COMMISSION STAFF WORKING DOCUMENT EU Drone Sector state of play Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions ‘A Drone Strategy 2.0 for a Smart and Sustainable Unmanned Aircraft Eco-System in Europe’
Date: 2022-11-29
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: air safety, drone, environmental law, innovation, noise level, noise pollution, public health, reduction of gas emissions, smart technology, sustainable mobility

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 29.11.2022  SWD(2022) 366 final  COMMISSION STAFF WORKING DOCUMENT EU Drone Sector state of play Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions ‘A Drone Strategy 2.0 for a Smart and Sustainable Unmanned Aircraft Eco-System in Europe’ {COM(2022) 652 final}  
 
 
1 

2 

3 
3.1 
3.2 
3.3 

4 
4.1 

4.2 

4.3 

5 
5.1 
5.2 

Table of Contents 

Introduction ....................................................................................................................................... 3 

Scope of the strategy ......................................................................................................................... 5 

Consultation Strategy ....................................................................................................................... 6 
Roadmap summary result analysis ...................................................................................................... 6 
Open Public Consultation ................................................................................................................... 7 
Informal Drone Experts Group and Drone Leaders’ Group report ..................................................... 7 

4.1.8 

4.1.7 

4.1.6 

4.1.2 

4.1.5 

4.1.3 
4.1.4 

EU drone policy up to now (“Drone Strategy 1.0”) ....................................................................... 7 
Formulating a policy ........................................................................................................................... 7 
4.1.1 
Communication for “A new era for aviation Opening the aviation market to the 
civil use of remotely piloted aircraft systems (RPAS) in a  safe and  sustainable 
manner” .............................................................................................................................. 7 
High  Level  Drone  Conferences  in  Riga  (2015),  Warsaw  (2016),  Helsinki 
(2017), Amsterdam (2018) ................................................................................................. 8 
Communication for “an Aviation Strategy for Europe” ..................................................... 8 
Communication  for  a  “Sustainable  and  Smart  Mobility  Strategy  –  putting 
European transport on track for the future”........................................................................ 9 
Communications on “the EU Security Union Strategy” and “Counter-Terrorism 
Agenda” ............................................................................................................................. 9 
Communication  for  an  “Action  Plan  on  synergies  between  civil,  defence  and 
space industries”, including a “Drones Technologies” Flagship ...................................... 10 
Communication on “the New EU Urban Mobility Framework” and publication 
of Urban Air Mobility guidelines ..................................................................................... 10 
Communication  on  a  “Roadmap  on  critical  technologies  for  security  and 
defence” and “Versailles” Declaration ............................................................................. 10 
Joint Communication on the “the Defence Investment Gaps Analysis and Way 
Forward” .......................................................................................................................... 11 
Developing and implementing a regulatory framework ................................................................... 12 
4.2.1 
Adoption of Regulation (EU) 2018/1139 on common rules in the field of civil 
aviation (2018) ................................................................................................................. 12 
Adoption  of  detailed  implementing  rules  allowing  effective  drone  operations 
and the development of industry standards ...................................................................... 12 
‘Open’ category ............................................................................................................... 13 
4.2.2.1 
‘Specific’ category ........................................................................................................... 14 
4.2.2.2 
‘Certified’ category .......................................................................................................... 14 
4.2.2.3 
4.2.3 
Adoption of a regulatory framework for the provision of U-space services .................... 15 
Research & Innovation on drones and related systems ..................................................................... 16 
Single European Sky ATM Research (SESAR)............................................................... 16 
4.3.1 
European Climate, Infrastructure and Environment Executive Agency (CINEA) ........... 17 
4.3.2 
European defence research and innovation ...................................................................... 18 
4.3.3 

4.1.9 

4.2.2 

Presentation of the EU drone eco-system today ........................................................................... 19 
The elements of the eco-system ........................................................................................................ 19 
Drone services offered today ............................................................................................................ 20 
Aerial operations .............................................................................................................. 20 
5.2.1 
Innovative air mobility ..................................................................................................... 20 
5.2.2 

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 
Office: DM24 05/123 - Tel. direct line +32 229-95146 

Giancarlo.CRIVELLARO@ec.europa.eu 

 
 
 
5.3 

Drones as an emerging sector of the economy .................................................................................. 21 

6 
6.1 
6.2 

6.3 

7 
7.1 
7.2 
7.3 

8 
8.1 

8.2 

The potential benefits of a viable drone eco-system in Europe ................................................... 22 
Growth and Jobs ............................................................................................................................... 22 
Decarbonisation and circular economy ............................................................................................. 25 
Decarbonisation ............................................................................................................... 25 
6.2.1 
6.2.2 
Circular economy ............................................................................................................. 28 
Digitalisation ..................................................................................................................................... 28 

Vision and strategic objectives ....................................................................................................... 30 
Vision ................................................................................................................................................ 30 
Strategic objectives ........................................................................................................................... 31 
SMART objectives ........................................................................................................................... 31 

The elements of a thriving EU drone eco-system in 2030 ............................................................ 32 
Building the European drone services market................................................................................... 32 
8.1.1 
Improving airspace capabilities (U-space development and integration with Air 
Traffic Management) ....................................................................................................... 33 
Facilitating Aerial Operations .......................................................................................... 35 
8.1.2 
Developing Innovative Air Mobility ................................................................................ 37 
8.1.3 
Ensuring societal acceptance............................................................................................ 38 
8.1.4 
8.1.5 
Promoting the human dimension (knowledge, training, competences) ............................ 40 
Strengthening European civil, security and defence industry capabilities and synergies ................. 42 
Providing funding and financing ...................................................................................... 42 
8.2.1 
Identifying strategic technology building blocks ............................................................. 44 
8.2.2 
Enabling testing and demonstrations................................................................................ 45 
8.2.3 
Driving for common standards ......................................................................................... 46 
8.2.4 
Increasing counter-UAS capabilities and system resilience ............................................. 48 
8.2.5 

9 

Action Plan ...................................................................................................................................... 53 

Synopsis consultation report .......................................................................................................... 56 
A 
Introduction ....................................................................................................................................... 56 
A.1 
A.2 
Feedback to the Roadmap ................................................................................................................. 57 
A.3  Open Public Consultation (OPC) ...................................................................................................... 61 
A.4  Drone Leaders’ Group (DLG)........................................................................................................... 66 
Targeted surveys and Interviews....................................................................................................... 66 
A.5 
Targeted consultations – presentation of responses .......................................................................... 67 
A.6 

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COMMISSION STAFF WORKING DOCUMENT 

EU Drone Sector state of play 

Accompanying the document 

Communication from the Commission to the European Parliament, the Council, the 

European Economic and Social Committee and the Committee of the Regions 

‘A Drone Strategy 2.0 for a Smart and Sustainable Unmanned Aircraft Eco-System 
in Europe’ 

1 

INTRODUCTION 

This  Staff  Working  Document  accompanies  the  Communication  from  the  Commission  on  ‘A 
Drone  Strategy  2.0  for  a  Smart  and  Sustainable  Unmanned  Aircraft  Eco-System  in  Europe’, 
which sets out the actions needed to ensure that a drone eco-system is deployed in the European 
Union in a way that supports the goals of the European Green Deal1, the digital transformation of 
the European Economy and of the Sustainable and Smart Mobility Strategy2. The actions set out 
in the Communication should ensure safe, smart, resilient, inclusive and clean drone operations in 
the European Union.  

The  development  of  drones  (unmanned  aircraft  systems)  services  supported  by  a  competitive 
industry  can  strongly  support  Europe’s  twin  transition  to  a  green  and  digital  economy  and 
contribute  to  the post-COVID  19  recovery  as  well  as  the future  resilience  of the  EU economy. 
From  daily  commuting,  goods  delivery  to  the  development  of  a  wide  spectrum  of  new 
applications and  services, drones  can  become  an  enabler  of  our economic and social  life  and a 
driving force of the further digitalization of the European economy.  

The European Green Deal is a new growth strategy for the EU, which calls for the reduction of 
greenhouse gas emissions in all sectors of the economy, including transport and the protection of 
the  human  health.  In  this  context,  the  transport  system  as  a  whole  should  be  made  smart  and 
sustainable. The Communication on the European Green Deal announced therefore a strategy for 
sustainable and smart mobility, which was adopted by the Commission in December 2020. In the 
Sustainable  and  Smart  Mobility  Strategy,  the  Commission  announced  its  intention  to  adopt  a 
Drone  Strategy  2.0  in  2022  to  reap  the  full  potential  offered  by  drones  to  contribute  to  the 
safeguarding of a well-functioning single market. Drone applications can also strongly contribute 
to  the  digital  transformation  of  many  businesses  and  help  to  meet  Europe’s  Digital  Strategy3 
targets.  

In order to enhance the competitiveness of the European drone eco-system as well as Europe’s 
security and defence capabilities, the Commission adopted in February 2020 an ‘Action plan on 

1   https://eur-lex.europa.eu/legal-

content/EN/TXT/?qid=1588580774040&uri=CELEX%3A52019DC0640 

2   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020DC0789 

3 

https://eur-lex.europa.eu/resource.html?uri=cellar:12e835e2-81af-11eb-9ac9-
01aa75ed71a1.0001.02/DOC_1&format=PDF 

Page 3 / 86 

 
 
 
                                                      
synergies  between  civil,  defence  and  space  industries’4,  and  which  includes  a  ‘EU  Drones 
Technologies Flagship’ project aiming at reaping synergies between the civil, including counter-
drones  technologies,  and  military  use  of  drones.  This  Action  Plan  also  identifies  autonomous 
systems  including  drones  as  a  critical  technology  for  which  Europe  needs  to  achieve 
technological  sovereignty.  These  objectives  were  reinforced  by  the  Versailles  Declaration 
adopted  by  the  Member  States  in  March  20225  which  marked  the  EU  decision  to  take  more 
responsibility  for  its  security  and  take  further  decisive  steps  towards  building  its  European 
sovereignty,  reducing  our dependencies  and  designing  a  new  growth  and  investment  model  for 
2030. In this respect, the Declaration addressed three key dimensions, first, enhance security and 
defence  capabilities,  second,  reduce  energy  dependencies;  and  third  build  a  more  robust 
economic  base.  Among  those  measures,  the Member  States  agreed to  foster  synergies  between 
civilian,  defence  and  space  research  and  innovation,  and  invest  in  critical  and  emerging 
technologies  and  innovation  for  security  and  defence.  They  also  agreed  to  take  measures  to 
strengthen and develop EU’s defence industry, including SMEs. 

To  reach  its  goals,  the  EU  needs  to  ensure  the  safe  and  efficient  development  of  a  drone 
ecosystem,  addressing  related  societal  concerns  such  as  safety,  security,  privacy  and 
environmental  protection,  while  simultaneously  nurturing  a  sustainable  economic  environment 
for  the  European  drone  industry  to  grow.  Although  EU  citizens  expressed  generally  positive 
attitudes  to  new  forms  of  air  mobility,  a  study6  led  by  the  European  Union  Aviation  Safety 
Agency (EASA) has shown that safety and noise pollution are on top of EU citizens’ concerns, in 
a list that also includes cybersecurity risks and the potential impact on wildlife. Therefore, there 
are  many  other  issues  beyond  safety  that  must  also  be  addressed  in  order  to  ensure  the  social 
acceptance of drones, such as environmental and privacy issues.  

In 2014 and 2015, the Commission adopted respectively a Communication on a new era for civil 
aviation7  and  the  Aviation  Strategy  for  Europe8  which  highlighted  that  safety  is  crucial  to  the 
successful integration of drones in the airspace  as well as the development of this industry and 
the services and applications enabled by drones.  

The  Aviation  Strategy  for  Europe  set  an  objective  to  establish  a  basic  legal  framework  for  the 
safe  development  of  drone  operations  in  the  EU  and  to  prepare  more  detailed  rules  that  allow 
drone operations and the development of industry standards. This regulatory framework is now 
largely in place.  

New  actions  are  needed  at  EU  level  because  the  drone  sector  is  developing  rapidly  with  new 
innovative ways of using drones emerging at a fast pace requiring an assessment of the regulatory 
and enabling framework to ensure that these new services can thrive in the EU internal market 
technologies  such  as  radiofrequency  communication9,  Artificial 
and  globally.  Related 
Intelligence10, advanced sensors and improvements in power sources are opening new prospects. 

4   Communication  for  an  “Action  Plan  on  synergies  between  civil,  defence  and  space  industries”, 

adopted in February 2021 including a “Drones Technologies” Flagship. 

5 

https://www.consilium.europa.eu/media/54773/20220311-versailles-declaration-en.pdf 

6  EASA  Study  on 

the 

societal  acceptance  of  Urban  Air  Mobility 

in  Europe  2021, 

https://www.easa.europa.eu/sites/default/files/dfu/uam-full-report.pdf 

7   https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52014DC0207&from=EN  

8   https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A52015DC0598  

9   https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=celex%3A32014L0053 

10  https://digital-strategy.ec.europa.eu/en/library/proposal-regulation-european-approach-artificial-

intelligence 

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Drones  are  used  as  daily  tools  in  ever  broadening,  data-demanding  economic  sectors  such  as 
agriculture,  construction,  surveillance,  filming,  healthcare,  energy,  environment,  public  safety 
and  security.  Future  perspectives  include  the  use  of  drones,  for  example,  as  platforms  for 
communication hubs or weather or pollution monitoring. Drones are also both users and enablers 
of  Global  Navigation  Satellite  System  (GNSS)  services,  they  can  be  used  to  complement 
Copernicus imaging, as well as to complement Secure Connectivity services. Conversely, the fact 
that customised drones can also be used for illegal purposes should be addressed. 

In the transport sector, the use of drones for deliveries is already tested in many countries. First 
pilot trials in passenger transport in Europe are expected to take place within the next few years.  

At the same time, it is important that Europe safeguards its open strategic autonomy in this area, 
as recognised in the “Action plan on synergies between civil, defence and space industries”11.  

Against  this  background,  the  existing  strategy  from  2015  has  been  overtaken  by  these  new 
developments and a new strategy is needed at EU level to provide a forward-looking vision for 
the future holistic development of the sector. 

This Staff Working Document gives an overview of the Commission services’ assessment of the 
challenges  that  the  drone  sector  faces  as  well  as  the  analysis  and  data  underpinning  the  new 
Drone  Strategy  2.0.  With  that,  it  aims  to  support  the  entire  drone  eco-system,  including  cities, 
regions and Member States in the development of drone activities for mobility and services. 

2  SCOPE OF THE STRATEGY 

The  term  “drone”  is  the  layman  term  for  “Unmanned  Aircraft  Systems”  which  means  an 
unmanned aircraft and the equipment to control it remotely. 

The  term  “Urban  Air  Mobility”  has  been  increasingly  referred  to  in  the  context  of  new  Urban 
Mobility  initiatives.  Due  to  the  lack  of  a  definition  and  in  line  with  the  regulatory  operation 
centric  approach,  EASA  has  developed  the  notion  of  Innovative  Aerial  Services  (IAS).  IAS 
correspond  to  the  set  of  operations  and/or  services  that  are  of  benefit  to  citizens  and  to  the 
aviation  market  and  that  are  enabled  by  new  airborne  technologies  –  the  operations  and/or 
services  include  both  the  transportation  of  passengers  and/or  cargo  and  aerial  operations  (e.g. 
surveillance, inspections, mapping, telecommunication networking). IAS can be further divided 
into “aerial operations” (surveillance, inspection, imaging, …), as well as a whole new emerging 
market  called  Innovative  Air  Mobility  (IAM)12  (including  international,  regional  and  urban  air 
mobility).  

