as partof the security package for the 2018 Winter Olympic Games, South Korea deployed drones with CCTV andfacial recognition technology (Perry, 2018).
In emergency situations, drones are used to assist the response by enhancing situational awareness. EENA(European Emergency Number Association) has collaborated with DJI, a large Chinese drone manufacturer,
to explore the use of drones by emergency services in a variety of situations ranging from search missions
to putting out chemical fires. They concluded that the emergency response system can be further enhanced
by pre- and post-incident drone use – in providing up-to-date maps and assisting in forensic evidence
gathering (EENA and DJI, 2016).
Drones to enforce compliance with transport policy goals
In order to be able to monitor the compliance of surface transport with emission policy goals, Trident
Alliance, a coalition of ship-owners and operators working together to ensure a robust enforcement ofmaritime sulphur regulations in ECAs (Emission Control Areas), has endorsed using “sniffer drones” to(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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monitor air pollution. The drones can be deployed above ships operating in the ECAs and will register any
breaches of international sulphur emission regulations. There are two main advantages to the drone
solution: using drone technology is a much cheaper option than traditional drone surveillance methods,
while at the same time drones can easily link sensor results to a specific ship (Marine Electronics &Communications, 2015).
Drones for support missions service models
The focus of the emerging support drone industry has increasingly been on delivering end-to-end products,
which combine hardware, software and services.
Some of the biggest drone manufacturers do so by taking over relevant companies – as was the case of
Parrot acquiring software manufacturer Pix4D and sensor manufacturer MicaSense, while sensor-chipcompanies such as Intel Corporation acquired autopilot system manufacturer Ascending Technologies andmobile vision processor manufacturer Movidius.
DJI, China’s largest drone manufacturer, on the other hand, has focused more on building strategic
partnerships – for example with camera manufacturer Hasselblad (creating the first 100-megapixel
integrated photography platform (Cade, 2017), infrared camera manufacturer FLIR, surveying system
software developer Leica Geosystems and micro ADS-B (automatic dependent surveillance-broadcast)transponder manufacturer uAvionix (Perlman, 2017). DJI has also formed a number of partnerships withservice providers – such as Shapeways (a digital design and printing company), Lufthansa Group, EENA,
Facebook and Apple (DBX Drones, 2016).
Alternatively established service providers for different transport related tasks, such as construction,
maintenance or monitoring have also either acquired drone companies, such as Autodesk and Caterpillar as
described above, or are acquiring off the shelf drones and equipping them with sensors themselves.
For regulators this poses important questions around accountability of such service provision that a not so
distant future could see, e.g. French railway tracks being assessed for maintenance by a Chinese drone
equipped with a German sensor offered by a US-based drone service provider and remotely controlled by
an operator located in the Philippines.
Major policy concerns with regards to support drones
Privacy is one of the major concerns for the public when it comes to sensor-equipped drones, as is (cyber)security. Questions about the impact on the workforce are also more immediate than for freight andpassenger drones due to the advanced technology readiness level of drones for support missions.

Drones for humanitarian aid and development projects
Imagine a drone capturing images of a disaster-struck area to assess the scale of the event and to help
identify the best response from humanitarian aid agencies. Imagine drones delivering blood or medical
supplies to areas cut off by seasonal floods. Imagine regular laboratory runs by drones to and from remoteareas.
Why drones for humanitarian aid and development projects?
The use of drones in humanitarian action is a rapidly emerging field, with the scope of activities ranging
from mapping, monitoring and damage assessments to delivering essential items to remote or otherwise
inaccessible locations (FSD, 2016).
The phased introduction and explorative testing of drones by the humanitarian aid community might serveas an example on a) how to open up space for innovation, b) create partnerships between clients, service(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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providers and public authorities and c) develop missions for drones that gain support from all parties
involved.
The 2016 Agenda for Humanity of the United Nations Secretary General states that to deliver collective
outcomes, the humanitarian sector must promote a strong focus on innovation (UN, 2016). Novel
technologies, such as drones, can be part of such innovation if they are tailored to support the delivery of
the core value: provide efficient and well-targeted support.
Based on findings from various trial projects a recent study analysing “Drones in Humanitarian Action”(FSD, 2016), found that the use of drones in humanitarian work is generally viewed as positive byhumanitarian and aid workers. The ease and speed of using drones for area assessments and monitoringhas been stressed alongside their capacity to access and deliver to hard-to-reach locations. However, someworry about the drones arriving too late onsite to provide useful information and that replacing actors fromfield operations might deteriorate the quality of aid. Moreover humanitarian workers have also stressed that
local populations may feel threatened by the use of drones, especially in countries and contexts with conflict
environments (FSD, 2016). In some cultures, without supplying appropriate information to the public,
drones may be associated with abnormal activity or witchcraft (Fraser, 2017a). Common concerns include
the fear of drones crashing, the fear of hijacking the drones for negative purposes, and fears of drones
carrying contagious diseases. However, community engagement sessions, such as provided by UNICEF to
introduce positive use cases for drones and thus support their social acceptance have generally been
welcome and have improved the understanding of the use of drones for humanitarian purposes (Fraser,2017b).
Two examples of a partnership between aid agencies, public authorities, the drone industry and inclusion of
local citizens can be studied in Africa. In this context it is important ensure that true partnerships that focus
on serving local needs are established in order to avoid abusing humanitarian projects in emerging
economies as “unregulated test grounds” for vehicles and yet unratified legal texts and conventions.
In Rwanda the world’s first regular drone medical delivery system at a national scale started operating in2016 as a partnership between Silicon Valley-based robotics company Zipline and the Rwandan
government.
The drones deliver blood to 12 regional hospitals from a base in eastern Rwanda. Health workers at clinics
and hospitals send their orders online or via text message and within minutes, the order is launched in a
fixed wing drone. Powered by two electric engines and moving at a speed of over 100 km/h it then drops
the cargo with a parachute at a predefined 5 metre radius drop zone, before returning to base wherecushions help soften the landing and shortening the necessary landing strip (Zipline, 2018). For theselected clinics the average delivery time of routine medical supplies in Rwanda has thus been reduced
from four hours to 45 minutes and emergency deliveries are now also performed (McVeigh, 2018).
The introduction of drone deliveries has helped introduce a cheaper and more demand-responsive system,
preventing stockouts at local facilities while at the same time minimising waste (which is particularly
relevant in case of blood which has a short shelf life and must be kept refrigerated) (Rosen, 2017). The
Rwandan authorities established supportive drone regulations.
In 2017, the Government of Malawi and UNICEF launched Africa’s first humanitarian drone corridor. With aradius of 40 km, an allowed operational ceiling up to 400 m altitude, a total area of 5 024 km2, the corridor
is designed to provide a controlled high altitude, long endurance flight testing platform for private sector,
institutions, NGOs and other partners to explore how drones can be used in humanitarian anddevelopmental causes. The corridor was opened with the goal of facilitating testing in mapping, alongsideconnectivity and transport, to address various needs for the population of about 500 000 people living
within the corridor area. Within this project, UNICEF Malawi has had over a dozen international and local
drone companies, NGOs and academic institutions performing tests, and facilitating training workshops to(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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strengthen community engagement and include citizens in the development of use cases and missions fordrones (Schroeder, 2018).
Overall, the need for clear guidance and rules for the use of drones was identified by the humanitariancommunity as the main factor needed to increase the usefulness of drones (FSD, 2016).
Drones for humanitarian and development projects today
Figure 1. Examples of humanitarian mapping projects (based on input by UNICEF, GlobalMedicand WeRobtotics)(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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Figure 2. Examples of humanitarian cargo drone pilot projects (based on input by UNICEF,
GlobalMedic and WeRobotics)

Lessons for the introduction of drones for other use cases
Lessons learned from the use of drones for Humanitarian aid and development projects can inform thelarge-scale deployment of drones for commercial use cases. They demonstrate how the technology can be
tailored to solve specific problems and how areas lacking connectivity can leapfrog by implementing latest
technologies when regulatory authorities, commercial drone service providers work together and engage
with the civic society. Moreover local transportation technology and service companies are emerging, thus
strengthening the local economy.
Furthermore, the adoption of a “Code of Conduct” for drone services similar to the “Humanitarian UAV Codeof Conduct” can contribute to building public confidence in the use of drones. (UAVcode.org, 2018)(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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Challenges for transport policy makers
National and international aviation authorities have already started developing regulatory frameworks toensure that drones will be safe and support a wide variety of use cases.
The pace of adoption for the commercial use of drones in the transport sector will be influenced by policies
and regulations within the next few years. The private sector is ready to explore market opportunities fordrones, but it requires transparent rules on allowable uses and what the industry must do to guarantee theefficiency, safety, sustainability and social equity of their drone services.
As noted earlier, there are many ongoing initiatives amongst international and national civil aviation
authorities to develop and implement new regulations. While safety regulations will build the foundation for
creating trust in the new technologies, there is a wide variety of other factors that need to be considered bytransport policy makers. Many countries have yet to develop regulations to create a legal environment forpassenger, freight and support drone missions that balance benefits, such as the creation of new markets
and jobs, increased accessibility of remote regions and improved services for special transport purposes,
such as emergency deliveries, with potentially negative impacts.
National and sub-national lawmakers should exercise caution in enacting laws affecting drones so as not to
stifle innovation by passing restrictive, burdensome and highly volatile legislation that will prevent newmarkets and jobs from being created. Instead, regulatory authorities should strike a balance that allows
commercial use of drones while addressing citizen and policy concerns. Those concerns can be addressedby creating a phased approach for different use cases in order to grow regulators’ and the public’s
familiarity with drones and ultimately gauge where the social licence for drone use lies amongst different
transport tasks.
Based on the previous chapters, the following framework may usefully serve to guide and assess policy
priorities for drone regulation as part of a future transport system.

Safety and security firstIf drone use is to scale up, it must be objectively safe from the perspective of regulators and felt to be safe
from the perspective of the general public.
As technology in aviation has been constantly evolving, so have the safety issues that the industry has
confronted and the ever-changing safety requirements deployed to address them. In this respect,unmanned aviation is no different. However, innovation in unmanned aviation has been happening at a
brisk pace, which is not typical in the world of aviation. The aviation industry has had a tendency to preferslow and proven evolution over quick revolution. The conservative nature of aviation and its purposefulabundance of safety measures explain the excellent safety record of today’s commercial aviation.
In manned aviation, there is always the expectation that when all systems fail, a pilot can still take overand safely land the aircraft. Pilots constantly train for such events and manufacturers have put in placecomprehensive procedures for the air crew to manage a system failure. Moreover, regulators rely upon thecooperation of human and machine capabilities to ensure the safety of aviation.
“Today manned aviation develops and improves upon ways to aid a pilot with the responsibilityof flying safely. Regulations (e.g., airworthiness certification) and procedures (e.g., periodic
maintenance) assure the integrity of the pilot’s aircraft. Initial and recurrent training prepare
the pilot for anticipated and unanticipated flight events. The pilot and perhaps others in theoperator’s organization assist in the preparation and planning for a safe flight. Civil Aviation
Authorities (CAA) and air navigation service providers (ANSP) provide and oversee a highly(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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organized infrastructure comprised of procedures, routes, and services to assure safe flight. All
aspects of the air navigation system combine to manage the safe, efficient flow of air traffic.
The introduction of RPAS challenges the extant aviation system infrastructure and raises
multiple questions.” (ICAO, 2016:2)
Safety functions currently performed by humans on board will need to be transferred to remote operators
or fully substituted by technological systems that perform at least as well (and hopefully better) than pilots,
e.g. lacking the eyesight of the human pilot, unmanned aircraft must rely on artificial sense-and-avoid
systems to perform collision avoidance and “remain well clear” of other traffic and dangerous situations.
Multiple other safety-relevant procedures must be reliably transferred from the current human-machineinteraction system to a machine-machine interaction system with little to no need for human intervention.
The main international and national regulatory bodies agree that the safety standards of drone systems
should be equivalent to comparable manned aviation system. This principle is known as the “equivalentlevel of safety (ELOS)”. Its goal is to achieve an approximately equal level of safety that may be
determined by qualitative or quantitative means. However as it is difficult to quantify what exactly the ELOS
requirements would entail another method is to directly specify the “target level of safety” (TLS) for drones,
which defines the acceptable mean number of collisions per flight hour which could result in fatalities bymodelling the end-to-end system performance. Given the fundamental change of managing dronescompared to current aviation, other metrics targeting overall system performance, e.g. “rate of loss ofcommunication” could be introduced in addition to the traditional reactive metrics.
With no on-board pilot, complex operating systems, ever-changing avionics and continuous software
updates, safety concerns appear to be one of the major hurdles for integrating drones into the conventional
airspace – a topic that is currently addressed by aviation regulators worldwide through guidelines andregulations underpinned by ICAO’s Standards and Recommended Practices (SARPs) (ICAO, 2011).
The lethal crash of a manned aircraft is an unfortunate reality that societies have accepted to a certain
extent in order to enjoy the benefits air travel and cargo transport bring to individuals and economies as awhole. In contrast, the social reaction to a lethal crash involving a drone is yet unknown, but will probably
cause a greater sense of unease since there is no direct human control involved. To build up a satisfying
safety track record a high number of drone missions must be carried out – which amounts to a chicken andegg problem, if drones are not allowed to fly. Drones may have to aspire to a higher safety standard thancurrent manned aviation, which is already quite high. Depending on standardisation guidelines, certificationof such drones is however likely to be expensive and time-consuming, especially as an entirely new set ofstandards will have to be developed.
Protecting drones from cybersecurity risks is another important challenge since they can be targets for acyber-attack themselves just as they risk being used as potential attack vectors.
Hacking is a real issue for drones. In its 2017 Threat Prediction Report, McAfee Labs identified“Dronejacking” as a quickly growing security threat (McAfee Labs, 2016). Already in 2015, a proof ofconcept hack of a drone was demonstrated at DefCon (Culpan, 2015), the world's largest “underground”
hacking conference, where hackers, corporations and government agencies meet every year todemonstrate cutting edge hacking research and latest countermeasures.
Every drone is equipped with its own firmware that includes built-in security features linked to the specificdrone design, e.g. maximum altitudes or range allowance from take-off, complemented by location specificsecurity features such as no-fly zone coordinates. Both sets of information must be protected fromtampering and modification.
McAfee expected drone exploit toolkits to be available on the darknet within a year, but also stated thatmost of the identified vulnerabilities discovered on commercial drones could easily be fixed with a software(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

CHALLENGES FOR TRANSPORT POLICY MAKERS – 37

update. However quick, reliable software patches are usually only available for high-end products by large
globally active product manufacturers.
Not only can an unauthorised party control the flight path of a hacked drone - including setting it
intentionally on a collision course - but the drone itself could be surreptitiously outfitted with hacking
software. It could then be used to collect data in drone “spying” attacks, e.g. by landing on the roof of a
private home, business, or critical infrastructure facility and or by attempting to break into the local
wireless network and transmit sensitive data back to the hacker.
What makes drones potentially easier to hack than other Internet of things (IoT) devices is that they aredesigned to have a quick and easy setup, often using unencrypted communication and many open ports.
Moreover, other security risks need to be taken into account, e.g. the illicit use (terrorism or criminal) ofdrones or the use of sensor-equipped drones for espionage.

Privacy a close second
Hand in hand with espionage and counterintelligence, the everyday privacy of citizens must be protected.
The privacy issues surrounding drone uses are distinctive because of the unique vantage point from which
they can survey their surroundings. There are significant concerns that camera-equipped drones could be
used to watch people without their consent or even knowledge.
There is also sensitive data on the drone itself that must be protected: it can range from information about
the authorised user of the drone, its mission profile, client data and all potentially privacy or businesssensitive data sets it collects during its mission. For support drones it is part of their mission to collect vast
amounts of data, which will sometimes include confidential or sensitive information about private property
or passers-by.
Privacy is already a significant regulatory concern due to the unique capabilities of sensor-equipped drones,
but also a relatively new one for civil aviation authorities and the transport sector as a whole. These issues
are usually managed through the lens of privacy laws rather than through aeronautical or transportation
regulation. Nevertheless, they have attracted the attention of privacy advocates in a number of places,
including North America, Europe, Japan and New Zealand. Even if those concerned are currently mostly
related to the use of leisure drones, clear regulations and accountability procedures will be paramount togain social acceptance to operate drones in greater numbers. In this ongoing debate, the case of Sweden isof particular interest as it reveals the scope of regulatory challenges and how complex it is for authorities tosimultaneously reconcile business interests and privacy. In October 2016, a Swedish court ruled thatunmanned aircraft equipped with cameras were surveillance equipment, which would require an expensive
permit to operate. That ruling grounded virtually the entire unmanned aircraft fleet of the country and UAS
Sweden, a trade advocacy group, argued that the ruling could put 5 000 local jobs at risk (BBC, 2016).
On June 20, 2017, the Swedish Parliament passed legislation allowing private individuals to operateunmanned aircraft equipped with cameras without a prior licence or approval from state authorities(Hofverberg, 2017). The legislation created debate on the protection of privacy rights in a changing
technology landscape. The government expects the integrity of the public will continue to be sufficiently
protected through the Swedish Privacy Act.
Under this legislation, the unmanned aircraft operator has the responsibility to properly evaluate whether or
not a flight can be performed without infringing on people’s privacy rights. A guide has been developed tohelp operators ascertain whether or not they are using their unmanned aircraft in a way consistent with
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rights of the individual. Individuals who feel that their rights have been violated can file a claim forcompensation against the drone operator.
As in the other 27 EU jurisdictions, in May 2018, Sweden privacy legislation will be replaced with the new
EU Directive 2016/680, the General Data Protection Regulation (GDPR), which will create a new frameworkfor data and privacy protection across the EU (European Commission, 2018). It will have the merit toharmonise how privacy concerns and unmanned aircraft are treated across the EU. Consequently, the newly
adopted Swedish rules will need to be changed to reflect changes in European privacy regulation.
A different approach to data privacy is pursued by China, especially within its planned “Social Credit
System”, that is currently under development, with first pilot tests underway since 2015 (State Council ofChina, 2014). and full implementation planned for 2020 with mandatory enrolment for all Chinese citizens.
The “Social Credit System” is a ranking system that will monitor the behaviour of Chinese citizens and rank
individuals based on their “social credit”, which will include whether people pay bills on time – similar toexisting financial credit systems – but also monitor other behavioural and moral dimensions. Monitoring of
behaviour in public spaces already relies on about 170 million CCTV cameras across China. Sensorequipped drones will allow for new vantage points and faster analysis.
The increased monitoring and surveillance capabilities provided by drones will continue to highlight thedifferent global perspectives on privacy and the role of government vis-à-vis their citizens. When it comesto cybersecurity and privacy standards for passenger drones, existing laws may have to be adapted andnew sets of security and privacy protocols will likely need to be negotiated and implemented.