11  https://ec.europa.eu/info/sites/info/files/action_plan_on_synergies_en_0.pdf 

12   The  concept  of  Innovative  Air  Mobility  (‘IAM’)  is  to  accommodate  operations  with  novel  aircraft 
designs  (that  do  not  automatically  fall  under  one  of  the  known  categories,  but  which  have  VTOL 
capabilities  for  take-off  and  landing,  specific  (distributed)  propulsion  features,  can  be  operated  in 
unmanned configuration, etc.), that are conceived to offer a new air mobility of people and cargo, in 
particular in congested (urban) areas, based on an integrated air and ground-based infrastructure. IAM 
describes a diverse array of aircraft types (such as manned and unmanned), whose designs are enabled 
by  ongoing  innovations  particularly  in  the  areas  of  hybrid  and  electrification  of  propulsion  systems, 
energy  storage,  lightweight  materials,  digitalisation  and  automation.  These  innovations  have  made 
possible  an  array  of  novel  designs  spanning  multi-rotor,  tilt  wing,  tilt-rotor,  powered  wing,  offering 
short take-off and landing (STOL) through to vertical take-off and landing (VTOL) capabilities. 

Page 5 / 86 

 
 
 
                                                      
Innovative Aerial Services

Innovative Air Mobility

Aerial 
Operations

Urban
Air Mobility

Regional
Air Mobility

International
Air Mobility

Innovative Aerial Services 

For  further  reference in the  following  text, the term  ‘drones’  will be  used to cover  all  vehicles 
involved in Innovative Aerial Services including manned eVTOL, as well as Unmanned Aircraft 
Systems used in the defence sector. However, as explained in the Drone Strategy 2.0, the purpose 
is not to address the conditions of operations of military drones, but rather seeks to identify areas 
of  cross-fertilisation  whereby  defence  projects  may  benefit  from  innovative  developments  of 
SMEs  for  civilian  drones  and  that  civil  aeronautics  benefit  from  developments  in  the  field  of 
defence. 

3  CONSULTATION STRATEGY 

As  part  of  its  consultation  strategy,  the  Commission  announced  in  the  roadmap  for  the 
preparation  of  the  Drone  Strategy  2.0  the  launching  of  an  online  Open  Public  Consultation 
(OPC), desk research as well as targeted stakeholder consultations in the context of a preparatory 
Fact  finding  study13.  Consultation  tools  used  for  collecting  information  for  the  study  included 
surveys/questionnaires,  interviews,  stakeholder  workshop  and  meetings  of  the  informal  drone 
expert  group. The  targeted  consultations  also  included  consultations  of  the  defence  community 
by  Commission  services  to  explore  civil/military  synergies  in  the  development  of  drone 
technologies. 

that 

stakeholders 

The 
competent 
authorities/administrations,  drone  operators  and  producers,  U-space  and  air  navigation  service 
providers,  local  rural  and  urban  communities,  airport  operators,  and  relevant  European 
associations. 

identified 

included 

national 

been 

have 

3.1  Roadmap summary result analysis 

The Commission published the intention to develop the Drone Strategy 2.0 on the website “Have 
your Say”, together with the roadmap for the Drone Strategy 2.014. 45 comments were received 
on  the  roadmap  in  the  period  between  4  June  and  2 July,  2021.  The  analysis  of  the  comments 
received to the Roadmap is available in Annex A. 

13  Fact finding study preparing a “Drone Strategy 2.0”, Final report”, 2022, Ecorys 

14  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13046-A-Drone-strategy-20-

for-Europe-to-foster-sustainable-and-smart-mobility_en 

Page 6 / 86 

 
 
 
                                                      
3.2  Open Public Consultation 

Citizens and organisations were invited to contribute to the online public consultation which was 
open between 8 October 2021 and 31 December 2021. A total of 258 comments were received. 
The analysis of the comments can be found in Annex A. 

3.3  Informal Drone Experts Group and Drone Leaders’ Group report 

The Commission also used its existing consultation platforms for the development of the Drone 
Strategy  2.0,  notably  the  Informal  Drone  Experts  Group15.  In  addition, in order to  give  a  high-
level steer to the development of the Drone Strategy 2.0, the Commission created on an ad hoc 
basis a ‘Drone Leaders’ Group’. In total, the Drone Leaders’ Group held four meetings between 
October  2021  and  April  2022,  collecting  the  views  of  its  26  members  representing  all  core 
stakeholder  groups  whether  from  the  national  authorities,  EU  agencies,  manned  or  unmanned 
aviation.  The  Group  also  organised  three  hearings  with  the  members  of  the  Informal  Drone 
Experts Group addressing the following issues: 

  Hearing 1 on Urban Air Mobility (cargo/passengers) and U-space (held on 18 February 2022) 
  Hearing 2 on Enhancing drone services including the SME dimension (held on 25 February 

22) 

  Hearing  3  on  Developing Civil-Defence  industry  synergies  and  technology  building  blocks 

(held on 8 March 2022). 

The Drone Leaders’ Group delivered a report including its Vision for the Drone Sector in 2030, 
identified  key  performance  indicators  and  identified  the  main  obstacles  (and  solutions)  for  the 
development  of  the  EU  drone  services  market.  The  most  cited  obstacles  were:  societal  issues 
(privacy,  security,  noise  and  visual  nuisances);  technology  (absence  of  standards,  immature 
technologies, problems of integration); regulation (‘specific’ and ‘certified’ categories, vertiports, 
rules  of  the  air,  ATM-UTM  integration);  lack  of  investment  and  funding;  and  market  issues 
(access to airspace, fragmentation). The Vision proposed by the Drone Leaders Group and a list 
of SMART performance indicators are presented in paragraph 7.1 below and the full report of the 
Drone Leaders’ Group is available in the Appendix of the synopsis consultation report. 

4  EU DRONE POLICY UP TO NOW (“DRONE STRATEGY 1.0”) 

4.1  Formulating a policy 

4.1.1  Communication for “A new era for aviation Opening the aviation market to 
the  civil  use  of  remotely  piloted  aircraft  systems  (RPAS)  in  a  safe  and 
sustainable manner”  

The  European  Summit  of  19  December  2013  called  for  action  to  enable  the  progressive 
integration  of  drones  into  civil  airspace  from  2016  onwards.  This  Communication  focused  on 
drones for civil use and responded to the call of the European manufacturing and service industry 
to  remove  barriers  to  the  introduction  of  RPAS  in  the  European  single  market.  It  set  out  the 

15   Commission 

group 
register/screen/expert-groups/consult?lang=en&groupID=3533. 

(E03533). 

Expert 

https://ec.europa.eu/transparency/expert-groups-

Page 7 / 86 

 
 
                                                      
Commission's views on how to address  drone operations in a European level policy framework 
which  would  enable  the  progressive  development  of  the  commercial  drone  market  while 
safeguarding the public interest. The regulatory action and the related research and development 
efforts  were  to  be  built  on  existing  initiatives  involving  a  number  of  actors:  the  European 
Aviation Safety Agency, the national Civil Aviation Authorities, the European Organisation for 
Civil  Aviation  Equipment  (EUROCAE),  EUROCONTROL,  the  SESAR  Joint  Undertaking 
(SJU),  the  European  Defence  Agency,  the  European  Space  Agency,  the  drone  manufacturing 
industry and operators. 

4.1.2  High  Level  Drone  Conferences  in  Riga  (2015),  Warsaw  (2016),  Helsinki 

(2017), Amsterdam (2018) 

The Riga Drone Declaration of 2015 stated that drones need to be treated as new types of aircraft 
with  proportionate  rules  based  on  the  risk  of  each  operation  and  EU  rules  for  the  provision  of 
drone  services  should  be developed quickly  as  well as  technologies  and  standards  ensuring  the 
full integration of drones in the European airspace. 

The Warsaw Drone Declaration of 2016 called for the swift development of a drone ecosystem 
that  is  simple  to  use,  affordable,  commercially,  and  operationally  friendly,  yet  capable  of 
addressing  all  societal  concerns  such  as  safety,  security,  privacy  and  environmental  protection. 
The Declaration also called for the safety rules to be kept simple, proportionate to the risk of the 
operation, performance-based, future-proofed, and based on global standards. Calling for urgent 
action on the airspace dimension, in particular the development of the concept of a U-space, a set 
of digital services enabling the safe scaling up of routine drone operations, the development of 
the U-Space was mentioned for the first time in a Declaration. 

The  Helsinki  Drone  Declaration  of  2017  supported  the  adoption  of  the  new  EASA  Basic 
Regulation as providing the foundation for a European legislative framework for drone services. 
The growing fragmentation along national boundaries of the EU drone services market was also 
noted  with  concerns,  indicating  the  urgent  need  for  close  cooperation  between  European  and 
national authorities. The Declaration called for the opening of the drone services market and in 
particular, the introduction of competition between U-Space providers to ensure that services are 
delivered at the best possible cost-benefit ratio while allowing fair and timely access to airspace 
for drone operators. 

The Amsterdam Drone Declarations of 2018 called for a push towards integrated smart mobility 
and fair access to all dimensions of public space, inviting cities and regions, also within the Smart 
Cities  initiative,  to  co-create  with  the  citizens  the  public  conditions  and  the  infrastructure  for 
integrated air and ground smart mobility solutions to flourish and for the timely delivery of the 
U-space regulatory framework. 

4.1.3  Communication for “an Aviation Strategy for Europe” 

In  2015,  the  Commission  adopted  its  Communication  on  “an  Aviation  Strategy  for  Europe” 
highlighting  the  fact  that  while  safety  is  crucial  it  cannot  be  looked  at  in  isolation.  In  this 
Communication,  drone  technologies  were  considered  as  a  major  opportunity  both  for  the 
European  aeronautical  manufacturing  industry,  especially  for  small  and  medium  sized 
enterprises, and for the many aviation and non-aviation businesses that will be able to integrate 
drones  into  their  activities  and  increase  their  efficiency  and  competitiveness.  The  Commission 
stated  its  intention  to  propose  a  basic  legal  framework  for  the  safe  development  of  drone 
operations  in  the  EU,  as  part  of  the  new  basic  aviation  safety  Regulation  replacing  Regulation 

Page 8 / 86 

 
 
216/2008 and tasked the European Union Aviation Safety Agency with preparing more detailed 
rules allowing the drone operations and the development of industry standards. 

4.1.4  Communication  for  a  “Sustainable  and  Smart  Mobility  Strategy  –  putting 

European transport on track for the future” 

In  its  2020  Sustainable  and  Smart  Mobility  Strategy,  the  Commission  addressed  the  future 
challenges  and  opportunities  for  European  mobility  and  the  transport  sector.  From  daily 
commuting  to  the  proper  functioning  of  global  supply  chains,  mobility  is  an  enabler  of  our 
economic and social life. As the second-largest area of expenditure for European households, the 
transport  sector  contributes  5%  to  European  GDP  and  directly  employs  around  10  million 
workers. Whilst mobility brings many benefits for its users, it is not without costs for our society. 
By  far,  the  most  serious  challenge  facing  the  transport  sector  is  to  significantly  reduce  its 
emissions  and  become  more  sustainable.  At  the  same  time,  this  transformation  offers 
opportunities  for  better  quality  of  life,  and  for  European  industry  across  the  value  chains  to 
modernise,  create  high-quality 
jobs,  develop  new  products  and  services,  strengthen 
competitiveness  and  pursue  global  leadership  as  other  markets  are  moving  fast  towards  zero-
emission mobility.  

In its Sustainable and Smart Mobility Strategy, the Commission announced its intention to adopt 
a Drone Strategy 2.0 in 2022 setting out possible ways to guide the further development of this 
technology and its regulatory and commercial environment. . 

4.1.5  Communications  on  “the  EU  Security  Union  Strategy”  and  “Counter-

Terrorism Agenda” 

In 2020, the Commission also adopted two Communications which both introduced new policy 
actions to counter possible threats that drones could pose. The EU Security Union Strategy16 and 
Counter-Terrorism  Agenda17  stated  that  the  threat  of  non-cooperative  drones  is  a  serious 
concern in Europe that needs to be addressed. In the Counter-Terrorism Agenda in particular, the 
Commission  committed  to  look  into  the  possibility  of  releasing  an  EU  handbook  for  securing 
cities from non-cooperative drones This initiative has expanded and will now include “Protection 
against Unmanned Aircraft Systems – Handbook on Counter-UAS for Critical Infrastructure and 
Public  Spaces”  and  “Protection  against  Unmanned  Aircraft  Systems  –  Handbook  on  Principles 
for Physical Hardening of Buildings and Sites”. 

The Commission introduced the Directive on the resilience of critical entities (CER Directive) 18  
in December 2020. This directive will reflect the priorities of the EU Security Union Strategy and 
address a wide range of non-cyber threats against critical entities and their infrastructure. It will 
cover eleven sectors, including the transport sector. The proposed Directive on the resilience of 
critical entities will introduce obligations on Member States and critical entities to conduct risk 
assessments  and  on  critical  entities  to  take  technical,  security  and  organisational  measures  to 
ensure  their  resilience  against  identified  risks.  Because  of  their  nature,  the  threat  of  non-
cooperative drones will be an integral part of their risk assessments. 

16  COM(2020) 605 final of 24 July 2020 

17  COM (2020) 795 final of 9 December 2020 

18  COM(2020)  829  final  of  16  December  2020.  The  European  Parliament  and  the  Council  reached 

political agreement on the proposed Directive on 28 June 2022 (Security Union (europa.eu) 

Page 9 / 86 

 
 
                                                      
4.1.6  Communication for an “Action Plan on synergies between civil, defence and 

space industries”, including a “Drones Technologies” Flagship  

The Commission adopted in February 2021 a Communication for an “Action Plan on synergies 
between  civil,  defence  and  space  industries”  19,  including  a  flagship  project  for  EU  drone 
Technologies  aimed  to  enhance  the  competitiveness  of  EU  industry  in  this  critical  technology 
area.  This  Communication  aimed  to  promote  the  competitiveness  of  the  European  drone  eco-
system,  as  well  as,  Europe’s  defence  capabilities,  by  reaping  synergies  between  the  civil  and 
military use of drones. It highlighted that the flagship project forms part of an overall ambition to 
be  further  set  out  in  the  “Drone  Strategy  2.0”.  This  Action  Plan  also  identifies  autonomous 
systems  including  drones  as  a  critical  technology  for  which  Europe  needs  to  achieve 
technological sovereignty. 

4.1.7  Communication  on  “the  New  EU  Urban  Mobility  Framework”  and 

publication of Urban Air Mobility guidelines 

To support the transition to cleaner, greener, and smarter mobility, in line with the objectives of 
the European Green Deal, the Commission adopted in November 2021 four proposals that will 
modernise the EU’s transport system20. By increasing connectivity and shifting more passengers 
and freight to rail and inland waterways, by supporting the roll-out of charging points, alternative 
refuelling infrastructure, and new digital technologies, by placing a stronger focus on sustainable 
urban  mobility,  and  by  making  it  easier  to  choose  different  transport  options  in  an  efficient 
multimodal transport system, the proposals will contribute to putting the transport sector on track 
to cutting its emissions by 90%. 

The  new  framework  announced  a  more  ambitious  approach  to  sustainable  urban  mobility 
planning  (SUMPs)21  and  related  indicators.  Such  new  and  integrated  approaches  to  using  and 
managing urban space includes urban air mobility (e.g. drones). 

This complements the proposal for revised guidelines for the Trans-European Transport Network, 
according to which the largest 424 EU  cities on the TEN-T network should adopt a sustainable 
urban mobility plan by 2025 and collect relevant data. 

To provide guidance on Urban Air Mobility (UAM) as specific topic related to Sustainable Urban 
Mobility  Planning,  UIC²  –  the  UAM  Initiative  Cities  Community  or  EU’s  Smart  Cities 
Marketplace – released a practitioner briefing in December 202122. 

4.1.8  Communication  on  a  “Roadmap  on  critical  technologies  for  security  and 

defence” and “Versailles” Declaration  

The  roadmap  on  critical  technologies  for  security  and  defence23,  adopted  in  February  2022,  is 
part of a number of Commission-led initiatives in areas critical for defence and security within 
the  European  Union.  It  is a  concrete  step towards a more  integrated  and  competitive  European 

19  https://ec.europa.eu/info/sites/info/files/action_plan_on_synergies_en_0.pdf  

20  https://ec.europa.eu/commission/presscorner/detail/en/ip_21_6776 

21  https://www.eltis.org/resources/tools/sump-self-assessment-tool  

22  https://ec.europa.eu/info/eu-regional-and-urban-development/topics/cities-and-urban-

development/city-initiatives/smart-cities_en  

23  COM(2022) 61 final 

Page 10 / 86 

 
 
                                                      
defence  market,  particularly  by  enhancing  cooperation  within  the  EU,  thereby  building  scale, 
mastering costs and enhancing operational effectiveness. The Commission thus provides input in 
the run-up to the EU Strategic Compass on Security and Defence. 

The Roadmap outlines a path to enhance the competitiveness and resilience of the EU security 
and defence sectors, notably by: 

 

inviting  Member  States  to  contribute  actively  to  the  Observatory  of  critical  technologies 
currently being established; 

  encouraging dual-use research and innovation at EU level. 

Two  preliminary  case  studies  have  been  carried  out  so  far,  including  one  on  the  defence 
technology area of autonomous systems. 

The “Versailles Declaration”24, adopted by the heads of EU Member States, emphasised the need 
to  foster  synergies  between  civilian,  defence  and  space  research  and  innovation,  and  invest  in 
critical and emerging technologies and innovation for security and defence. 

4.1.9  Joint  Communication  on  the  “the  Defence  Investment  Gaps  Analysis  and 

Way Forward” 

The  analysis  of  defence  investment  gaps  and  the  way  forward25,  adopted  in  May  2022,  is  a 
response  by  the  Commission  and  the  High  Representative  to  a  task  given  by  the  European 
Council  at  the  Versailles  Summit.  It  presents  an  analysis  of  the  defence  investment  gaps,  and 
propose further measures and actions necessary to strengthen the European defence industrial and 
technological base, including defence related drone activities. It also responds to the call made in 
the context of the Conference of the Future of Europe for stronger EU action in defence. 

The Joint Communication presents a new level of ambition to build a stronger Europe in defence. 
It  focuses  in  particular  on  the  joint  acquisition  of  military  equipment,  on  strategic  defence 
programming  to  set  clearer  priorities,  and  on  the  support  to  the  European  industrial  base, 
including  the  strengthening  of  the  European  defence  R&D  framework,  the  European  Defence 
Fund (EDF).  

The joint communication proposes to work on strategic short-, medium- to long-term capabilities 
to  improve  Europe’s  defence  capabilities. These include  development  and  operationalisation  of 
the  medium-altitude  “Eurodrone”  (MALE  RPAS)  –  which  forms  part  of  PESCO  and  EDF 
projects. Also, in the short- to medium-term developing and procuring counter drone-capabilities 
and weaponised medium-sized drones are identified as priorities. 

24  https://www.consilium.europa.eu/en/press/press-releases/2022/03/11/the-versailles-declaration-10-11-

03-2022  

25 

JOIN(2022) 24 final 

Page 11 / 86 

 
 
                                                      
4.2  Developing and implementing a regulatory framework 

4.2.1  Adoption of Regulation (EU) 2018/1139 on common rules in the field of civil 

aviation (2018) 

The  adoption of  the  new  EASA  Basic  Regulation26  repealing  Regulation  (EC)  216/2008  was a 
landmark for the implementation of an EU wide drone policy. The new Regulation extended the 
scope of EU competence to all drones, irrespective of their weight or size, including the design, 
production, maintenance and operation of unmanned aircraft, their engines, propellers, parts and 
non-installed  equipment,  as  well  as  the  equipment  to  control  unmanned  aircraft  remotely.  The 
operation-centric  approach  reflects  the  fact  that  drones  can  be  used  for  a  large  number  of 
missions  (recreational,  exploration,  delivery,  etc.)  that  all  display  different  levels  of  risks  for 
other  airspace  users.  This  complexity  could  not  be  reflected  by  a  framework  only  based  on 
criteria such as weight. The operation-centric approach also ensures that new developments are 
not hampered by unnecessarily heavy and costly rules and procedures, which is in line with the 
Commission's  Better  Regulation  approach.  The  new  EASA  Basic  Regulation  gave  the 
Commission the legal power to adopt implementing and delegated acts in order to implement the 
essential  requirements  contained  in  the  Regulation  and  guarantee  a  high  and  uniform  level  of 
civil aviation safety. 

4.2.2  Adoption of detailed implementing rules allowing effective drone operations 

and the development of industry standards 

In  line  with  the  operation  centric  approach  embedded  in  Regulation  2018/1139,  the  EU  drone 
regulatory  framework  should  therefore  be  able  to  address  safety  and  security  concerns  of 
different  types  of  drones  and  operations,  keeping  in  mind  the  risk  level  of  the  operation. 
Accordingly,  the  Commission  adopted  in  2019  two  Regulations:    Commission  Delegated 
Regulation  2019/94527  on  unmanned  aircraft  systems  and  on  third-country  operators  of 
unmanned aircraft systems and Implementing Regulation 2019/94728 on the rules and procedures 
for the operation of unmanned aircraft. 

Limited  to  outdoor  operations,  Implementing  Regulation  2019/947  applies  since  31  December 
2020. It lays down detailed provisions and conditions for the operation of drones, including the 
requirements to qualify as a remote pilot, minimum age of the pilot, requirements regarding the 
drones' airworthiness requirements, risk assessments, cross border operations, registration of the 
drone and its operator and competent authority. Regulation 2018/1139 introduces an approach to 
safety rules proportionate to the risk of the operation conducted by the aircraft. This approach is 
reflected in Article 3 of the Commission  Implementing  Regulation (EU) 2019/947. This article 
defines 3 categories of UAS operations, ‘open’, ‘specific’ and ‘certified’, corresponding to three 

26   Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common 
rules  in  the  field  of  civil  aviation  and  establishing  a  European  Union  Aviation  Safety  Agency,  and 
amending  Regulations  (EC)  No  2111/2005,  (EC)  No  1008/2008,  (EU)  No  996/2010,  (EU)  No 
376/2014 and Directives 2014/30/EU and 2014/53/EU of the European Parliament and of the Council, 
and repealing Regulations (EC) No 552/2004 and (EC) No 216/2008 of the European Parliament and 
of the Council and Council Regulation (EEC) No 3922/91. OJ L 212, 22.8.2018, p. 1 

27  Commission  Delegated  Regulation  (EU)  2019/945  of  12  March  2019  on  unmanned  aircraft  systems 

and on third-country operators of unmanned aircraft systems, OJ L 152, 11.6.2019, p. 1 

28  Commission Implementing Regulation (EU) 2019/947 of 24 May 2019 on the rules and procedures for 

the operation of unmanned aircraft, OJ L 152, 11.6.2019, p. 45 

Page 12 / 86 

 
 
                                                      
levels  of  risks  (low,  medium,  high).  They  are  addressed  by  three  different  set  of  rules,  all 
including a combination of rules on the design of the UAS and on its operations. 

The conversion of existing authorisations, certificates and declarations issued under the previous 
(nationally applicable) regulations could take place until 31 December 2022. A limited number of 
provisions  will  apply  as  from  1  January  2024,  e.g.  European  Standard  Scenarios  or  the  use  of 
drones in the Open category (linked to the creation of appropriate European standards). 

Commission Implementing Regulation 2019/947 allows Member States to further specify certain 
elements such as the minimum age for remote pilots and geographical zones for safety, security, 
privacy, and environmental reasons. Member States may:  

  prohibit certain or all drones operations, request particular conditions for certain or all drones 

 
 
 
 

operations or  
request a prior operational authorisation for certain or all drones operations;  
subject drone operations to specified environmental standards;  
allow access to certain drone classes only; 
allow  access  only  to  drone  equipped  with  certain  technical  features,  in  particular  remote 
identification systems or geo awareness systems. 

Commission  Delegated  Regulation  2019/945  entered  into  force  in  June  2019  and  was 
immediately applicable. It lays down the technical requirements relating to the unmanned aircraft 
itself. More specifically, this act lays down the regulation on:  

 
 
 

the product requirements for the design and manufacture of drone; 
the obligations of economic operators, importers, and distributors;  
the  definition  and  requirement  of  presumption  of  conformity  as  well  as  the  type  of  drone 
whose design, production and maintenance shall be subject to certification; 

  making drones intended for use in the 'open' category and remote identification add-ons;  
 

third country drone operators when they conduct drone operation pursuant to Implementing 
Regulation 2019/947 within the single European sky airspace. 

Under  Commission  Implementing  Regulation  2019/947,  national  competent  authorities  must 
establish  and  maintain  registration  systems  for  drones,  whose  design  is  subject  to  certification 
and  for  drone  operators  whose  operation  may  present  a  risk  to  safety,  security,  privacy,  and 
protection of personal data or the environment. 

On  visual  and  noise  pollution,  limits  reflecting  the  state  of  the  art  in  the  market  have  been 
introduced  for  small  drones  with  a  weight  of  less  than  4  kg  and  which  may  be  flown  close  to 
people by virtue of Regulation (EU) 2019/945. These limits will become even lower over time. In 
addition,  further  local  noise  constraints  can  be  set  in  respect  of  ‘UAS  geographical  zones’. 
Directive 2002/49/EC on noise also imposes to all agglomerations of more than 100.000 people 
to prepare action plans to manage and limit the noise from air operations including drones. 

On  emissions,  Regulation  (EU)  2019/945  imposes  that  small  drones  must  be  powered  by 
electricity. If managed properly, drone operations, particularly in urban area, can contribute to the 
reduction of air pollutants, rather than causing additional adverse health effects for the citizens. 

4.2.2.1  4.2.2.1 

‘Open’ category 

The  operations  in  the  ‘open’  category  are  performed  with  drones  with  a  Maximum  Take  Off 
Mass  of  25kg,  marked  with  a  Class  Identification  Label,  complying  with  the  technical 
requirements set out in Regulation 2019/945, always maintaining a Visual Line of Sight between 
the drone and the remote pilot and at a maximum altitude of 120 meters. They present the lowest 

Page 13 / 86 

 
 
risk  of  operations  and  therefore  do  not  require  any  prior  operational  authorisation,  nor  an 
operational declaration by the drone operator. 

4.2.2.2  4.2.2.2 

‘Specific’ category 

If  one  of  the  conditions  of  the  ‘open’  category  cannot  be  met,  the  operation  is  considered  as 
riskier than allowed under the 'open' category and must then comply with either the ‘specific’ or 
the ‘certified’ category conditions, depending on the level of the risk. If the operations falls in the 
‘specific’ categories, the drone operators has several possibilities: 

First,  to  carry  out  a  full  operational  risk  assessment  (Specific  Operation  Risk  Assessment 
(SORA)) on which basis the competent authority may grant an operational authorisation. 

Secondly,  submit  an  operational  declaration  of  compliance  with  so-called  European  ‘standard 
scenarios’  (as  defined  in  Annexes  of  Regulation  2019/947)  to  the  competent  authority.  Such  a 
declaration to the competent authority must contain:  

 
 
 
 

administrative information about the drone operator; 
a statement that the operation satisfies the operational requirement of a standard scenario;  
the commitment of the drone operator to comply with the relevant mitigation measures;  
confirmation  by  the  drone  operator  that  an  appropriate  insurance  cover  will  be  in  place,  if 
required by Union or national law.  

Once the competent authority has confirmed receipt of a complete declaration, the operation may 
take place. 

Thirdly,  a  light  UAS  (Unmanned  Aircraft  System)  operator  certificate  (LUC)  which  gives  the 
privilege to the Drone operator to start operations without requiring a prior authorisation. 

In the situation where an operator intends for the operation to take place partially or entirely in 
the airspace of a Member State other than the one of registration, the drone operator must provide 
the  competent  authority  of  the  Member  State  of  the  intended  operation  with  an  application 
including: (1) a copy of the operational authorisation granted (in the initial Member State); and 
(2) the location(s) of the intended operation and eventual mitigation measures.  

The  competent  authority  of  the  sought  Member  State  will  assess  the  intended  operation  and 
operational authorisation granted by the initial Member State and can then provide confirmation 
that the operation may be undertaken.  

In  the  event  where  a  declaration  of  compliance  has  been  made  to  another  competent  authority 
than  the  one  of  the  member  state  where  the  operation  would  take  place,  then  the  operator 
provides  the  competent  authority  of  the  member  state  of  the  intended  operation  with  a  copy 
thereof, as well as a copy of the confirmation of receipt and completeness. 

4.2.2.3  4.2.2.3 

‘Certified’ category  

The ‘certified’ category of operations presents the highest risk and therefore are subject to stricter 
safety requirements and conditions in order to ensure the highest level of safety which require the 
certification of the drone and the certification of the operator, as well as – where applicable – the 
licensing of the remote pilot. 

These  conditions  are  applicable  as  soon  as  the  operation  is  conducted  in  any  of  the  following 
conditions: 

  over assemblies of people; 
 

involving the transport of people; 

Page 14 / 86 

 
 
 

involving  the  carriage  of  dangerous  goods,  that  may  result  in  high  risk  for  third  parties  in 
case of accident; 

  Or if the drone has a characteristic dimension of 3 metre or more so as to mitigate the risks 

for third parties in case of accident. 

This category should allow a development of a whole new market called Innovative Air Mobility 
(IAM)  (international,  regional  and  Urban  Air  Mobility  (UAM))  to  emerge  with  a  use  of  new 
types of vehicles, including drones. IAM would represent a major development for the transport 
of  freight  and  people,  particularly  within  or  out  of  urban  environments  that  can  contribute  to 
reduce emissions and increase road safety, while providing new services to all communities.  

4.2.3  Adoption of a regulatory framework for the provision of U-space services 

Fulfilling  one  of  the  policy  objectives  set  in  the  Sustainable  and  Smart  Mobily  Strategy,  the 
Commission adopted on 6 April 2021 an initial regulatory framework for U-Space, consisting of 
three  Implementing  Regulations  (EU)  2021/664,  (EU)  2021/665  and  (EU)  2021/66629.  The  U-
space framework, which will be applicable as from 26 January 2023, will ensure the scaling up of 
routine  drone  operations  in  designated  geographical  zones  while  ensuring  the  safety  of  both 
people on the ground and traditional users of the airspace.  

It  introduces  new  services  for  drone  operators,  allowing  them  to  carry  out  more  complex  and 
longer-distance operations, particularly in congested, low-level airspace (below 120m), and when 
out  of  sight.  The  three  U-space  regulations  cover  the  roles  and  responsibilities  of  the  various 
entities  involved  in  the  definition  of  U-space,  the  provision  of  U-space  services,  and  the 
minimum necessary services required for manned and unmanned aircraft to operate within the U-
space.  

The intent of the U-space regulations is to ensure that any drone operator planning flights in U-
space is required to subscribe to one of the U-space service providers (USSPs). Flights may only 
be  performed  after  a  flight  authorisation  has  been  requested  and  issued.  The  three  main  (new) 
actors from a transaction perspective are: the drone operators willing to provide a drone service 
to  a  customer;  the  USSP  (enabling  the  drone  operation);  and  finally,  the  Common  Information 
Service. Peripheral actors include Air Navigation Service Providers (ANSPs) who  will continue 
to provide air navigation services for manned aircraft, while USSPs provide U-space services for 
drones.  ANSPs  must  collaborate  with  USSPs  (on  a  price  for  service  basis)  to  ensure  flight 
authorisations  are  coordinated  and  to  exchange  information  about  the  airspace  designations. 
Member States have full authority on the designation of U-space and decide how their airspace 
should  be  accessed  and  restricted.  In  addition  to  the  four  baseline  services  required  by  the  U-
space  regulation,  Member  States  can  require  USSPs  to  provide  additional  U-space  services  to 
support safe and efficient drone operations. 