Challenges for the overall transport system and their impact on drone
policies
Safe and secure operation, in combination with clear privacy and accountability regulation, will build trust in
drone transport. But as with other areas of transport, many other challenges will have to be addressed inorder for societies to accept drone use. For example, a survey by the US Postal Service in 2016 revealed
that only 32% of US consumers believe that drone delivery will be safe (Office of Inspector General, 2016).
Perhaps even more telling is that the potential adoption of drone delivery led to a drop in public trust ofcompanies with a high level of esteem among US consumers – including Amazon, Alphabet, FedEx and UPS.
Challenges related to public acceptance will have to be assessed when considering the deployment of large
fleets of drones as part of the future transport system. Assessment guidelines must carefully balance
potentially positive and negative factors.
These areas for policy guidance include environmental concerns:


Noise, vibrations and light pollution and their impact both on humans and wildlife;Energy consumption, emissions and overall sustainability of drone transport

They also extend to several economic and societal concerns:

Accountability and liability

Workforce impacts

Social equity



Visual amenity (both during flight and for air/ground interfaces) and integrity of the environmentImpact on real estate values and infrastructure financing cost(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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Noise, vibrations and light pollution
Current noise emission regulation in aviation
Aviation noise is one of the most significant causes of adverse community reaction to development andoperation of airports (ICAO, 2018). There are well-established links between aviation noise andpsychophysical wellbeing. Negative impacts of noise include annoyance, sleep disturbance, cardiovasculardiseases, cognitive impairment and mental health problems (European Commission, 2017).
ICAO’s action to reduce noise pollution is based on the Balanced Approach to Aircraft Noise Management(ICAO, 2004). The Balanced Approach consists of identifying the noise problem at an airport and thenreducing it through the exploration of four principal elements, with the goal of addressing the noise problem
in the most cost-effective manner. The elements of the approach are: 1) reduction at source of plane noise,2) land use planning and management measures, 3) noise abatement operational procedures, 4) local
operational restrictions. The Balanced Approach seeks to harmonise methods used across the world toaddress aircraft noise, while allowing a relatively high degree of flexibility across countries to identify noiseproblems.
Through the Environment Action Programme to 2020 (EU, 2013), the EU has committed to decrease noise
pollution by 2020 towards the levels recommended by the WHO. The Environmental Noise Directive sets ageneral framework for the assessment and management of noise in the EU; it defines indicators andpopulation exposure assessment methods, and it specifies the requirements for mapping of noise. In
addition to the Environmental Noise Directive, aviation-specific regulation includes: Regulation No 216/2008
and Regulation No 748/2012 with respect to limitation of aircraft noise, and Regulation No 598/2014 on
operating restrictions at Community airports (although land-use management and airport operational
procedures generally fall within the competence of Member States, airport authorities also have the power
to set local operating restrictions).
In the United States, all aviation-related aircraft noise rules are specified in Title 14 of the Code of Federal
Regulations. Part 36 refers to noise standards by aircraft type and in aircraft certification; Part 150
addresses airport noise compatibility planning, and Part 161 relates to access restrictions. FAA has
exclusive authority over all matters related to operation of aircraft and aircraft certification. Airport
authorities have certain competences in planning and implementing operational restrictions, while local
governments have some authority over zoning and land use controls.
Potential issues with drones
One of the most important issues associated with a more widespread use of commercial drones is theimpact on noise levels, especially in urban and peri-urban settings. One potential outcome of scaled-up
drone operations is an increase in urban noise volume exceedances above legal or desired limits. The
impact of these will depend not just on their volume, but on the duration of the exceedances and theirfrequency. There will likely be pressure for drone operations to fall in line with a trend in reduced urban
noise levels that may accompany the uptake of electric vehicles, active travel and shared vehicle use andreduced overall vehicle kilometres travelled.
Another issue is the possible impact of large-scale drone operation on property rights, and whether
compensatory or protective measures should be introduced. This is particularly relevant for residential
zoning districts with lower average noise levels. As the number of air/ground interfaces is potentiallywithout limits, zoning regulations will have to address these questions. This point raises the issue of whichauthority will have the right to regulate those “droneports” and what regulatory procedures must be
followed to be able to build and operate these.

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Status of current discussion
The marginal change in noise volume resulting from increased drone operations in a city seems logarithmic(Lohn, 2017): the more units already in use, the smaller the increase in overall drone noise volume. While
ground-level drone sound levels are comparable to background noise levels in current urban environments(Lohn, 2017), there is evidence that their higher-pitched noise signature can produce higher annoyancelevels (Christian and Cabell, 2015). Whether this noise can be interpreted as a violation of property rightlaws in certain contexts (e.g. as a “taking” in the context of the US Constitution’s 5th Amendment “…norshall private property be taken for public use without just compensation”) is not yet decided as there islittle basis in case law for this specific case. In determining whether there has been a taking in the US,
consideration has been given to the altitude, type of aircraft, frequency and timing of flights over a property
in a number of aircraft noise lawsuits (Widener, 2016). The question remains, how the problem ofincomplete aircraft noise regulation will be approached when the costs of a widespread drone operation are
more dispersed than they are in case of airplanes.
Similarly, the potential impacts of large-scale drone operations on vibration and night-time light pollution
on both humans and wildlife requires better understanding than at present before making a case for dronespecific regulation. Currently there are very few studies assessing these impacts and this indicates that
research funds may need to be oriented to support building knowledge here. More research as well as broad
public consultation will be necessary to gain better certainty around the balance of the benefits anddisbenefits of large-scale drone deployment for both day and night-time operations over both dense urban
areas and remote or even protected landscapes.
Energy consumption, emissions and sustainability of drone transport
Current energy consumption, emissions and sustainability of aviation
Aviation is a significant contributor to global CO2 emissions, accounting for over 2% of global man-madeemissions; that contribution is expected to increase to 3% by 2050. ICAO (2016a) estimates that aviationfuel use and carbon dioxide emissions will increase in the coming decades as aviation demand increases,
even as emissions per RPK (revenue passenger kilometre) decrease due to technological and operational
improvements. This is further reinforced by a fact that there are few commercially viable alternatives to
traditional jet fuel.
National policies affect mainly domestic aviation, which accounts only for 30–35% of total air transport(IPCC, 2014), and CO2 emissions of international aviation have not been included in the Paris climateagreement. In order to address this issue, ICAO has proposed a Carbon Offsetting and Reduction Scheme
for International Aviation (CORSIA), a market-based measure to offset CO2 emissions generated byinternational aviation (ICAO, 2016b). CORSIA will be implemented from 2021 on (until 2023 in a pilot
phase, from 2023 until 2026 in a voluntary phase, finally from 2027 onwards on a compulsory basis for allstates, with some exceptions). So far, 73 countries (including the United States and China) accounting forover 88% of international aviation emissions have signed up to participate in the scheme from 2021 (IATA,
2017). The scheme is designed to complement existing initiatives related to technical performance of
airplanes (such as ICAO’s first global CO2 certification standard for new aircraft (ICAO, 2017) andsustainable alternative fuels (e.g. ICAO’s 2050 Vision for Sustainable Aviation Fuels).
Potential issues with drones
One of the main questions concerning drone transport is whether drones could offer a comparable or evenmore energy-efficient alternative to existing modes of transport. A gradual shift of freight delivered by truck
to drone-based systems raises questions about the effects on the total energy consumption required for
package delivery. Some of the issues that need to be assessed on a case-by-case basis are the weight ofpackages and the drone itself, length of trips and route optimisation. Gulden (2017) raises doubts that(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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drone delivery can efficiently substitute truck delivery – especially in light of the increasing energyefficiency of trucks.
There is also a question of whether the increased demand for drones – and hence for electricity – will
exceed the potential energy savings from switching to autonomous air cargo. Similar questions arise forpassenger drone travel.
Status of current discussion
The use of drones as a complement to a traditional road-based delivery system has been generally
assessed as energy saving through their contribution to truck delivery route optimisation. However, current
studies suggest that the energy-efficiency of VTOL drone delivery is largely limited to transporting lightitems across short distances (Gulden, 2017) – per-kilogram efficiency increases initially and flattens out
quickly as more drone weight and battery are needed to support the load and traverse longer distances(Lohn, 2017).
Much of the current discussion focuses on lifecycle emissions (Uber Elevate, 2016). A higher number ofdrone distribution centres (additional warehouses with battery charging facilities) brings significant
efficiency improvements through reducing distances – but at the cost of higher lifecycle impacts throughadditional energy needed for the centres (Stolaroff et al., 2018). With the goal of improving energyefficiency and reducing the environment footprint of electric vehicles (drones included), there is also asignificant effort aimed at promoting alternative fuels for electricity generation (Tessum et al., 2014). Thereis also a push for promoting strategies for the efficient use of drone platforms – aimed particularly atovercoming inefficient use of drone batteries in targeting longer and more autonomous flights (Corral et al.,2016).
Overall, a bulk of research concentrates on finding the most efficient setup for drones to help reduce thenegative environmental consequences of emissions and energy use in the freight sector (Stolaroff et al.,2018).
Given the ramp up time of large-scale drone services, it still remains unclear how drone services will affectParis COP 21 agreements.
Accountability and liability
Current accountability and liability in aviation
Liability refers to the state of being legally responsible for damage. In aviation, that typically includes thedamage caused to people and property (third parties) either on the ground or in mid-air collisions.
There is no common international regime for third-party liability in aviation (whether manned or
unmanned). While a global legal instrument exists (the Rome Convention), very few countries have ratified
it (Masutti, 2016). It follows that rules governing liability for third-party damage are based on domestic law.
Liability can be limited through a cap on the potential level of compensation or unlimited, with no cap on
the amount of damages for which defendants are potentially liable. In practice, compensation will be limitedby the value of the insurance policy purchased. Hence regulations exist to establish minimum insurance
requirements, such as in the EU (see Current State of Play).
Liability can also be strict or fault-based. In a strict liability regime, the party is liable without any proof of
negligence or fault, whereas in a fault-based regime an entity may only be liable if some form of negligenceis established, or it may be able to avoid liability if it can prove that it was not at fault. In Europe, mostcountries adopt a strict liability regime but some countries have fault-based regimes (e.g. the Netherlands)
and others combine the two (e.g. the United Kingdom with respect to mid-air collisions). Outside Europe,
the case of Australia shows that a framework can equally foresee strict and unlimited liability for the aircraft
owner and the operator (Steer Davies Gleave, 2014).