29  Commission Implementing Regulation (EU) 2021/664 of 22 April 2021 on a regulatory framework for 

the U-space (OJ L 139, 23.4.2021, p. 161) 
Commission Implementing Regulation (EU) 2021/665 of 22 April 2021 amending Implementing 
Regulation (EU) 2017/373 as regards requirements for providers of air traffic management/air 
navigation services and other air traffic management network functions in the U-space airspace 
designated in controlled airspace (OJ L 139, 23.4.2021, p. 184). 
Commission Implementing Regulation (EU) 2021/666 of 22 April 2021 amending Regulation (EU) 
No 923/2012 as regards requirements for manned aviation operating in U-space airspace (OJ L 139, 
23.4.2021, p. 187) 

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4.3  Research & Innovation on drones and related systems 

A  large  number  of  collaborative  research  and  innovation  projects  addressing  drones  and 
Innovative Air Mobility, as disruptive fields of aviation, have been funded at EU level through 
various Commission research and innovation frameworks: 

  Horizon 2020, which was the EU's research and innovation funding programme from 2014-
2020  with  a  budget  of  nearly  €80  billion.  It  included  specific  topics30  that  funded 
transnational  research  projects  researching,  developing  and  testing  drones  for  specific 
capabilities, from transport to civil protection to law enforcement and border management. 
  Horizon Europe31, which succeeded Horizon 2020 and is EU’s key funding programme for 

research and innovation for 2021-2027 with a budget of €95.5 billion. 

  Connecting  Europe  Facility  for  Transport,  which  is  supporting  investments  in  building 
new  transport  infrastructure  in  Europe  or  rehabilitating  and  upgrading  the  existing  ones. 
Between  2021  and  2027  the  European  Climate,  Infrastructure  and  Environment  Executive 
Agency will manage €25.81 billion to support transport infrastructure projects throughout the 
EU and beyond. 

  The  European  Defence  Industrial  Development  Programme  (EDIDP),  which,  with  a 
financial  envelope  of  €500  million  for  2019-2020,  was  the  first  ever  EU  grant  programme 
targeting  capability  development  and  co-financing  the  joint  development  of  (new  and 
upgrading  of  existing)  defence  products  and  technologies.  EDIDP  was  one  of  precursor 
programmes of the European Defence Fund. 

  The European Defence Fund (EDF), which, with a budget of close to €8 billion for 2021-
2027, promotes cooperation among companies and research actors of all sizes and geographic 
origin in the Union, in research and development of state-of-the-art and interoperable defence 
technology and equipment. 

Those projects addressing drones, including Innovative Air Mobility, are advancing the state of 
the  art  in  multidisciplinary  areas  such  as  autonomous  flights  for  transport  monitoring,  aerial 
means for search and rescue, and automated electric mobility. They are developing new know-
how  and  are  testing  innovative  solutions  that  help  to  make  transport  safer,  more  resilient  and 
more environmentally friendly. 

Public concerns about drones and IAM are also addressed. Research and innovation helps drones 
and  IAM  not  only  to  become  more  safe  and  secure, quiet,  and  green  but  also more  accessible, 
affordable, and acceptable by the public. 

4.3.1  Single European Sky ATM Research (SESAR) 

In  2017,  the  European  Commission  mandated  the  SESAR  JU  to  coordinate  all  research  and 
development  activities  related  to  U-space  and  drone  integration.  In  2017,  the  SESAR  JU 
published the U-space Blueprint, setting out the vision and steps for the progressive deployment 
of U-space services from foundation services to fully-integrated operations. This was followed by 
the 2020 edition of the European ATM Master Plan, which incorporated a drone roadmap. 

30  See for example research and innovation under the EU civil security innovation and security research 
programme: 
https://home-affairs.ec.europa.eu/policies/internal-security/innovation-and-security-
research_en#:~:text=EU%20security%20research%20is%20one,anticipating%20tomorrow's%20threat
s  

31  https://ec.europa.eu/info/funding-tenders/find-funding/eu-funding-programmes/horizon-europe_en  

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In 2017 and 2018, the SESAR JU launched 19 exploratory research projects and demonstration 
projects aimed at researching the range of services and technological capabilities needed to make 
U-space  a  reality.  The  projects  brought  together  some  25  European  airports,  25  air  navigation 
service providers, 11 universities, more than 65 start-ups and businesses, as well as 800 experts, 
working  in close cooperation  with standardisation  and  regulatory  bodies,  including  EUROCAE 
and EASA. 

In the Horizon 2020 framework, the EU has invested €44 million into research and development 
through  SESAR  JU,  namely  €9  million  for  “exploratory  research”,  €30  million  for  “industrial 
R&D” and €5 million for “very large demonstrators”. Overall, by the start of 2018, the EU had 
provided  grants  for  more  than  €400  million  to  drone  related  projects  (covering  both  civil  and 
military  projects),  90%  of  which  correspond  to  the  7th  Framework  and  Horizon  2020 
Programmes32.  

In May 2019, SESAR JU launched an open call for exploratory projects within the framework of 
the SESAR 2020 research and innovation programme. The call covered a wide range of topics 
and aims at fostering new and innovative ideas to transform air traffic management in Europe. 

The SESAR 3 JU was set up in 2021 to build on the work and achievements of earlier SESAR 
research  and  innovation  programmes  (SESAR  1  and  SESAR  2020)  and  accelerate  the  market 
uptake of innovative solutions through a portfolio of demonstrators and a fast-track mechanism. 

It  is  co-funded  by  the  European  Union  through  the  Horizon  Europe  research  and  innovation 
programme and industry as follows: 

  Horizon Europe - EUR 600 million 
  Eurocontrol – up to EUR 500 million (in-kind and financial contributions) 
 
Industry - EUR 500 million minimum (in-kind and financial contributions) 

In addition, the Digital European Sky programme will benefit from funding for its demonstrators 
from the Connecting Europe Facility (in coordination with CINEA) to the value of at least EUR 
200 million. 

4.3.2  European  Climate,  Infrastructure  and  Environment  Executive  Agency 

(CINEA) 

CINEA also managed a cluster of drone and IAM projects under the EU Research and Innovation 
programme Horizon 2020, combining several aeronautical disciplines together with cross-cutting 
areas  to  test  and  advance  the  pre-deployment  of  drones  and  new  urban  air  vehicles  in  very 
different  environments33.  This  comprehensive  approach  includes  the  efficient  integration  with 
urban infrastructures, with energy and communication networks and with other transport modes. 

In addition to the Horizon 2020 and Horizon Europe programmes, CINEA also implements other 
key  EU  programmes  such  as  the  Connecting  Europe  Facility  (CEF)  for  deployment  of 
infrastructures,  including  for  transport  at  large  and  air  traffic  management  (ATM).  In  close 
cooperation with the SESAR Joint Undertaking, a call for proposals was launched under CEF in 
2021,  containing  provisions  for  a  series  of  Digital  European  Sky  Demonstrators.  The  future 
demonstrators are a key tool to support the vision of delivering the Digital European Sky. A total 

32  https://ec.europa.eu/info/research-and-innovation/funding/funding-opportunities/funding-programmes-

and-open-calls/horizon-2020_en  

33  https://cinea.ec.europa.eu/publications/drones-and-sustainable-urban-air-mobility-uam_en 

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budget of EUR 60 million is earmarked for the future demonstrators, which are expected to be 
launched in 2022 and to run until 2025.  

One of the CEF Digital European Sky topics is “U-space and urban air mobility”. To unlock the 
potential of the drone economy and enable urban air mobility (UAM) on a wide scale, a new air 
traffic management framework for low-altitude operations needs to be put in place. Known as U-
space, the framework foresees a set of new services relying on a high 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  of 
environments - even the most congested. 

4.3.3  European defence research and innovation 

Drones  have  been  actively  used  in  the  defence  sector  over  the  last  decades  as  well.  The 
Commission launched in 2016 the European Medium Altitude Long Endurance Remotely Piloted 
Aircraft  System  (MALE  RPAS)  programme  to  ensure  EU’s  sovereignty  in  the  field  of 
Intelligence,  Surveillance,  Target  Acquisition  and  Reconnaissance  (ISTAR)  and  to  foster  the 
European  Defence  Technological  and  Industrial  Base  (EDTIB).  As  part  of  the  direct  award 
project  within  the  European  defence  industrial  development  (EDIDP)34  work  programme,  this 
project  led  by  four  European  entities  (Airbus  Defence  and  Space,  Leonardo  and  Dassault 
industrial partners), received an EU contribution of €100 million for a total cost of €300 million.  

The European Defence Fund, for which the EDIDP was a predecessor, is a powerful instrument 
to boost industrial Defence cooperation throughout Europe and increase EU’s technological edge 
and develop the capabilities that are key for the strategic autonomy and resilience of the Union. 

EDIDP had a budget of €500 million for 2019-2020, to be compared to the €8 billion from the 
EU budget dedicated to the European Defence Fund for 2021-2027. This means that the EU will 
become one of the top 3 defence research investors in the world. 

4-8%  of  this  budget  will  be  set  aside  to support  innovative  disruptive  technologies for  defence 
that  will  boost  Europe’s long-term  technological  leadership  and  contribute  to  high-end  defence 
products.  One  category  of  actions  considered  is  called  “Digital  Transformation”  and  includes 
calls and topics related to unmanned aircraft. 

Coherence  with  other  EU  initiatives  is  key  and  the  Action  Plan  on  synergies  between  civil, 
defence  and  space  industries  complements  the  European  Defence  Fund  with  the  aim  to  avoid 
unnecessary  duplication,  enhance  complementarity  and  ensure  cross-fertilisation  between  civil, 
security and defence. 

The  emergence  of  new  types  of  platforms,  from  micro  drones  to  larger  drones,  as  well  as  the 
current  development  of  MALE,  offer  an  opportunity  to  foster  synergies  with  sustainable  and 
smart  mobility  objectives,  improve  the  competitiveness  of  European  industry  and  strengthen 
Europe's  strategic  autonomy  in  this  key  technical  domain.  This  also  represents  an  excellent 
opportunity  for  civil-military  cooperation  since  many  of  the  technological  building  blocks 
building up these systems, such as Detect and Avoid, autonomy, datalinks, electro-optical sensors 
and  other  payloads  are  paradigmatic  cases  of  dual-use  enabling  technologies,  which  ideally 
should also have European origins. 

34  The  European  Defence  Industrial  Development  Programme  (EDIDP)  was  a  two-year  programme 
(2019-  2020)  of  the  European  Commission  aiming  at  supporting  the  joint  development  of  defence 
technologies and products. 

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5  PRESENTATION OF THE EU DRONE ECO-SYSTEM TODAY 

5.1  The elements of the eco-system 

The  Drone  Value  Chain  includes  many  actors  which  are  coming  from  the  transport  sector  and 
beyond.  To  present  the  drone  value  chain,  distinctions  should  be  made  between  the 
systems/products put in place to enable drones to operate safely and securely; and the services (or 
groups of services) that drones can deliver to the end-customers, as presented in the figure below: 

The drone eco-system 

In more details, the B2B drone value chain includes several segments which are all interlinked:  

  Drone operators (service provider) performing Innovative Aerial Services;  
 
  Drone  manufacturers  which  produce  the  hardware.  This  activity  may  also  include  the 

IAM operators offering innovative transport services;  

assembly of some components produced by third parties;  

  Producers of other payloads to be integrated to the drones, e.g., for filming, inspection, cargo, 

monitoring or measuring purposes;  

  Technology providers for the platform who develop equipment and software systems whether 
for  communication,  control  of  the  flight,  situational  awareness,  or  to  enable  specific  or 
autonomous operations);  

  Distributors selling or renting finished drone to third companies;  
  Ground infrastructure operators such as vertiports and airports;  
  Air  traffic  management  suppliers  (e.g.  ANSPs,  U-space  service  providers,  Common 

Information Service Providers);  

  Telecommunication  infrastructure  providers,  as  well  as  navigation  and  surveillance 

infrastructure providers.  

These actors are grouped in the following drone market segments: 

  Drone services market: primarily service providers and customers. The drone services market 
facilitates access to all industries as the final customer and eventually provides most societal 
value.  For  example:  by  safely  operating  drones  for  data  gathering  or  inspections,  data  is 
delivered  into  value  chains  in  sectors  like  agriculture,  construction,  security,  etc.,  where  it 
can  be  processed  and  analysed  for  specific  purposes.  The  key  point  is:  the  drone  is  a  data 
gathering instrument in a longer value chain that includes other technological applications to 
make best use of the data collected. 

  Drone operations market: primarily drone technology developers and drone users/pilots. The 
drone operations market is the tool to deliver transport for passengers or cargo as well as to 
deliver drone services where the drone becomes a link in a full value chain.  

Page 19 / 86 

 
 
 
 
  Enabling services and infrastructure market: primarily associated with the implementation of 
U-space  services,  and  enabling  service/infrastructure  providers.  The  enabler  for  automated 
longer distance, scalable drone operations and drone services. This enabler should be as cost-
effective as possible, while providing fair access to airspace for a diversity of drone operators 
from across the EU.  

Each individual link of the value chain needs in principle to be competitive to allow access by all 
industries potentially benefitting from drone operations and services, as well as final customers, 
and ultimately to provide societal value. 

5.2  Drone services offered today 

As introduced in section 2, drone operations can be classified in two main groups: 

(1)  Aerial Operations - in this case, drones are used as daily tools in ever broadening fields such 
as  inspection  (pipe  line,  rail,  windmill  maintenance),  agriculture,  mapping,  architecture, 
constructions,  real  estate,  energy,  environment  and  public  safety  (firefighting,  search  and 
rescue, border patrol, local law enforcement); 

(2)  Innovative Air Mobility – where drones and electric Vertical Take Off and Landing aircraft 

(eVTOL) are used for the transport of people and cargo. 

5.2.1  Aerial operations 

The  drone  services  market  related  to  aerial  operations  is  well  established  and  includes  the 
following mature use cases, with a confirmed or very short term expected commercial viability:  

  Data collection, for example: aerial photography and data collection for scientific research; 
  Surveillance, providing aerial security and monitoring; 
  Surveying, inspection and maintenance, for example: improving urban planning;  measuring 
building energy efficiency, allowing servicing of infrastructure in particular in environments 
where safety is a concern; 

  Entertainment  or  advertising,  for  example:  using  a  drone  swarm  to  replace  fireworks 

displays. 

This  is  by  no  means  an  exhaustive  list  and  other  use  cases  are  developing  rapidly  and  are 
expected to become commercially viable with 2 to 5 years, for instance: 

  Precision agriculture: monitoring of crops, spraying, environmental protection, planting, etc; 
  Emergency and other public services, including police, firefighting as well as natural disaster 

response.  

5.2.2  Innovative air mobility 

Innovative Air Mobility covers use cases related to the transport of goods and people. Those use 
cases show considerably less maturity and longer term expected commercial viability compared 
to most aerial operations. 

Indeed,  we  are  at  the  dawn  of  small  parcel  delivery  services  by  drone,  with  pioneer 
implementations existing in Europe (e.g. “Manna” drone delivery service near Dublin, Ireland, or 
“Wing” drone delivery service near Helsinki, Finland), and medical transport is also developing 
fast (transport of medical samples between hospitals and laboratories, delivery of prescriptions to 
remote areas…). However, operations related to the transport of people – or heavier cargo - have 
yet to materialise. 

Page 20 / 86 

 
 
High noise levels, lack of helipads availability and high operational costs can explain the lack of 
success  of  passenger  transport  by  helicopter  so  far.  Recently  though,  the  interest  in  Urban  Air 
Mobility  has  been  reinforced  by  the  development  of small,  electrically  powered  Vertical Take-
Off and Landing (eVTOLs) aircraft. An eVTOL aircraft is a type of manned or unmanned aircraft 
that  uses  electric  power  to  hover,  take-off  and  land  vertically,  without  the  use  or  need  for  a 
runway. In an initial phase, these vehicles will have a qualified pilot on board. In a later stage, it 
will  then  be  possible  to  have  the  drone  remotely  piloted  (from  the  ground)  or  even  proceed  to 
fully automated flights (remove the pilot on board or on the ground). 

Passenger drones may be used within large and sprawling urban areas as part of a new Urban Air 
Mobility approach, or to connect cities with regions that are either difficult to access by surface 
transport  or  lack  the  infrastructure  or  scale  necessary  to  support  traditional  forms  of  aviation. 
Although  the  capabilities  of  these  aircraft  have  been  improved  significantly,  there  are  still 
performance  issues  that  need  to  be  addressed,  linked  for  example  to  the  batteries  and  range 
limitations,  as  well  as  social  acceptance.  Furthermore,  their  financial  viability  also  depends  on 
several  conditions  like  the  targeted  level  of  safety,  the  fact  that  the  first  phase  of  commercial 
operations  will  be  carried  out  with  a  pilot  on  board,  initial  higher  costs  related  to  the  OEMs 
production  and  maintenance,  traffic  management  and  operational  constraints  related  to  social 
acceptance and which are examined in Chapter 8 below. 

5.3  Drones as an emerging sector of the economy 

The EIB monitors the evolution of the drone sector in particular for Urban Air mobility and U-
space and provides funding and technical assistance including for infrastructures that will enable 
drone  operations.  However,  as  found  by  the  EIB,  most  private  sector  entities  in  the  drone 
ecosystem  are  small  scale and  some  are  yet  without a  robust  business  plan  in  place to  achieve 
commercial operations. There is a reliance on central funds, grants and venture capital to invest 
in research and development projects. All of this suggests a need to mature the industry capability 
rapidly, which requires having funding and financing mechanisms available to suit each part of 
the cycle and avoid falling into the first ‘valley of death’, as shown in the Figure below: 

 (Source: European Investment Bank) 

Financial cycle of a business 

Page 21 / 86 

 
 
 
The European Investment Bank Guide to Finance for Drone Projects maps out the advisory and 
financial products that can potentially be used to support investments in drones, depending on the 
area of investment and the maturity of the market.35 The EIB itself identified a lack of products 
covering  vehicles,  associated  technologies  and  enablers  and  maintenance  during  the  early 
commercialisation stage. These areas might be covered by venture capital activities. 

Venture  capital  is  more  abundant  outside  of  Europe,  with  the  US  leading  the  world  in  drone 
venture  capital  investment.  The  majority  of  investments  are  focused  on  drone  operations  (e.g. 
drone  hardware)  rather  than  enabling  systems  and  end  services.36  There  is  an  incentive  for 
European start-ups to move to the US to seek venture capital funding for their projects.37 Europe 
also  lags  behind  both  the  US  and  China  in  total  investment  in  drone  services  and  number  of 
vehicles respectively. A constraint faced worldwide is that investment in this immature industry 
is a high risk and long-term horizon investment. The projected development of the drone market 
in  the  future  suggests  profitability  in  various  applications  by  2040,  but  timescales  remain 
imprecise and perhaps speculative. The main issue is the lack of established business models for 
drone  services,  which  means  any  business  who  wants  to  invest  in  drone  services  needs  to  be 
willing to sustain losses for a relatively long amount of time while the market matures38. 

6  THE POTENTIAL BENEFITS OF A VIABLE DRONE ECO-SYSTEM IN EUROPE 

6.1  Growth and Jobs 

There is a variety of studies on the current and future expected market size of the drone market. 
Based  on  an  analysis  of  the  available  studies  and  forecast,  the  estimated  amount  of  the 
commercial value of drones  in 2030 ranges between € 10,3 billion and € 20,4 billion, with the 
most likely outcome being € 14,5 billion, with an associated CAGR of 12.3%, as presented in the 
figure below: 

35   https://www.eib.org/attachments/publications/eib_guide_to_finance_for_drone_projects_en.pdf. 

36  McKinsey  estimated  in  2017  that  start-ups  had  attracted  more  than  $3  billion  in  funding  to  explore 
investment  was  aimed  at  vehicle  development: 

drone  applications.  About  half  of 
https://www.mckinsey.com/industries/travel-logistics-and-infrastructure/our-insights/commercial-
drones-are-here-the-future-of-unmanned-aerial-systems. 

the 

37   See  for  example  German  start-up  Lilium,  which  is  aiming  to  offer  a  UAM  service  in  New  York  by 

2025. 

38   See  for  example  Wing,  which  has  successfully  implemented  drone  deliveries  in  Helsinki,  but  relies 
predominantly on finances from the large multinational parent company Alphabet who generally has a 
high technology risk appetite. 

Page 22 / 86 

 
 
                                                      
Source: Drone Strategy 2.0 Fact-Finding Study, Ecorys 

Estimated commercial value of drones (in EUR billion) in Europe 

Furthermore, a recent study by the JRC39 , currently being updated to include more scenarios and 
to compare the EU situation with the US one, has shown that the existing land-use patterns in the 
EU can ensure financial viability of drone delivery services in most cities. In addition, as shown 
in the next figure, the research shows that as soon as the demand for freight deliveries by drones 
increases, the number of financially viable drone “nests” in the EU could be substantially higher 
than  in  the  US  (due  to  the  land-use  pattern  of  EU  cities)  thus  representing  a  potentially  more 
interesting market: 

Number of estimated economically viable drone delivery nests as a function of Market 
Penetration (MP) for EU and US for a box cost of 0 and 0.5 euro. 

39 https://etrr.springeropen.com/articles/10.1186/s12544-019-0368-2 

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In  general  drone  services  are  providing  automated  solutions,  which  have  an  impact  on 
employment.  These  effects  could  work  both  ways  (negative  or  positive)  and  likely  in  parallel. 
According  to  a  recent  study  by  the  International  Transport  Forum  (ITF),  drones  will  increase 
productivity  in  some  sectors.  Businesses  may  also  replace  human  centric  tasks  using  other 
justifications, for example safety benefits associated with inspection of dangerous infrastructure. 
In practice a combination of both people and drones will likely be used over the short to medium 
term. As with all technological changes in the workplace, learning or reskilling programs would 
facilitate transitions in the labour market. Apart from employment effects related to the changing 
business models, drones could also create new tasks. 

Predictions with varying geographic scale and timelines are available for the potential number of 
operational drones show:  

  A  current  baseline  (2020)  of  between  100,000  –  200,000  commercial  drones  in  use  in 

Europe; 

  A  commercial  drone  fleet  of  between  400,000  –  800,000  in  Europe  in  2030  (with  higher 

probability that it is closer to the lower bound). 

According  to  SESAR  (2016),  there  is  substantial  job  creation  expected  (such  as  localised 
operations,  pilots,  insurers  and  others).  One  might  expect  a  large  opportunity  for  jobs  in  the 
software development/automation and telecommunications /data industries. In total, the sector is 
conservatively  expected  to  create  roughly  100.000  direct  jobs.  When  including  wider 
employment effects (so called indirect effects), the total number of jobs at a European level rises 
to between 250.000 and 400.000 jobs towards 2035.40   

To provide an idea of the potential number of jobs in the EU in 2030 the support study took the 
employee productivity figure used by SESAR JU in their drone outlook study and scaled it based 
on updated market predictions. The figure applied is 100.000 euro per employee. The study has 
determined  a  low,  medium  and  high  scenario,  which  have  a  similar  growth  rate  as  the  market 
value predictions. In the medium scenario, the total number of direct employees is estimated at 
around 145.000 in Europe in 2030. The results are presented visually in the Figure below:  

Source: Drone Strategy 2.0 Fact-Finding Study, Ecorys 

Estimated number of (direct) employees in Europe (x 1.000 employees)  

40   SESAR JU (2016), European Drones Outlook Study. 

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Indirect  effects  are  retrieved  from  macroeconomic  multipliers  produced  by  the  OECD41.  The 
relevant  multipliers  from  sectors  such  as  computer  related  activities,  electrical  machinery,  etc. 
range  between  1.9  and  3.0.  The  multipliers  provide  a  simple  method  for  determining  indirect 
employment  impacts  based  solely  on  the  expected  level  of  direct  employment  impacts.  Using 
these  multipliers  the  external  study  suggests  that  the  total  employment  impact  of  the  drone 
industry (direct and indirect) should range between 200.000 to 600.000 additional employees in 
2030. 

6.2  Decarbonisation and circular economy 

6.2.1  Decarbonisation 

Decarbonising transport remains one of the major challenges ahead in order to mitigate climate 
change.  Globally,  roughly  25%  of  the  greenhouse  gas  (GHG)  emissions  are  emitted  by  fuel 
combustion from transport. And as of today, the sector remains dependent on oil for 92% of its 
energy demand. 42  

In the EU, transport emissions represent around 25% of the EU’s total greenhouse gas emissions. 
A clear path is needed to achieve a 90% reduction in transport-related greenhouse gas emissions 
by  2050,  in  line  with  the  European  Green  Deal  objectives.  Although  emissions  reduction  is 
possible across almost all drone use cases, the emissions reduction potential is mostly associated 
with logistics and passenger transport. 

A  number  of  drone  applications  are  powered  through  electric  propulsion  (and  other  emerging 
technologies)  providing  a  decarbonised  alternative  to  current  modes  of  transport  and  therefore 
supporting  the  Paris  Agreement  and  the  European  Green  Deal  objectives  to  achieve  net  zero 
emissions.  Drones  have  the  potential  to contribute  to  the  decarbonisation  and modernisation  of 
the  transport  and  mobility  system,  addressing  its  negative  impact  on  the  environment  and 
improving the safety and health of European citizens. 

However,  while  drones  are  emission  free  the  production  of  electricity  may  generate  emissions. 
Most  drones  are  powered  by  electricity  and  produce  zero  tailpipe  emissions  creating  no  direct 
(scope 1) greenhouse gas emissions, as combustion engine drones will likely not be used in the 
future. This means they can immediately contribute to reduce net greenhouse gas emissions. All 
drones  will  consume  energy  creating  indirect  (scope  2)  emissions.  The  amount  of  energy  used 
and  subsequently  the  amount  of  scope  2  emissions  will  depend  on  the  design  of  the  drone,  its 
payload,  the  energy  mix  used  for  electricity  production,  and  the  method  of  electricity 
transmission to the battery. The production and scrapping of drones at the end of their lifespan 
will also consume energy and produce indirect (scope 3) emissions. The net emissions of drones 
compared to traditional modes of transport will depend on the specific use case, the local context 
and the source of energy supply. 

Given  the forecasted  fast  drone  development  in  the  future,  the  environmental  impact  of  drones 
must be given high consideration and requires further research. Expected environmental impacts 
will  especially  arise  from  the  manufacturing,  the  utilization,  and  the  waste  streams  of  drone 

41   OECD  STAN  Database  for  Structural  Analysis  (ISIC  Rev.  4):  For  selected  industries  factor  is 
determined  by  division  of  "Production  (gross  output)"  by  "Number  of  persons  engaged  (total 
employment)". 

42   International  Transport  Forum  (2021),  Ready  for  Take-Off?  Integrating  Drones  into  the  Transport 

System. 

Page 25 / 86 

 
 
                                                      
products and of the related infrastructure as well as by the development of drone operations in 
metropolitan areas, which will entail the development of suitable network of vertiports.  

Drones  have  the  potential  to  reduce  energy  use  especially  if  sustainable  use  of  batteries  is 
mandated. Transport-related CO2 and other emissions could be reduced (e.g. last mile transport 
for low weight goods when energy comes from sustainable sources) in comparison to traditional 
modes of transport. On the other hand, there is clearly a debate about negative externalities43 that 
might  be  realised  with  the  further  scaling  of  drone  activity  (such  as  noise  related  impacts).44 
These environmental impacts on noise, air pollution and wildlife are further addressed in chapter 
8.1.4 below. 

The  potential  emissions  reduction  for  drone  delivery  were  estimated  in  the  support  study  by 
means of a “quick scan” analysis. The following methodological steps were taken to determine 
the potential emissions reduction for goods delivery:  

  Step  1:  Determining  the  commercial  value  of  good  delivery  services  and  share  of  goods 

delivery within the estimated economic value of the European drone industry; 

  Step 2: The added value (expressed in euro p. eVTOL unit) of delivery drones is estimated; 
  Step 3: Assessing the number of delivery drones towards 2030; 
  Step 4: Estimating the number of potential drone deliveries and freight potential by assuming 

the average productivity of delivery drones; 

  Step 5: Retrieving the emissions key figures from existing literature; 
  Step  6:  Providing  an  estimated  bandwidth  of  the  potential  emissions  reduction  from  drone 
delivery services by determining the expected modal shift (e.g. electric van, diesel van, cargo 
bike and drone). 

By replacing cargo deliveries and last-mile express deliveries from traditional means of transport 
to  drone services, the emissions  reduction  potential is  estimated  at  around  120,000  ton  CO2  in 
2030 in  Europe. The  results  (and  bandwidths  associated  with the analysis)  are presented  in  the 
figure below.  

43   Externalities occur when producing or consuming a good cause an impact on third parties not directly 

related to the transaction. 

44   International Transport Forum (2021). 

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 (Source: Ecorys) 

Source: Drone Strategy 2.0 Fact-Finding Study, Ecorys 

Potential emission reduction for drone deliveries (in ton CO2) 

Several  scientific  studies  in  the  field  of  the  impact  on  the  level  of  CO2  emissions  from  drone 
deliveries  have  been  performed.  Besides  the impact in  the  drone  delivery  domain, there  is  also 
impact on decarbonisation expected in other applications and sectors. For example, drones might 
be  used  instead  of  high  emissions  vehicles  in  some  agricultural  practices  such  as  spraying  or 
planting. The findings from several studies (non-limitative) can be briefly described as follows:  

  Park, J., Kim, S., & Suh, K. (2018) 45 studied the environmental impact of drones compared 
to motorcycle delivery and differentiating between urban and rural areas. The results showed 
that  global  warming  potential  (GWP)  per  1  km  delivery  by  drone  was  one-sixth  of  a 
motorcycle delivery. In addition, the particulates produced by drone delivery were half that 
of  motorcycle  delivery.  The  researchers  conclude  that  the  actual  environmental  impact 
reduction  in  case  of  delivery  distance  was  13 times  higher  in a  rural  area than  in  an  urban 
area.  When  increasing  the  use  of  environmentally  friendly  electricity  systems,  for  instance 
solar  and  wind  power,  this  could  further  enhance  the  environmental  effects  of  a  drone 
delivery system. 

  Borghetti,  et  al  (2022)46  investigated  the  viability  of  last-mile  delivery  drones  in  Milan, 
where  they  used  stated  preference  survey  and  financial  analysis.  Findings  show  a  high 
propensity  by  end  users  to  use    last-mile  delivery  by  drones  can  be  successfully  used  to 
deliver  small  and  light  packages,  reducing  environmental  and  social  impacts,  and  ensuring 
profits  for  the  transport  provider.  In  light  of  the  financial  viability  of  last-mile  delivery 
drones, they could be a solution to reduce traffic congestion and CO2 emissions. 