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Potential issues with drones
Liability issues are linked to the nature of unmanned aviation. The nature of drone operations makes it
difficult to allocate liability amongst manufacturers, operators, the (remote) pilot, software providers or any
other entity involved in drone operations. In case of mid-air collisions, drones may be involved either incrashes with other drones or with manned aircraft.
The definition of damage may also prove contentious. In the aviation industry, incident reporting practices
help understand the risks and potential impacts caused by aircraft. Databases with occurrences are also
useful to the industry at large in order to develop better safety standards and ancillary products, including
insurance packages. If incidents and accidents are not clearly defined with a specific focus on drones, itfollows that reporting occurrences in a consistent manner may be difficult and hence the potential for
lessons learnt may be lower.
When it comes to operators, the lack of a harmonised liability regime internationally can result in more
complex (and hence more costly) legal proceedings for operators active in more than one country. In thiscase, specific insurance policies capable of covering requests for damages both in strict and fault-based
liability regimes may be available for international operations.
In the case of potential victims, issues may arise with respect to identifying the source of damage andreporting this to the competent authorities. Victims, who may be individuals or businesses on the ground,would not find it easy to directly identify the owner and/or the operator, let alone establish responsibility.
Similarly, it is unclear whether victims should report occurrences to local police and/or competent aviation
authorities, and whether such information would be shared.
Status of current discussion
There is no push for harmonising liability regimes in the aviation sector at the international level. Whileharmonisation would reduce uncertainty, it does not appear to be a condition sine qua non for clarifying
roles and responsibilities in the case of drone accidents and incidents.
Solutions are likely to come both from the industry itself and from regulators. The insurance industry will
most likely build on the emerging body of evidence on drone crash incidents to come up with products
tailored to the needs of commercial drones. Manufacturers and regulators could agree on production
standards to include small identification plates as well as geofencing software in order to better identify
each aircraft in case of accidents and incidents. Discussions on the creation of national and international
registers of commercial drones would benefit from all of the above.
As described by Masutti (2016), it is reasonable to believe that the future set of regulations for drones
should aim at creating a fair balance between the protection of victims and the financial interests of theplayers in the marketplace by, for example, setting limits on compensation.
Workforce
Current workforce in aviation
The aviation industry employs approximately 9.9 million people (ATAG, 2016). Airport operators account for
447 500 of these jobs, airlines – 2 669 000, air navigation service providers – 224 000, the latter two are
expected to be impacted quickly following the introduction of drone services.
In the US, there were 609 306 active pilots certificated by FAA (FAA, 2018), 23 130 air traffic controllers,
7 920 airfield operation specialists, 6 760 aircraft cargo handling supervisors and 108 510 flight attendants(DOT, 2015). In the EU, employment in air transport was estimated at 665 000 people, with 375 000 air
and cabin crew employees, and 245 000 airport operation and handling staff (Steer Davies Gleave, 2015).

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Potential impacts of drones on employment in aviation industry
The development of drones and their integration into the airspace is expected to have a significant impact
on this workforce. In the US, the total impact is estimated at 103 776 new jobs by 2025, including 50 529
manufacturing jobs (AUVSI, 2013). FAA (2018) expects the demand for drone pilots over the next five
years to exceed 300 000 new jobs. SESAR JU (2016) estimates that approximately 105 000 jobs will becreated by 2035 (135 000 by 2050) as a direct impact of drone integration, with the services sector(piloting and operations, and value-added services) contributing most to the overall job increase. With anassumption of a single pilot managing multiple specific drones from 2025, approximately 250 000 pilots are
expected to support the operation of a fleet of 400 000 drones in 2035; 20% of these jobs will represent
incremental job creation (SESAR JU, 2016). A creation of additional 250 000-400 000 jobs in non-aerospaceindustries is also expected.
Control over training and licensing
Through the Manual on RPAS – a result of long-term on-going consultation with aerospace industry
stakeholders – ICAO has developed high-level guidance for safe and harmonised integration of drones(ICAO, 2015). Rules for licensing aircraft for cross-border operations are subject to international standards
under the Chicago Convention. Apart from this, the specific design and enforcement of training andlicensing guidelines falls under the jurisdiction of nationally-defined competent authorities, typically civil
aviation authorities.
In case of the European Union, new regulation harmonising training and licensing legislation is currently
being drafted (EASA, 2018).
Status of current discussion: licensing of pilots for drones
Recent changes to licensing requirements have generally contributed to lowering barriers to entry. In the
United States, Part 107 replaced the pilot licence requirement with a knowledge test and a drone certificate(FAA, 2016). In the EU, through EASA’s new proposed regulatory framework, licensing requirements will beharmonised and proportionate to the level of operational risk – for example, in the “open” category, therequirement for prior authorisation will be removed (EASA, 2018).
Some obstacles are harder to overcome: BVLOS operations and flights over urban areas continue to be
subject to more stringent rules, although waivers and special certifications can be obtained.
Positive aspects on workforce diversity and work-life balance (e.g. opening up the piloting profession tomore women and people with disabilities due to different job requirements for remote operators) will alsoneed to be assessed.
Social equity
The nexus of digitalisation, new business models and lack of infrastructure funds is already having an
impact on many aspects of modern life, including the way in which people and goods (can) move. Within
the right regulatory framework new technologies and business models can help to ensure that more people
can fulfil their mobility needs in a sustainable and cost efficient way. For example, drones may offer
remote, often indigenous communities unique opportunities create more social equity. Usually accessible
only by air, these remote communities, e.g. in Canada, have extremely high costs of living. Drones may
offer a substantially reduced cost structure and might provide remote communities with new economic
opportunities to retain youth. (Harris, 2017)
There is a risk, however, that without regulation that takes the overall outcomes from transport into
account, drones may only provide services for those who can pay for premium services. While policy
makers can allow these markets to establish themselves, two questions remain: how much attention should
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impactsofdrone

fleets,especially

for

those

who

cannotaffordthese

services,

but

may

be

disproportionately exposed to negative impacts (e.g. the location of drone ports and increased noise/nighttime disturbances in areas with cheaper land prices).
Visual amenity
The impact of drones on the perception of cities and landscapes might prove to be another obstacle towider institutional and public acceptance. Visual considerations are especially hard to assess for policy
makers.
A parallel could be drawn between the effect of wind turbines, and drones, on visual amenity. Public
opposition to wind farm development is well established in Europe and North America. There is frequently a
gap between public attitudes towards cleaner energy and individual support for wind farm construction in
one’s proximity – the so-called NIMBY (Not In My Back-Yard) problem. In line with this, Jones and Eiser(2010) have discovered how in the United Kingdom the support for specific offshore projects is often
significantly higher than for undefined plans for onshore projects – potentially in the vicinity of settlements.
One reason for this could be the so-called “visual pollution”, and its impact on house prices. Gibbons (2015)
used house price reductions as a proxy for visual impacts of wind turbines, and found an average reductionof 5-6% for housing with a visible wind farm within 2 km. There is also a parallel to be drawn to thedisamenity of close proximity to very crowded roads and urban motorways.
Drones can similarly be a source of visual disamenity, and positive views about their energy saving andconvenience increasing qualities could suffer from a NIMBY problem too. However, droneports are unique intheir non-localised nature, which limits the options for organised community engagement and compensationconsiderations – policy solutions widely discussed in the context of wind farms.
Drones within more traditional urban contexts might also raise questions of visual integrity, which is an
important concern for historic towns and cultural heritage sites across the globe. UNESCO guidelines define
integrity (one of the criteria for selection of World Heritage Sites) as “a measure of the wholeness andintactness of the natural and/or cultural heritage and its attributes. Examining the conditions of integrity
therefore requires assessing the extent to which the property … suffers from adverse effects ofdevelopment and/or neglect” (UNESCO, 2017: Art. 88). UNESCO’s Vienna Memorandum (UNESCO, 2005)
additionally states that “urban planning infrastructure … must include all measures to respect the historicfabric, building stock and context, and to mitigate the negative effects of traffic circulation … Townscapes,
roofscapes, main visual axes … are integral parts of the identity of the historic urban landscape”. This has
traditionally involved the establishment of buffer zones around the property, to protect “important views”
from and toward the property. In disputes – in historic parts of Vienna, Prague, Vilnius, to name just a few– the recommendation has normally been to extend zoning regulations and high-rise limitations (UNESCO,2013).
Drones represent a challenge different to the building of modern skyscrapers, but might nevertheless beeasily considered an intrusion to historic sites’ visual integrity. On the other hand, some cultures might
welcome the sight of drone transport as a signifier of modernity and increased attractivity of thesurroundings.
Impact on real estate values and infrastructure financing costs
Both issues are raised as concerns by many policy makers. The impact on real estate values is particularly
worrisome to local and urban governments while the issue of infrastructure costs related to drone use,
particularly drone-compatible ATM management, has been raised by national civic authorities. Limited
research input on these questions is currently available.