  WING  investigated  –  by  means  of  ex-ante  and  ex-post  studies  –  the  effects  of  drone 
deliveries  to  society.  One  of  these  studies  are  performed  by  Gaia  Consulting  Oy47,  which 
studied  the  potential benefits  of  drone  deliveries in  Finland. The  benefits are  expressed for 

45   Park, J., Kim, S., & Suh, K. (2018).  A comparative analysis of the environmental benefits of drone-

based delivery services in urban and rural areas. Sustainability, 10(3), 888. 

46   Borghetti,  F., Caballini,  C., Carboni,  A., Grossato, G., Maja, R., & Barabino, B. (2022).  The Use of 
Drones for Last-Mile Delivery: A Numerical Case Study in Milan, Italy. Sustainability, 14(3), 1766. 

47   Gaia Consulting Oy (2021), Potential Benefits of Drone Deliveries in Helsinki. 

Page 27 / 86 

 
 
 
                                                      
local businesses, consumers and society. Societal benefits are expressed via the reduction of 
vehicle kilometers travelled by road (equal to a reduction of 11 million km); reducing CO2 
emissions (reduction of 2.000 t CO2); reducing road accidents (38 less road accidents). For 
local businesses and consumers, the benefits  are linked to lower delivery costs (45% lower 
costs) and the connectivity (expressed via delivery reach and product variety).  

6.2.2  Circular economy 

The  development  of  a  drone  value  chain  should  also  give  careful  consideration  to  circular 
economy  aspects.  The  risks  associated  to  the  lack  of  raw  materials  are  concrete  and  the  EU 
cannot accept being dependent on external support for the implementation of this key technology. 
On the other hand, this issue may represent a significant opportunity for the European industry 
industry,  building  competitive  advantage  on  environmental 
for  developing 
sustainability and Circular Economy. The waste of electronics components must be avoided and 
the  drone’s  end-of-life  opportunities  should  and  could  be  more  effectively  and  efficiently 
addressed now at the beginning of the fast-emerging drone sector.  

the  drone 

Moreover,  when  looking  at  drones  we  cannot  focus  only  on  the  airborne  segment.  To  execute 
their  tasks,  drones  require  dedicated  ground  infrastructures.  The  same  Circular  Economy 
considerations apply to the ground segment as drone operations spread across the territory.  

6.3  Digitalisation 

The development of Innovative Aerial Services and the digital transformation go hand in hand. 
Drone  technology  and  its  multiple  applications  are  based  on  a  high  level  of  digitalisation  and 
automation,  as  described  below.  At  the  same  time,  drones  can  deliver  accurate  and  actionable 
data  to  improve  operational  workflows,  streamline  processes  and  contribute  to  finding  digital 
solutions in a wide variety of use cases, such as agriculture, construction, mining, surveillance, 
and inspection. 

Embracing digital technologies has become essential for many businesses to remain competitive 
in an ever increasingly interconnected economy. Digital technologies and products have also the 
potential  to  lower  the  environmental  footprint  of  the  economy  and  lead  to  higher  energy  and 
material efficiencies. 

The 2030 Digital Compass48 identified five key industrial ecosystems for digital transformation: 

  Manufacturing; 
  Health; 
  Construction; 
  Agriculture; and 
  Mobility. 

Out  of these, at  least four  (health,  construction, agriculture,  and  mobility)  have the  potential to 
directly  benefit  from  the  introduction  of  aerial  operations  and  innovative  air  mobility  to  drive 
changes  in  their  respective  sector,  as  illustrated  by  the  drone-use  cases  listed  in  5.2.  But  other 
ecosystems could also reap benefits from synergies with the technological development brought 
by drones, in particular in the fields of automation and artificial intelligence. 

48  2030  Digital  Compass:  the  European  way  for  the  Digital  Decade,  COM(2021)  118  final,  Brussels, 

9.3.2021 

Page 28 / 86 

 
 
                                                      
This  digital  transformation  will  not  only  concern  industrial  ecosystems  but  also  affect  public 
services, and enable an efficient, holistic, and easy access to public services to all citizens. Here 
again  drone  services  have  the  potential  to  support  this  transformation  by  connecting  remote 
communities and ensuring the continuity of public services. 

The contribution of drones to the digitalisation of the economy is not limited to drone  services 
provided to industrial and public sectors but extends across the whole drone value chain. Drone 
operations and enabling services have indeed the potential to be instrumental in the digitalisation 
of aviation. 

First,  drone  vehicles  are  catalyst  for  innovation  in  aviation.  They  are  not  only  spurring  the 
electrification  of  aviation  and  the  development  of  more  sustainable  aircraft,  but  they  are  also 
advancing automation and connectivity at an unprecedented speed in air transport. 

Autonomous  flight  technology  should  enable  accurate  operations  (including  detection  and 
avoidance of other vehicles and obstacles) without any involvement of human operations. Also 
here, the drone operations market is expected to act as a catalyst for the development of aviation, 
functioning as an enabler of innovation and digitalisation. 

The  standard  SAE  J3016  developed  for  road  vehicles49  is  commonly  used  as  basis  when 
assessing  the  level  of  automation  within  drones.  The  standard  defines  six  levels  from  no 
automation to full automation.  

Currently, due to restrictions in permitted level of flight automation, the use of drones still faces 
limitations. Nevertheless, drones are applied at various levels of autonomy, as illustrated in the 
figure below. Drones are applied at low automation degree in inspection & maintenance; location 
& detection; photography and filming, and monitoring. At partial automation degree, drones are 
used  in  mapping;  spraying  &  seeding,  measuring;  and  surveying.  At  degree  of  conditional 
automation, drones are used in mapping, delivery and surveying.  Initial steps are taken in high 
automation in the case of photography and filming.  

A  enabling  service  such  as  U-space,  the  set  of  digital  services  and  operational  procedures 
designed to support a safe, efficient, and secure access to airspace for large numbers of drones, 
can be an accelerator of the ATM innovation life cycle, facilitating faster, lower risk adoption of 
new technologies or approaches (automation, AI, cloud, etc.) in manned aviation. 

Such disruptive innovations can reduce innovation cycles from about 30 years that are typical in 
traditional aviation to about 5-10 years. To achieve this, the development and deployment of the 
integration of drones into the airspace, and in particular the development and implementation of 
U-space services, may be used as a ‘laboratory’ that can support faster life cycles in the manned 
aviation environment, and ultimately the implementation of the digital European sky50. 

The digital European sky leverages the latest digital technologies to transform Europe’s aviation 
infrastructure  enabling  it  to  handle  the  future  growth  and  diversity  of  air  traffic  safely  and 
efficiently,  while  minimising  environmental  impact.  In  doing  so,  these  technologies  enable  the 
system to become more modular and agile, while building resilience to disruptions, traffic growth 
and  diversity  of  air  vehicles51.  Drones,  relying  on  an  operations-centric  approach  and  a 
digitalised  system,  can  be  a  catalyst  towards  increased  levels  of  digitalisation  of  the  entire 
aviation system, currently still relying on a human-centric approach, for example in ATM. 

49   https://www.sae.org/standards/content/j3016_202104/  

50  Strategic Research and Innovation Agenda - Digital European Sky, SESAR Joint Undertaking, 2020. 

51   Digital European Sky – Blueprint, SESAR Joint Undertaking, 2020. 

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7  VISION AND STRATEGIC OBJECTIVES 

7.1  Vision 

Setting  out  a  vision  involves  on  the  civil  side  to  cater  for  the  situation  of  three  different  but 
interlinked  markets:  Aerial  Operations,  Innovative  Air  Mobility  and  U-Space  services  as 
described  above.  The  drone  eco-system  also  includes  the  defence/military  dimension,  as  both 
sides stand to benefit from technological synergies.  

This  vision,  developed  by  the  Drone  Leaders  Group  (see  A.4)  for  2030,  can  be  formulated  as 
follows: 

By  2030  drones  and  their required  eco-system  will  have  become  an  accepted part  of 
the life of EU citizens and Member States. 

They  will  be  used  to  provide  numerous  services  to the  benefits  of  diversified  civilian 
and  defence  end-users,  including  EU  citizens,  organisations,  States,  and  industry. 
These aerial operations will include emergency services, inspections, and surveillance, 
using drones as flying Internet of Things (IoT) platforms to gather data, as well as for 
the delivery of goods. 

Innovative Air Mobility (IAM) services will also have started to provide regular people 
transport  services  in  various  European  cities  and  for  some  regional  connections, 
initially  using aircraft  with  a  pilot on  board  but  with  the  aim  to  fully  automate their 
operations.  Drone  services  will  effectively 
integrate  or  complement  existing 
transportation systems and contribute to the decarbonisation of the transport system, 
while  minimising  their  impact  on  the  environment  throughout  their  life  cycle.  Urban 
Air Mobility (UAM) will have started to become a part of the future urban multimodal 
intelligent  mobility  ecosystem  and  the  infrastructure  enabling  these  services  will  be 
widely deployed and integrated. 

A wide spectrum of distinct types of drones and use cases will coexist in the future. The 
EU  legislator,  the  Commission,  the  European  Union  Aviation  Safety  Agency  (EASA) 
and the Member States all have an institutional responsibility to safeguard the safety, 
security and efficiency of their operations. They will ensure that all drone services are 
provided in  a  manner that  ensures  safety, security, privacy, and  affordability, in  line 
with  citizens’  expectations  and  addressing  their  concerns.  Drones  used  for  the 
transport  of  people  and  goods  will  be  particularly  oriented  to  the  achievement  of 
publicly accessible services, thus creating benefits for citizens and local communities.  

The current U-space regulatory framework will have been completely rolled out in a 
seamless  EU  market.  Additional  advanced  U-space  services  will  support  large  scale 
highly automated and digitally connected affordable, safe, secure, and environmentally 
friendly  unmanned  aircraft  operations  in  several  Member  States.  The  integration 
between manned and unmanned traffic in the same airspace will have been initiated, 
inside and outside U-space airspace.  

The  EU  drone  industry  will  become  viable,  and  accessible  to  EU  citizens  and 
businesses  with  an  active  participation  of  actors  of  all  sizes,  including  a  variety  of 
diversified  SME’s,  fostering  collaboration  between  all  actors,  and  broadening  the 
spectrum significantly beyond the limited number of global multinational stakeholders.  

Civil-defence  industry  synergies  will  be  systematically  identified  and  exploited.  They 
will benefit both sectors. They will improve the competitiveness of European industry 

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and  strengthen  Europe's  strategic  autonomy,  by  allowing  Member  States  to  rely  on 
competitive UAS technology of European origin.  

The drone eco-system thus created will provide jobs, promote, and protect European 
technological know-how and allow for growth opportunities for the EU economy as a 
whole,  enabling  European  companies,  including  new  SMEs  to  grow  and  flourish  as 
global leaders. 

This was the basis for the Commission vision spelled out in the Drone Strategy 2.0 for a Smart 
and Sustainable Unmanned Aircraft Eco-System in Europe. 

7.2  Strategic objectives 

As set in the Commission roadmap for the Drone Strategy 2.052, the following elements are part 
of the strategic objectives of this strategy: 

The strategy should foster the uptake of this innovative technology in Europe, while establishing 
the  right  balance  between  safety,  security,  health  protection  and  other  societal  concerns,  and  a 
sustainable economic environment. 

The safety, security, health protection and privacy of people in the air and on the ground remains 
the priority. In addition, the future policy framework should provide an innovative, cost-efficient 
and market-led business environment for the development and take-up of new drone services and 
technologies within the EU’s internal market. It should also guarantee their widest possible social 
acceptance.  

The Drone Strategy 2.0 should provide a comprehensive policy package and address obstacles to 
the development of new drone applications and transport services and to the competitiveness of 
this  industry.  As  outlined  in  the  Action  Plan  on  synergies  between  civil,  defence  and  space 
industries,  reaping  synergies  between  the  civil,  security  and  defence  use  of  drones  and  related 
technologies, including counter-drones’ solutions, can be an important success factor. 

The  ambition  of  the  strategy  is  therefore  to  further  develop  the  drone  sector,  in  light  of  the 
European Green Deal, Smart and Sustainable Mobility Strategy, Digital Strategy and other Union 
policies. 

7.3  SMART objectives 

The  Drone  Leaders’  Group  proposed  a  number  of  SMART  (Specific  Measurable  Achievable 
Reasonable  Time-bound)  objectives  to  be  used  to  measure  progress  on  achieving  the  above 
Vision and the targets to be reached by 2030. In this regard, the Group agreed on the following 
set of objectives: 

  Number of cities/regions that will be served by IAM regular commercial services (Target for 

2030: at least 45 in the EU and at least one per Member State) 

  Number of Member States where emergency health services (medical samples, defibrillators, 
air ambulances) will be provided using drones (Target: services used in at least 20 Member 
States)  

  Use of European U-spaces Airspace by commercial drone flight operations (Target: at least 

100.000 a day) 

52   https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13046-A-Drone-strategy-20-

for-Europe-to-foster-sustainable-and-smart-mobility_en. 

Page 31 / 86 

 
 
                                                      
  Number of EU Member States where advanced U-space Services (additional to those defined 
in the current regulatory framework) are operational in at least one U-space. (Target: at least 
6 Member States) 

  Number of USSPs designated in each U-space airspace (Target: at least 2) 
  Safety  level  achieved  (Target:  the ratio  between  the number  of  accidents  vs  the  number  of 

drone flights is as low as required for manned aviation)  

  Aerodromes falling under the EASA Basic Regulation, cities with over 100.000 inhabitants, 
and critical infrastructures will have assessed the security risk related to drone incidents and 
put in place procedures and measures that will protect them from such incidents proactively 
and reactively (Target: 100%) 

  Number of assessments run by the EIB “European Drone Investment  - Advisory Platform” 
and number of loan agreements granted by European Investment Bank (EIB) to drone sector 
stakeholders (Target: increased percentage respectively of 10%, year on year)  

  Carbon emissions of urban and regional IAM operations (Target: 0%) 
  The civil and military drone technology used in Europe will be designed and/or produced in 

Europe (Target: at least 50% of total value of drones used in Europe) 

  Number  of  Universities  /  Technical  Schools  that  offer  drones  subjects  or  specialisations 

(Target: at least 40 in the EU and one per Member States). 

  Turnover in the overall drone eco-system and its contribution to EU GDP (Target: at least € 

15 billion) 

8  THE ELEMENTS OF A THRIVING EU DRONE ECO-SYSTEM IN 2030 

8.1  Building the European drone services market  

As  mentioned,  the  drone  sector  is  composed  of  several  different  dimensions  including  State 
activities  (including  security,  military  and  rescue-services),  non-commercial  use  (hobby),  and 
commercial  activities  (including  hardware  and  software  developments,  maintenance,  the 
provision of infrastructures such as vertiports). 

The  current  EU  legal  framework  already  offers  many  possibilities  for  the  operation  of  small 
drones used for recreational or professional purposes. However, the feedback received during the 
consultation process showed that the current regulatory framework does not sufficiently support 
the scaling up of commercial drone operations, particularly for some of the most promising use 
cases. Furthermore, the current framework, for instance, does not allow the transport of people. 
There is thus a need to define further regulatory requirements, notably in urban areas. 

Whilst economic players from across the whole drone industry and beyond are joining forces to 
develop drone activities, it requires addressing several obstacles to make them become a reality 
by 2030.  

The regulatory dimension is only one aspect of these challenges faced by the Drone sector, which 
comes across the 10 different areas identified in the Drone Strategy 2.0. The first steps to address 
them was to define a clear vision. The high-level vision set out above is providing the foundation 
for the next steps to be taken at EU level to develop a viable drone eco-system in Europe. 

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8.1.1  Improving  airspace  capabilities  (U-space  development  and  integration  with 

Air Traffic Management) 

The  provision  of  air  traffic  service  follows  the  demand  for  air  transport  and  other  airborne 
operations. Since the beginning of aviation, this demand has generally seen a pattern of growth. 
Whenever  ATM  is  not  able  to  deliver  capacity  where  and  when  it  is  needed,  traffic  limitation 
measures are taken to continue to ensure safety, causing rapid increases in delays and thereby a 
deterioration in environmental and cost efficiency and the achievement of airspace user needs. 

As the drone service market continues to grow and take shape in Europe, the pressure is on to 
make sure that these air vehicles are safely and securely integrated into our already busy airspace. 
Transforming  infrastructure  to  support  such  operations  is  critical  to  harnessing  the  potential  of 
the sector, unlocking market growth, jobs and services to EU citizens. But a simple adaptation of 
our current air traffic management system is not enough; accommodating these air vehicles in the 
numbers forecasted required a new approach. 

Therefore, to unlock the potential of the drone economy and enable innovative air mobility on a 
wide scale, a new ATM paradigm was developed to safely cater for a high level of expected low-
altitude unmanned operations. This concept, referred to as U-space, includes new digital services 
and operational procedures and its development had already announced in 2017. 

U-space  is  a  set  of  services  and  procedures  relying  on  a  high  level  of  digitalisation  and 
automation of functions to support safe, efficient and secure access to airspace for large numbers 
of drones. It provides an enabling framework to support routine drone operations and addresses 
all types of missions including operations in and around airports. 

As  mentioned  in  section  4.2.3  above,  the  European  Commission  adopted  in  2021  the  U-space 
package  -  three  regulations  that  together  create  the  conditions  necessary  for  both  drones  and 
manned aircraft to operate safely in section of our airspace known as the U-space. 

These  regulations  introduce  new  services  for  drone  operators, allowing them  to carry  out  more 
complex  and  longer-distance  operations,  particularly  in  congested  airspace,  and  when  out  of 
sight. U-space creates and harmonises the conditions needed for manned and unmanned aircraft 
to operate safely, to prevent collisions between drones and other aircraft, and to mitigate the risks 
of drone traffic on the ground. 

U-space is expected to provide the means to manage safely and efficiently high-density traffic at 
low  altitudes  involving  heterogeneous  unmanned  vehicles,  including  operations  overpopulated 
areas and within controlled airspace. Ultimately, U-space will have to integrate seamlessly with 
the ATM system to ensure safe and fair access to airspace for all airspace users, including  IAM 
flights departing from airports. 

The current U-space Regulation identifies an initial set of U-space services required to implement 
an  initial  U-space  environment.  In  order  to  enhance  U-space  deployment  to  support  IAM,  it  is 
necessary to continue research and development in accordance with the European ATM Master 
Plan (MP) vision, and the Roadmaps to achieve this as described in the Strategic Research and 
Innovation  Agenda  (SRIA)  for  the  Digital  European  Sky.  The  first  SESAR  3  JU  Digital  Sky 
Demonstrators  addressing  U-space  will  focus  on  direct  support  for  the  deployment  of  initial 
services, in support of the U-space Regulation. In parallel, research should continue to develop 
the overall concept of operations for U-space and IAM, both in terms of service definition and in 
the supporting technologies, in order to deliver more advanced services. This development should 
be designed to increasingly consider the ATM and U-space environments together so that, by the 
time the full U-space environment is deployed, the two environments will have become one, fully 
integrated  air  environment  seamlessly  encompassing  small  drones,  IAM,  ATM,  RPAS  and 
Higher Airspace Operations (HAO).  

Page 33 / 86 

 
 
The  introduction  of  new  types  of  aerial  vehicles  within  the  airspace  requires  ensuring  a  fully 
collaborative  approach  between  all  actors  with  the  objective  of  ensuring  an  efficient  interface 
between  U-space  and  ATM,  as  well  as  avoiding  airspace  fragmentation.  An  efficient  U-space–
ATM  interface  is  required  to  enable  an  adequate,  robust  and  timely  exchange  of  U-space 
information  services  between  various  U-space  stakeholders  such  as  drone  and  IAM  operators, 
USSPs,  ATM  service  providers,  data  service  providers,  aeronautical  data  providers  and 
authorities. The relevant solutions are expected to have a positive impact on access and equity, 
enabling  seamless  ATM  /  U-space  high-density  automated  and  fully  digitalised  operations 
managed in close cooperation with UAS/IAM fleet operators. 

In  a  longer  term,  a  fully  integrated  ATM  /  U-space  CONOPS  definition  is  required  to  cover 
seamless operations inside and outside controlled airspace, further defining the interface between 
ATM  and  U-space,  as  well  as  examining  the  corresponding  information  exchange  concept  and 
requirements. Information exchange will be critical to enable a safe convergence of U-space and 
ATM.  The  possibility  of  a  fully  integrated  airspace  without  segregation  between  U-space  and 
ATM users is the ultimate goal. 

A  fully  integrated  ATM  /  U-space  ecosystem  without  segregation  between  U-space  and  ATM 
operations also requires the setting up of common fundamental enablers. Some of these enablers 
include the  definition  of  a common  altitude  reference  system  (CARS),  separation  minima,  safe 
operating  distances  from  buildings  and  fundamental  aviation  tenets,  such  as  airspace 
classification. 

The  need  to  revise  the  rules  of  the  air  becomes  necessary  to  consider  the  specificities  of 
unmanned traffic in general, as well as of mixed traffic (unmanned and manned). Such work has 
been  initiated  by  EASA,  as  part  of  the  process  of  establishing  a  comprehensive  set  of  new 
regulations  to  enable  operations  of  UAS  in  the  ‘certified’  category  and  aircraft  with  VTOL 
capability  to  deploy  the  potential  of the  IAM.  Systems  allowing  drones  to  have  a  capability  to 
“detect  and  avoid”  (DAA)  and/or  “sense  and  avoid”  (SAA)  other  aircraft  do  not  exist  yet  and 
EASA objective is to develop them in accordance with a European harmonised set of validated 
standards adapted to the European airspace and working in all airspace classes. Therefore, there 
is a need to use strategic and tactical mitigation means offered by the ATM/U-space system in a 
first  phase  until  these  systems  are  available,  provided  that  the  traffic  and  traffic  complexity  is 
such that safe operations can be guaranteed. 

Always  keeping  safety  as  the  primary  goal,  further  work  will  be  required  on  enablers  for 
automation  and  autonomy  for  U-space  and  IAM.  In  this  framework,  a  critical  aspect  of  the 
integration  will  be  the  role  of  humans,  particularly  regarding  the  high  level  of  automation  that 
will be delivered by U-space services and the known automation disparity between ATM and U-
space. IAM integration in the ATM / U-space ecosystems is also a specific research topic, as well 
as  the  challenge  of  how  to  support  the  transition  from  piloted  vehicles  to  IAM/autonomous 
operations.  Of  course,  the  evolution  of  the  ATM  /  U-space  convergence  will  need  to  be 
synchronised and coordinated with the development of IAM services and the certification of IAM 
vehicles.  Special  consideration  should  be  given  to  the  operational  limitations  of  these  new 
vehicles and how U-space and ATM can contribute to their operational safety by protecting their 
operations in contingency and non-nominal situations. 

As research continues in each thread, lessons from one environment should be applied to each of 
the  others  such  that  the  final  environment  is  safe,  economically  viable  and  environmentally 
sustainable. This will contribute to making aviation smarter and more sustainable, and delivering 
the Digital European Sky.  

On the topic of Communication, Navigation and Surveillance (CNS), the SRIA of the SESAR3 
JU  clearly  describes  the  transformation  from  three  separate  CNS  domains  into  one  integrated 
CNS  (ICNS)  environment.  This includes  all  current CNS  technologies used for  ATM, but also 

Page 34 / 86 

 
 
those needed to support U-space, IAM, RPAS integration and HAO. The research programme, as 
envisaged in the SRIA, should look to ICNS as the mechanism by which all airspace users can 
inter-operate safely, while reducing costs and environmental impact through rationalisation and 
multi-use  of  existing  and  developmental  technologies.  This  integration  should  include 
technologies from other domains, such as the telecommunications and the space industries, and 
should  address  increased  connectivity  through  digital  communications  as  well  as  the  more 
conventional  elements.  Research  and  demonstration  under  this  Action  should  address  both 
technological  issues  and  the  specific  performance  and  certification  requirements  of  all  relevant 
technologies that arise from the evolving U-space and IAM domains. 

8.1.2  Facilitating Aerial Operations 

As mentioned in Chapter 2 above, the terms “Aerial Operations” refers to the use of  new aerial 
technologies and services provided to customers for other purposes than the transport of people 
and  freight.  These  small  drones  equipped  with  advanced  sensors  and  AI  technologies  can  be 
deployed  in  diverse  sectors  such  as  construction,  railways,  ports,  agriculture,  energy,  public 
safety, security, filming, insurance, real estate, transport of small payload, etc.  

Companies’ drone programmes can be either outsourced to third companies offering specialised 
drone  services  or  partially  developed  in-house,  using  leased  fully  tested  material  from  third 
company  suppliers  or  finally,  they  can  be  fully  developed  internally.  In  this  case,  it  may  also 
require  buying  hardware,  software  and  consulting  services  at  an  initial  higher  cost  for  their 
implementation.  The  aerial  operations  eco-system  is  largely  composed  of  Small  and  Medium 
Enterprises  providing  hardware,  software  and  services  to  commercial  drone  operators  (see 
description in chapter 5.2.1 above. 

Most companies which are developing drone programmes chose to do it internally and to a large 
extent operations are conducted in visual line of sight. In fact, despite the risk-based operation-
centric approach  underpinning the development of the regulatory framework for drones, one of 
the key challenges faced by companies in the commercial drone sector is to be able to build up 
drone  programmes  based  on  fully  autonomous  drone  operations  in  beyond  visual  line  of  sight 
conditions. 

As highlighted in the Communication, one of the missing regulatory elements at a European level 
is  to  perform  operations  at  both  end  of  the  drone  operations’  risk  spectrum  in  the  ‘specific’ 
category. On the one hand, for simple low risks operations in Beyond Line of Sight Operations or 
Extended Visual Line of Sight, which are not  falling under the ‘open’ category and are not yet 
subject  to  a  European  standard  scenario,  there  is  a  need  to  develop  further  European  Standard 
Scenarios. On the other hand, for more risky operations there is a need to develop methodologies 
and procedural mechanisms which can facilitate the granting of an operational authorisation from 
the competent authority. 

Whenever operations do not fall under the ‘open’ category, drone operators must carry out a risk 
assessment  to  determine  under  which  category  the  operation  will  fall,  ‘specific’  or  ‘certified’. 
Many  stakeholders  highlighted  the  complexity  of  conducting  this  risk  assessment  and  the  fact 
that the operation approval granting process might be a lengthy one and its outcome uncertain. 

This is in particular the case if the level of robustness of any of the operational safety objectives 
linked with the drone design is considered “medium”, as the national competent authority could 
in this case require a full design verification of the drone by EASA. 

One  of  the  possibilities  to  facilitate  the  launching  of  a  low-risk  operation  in  the  ‘specific’ 
category  is  that  the  operation  falls  under  a  European Standard  Scenario  as  it  would  suffice  for 
UAS operators to submit an operational declaration of compliance to the competent authority. 

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The widespread consultations with industry stakeholders highlighted the need to improve some 
regulatory  aspects  related  to  the  ‘specific’  category,  as  pending  the  development  of  new 
European standard scenarios, drone operators have to undertake the SORA in order to receive an 
authorisation from the competent authority which is perceived to be more cumbersome and may 
generate some business uncertainty. One of the risks for the drone operator is that the competent 
authority may reach the conclusion that the operation should be performed under the conditions 
of the ‘certified’ category instead of the ‘specific’ category, which requires the certification of the 
aircraft, the operators and the remote pilot as applicable.  

As a large part of commercial operations performed by drones are presenting a low to a medium 
risk,  more  efforts  could  be  made  to  facilitate  use-cases  in  the  ‘specific’  category  of  drone 
operations.  Indeed,  in  some  cases,  requirements  to  permit  operational  authorisations  are 
considered as disproportionate to the level of risks from both an operational and financial point of 
view. The same also applies to the testing and demonstration of new types of aerial operations for 
which the requirements are considered as too restrictive. The SORA mitigation requirements to 
reach  Specific  Assurance  and  Integrity  Levels  (SAIL)  category  III,  even  using  proven  and 
reliable systems, are difficult to reach without a drone redesign and could be reviewed.  

The administrative burden related to the operational authorisation process could be alleviated by 
developing  further  European  standard  Scenarios  and pre-defined  risk  assessments.  However,  at 
this stage, only two European Standard Scenarios have been developed. Further developing this 
regulatory approach will also support the inclusion of Small and Medium Enterprises in the drone 
operations  market.  In  addition,  new  European  Standard  Scenarios  could  also  address  specific 
needs related to State or military operations and maritime surveillance activities. 

Consequently, the development of standard scenarios can enable rather complex operations to be 
safely  incorporated  in  the  airspace  with  a  minimum  of  formalities.  At  this  stage,  already  two 
standard scenarios have been adopted53: (1) STS-01 – VLOS over a controlled ground area in a 
populated  environment,  and  (2)  STS-02  –  BVLOS  with  Airspace  Observers  over  a  controlled 
ground  area  in  a  sparsely  populated  environment.  Considering  that  a  large  part  of  Aerial 
Operations  are  presenting  a  low to  a  medium  risk,  the  conditions  for  the  ‘specific’ category  of 
drone operations could be alleviated by developing further European Standard Scenarios and pre-
defined risk assessments54. 

Further, to support the development of urban and higher risk operations in the ‘specific’ category, 
EASA should review its AMC/GM for the specific category of operations to ensure that design 
verification  requirements,  and  their  application  by  national  competent  authorities,  are 
proportionate with the risk of the operations in the ‘specific’ category. Particular attention should 
be  paid  to  the  required  scope  of  the  design  verification  (full  drone  design,  mitigation  means 
and/or enhanced containment functions). 

53  Commission  Implementing  Regulation  (EU)  2020/639  of  12  May  2020  amending  Implementing 
Regulation  (EU)  2019/947  as  regards  standard  scenarios  for  operations  executed  in  or  beyond  the 
visual line of sight, OJ L 150, 13.5.2020, p. 1. 

54   European  standard  scenario  (STS)  and  the  pre-defined  risk  assessment  (PDRA)  aims  to  facilitate 
respectively the declarative and the permit application process by drone operators by ensuring that the 
risk assessment has already been performed in accordance with the SORA methodology for some low 
to medium risk operations performed in the ‘Specific category’. 

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8.1.3  Developing Innovative Air Mobility  

Drones are no longer limited to small, electric rotor aircraft commonly used by recreational users 
or commercially, and have the potential to replace conventional piloted aircraft. eVTOL aircraft 
in particular have opened a whole new range of possible mobility services to urban and sub-urban 
local  communities.  As  drone  technology  has  advanced,  the  identified  potential  use  cases 
involving  manned  eVTOLs  have  rapidly  expanded,  particularly  for  public  services  such  as 
emergency medical transport and evacuation, air taxi or deliveries. In addition to intra-urban or 
sub urban eVTOL aircraft using vertiports on top of buildings and other dedicated landing pads, 
there are also fixed wings type of drones which offer longer range connectivity. These operations 
are falling under the 'certified' category and should be subject to the same safety levels as manned 
aviation. Therefore, drone operators, remote pilots and drones (including manned VTOL aircraft) 
should be subject to uniform rules and procedures. The remaining significant technical and safety 
regulatory  gaps  which  are  preventing  such  ‘certified’  operations  to  be  performed  should  be 
addressed by new regulatory rules addressing the certification of aircraft, as well as the approval 
of the drone operator and the remote pilot licence by the competent authority. 