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Drones in urban settings
Using airborne vehicles to move effortlessly around cities has captured the minds of the public ever since
Fritz Lang’s 1927 movie Metropolis.
As yesterday’s science fiction is on the verge of becoming today’s reality, urban populations and city
authorities face a new set of questions. Drones can present a number of opportunities for cities, frompotentially alleviating pressure on ground transportation networks to enhancing the speed and availabilityof emergency services and becoming crucial tools for different city departments to perform their duties insafer, more cost efficient manners.
Drones also present new challenges to cities, ranging from questions regarding the safety and security ofdrone operations and most importantly the allocation, design and regulation of droneports within complex,
constantly changing urban environments. In 2016, there existed 3 883 airports with scheduled commercial
flights globally and 41 788 airfields in total, including military and general aviation. There are potentially nolimits to the number of droneports in any city – let alone globally.
There is the issue of integration, or competition, with existing urban ground transport services and thoseregarding privacy, visual amenity and noise. Local communities and urban planners are already exploring
what infrastructure requirements could be necessary in urban areas to accommodate the operations ofdrones and some cities are beginning to consider these in their city planning processes.
With large-scale drone operations in cities becoming a more distinct possibility, local governments aredemanding a voice in the decision-making process.
Urban land use and zoning regulations are typically decided on the local level and mayors could use theseplans to designate where drones may take-off and land as well as other operational criteria, very similar to
the authority to regulate the access and operation of other transport modes, e.g. parking, access, routing
and operations of private cars and public bus services.
The design and location of new air-ground interfaces are of particular interest in cities. Three different
approaches have been suggested:Use of existing infrastructure (e.g. passenger drones landing on flat roof buildings or close toexisting urban highway junctions)

Creation of new small scale logistics centres dispersed across the cityCreation of new street furniture or new designs for buildings

The service models for urban areas include fixed-route transfers, e.g. to and from airports and other highcapacity multimodal transfer terminals, or on-demand route generation, relying on many dispersed
dronepads similar to helicopter landing facilities on top of buildings or making use of unused on groundspace next to existing road infrastructure, e.g. empty parking sites or the “eyes” of clover leaf highway
crossings.
Current regulatory status
Most national frameworks forbid the use of drones in urban areas, typically because the risks are greatest
in congested areas where flight occurs over other people’s property (Perritt Jr. et al, 2016). Nevertheless,the competitive advantage of commercial drones is greatest precisely in dense, urban and suburban areas(SESAR JU, 2016). In the case of delivery, routing density is a crucial factor of competitiveness whencomparing drones to delivery vans (The KiM Netherlands Institute for Transport Policy Analysis, 2017).
Hence, the case of urban operations by commercial drones best exemplifies the trade-offs emanating fromdifferent regulatory approaches and deserves a specific discussion.

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Regulatory conundrum
In banning drone operations in urban areas, national regulations depart from the basic premise thataviation regulatory frameworks are well suited for drones, subject to adequate modifications and updates.
Whereas manned aircraft are normally allowed to fly over cities (with exceptions due to noise regulations atnight), public safety concerns have prevailed in the case of drones.
Safety concerns are mitigated by the low altitude at which drones fly. Conventional aircraft are not allowed
to fly at such low heights, making it easier for air traffic managers to develop ‘drones only’ urban airspace.
Nonetheless, unless autonomous collision avoidance systems and drone-to-drone communication systems
cannot be shown to work reliably, zero risk under an outright ban is the only acceptable level of risk that
regulators are willing to accept even when the likelihood of airplane-to-drone crashes is very limited.
It also matters that the connectivity needed for drones to stay electronically connected to their pilots incongested, built-up areas over significant distances is expensive and so the only economically viable way
for drones to retain their competitive advantage is to rely on fully autonomous aircraft in dedicated airspace(Forbes, 2017).
However, in a similar fashion to insurance markets, regulatory agencies will only be able to relax
requirements as the body of evidence on drone crashes and their impacts grow. Paradoxically, restrictive
regulations are putting a break on the possibility of observing and collecting the outcome of real-life
occurrences and creating more evidence-based approaches to safety. Several drone operators have simply
stopped developing their business cases for urban settings as a result of those very restrictive rules.
Overlapping responsibilities
The outright ban to fly over cities also raises a critical question of regulatory responsibilities: Whichjurisdiction applies to urban drone operations – national regulations or local authority rules? This is likely to
become one of the greatest challenges for regulators and policy makers over the coming years.
Recent legal research in the United States shed some light on the potential magnitude of this challenge. In
the United States, there is a likely conflict of jurisdiction between federal laws and rules by the FAA andstate law. In the aviation context, federal law generally pre-empts state law (Perritt, Jr. and Sprague,2015). However, state and municipal authorities may find that they have the power to regulate certain
aspects of drone operations as part of a complex matrix of responsibilities (Box 2).

Box 2. Federal versus state rules in the US
The Federal Aviation Administration (FAA) is the air safety’s regulatory agency in the United States. The FAA
initially took a restrictive approach to authorising drone applications across the United States. Its guidelines andpolicy documents were understood to effectively prohibit the use of drones of any size without explicit FAA
approval (Clarke and Bennett Moses, 2014). The first approval for commercial flights was granted in September
2013 and the authorisation only applied in the Arctic. New rules for non-hobbyist small unmanned aircraft (UAS)
operations – Part 107 of the Federal Aviation Regulations, passed in 2016 – cover a broad spectrum of commercial
uses for drones weighing less than 55 pounds (approximately 30 kg) (FAA, 2016).

In the absence of a comprehensive federal framework to regulate all commercial drone operations, states andmunicipalities have contemplated putting forward their own regulations. In the United States, the Commerce
Clause prohibits states from interfering with interstate commerce, while the Supremacy Clause nullifies state lawthat conflicts with federal law. In conjunction, these clauses allow the FAA’s authority to preempt state andmunicipal drone regulation. But, in the case of conflicts, which jurisdiction is more likely to prevail over the other?

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Case law provides some potential answers. States or municipal legislation or rules that target drones are more
likely to be pre-empted than a statute or regulation of general effect, such as relating to noise, taxation, or
environmental protection. Moreover, pre-emption is less likely if a state narrowly targets a particular highly
localised area of drone operations, and relates it to matters of traditional state concern, such as personal privacy,
or security of property occupancy. Limiting the purposes for which drones may be flown, for example, prohibiting
flights for surveillance or to capture imagery of a particular individual, might be permissible.

States and municipalities may not, however, regulate the height at which drones can be flown. Because the FAA
prescribes a maximum height above ground level, justified by reducing interference between drones and higher
flying manned aircraft, these requirements would be pre-empted. On the other hand, a state or local ruleestablishing a minimum height is less likely to be pre-empted because there is no FAA-established minimum
height, and because of traditional police power to regulate land use. The cases involving claims of trespass to landby aircraft might suggest otherwise, however.

Sources: Adapted from Perritt, Jr. and Sprague (2015) and Perritt, Jr. and Sprague (2017).

In Europe, some city governments have obtained derogations from civil aviation authorities to run public
events dedicated to hobbyist drones, such as Paris opening up its parks to drone owners on Sundays during
the summer, as part of the plan ‘Paris, capital of start-ups’. When it comes to commercial operations, thetypical procedure involves the drone operator obtaining a national licence from the civil aviation authority;
subsequently, the operator can apply to the local prefecture (Interior Ministry local office) for a case-bycase approval of operations in a given area of the city for a limited amount of time.
The third instance in which responsibilities may be unclear is for operations within a city, but not in an
open/public space. For example, both civil aviation and local authority rules may not apply in the case ofoperations taking place within a closed urban space, such as a factory, a hangar, or a shopping centre.
Developing drone infrastructure
Regulatory issues and jurisdictional questions are inevitably linked to infrastructure development. To use
drones for transport in urban areas, vertical take-off and landing are a must (The KiM Netherlands Institutefor Transport Policy Analysis, 2017). Vertical take-off may be at odds with high-rise development anddensification of urban areas, while landing sites will compete with other priorities for the allocation of scarceland resources. In this context, land-use planning and interactions may be more of a barrier to commercial
drone development than airspace management and city planners and regulators will need to work together
to address the challenges of urban infrastructure for drones.
The public and the private sector alike may come up with solutions. For instance, cities may start planningfor dedicated aerodromes and build those similarly to car parks. If landing sites remain under public
ownership, sub-national authorities will have more direct powers to regulate drone conduct and to specify
where drones may take-off and land in a city. Once again looking at case law in the United States provides
support for the proposition that states and municipalities have the authority to regulate airport siting vis-àvis federal agencies (Perritt, Jr. and Sprague, 2015).
Privately developed, drone-friendly urban sites have not yet been built but new concepts are emerging. A
droneport prototype designed by the Norman Foster Foundation in collaboration with universities worldwide
and exhibited at the Venice Arsenale in 2016 consists of a traditional brick structure with vaulted shelters.
The government of Rwanda has identified a site and contributed funding to the project (Norman Foster
Foundation, 2016). The idea is to create a network of droneports to deliver medical supplies and othernecessities to areas of Africa and other continents that are difficult to access due to a lack of transport(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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infrastructure. Away from congested existing urban areas, a new wave of urbanisation could well beaccompanied by innovations of this kind.
Infrastructure development in the form of landing sites or droneports will put to test existing planning andairport rules. Widespread growth in urban aerodromes would require some reallocation of responsibilities. A
first option is that all regulatory functions related to aerodromes are absorbed within city council
departments. Alternatively, national civil aviation authorities could remain in charge of safety and standards
while devolving infrastructure planning only to sub-national authorities.
Efforts in industry self-regulation could also see operators and landing site managers come up withstandards and guidelines to promote the emergence of dedicated infrastructure in cities. This would open
up more opportunities for collaboration between planners, regulators and drone operators in areas such as
crashes, noise and other related drone-hazards with the aim of developing the safest and mostoperationally sound drone infrastructure plans into the urban fabric.

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Preparing for tomorrow
Competing visions for the future of mobility are being pursued at present. New technologies to better
understand, monitor, provide and manage mobility emerge almost constantly and transform how people
and freight move.
Among these constant changes, the disruptive potential of drones to the existing transportation system isstill unclear. Specialised services might work well in a particular socio-cultural and economic context, e.g.
mid-range freight services in countries with less extensive ground transport networks or high-value
passenger shuttle services in cities with many flat roof skyscrapers downtown, but might fail in others. At
the same time, civil aviation authorities are faced with the challenge to prepare for the safe integration oflarge fleets of drones and to balance the need for evolving rules/frequent review of regulations due to thequickly evolving technologies with predictability for business and expectations of the civic society. The
future proofing of policies and regulations will be a challenge as they must be designed to accommodate
both the rapid development of drone technologies and the novel emerging transportation services.
A few key elements need to be put in place in order for the overall transport system to benefit from theintroduction of drones for passenger and freight transport and support missions.
These include:Establishing a public-private policy dialogue for drones as part of the overall transport system



Building regulatory capacity in authorities



Development of a well-rounded R&D strategy and establishment of experiment and testingareas/licencesCollecting and sharing data on drones to understand their impact and tailor policies



Developing visions to integrate drones with transport system

Establishing a public-private policy dialogue for drones as part of theoverall transport system
In several countries, including France, Germany, Spain, the United Kingdom, the United States and Japan,
joint public-private discussion forums have already been set up to serve as a national exchange platform
bringing together the different parties interested in the development of a market for the use of civil drones.
(see Box 3 French Civil Drone Council)
While the organisational structure, decision-making procedures and the composition of the parties mayvary, these discussion forums generally are comprised of public authorities, universities and research
centres, drone manufacturers – large industrial conglomerates as well as SME’s, drone operators andtraining services, potential drone service customers and support services, e.g. legal, financial and insurance
sectors.
Among the high-level goals that most of these drone platforms share, are:

the study of possible solutions to scientific, technical, socio-economic and regulatory challenges



the exchange and coordination between national players andinternational discussion and harmonisation where beneficial.

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Sub-committees are often established in order to tackle specific questions in more depth, e.g. to establish
training requirements for drone pilots and controllers or to tackle long-range operations. These subcommittees often focus on the issues that currently feature most prominently in the national regulatory
authorities’ concerns. International platforms have also emerged, among them the non-profit UVSInternational that includes 32 national drone associations and more than 4 100 companies from35 countries. JARUS, the Joint Authorities for Rulemaking on Unmanned Systems is a group of experts from
National Aviation Authorities and regional aviation safety organisations from 52 countries, plus EASA and
EUROCONTROL, which work on recommendations to create a single set of technical, safety and operational
requirements for the integration of drones into airspace management.
Working closely together all parties want to jointly shape the regulatory framework for drones, thus
providing industry and society with a stable outlook on what to expect from drones.
Currently these platforms benefit from the expertise of civil aviation experts, but not many consider
including know-how from other transport domains. Inviting specialists from other transport sectors might
be beneficial in a few crucial areas, e.g. the design and regulation of air/ground interfaces as well as for
insurance questions, where learnings from automated ground vehicles might be taken into account for thedevelopment of drone insurance regulations. Moreover, it might be worth including the viewpoints of subnational transport authorities, particularly cities in the composition of the discussion platforms.
The establishment of national drone councils and their close coordination with international public-private
discussion forums will be of great use to transport policy makers.

Box 3. The French Civil Drones Council
Since 2012 and the introduction by the French CAA (DGAC) of a regulatory framework for UAV (drones)
operations, the French civil drone industry has undergone significant development. The Civil Drones Council (CDC)
was created in 2015 to pursue and accelerate this development by helping to structure the sector throughdialogue between the main players in the industry, and coordinating the efforts to remove the operational,
technological, economic and regulatory barriers all players face in order to develop the market (DGAC, 2017).
The CDC, a public/private body with no legal status, consists of an executive committee and four technicalcommittees which themselves comprise different working groups. The Executive Committee leads, coordinates andmonitors the actions of the four technical committees. It is chaired by Patrick Gandil, the Director General of Civil
Aviation, and meets every six months. The four technical committees are each focused on a given thematic:
operations, regulations and uses, technologies and safety, support and promotion of the industry and training.
The CDC is open to all French actors whose activities affect the civil drone industry, on a voluntary basis. Today itbrings together manufacturers, operators, professional syndicates, test centres, training centres, administrations,
the French data protection agency, major customers, major aeronautical groups, research organisations, clusters,
incubators, insurers and lawyers. The DGAC chairs the Civil Drones Council and DGAC staff assume the generalsecretariat, while industry members co-chair the technical committees and their working groups.
Since its creation, the CDC has launched a number of structuring actions, in particular to involve French
manufacturers and operators in European regulatory and normative processes and has worked to facilitate theimplementation of current regulations for professional operators. It has launched several major initiatives oninnovative uses with very high added value, at the same time pushing for an evolution of the French regulations
from operational restrictions, which have allowed the emergence of the sector, towards a more aeronautical logic(airworthiness, demonstration of safety) which is essential to authorise those new uses.
For example, a "long range operations" (LRO) approach is underway to make it possible to monitor linear networks(railways, electricity networks), sometimes for several hundred kilometres, by drones. The development of an
adapted safety methodology should enable the first large-scale pre-industrial operations in 2018. The full LRO
missions will not become reality for a few more years, but these “interim” LRO missions, allowed above lowpopulated areas only, present significant interest for the network operators, in that they allow them to set up theirinternal organisation for drone monitoring and realistically assess what benefit they will get from a “full drone
monitoring” of their network.

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Building regulatory capacity in authorities
The digital revolution has already had a significant impact on how governments serve their citizens. Somecountries are leading in providing e-services, others see the growth of large national “digital” sectors driven
by private companies. A recent OECD report found that this generated considerable mismatches between
the supply of and demand for ICT skills in general and for ICT specialist skills in particular (ReimsbachKounatze, 2015), which suggest that government authorities might increasingly have to bid against private
firms for people with the required skills and could be forced to pay a premium to attract them to public
service.
Given the potential capacity constraints of public servants to even ask “the right questions” vis-à-vis highly
specialised technology developers and providers, policy makers involved with creating new regulations needto consider how best to address this mismatch in skills.
In 2017, the Canadian government earmarked CAD 77 million over 5 years to reinforce Transport Canada’s
regulatory capacity with respect to autonomous technology, namely by developing regulations for the safe
adoption of connected and autonomous vehicles and drones. By working with industry, provinces, territories
and municipalities to establish pilot projects, Transport Canada aims to increase its ability to establish andprovide the standards and certifications that industry will need to safely use these new technologies.
Establishing drone councils (as discussed above), cross-agency (international) coordination and a shift tomore open policy development processes, including expert citizen participation models, could alleviate someof the capacity constraints.

Development of a well-rounded research and development strategy andestablishment of experiment and testing areas/licences
When it comes to innovation, transport clearly has all the markings of a “legacy sector” where thetraditional way of doing things is protected by large, powerful institutions and industry players. The aviation
sector certainly prefers slow, incremental changes in order to protect its high safety standards - and with
this, incumbent players. Nevertheless, the recent confluence of technologies that enable drone transport
have clearly raised the awareness of policy makers and the industry alike and spurred more innovation
friendly approaches.
Bonvillian and Weiss (2015) detail a few strategies on how policy makers can support innovation in thelegacy sectors in order to overcome their particular issues. One strategy includes “front-end, supply-side”
policy measures that include direct government support for R&D, technology prototyping, testing anddemonstrations. Furthermore, they argue that network economies can be achieved by imposing or agreeingon performance and interoperability standards.
For the drone sector this means creating competitive funding sources for R&D, dedicating test sites for
prototype trials and eventually large demonstrations sites. Already significant funds are dedicated to drone
R&D across the globe.
In the United States this is mainly driven by military related application for which a budget of USD 1.7
billion for drone R&D was approved as part of the 2017 Presidential Budget. This is complemented by NASAand FAA spending about USD 20 million annually to focus on air traffic management R&D and further
funding from venture capital in the excess of USD 500 million to date. At the EU level, the Horizon 2020
programme is addressing drone research for air traffic management with about EUR 10 million annually,
complemented by about EUR 50 million from the European Defence Agency. There is significant R&D
spending on national levels, particularly in France and Germany and the numbers are increasing, but SESAR
JU (2016) puts the overall R&D budget needs at a total of EUR 400 million over the next 5-10 years. Asian
countries, among them China, Japan and South Korea are also heavily investing in R&D for drones and(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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dedicating test sites for prototype work and large scale experiments in order to facilitate R&D cooperation
between academia, companies and regulating authorities. In South Korea, for instance, the Ministry ofLand, Infrastructure and Transport (MOLIT) has designated seven dedicated airspace zones for theactivation of the drones industry and selected 25 representative companies to promote pilot projects.
MOLIT also plans to have clarified drone regulations in the country and established a national flight test sitein Goheung by 2020. (Cho, 2017).
The significance of large scale test sites that offer opportunities to test drones in a wide variety ofconditions has been recognised in many countries and include seven FAA managed test sites in the UnitedStates (FAA, 2017), and several test sites in the EU, among them a UK site that includes 7 100 km2 withunlimited height restrictions over sea (ICATS, 2014). Of particular importance are test sites for trials that
focus on two particular questions: how to safely integrate drones into all areas of airspace management andhow to design and manage all forms of air/ground interfaces safely and efficiently.
While questions that are closely connected to vehicle design and flight management of drones are currently
the focus of R&D efforts (see Floreano and Wood, 2015) transport policy makers will also need answers to
broader questions about how drones will affect transportation systems and societies as a whole. As Rao etal. (2016) in their overview about “The societal impact of commercial drones” state: “Rather than thetechnology itself, it is our use of it that affects our perception, and thus our behaviour.” Focusing on drones
in isolation from the overall transport system will “probably get the technology right”, but research
programmes and funds will also need to develop a more pro-active approach towards questions regarding
the environmental, economic and social impacts of drones overall. As Rao concludes: “The future success ofcivilian drones depends on the ability of varied stakeholders to reconsider how this emerging technology
platform can be best harnessed to serve the broad interests of society” (p. 89).
Universities and applied research centres able to support priority research efforts across the whole
spectrum – vehicles, operation systems, unified air management systems and the effects on the overall
transport system from an economic, socio-cultural and political perspective – are currently emerging.
Examples include MIT’s well-known AeroAstro programme, the Delft University of Technology, who ispartnering with Delft city for deploying and assessing a fully autonomous urban drone network or
Singapore’s Nanyang Technological University who partners with Singapore’s CAA to further develop air
traffic management for drones (2017).
Today’s efforts to formulate a broad R&D perspective for drones will have benefits for the short and longterm efficiency, sustainability and social equity of transport.

Collecting and sharing data on drones to understand their impact andtailor policies
The availability of accurate, timely and meaningful data is key for governments, industry and civic society
to understand the proper functioning of any kind of system.
Aviation has a long tradition of collecting and sharing extensive operational and performance data sets,
which are then used to formulate policies and regulations, monitor the industry and predict future needs.
The importance of statistics in aviation is captured in Article 67 of the Chicago Convention (ICAO, 1944)
which requires states to collect data on traffic, costs and financial statements for international aviation.
Most countries also do the same for domestic aviation.
However, with respect to unmanned aircraft, data is sorely lacking. Basic information such as the number ofaircraft is practically non-existent, except in jurisdictions where registration is mandatory. Aside frompossibly knowing the number and composition of the (leisure) drone fleet, very little data is currently
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period, the number of flight hours during that period, the types of mission flown and eventually the numberof passengers and the weight of freight carried should be collected in order to enable authorities to conduct
meaningful safety, security and economic analysis.
Governments may also require access to location data, either directly from the operator or from a future
UTM system to better identify heavily travelled corridors and to better understand future infrastructureneeds of unmanned aircraft. Given the technical systems already needed to perform any drone flight thisdata could be easily generated at little or no cost.
Thus civil aviation authorities should work with industry and ICAO to develop data requirements and datareporting and sharing standards that would help close the existing information gap for drones.

Develop visions to integrate drones with transport system
Until most recently regular drone transport was the domain of science fiction or cartoon movies, such as theJetsons. Visions centred around either utopian or dystopian distant futures.
Today leading academics, architects or global design practices, such as Carlo Ratti, Sir Norman Foster and
IDEO are developing feasible visions for drone services that are integrated with the transport system(Yalcinkaya, 2018).
Carlo Ratti, director of MIT Senseable City Lab together with ANAS, an Italian highway company developed
a concept that integrated new infrastructure for autonomous cars with drone infrastructure along highways
in order to tackle different issues of safety, emergency support, emissions monitoring etc. with the mostappropriate, efficient technology. Similar ideas about the fluid cooperation between ground and dronetransport have been reflected in the Daimler/Matternet combined drone-van delivery system described inchapter “Freight Drones”.
Air/ground interface designs/Drop-off points/droneports
Not only will the interplay between different modes of transport have a significant impact on the usefulness
and acceptance of drones, but as the real value of passenger and freight drones is generated when they
touch ground and their “payload” emerges, the impact of the potentially millions of droneports will need to
be understood and then integrated with the transport system as a whole.
The design of these droneports has been given very fleeting consideration so far, with the exception of
proposals for scalable droneports for rural droneports in Africa by architect Sir Norman Foster andsuggestions for the design of landing infrastructure on top of skyscrapers or adjacent to existing groundtransport infrastructure, such as repurposed parking lots or adjacent to highway “cloverleafs” as proposedby Uber. Many more differently sized and equipped droneports must first be envisioned before policy
makers can have a meaningful discussion about their introduction and regulation. Particularly city levelauthorities will need to have a better understanding of the variety of possible droneports to assess theirimpact on existing land use and zoning laws.
There has been a lot of discussion about the feasibility and economic efficiency of a drone delivery system,
but a question of how it should be designed to ensure convenience and safety remains, specifically, where
drones should pick up and drop off packages (and, in time, passengers). The Norman Foster Foundation(2016) has designed what is thought to be the first droneport in the world – flexible spaces covered by avaulted brick structure on the ground. However, Norman Foster’s droneport was designed for rural areas
with abundance of space.
Designs for droneports in cities have focused on multi-level structures. Saúl Ajuria Fernández’s “Urban
Droneport” (2016), for example, is a solar-powered spherical drone hub designed for the city of Madrid. It(UN)CERTAIN SKIES? DRONES IN THE WORLD OF TOMORROW – © OECD/ITF 2018

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consists of several levels (which can be modified), and consists of two parts: a logistics centre in the lower
levels (with an industrial storage systems), and a state institute of technology development on the upper
floors. In 2017, Amazon patented a “Multi-level Fulfilment Centre”: a high-rise urban droneport that can belocated in densely-populated downtown districts and its height adjusted to local zoning regulations. The
centre can be designed to accommodate all types of orders, and potentially a self-service location.
With relation to urban landing and drop-off points, Mark Dytham expects future buildings to “sprout
branches” to land on (Fairs, 2017). Some, among them Uber Elevate (2016), have focused on utilising
rooftops or areas close to high frequency car routes, e.g. urban highways and using the now empty centresof “clover leaf” structures for future dronepads. Humphreys & Partners Architects (2017) envisioned an“Apartment of the Future”, with a full-scale landing pad on the rooftop, and with a secured drop-off padthat can be lowered by an elevator and delivered directly to the resident’s apartment by another drone. In
their vision of a “Drone Tower”, Charles Bombardier and Ashish Thulkar (2016) also focused on channellingthe convenience of future drone proliferation onto residents, but by designing large balconies toaccommodate small electric aircraft or shipping drones. In Priestman Goode’s “Dragonfly” concept, delivery
drones work in conjunction with autonomous barges, which would act both as a distribution centre and acharging station. The drones would deliver packages on landing pads placed on the rooftops and sides ofbuildings (Ravenscroft, 2018). Given the many constraints – drone vehicle designs, building construction
technologies and legal frameworks for buildings and cities – more in-depth studies that combine design
thinking with rigorous technical analysis and projections are needed.
Globally renowned design ideation companies like IDEO and frog, as well as local product design
companies, are starting to work with industry to develop feasible visions for different drone missions.
Analysing and comparing those visions will allow policy makers to better understand the commonalities ofdrones, e.g. the safety requirements or airspace management systems necessary to operate them during
flight. How air/ground interfaces for different purposes and within different urban and non-urban contexts
should also be designed and which existing land use, building code and related regulations will be affected.
These analysis-based visualisations will enable authorities beyond the immediate aviation and transport
sector specialists to identify significant challenges for drone transport that must be assessed and regulated
by policy makers in order to leverage the full potential of social benefits.

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ANNEX – 55

AnnexEuropean Union
In December 2015, the European Commission proposed to create an EU-wide framework for drones as partof its wider Aviation Strategy (European Commission, 2017). It tabled a legislative proposal that would
allow the establishment of technical rules and standards for drones and drone operations. In parallel, theEuropean Aviation Safety Agency (EASA) has been tasked with developing technical rules and safety
standards. An intense consultation is ongoing since 2015 with Member States and industry. A 2017 Helsinki
Declaration (EASA and Trafi, 2017) has been a major stepping stone to delivering a high-level drones
strategy. With a commitment to ensure safe commercial drone operations by 2019, the Declaration
identified three areas of cooperation:


Legal requirements for drones and drone operations;

R&D efforts to speed up integration;Effective standard-setting processes.

In accordance with Regulation (EC) No 216/2008, the regulation of civil drones weighing less than 150 kg
fell within the competence of EU member states. In December 2017, a new Basic Regulation was proposed.
It addresses the problem of regulatory fragmentation by extending EU competences to cover all drones,
regardless of their size or mass. A new framework, proposed by EASA, categorises risk-mitigating measures
into two main groups:
Open category, which includes limitations, operational rules and competency requirements for the
remote pilot and technical standards for the UAS, removing the need for prior authorisation;

Specific category, which is based on a system that includes risks assessments conducted before
starting an operation, operators complying with a standard scenario, or operators holding acertificate outlining specific privileges (EASA, 2018).

Following EASA’s technical opinion, the Commission is expected to develop and adopt drones legislation
during the course of 2018. Industry can then develop the corresponding standards.
In March 2018, SESAR JU published a roadmap for drone integration (SESAR JU, 2018). It identified themain R&D activities to be pursued in an attempt to secure complete and seamless integration of all types ofdrones into all environments and classes of airspace. The high-level strategy to enable this vision involves
the establishment of a new framework for drone operations (U-space) and the evolution of air traffic
management (ATM) towards the integration of large remotely piloted aircraft systems (RPAS). The
document will feed directly into the 2018 European ATM Master Plan.
U-Space and RPAS (EASA, 2018). U-space will encompass services and procedures to ensure safe andefficient airspace access of large numbers of small drones. It covers altitudes up to 150 meters and will
guarantee that drone use in low-level airspace is safe, secure and environmentally friendly. U-spaceproviders would act just like air traffic service providers for aviation, but in a highly automated and digitalway, effectively informing operators where and how drones can fly, and supplying them with services suchas registration and identification of drones. U-space will develop in an incremental fashion over the courseof the next decades; its full utilisation is estimated at after 2035.
RPAS integration forms the evolutionary thread of implementing EASA’s vision. It will involve gradualaccommodation and integration of large RPAS with manned aviation, with the goal of RPAS and manned
aircraft interacting with ATM in the same way (with special provisions designed to compensate for the factthat the pilot operates the aircraft remotely).

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EU network of drone demonstrators
Regulators would need to learn from real practice to make the rules future proof. That is why theCommission, together with the European Aviation Safety Agency, will manage a network of demonstrator
projects. These projects can give guidance on where the regulatory bar for safe and secure operations
would be set; industry then can demonstrate that their solutions would fall within the regulatory limits.
Such reassurance would allow industry to further invest to test the feasibility of their technological solutions
and standards.
United States
The Federation Aviation Administration (FAA) is responsible for developing policy and plans for the safe andefficient use of the US navigable airspace. Drones integration into the National Airspace System (NAS)involves co-ordination with existing national security, safety and privacy policies. FAA policies define theacceptable minimum standard levels of safety that must be met in three primary areas: equipment,
personnel, operations and procedures. The FAA has published the Integration of Civil Unmanned UAS in the
NAS Roadmap in 2013 (FAA, 2013).
With respect to operational rules, the FAA Modernisation and Reform Act of 2012 recognised the need forsafe integration of drones into the NAS (FAA Modernisation and Reform Act, 2012). Section 333 grants “theSecretary of Transportation the authority to determine whether an airworthiness certificate is required for a
UAS to operate safely”. Under special certifications and authorisations, limited operations are allowed for
new types of aircraft (since drones are, in the view of the FAA, aircraft) that are unable to meet current
airworthiness standards.
Following the need to develop regulatory standards that would enable current drones technology to comply
with the Title 14 of the Code of Federal Regulations, the FAA has outlined a series of guidelines related to
non-hobbyist small drones (weighing less than 55 pounds, 25 kg) in 2016. Part 107 rule concludes therulemaking process under the Operation and Certification of Small Unmanned Aircraft Systems (NPRM) andoutlines the main rules governing the operation of small drones (FAA, 2016). Below are some of the main
provisions of the rule:
Table 1: Main provisions of Part 107 rule (FAA, 2016)
Operational
limitations (mostrestrictions arewaivable if theapplicantdemonstrates thisdoes not raise safetyconcerns)

Weight of less than 55 lbs.
VLOS only
Daylight only
Must not fly over humans
Must yield right of way to other aircraft
Maximum groundspeed of 100 mph
Maximum altitude of 400 ft. GL (or within 400 ft. of a structure)
Minimum visibility of 3 miles from control station
Operations in Class G airspace allowed without ATC permission
Operations in Class B, C, D airspace allowed with ATC permission
One person – one UAS at one time
Foreign-registered small UAS are allowed to operate if they satisfy the requirements of part 375

Remote pilot incommandcertification andresponsibilities

A remote pilot certificate with a UAS rating or direct supervision of a person with one
Remote pilot certificate qualifications: test/part 61 pilot certificate, vetted by the Transportation
Security Administration, at least 16 years old
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Aircraft requirements

FAA airworthiness certification not required

Model aircraft

Not applicable to models satisfying criteria of section 336

Source: FAA 2016

According to the Jones (2017, p. 5), “the creation of an effective ban, or permitting and licensing on an ad
hoc basis while watching the trajectory of drone technology, may allow for regulatory flexibility without theneed for additional legislation” in the United States.
With respect to airspace management, the UAS Comprehensive Plan, prepared by the FAA Joint Planningand Development Office (2013), outlines the strategy of acceleration of integration efforts and provides thefoundation for interagency co-ordination and planning. The plan is a result of collaboration between Next
Generation Air Transportation System (NextGen) partner agencies: the Departments of Transportation,
Defence, Commerce and Homeland Security, the National Aeronautics and Space Administration (NASA)and the FAA, as well as industry representatives. The plan identifies incremental advances in R&D,
rulemaking and development of drone-related technologies as the key drivers of drone integration. Six
high-level goals were developed to address safe integration, with a target year of initial implementation of
the goal:Routine public small VLOS operations conducted in the NAS (2015)



Routine civil small VLOS operations conducted in the NAS (2015)



Routine public operations in the NAS (2015)



Routine civil operations in the NAS (2020)

Define, determine, and establish acceptable levels of automation for drones in the NAD (to be
determined)

Foster US international leadership in drone capability and in standards development (ongoing).

Each of the partner agencies is tasked with working towards achieving these national goals and may
develop specific plans and roadmaps.
China
The Civil Aviation Authority of China (CAAC) is in charge of regulating drone operations and integrating
drones with the national airspace. As specified in the 2017 Management Regulations on the Registration of
Civilian drones, all civil drones weighing 250 g or above must be registered online with the CAAC. Bothmanufacturers and owners of drones must submit relevant information online – manufacturers of produced
models, while owners must submit personal information and list all of their devices (with technical details).
A unique QR code is generated and must be placed on each drone (CAAC, 2017a).
All civilian drones are subject to VLOS, daytime and isolated area (with at least 10 km from other aircraft)flying rules, can operate at a maximum altitude of 120 m (400 ft.) and maximum speed of 120 km/h
(CAAC, 2017b). CAAC uses a classification scheme according to weight: all drones weighing above 7 kg
require a CAAC licence, and above 116 kg – a pilot’s licence and a CAAC certification for operation.
Commercial use of drones also requires obtaining a special licence from CAAC. Pilots must meet minimum
qualification requirements.

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(Un)certain Skies? Drones in theWorld of Tomorrow
This report investigates the role of drones as part of the future transportmix. It specifically addresses the issues policy makers face in engaging
with the emerging private drone sector. Drones have the potential to
improve existing practices, for instance in the surveying of infrastructure.
They also have innovative uses in areas such as freight delivery, passenger transport in both urban and rural areas, or in disaster relief. With thesector developing at a rapid pace, regulators will want to create frameworks for drone use that allow innovation while ensuring positive overalloutcomes.

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2018-05 /Photo credit: Zapp2Photo/Shutterstock

The work for this report was carried out in the context of a project
initiated and funded by the International Transport Forum’s Corporate
Partnership Board (CPB). CPB projects are designed to enrich policy
discussion with a business perspective. Led by the ITF, work is carriedout in a collaborative fashion in working groups consisting of CPB
member companies, external experts and ITF researchers.