New  aircraft  types  are  coming  onto  the  market  with  alternative  propulsion  and  new  vehicle 
designs,  all  increasingly  automated  and  remotely  piloted.  These  have  the  potential  to  meet  the 
demand for alternative modes of transportation in large cities or rural area, and the challenge of 
reducing  noise  and  CO²  emissions  (green  propulsion  and  optimized  designs).    Urban  Aerial 
Mobility thus offers to local decision-makers the opportunity to rethink  their mobility and land 
development  planning  by  giving  their  territorial  development  projects  a  new  orientation, 
reconvert the existing means of transport and improve the quality of life of their populations. 

Several  studies  estimate  that  impact  of  Innovative  Air  Mobility  on  overall  travelling  time, 
particularly over congested road traffic to be positive. These services can be seen from multiple 
angles:  

  Air taxi services based on a wide network of point-to-point travel often associated with 

eVTOLs and similar to current road taxis.  

  Scheduled air passenger transport following pre-determined routes, regular schedules, 
and a network of stops throughout the city, complementing existing ground public 
transport. 

  Drones could potentially deliver small payloads faster to the customer (B2C) for example 

by reducing the number of pickups and thereby save time; 

According to studies, in a city like Helsinki, drones for consumers could deliver orders 35  - 75 
percent faster, depending on the scenario. The impact on time savings as a result of reduced pick-
ups  in  this  area  is  estimated  at  approximately  1.5  million  hours.  In  addition,  delivery  costs 
(incurred by service providers) will likely reduce by up to 45 per cent in case of instant deliveries 
compared  to  conventional  methods  of  delivery.55  This  would  clearly  lead  to  a  reduction  in 
consumer costs for delivered goods. 

The  addition  of  aerial  mobility  in  the  city's  landscape  gives  urban  planning  authorities  an 
additional  dimension  to  play  with. This  opportunity will  require  new  tools,  new  skills  and  will 
open up a new field of decisions to be made, supporting a gradual transformation over a period of 
at  least  five  to ten  years.  In  the  short term,  the  most  useful  developments  will  emerge  through 
gradual homogenic integration as cities continue to modernise themselves, and only in agreement 
with the local authorities and communities. 

55   Gaia Consulting Oy (2021), Potential Benefits of Drone Deliveries in Helsinki. 

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IAM eVTOL operations require some physical infrastructure assets such as vertiports and other 
landing paths, including embarking and disembarking facilities, such as lockers or other storage 
facilities, for package deliveries as well as charging stations. Vertiports are a key enabler for the 
IAM concept and city authorities56 are increasingly starting to include drone transport into their 
urban  development  plans.  Vertiports  should  be  open  large  multi-landing  locations  that  have 
support facilities (including charging infrastructure, support personnel, etc.) for multiple eVTOL 
companies.  A  regulatory  framework  for  vertiports  and  other  ground  infrastructure  should  be 
developed,  and  a  particular  attention  should  be  given  to  ensure  appropriate  interface  with 
aerodromes,  interoperability,  and  open  access  of  equipment  to  ground  infrastructures  by  drone 
operators and environmental impacts. In this regard, the regulatory framework should ensure that 
those  ground  infrastructures  do  not  become  proprietary  and  follow  the  same  open  model  as 
airports and heliports. 

Over  time,  drones  for  transport  can  be  expected  to  affect  land  use  and  property  values,  both 
positively  and  negatively.  Where  drones  are  perceived  to  provide  benefits,  property  values  are 
likely  to  increase,  but  where  they  are  perceived  to  be  an  annoyance  (e.g.  due  to  noise,  visual 
disturbance or privacy concerns), property values are likely to decrease.  

Drones may also affect land use patterns, as improved accessibility may create an incentive for 
people or businesses to move away from dense urban areas.  

Although  drones  have  the  potential  to  improve  many  aspects  of  our  society  and  economy,  the 
realisation of these benefits will depend on putting into place a good foundation. The question of 
market access of drone operators has to be addressed at EU level. Currently, the economic and 
financial  conditions  to  obtain  a  Community  Air  Carrier  operating  licence  are  set  out  in 
Regulation (EC) 1008/200824. This Regulation covers the transport of passengers, cargo and mail 
and is therefore also potentially applicable to drone operators. However, these rules, which were 
originally  designed  to  cover  large  Commercial  Air  Transport  undertakings,  might  be 
disproportionate  for  drone  operators.  A  review  of  this  Regulation  should  ensure  fair  market 
access and establish common requirements which are more suited to the economic and financial 
situation  of  drone  undertakings.    The  use  of  existing  tools  such  as  the  Union  framework  for 
screening of foreign direct investment (FDI)57 could avoid hindering the development of IAM by 
removing barriers to access to venture capital.  

With careful management, drones could improve access to places of opportunities (such as jobs, 
health  care,  education)  and  contribute  to  a  safer,  more  efficient  and  more  sustainable  transport 
system.  However,  they  have  also  the  potential  to  increase  noise,  vibration  and  other 
environmental  impacts  while  exacerbating  inequality  in  the  transport  system  if  they  are  not 
managed carefully.  

8.1.4  Ensuring societal acceptance  

Drone in general and IAM services in particular may only emerge if local communities and their 
representatives subscribe to them. A study led by EASA showed that “EU citizens initially and 
spontaneously express a positive attitude towards and interest in UAM; it is seen as a new and 
attractive means of mobility and a majority is ready to try it out”58. The social benefits of drone 

56 

https://civitas.eu/urban-air-mobility 

57  
Regulation (EU) 2019/452 of the European Parliament and of the Council of 19 March 
2019 establishing a framework for the screening of foreign direct investments into the Union, OJ 
L 79I , 21.3.2019, p.1. 

58  EASA, “Study on the societal acceptance of Urban Air Mobility in Europe”, May 19, 2021 

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operations  should  be  highlighted  as  they  would  justify  support  from  national  and  local  public 
authorities to further their  development. The main  benefits  which can secure public acceptance 
would first and foremost be emergency medical transport, transport of medical products and other 
first  aid  and  rescue  applications.  The  point-to-point  transport  of  people  for  example,  in  the 
context of city centre-airport or port links, are another useful application which could support the 
acceptability  of  for  example  the  siting  of  drone  vertiports  and  other  specific  infrastructures 
located close to residential areas, as IAM would provide improved connectivity. 

It is clear that the fact that the drones operated at a low and medium altitude over populated areas 
also  raise  safety  concerns.  EU  citizens  want  to  limit  their  own  exposure  to  all  possible  risks, 
whether related to safety, noise, security  and environmental impact (including the protection of 
the wildlife), as well as other concerns related for instance to cyber-security. Furthermore, on the 
economic  side,  the  issue  of  affordability  is  of  key  importance.  IAM  should  not  be  seen  as  a 
service for a small part of the population only. Public acceptance will also be based on the price 
of the service offered by IAM operators.59 

As  highlighted  in  the  EASA  study,  the  environmental  impacts  of  drones  are  both  positive  and 
negative.  Besides  the  noise  aspect,  drones  may  also  have  negative  impacts  on  wildlife  and 
generate  visual  disturbance.  All  these  impacts  will  need  to  be  clearly  identified  and  carefully 
managed. 

According  to  the  EASA  study,  the  acceptability  of  intra-urban  and  inter-city  drone  operations 
involving goods delivery and air taxi would require addressing in priority: 

  high safety level; 
  noise;  
 
 

environmental impact (including greenhouse gas emissions) and the impact on wildlife;  
security and, in particular, protection from cyber-attacks from such autonomous devices; 

In  terms  of  safety,  EASA  and  national  aviation  authorities  have  a  duty  to  ensure  the  safety  of 
flights,  operations  and  passengers  for  both  drones  and  manned  aircraft.  The  overall  objective 
which has been set for drones is to achieve the same level of safety as in manned aviation. EU 
aviation safety rules provide a framework to ensure that this goal can be achieved. It also implies 
regular  audits  and  inspection,  oversight  by  the  competent  authorities  in  order  to  guarantees  the 
initial and ongoing airworthiness of aircraft and the entities operating them.  

As  mentioned  in  chapter  1.5.2.3  above,  similar  to  manned  aviation,  drone  manufacturers  will 
have to obtain a certificate of airworthiness ensuring the safety of passenger and cargo transport 
operations,  initially  with  a  pilot  and  later  for  autonomous  operations.  The  drone  operators  will 
have  to  obtain  an  Air  Operator  Certificate  or  its  equivalent  for  eVTOL  aircraft  operators  and 
remote pilot will have to hold a licence similar to airline pilots. These regulatory developments 
will have to be addressed in the coming years as explained in the Communication. 

Noise is a key factor which has been highlighted as a major obstacle to drone integration. This is 
due not only to the actual noise drones produce (often a high-pitched tone), but also to the ways 
in which noise is perceived – such as disruption of people’s tranquillity and people’s familiarity 
with  and  acceptance  levels  of  drones,  or  surrounding  noise levels).  In  cities, the  ambient  noise 
levels of conventional vehicles may make drone noise less apparent if flown along main roads at 
very  low  altitude.  However,  their  proximity  to  residential  areas,  and  the  increasing  uptake  of 

59 

“Seat prices as presented today range from less than €100 (RATP ADP) to €300 or €400 (ADP target 
for the 2024 Olympics). The profitability horizon of an air mobility service when announced is quite 
distant (after 2050).” Air and Space Academy, AAE Dossier 53 2022, “The viability of electric urban 
transport aircraft”. 

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quieter  electric  ground  vehicles,  may  make  drones  more  noticeable and  create strong, localised 
pushback  as  the  market  expands.  To  help  avoiding  this,  the  Commission  will  fund  the 
development by EASA of an online platform as a “pilot project Sustainable IAM Hub” that will 
provide  support  to  authorities,  cities,  industry  and  other  stakeholders  for  IAM  implementation. 
This  European  cross-sectorial  governance  platform  for  IAM  should  enable  engagement, 
alignment,  and  coordination  between  the  different  stakeholders.  Furthermore,  when  developing 
the IAM regulatory framework, EASA could examine possible alleviations for specific use cases 
or operations that would be in the direct interest of the public. EASA should also continue the 
development  of  suitable  drone  and  eVTOL  noise  modelling  methodologies,  which  should  be 
taken into account by the Commission for the next amendment of Annex II of the Environment 
Noise Directive for the purposes of adapting common noise assessment methods to scientific and 
technical progress. 

Unsurprisingly drone noise primarily depends on the drone model and payload, as well as on the 
operating  state  or the  flight  manoeuvre.  Drone  noise annoyance  strongly  depends  on  the sound 
pressure level, which is the same as for other transportation noise sources. Comparisons of drones 
to  other  transportation  noise  sources  are  still  scarce,  which  seems  to  be  a  large  gap  in 
understanding  the  potential  impact.  The  Environmental  Noise  Directive  should  take  account  of 
IAM developments to counter misapprehensions about drone potential noise impact. Rather than 
attempting  to  drive  acceptance  from  the  public  for  unacceptable  noise  and  visual  disruption, 
focus  should  instead  be  on  how  to  make  civil  drones  more  acceptable,  through  technological 
improvement.  This  would  be  in  conjunction  with  the  creation  of  exchange  platforms  between 
industry  and  neighbourhood  associations  and  give  industry  operational  experience  and 
opportunity  to  develop  technologies  and  testing  methodology  to  evaluate  noise  in  an  urban 
operating environment, as well as give regulators valuable feedback on the adequacy of rules.  

Regarding  environmental  aspect,  the  EASA  study  highlighted  in  particular  the  perception  that 
drones can negatively impact wildlife and protected nature areas. Like for noise, scientific papers 
specifically evaluating the effects of drones on wildlife are also scarce but increasing. The impact 
on  wildlife  (even  in  urban  areas)  is  an  increasingly  important  consideration  as  drone  activity 
scales up. Among different animal types, birds, especially in larger groups, are the most sensitive 
to  drones.  Flightless  birds  and  large  birds  are  more  likely  to  be  disturbed  than  smaller  ones. 
Terrestrial  mammals  are  overall  less  reactive  to  drones  than  birds.  Given  the  low  altitude  at 
which small drones operate, drones may also interact with local fauna, generating a new type of 
anthropogenic disturbance that has not yet been systematically evaluated. 

On  cybersecurity  too,  it  is  increasingly  apparent  that  low  and  medium  altitude  overflights  of 
populated  areas are  perceived  as  a  threat, hence  the strong  focus on  the  vulnerability  to  cyber-
attack of these aircraft systems and controls. This aspect is covered under chapter 8.2.4 below. 

8.1.5  Promoting the human dimension (knowledge, training, competences) 

Changes  in  skills  requirements  are  most  visible  in  sectors  that  are  strongly  influenced  by  the 
digitalisation of their operations, notably in air transport. To realise the full potential of drones, 
the private sector is not only developing the drones themselves, but also the technologies needed 
to  support  their  integration  into  the  transport  system.  Drones  need  to  integrate  not  only  the 
aviation system, but also the transport system and society more broadly. This requires input from 
experts  in  new technology  fields  and  other transport sectors  beyond aviation;  and  experts from 
both  aviation  and  from  outside  the  sector  need  to  understand  the  regulatory  environment  and 
culture of both aviation and other transport policy fields, such as urban transport planning.  

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This  will require new competency profiles. Digitalisation and automation are  at the core of the 
drone  operations  development  and  is  already  affecting  employment  in  this  sector.  The 
development  of  skills  and  competence  will  a  key  factor  to  maintain  European  leadership  by 
ensuring  that  the  different drone  segments  can  cope with complex  regulatory  requirements, i.e. 
certification  of  drone  operators,  SORA,  certification  of  Common  Information  Services  and  U-
space service providers. Without a highly educated, qualified and experienced workforce on the 
ground  and  in  the  air,  operational  safety  cannot  be  achieved.  The  qualification  level  of  a 
sufficient number of pilots for the initial phase of eVTOLs and remote pilots for the control unit 
could  pose  a  recruitment  and  training  problem  if  the  number  of  e-VTOLs  increases.  The 
autonomy or remote control of e-VTOLs envisaged in the future could provide part of a solution 
to this problem but there is a need for the sector to keep pace with the needs as drone operations 
will increase. 

To  ensure  that  remote  pilots  have  the  requisite  level  of  knowledge  and  skills  in  line  with 
continuous advancing technological development, Commission initiatives could be used like the 
“European Skills Agenda for sustainable competitiveness, social fairness and resilience”  and its 
flagship  action: the  “Pact  for  Skills”  aims  to  gather  industry,  private  and  public  entities,  which 
could support the Drone  ecosystem and the digitalisation  priorities identified in the Sustainable 
and  Smart  Mobility  Strategy  (see  4.1.4).  These  partnerships  can  build  on  the  “Blueprint  for 
sectoral  cooperation  on  skills”60  for  gathering  sectoral  skills  intelligence,  mapping  key 
occupation needs, defining occupational profiles and developing training programmes.  

The  sector  should  develop  and  enhance  competency-based  training  such  as  those  of  drone 
specialists. Initially, the ‘certified’ category will involve two different types of pilot licences. One 
for flying a ‘VTOL aircraft’ with an on-board pilot and one for flying an ‘unmanned aircraft’ as a 
remote pilot who may control one drone at a time, or control simultaneously several drones, also 
of different types and from different operators. Training should also be given as a priority to IAM 
operators’ personnel in view of future autonomous operations.  

The  EU  sectoral  social  dialogue  as  well  as  partnerships  between  research,  universities  and 
industry  on  education  could  provide  a  framework  to  develop  a  joint  approach  to  the  social 
challenges  related  to  digitalisation,  training  requirements  and  professional  qualifications. 
Education and training programmes specific to drone technologies, the regulatory framework and 
the integration of SUMP’s activities should be set up in all Member States. Such academic and 
vocational programmes across Europe would foster the competences and technological progress 
but also increase the public awareness and acceptance of drone utility.  

To support the implementation by Member States of the newly created regulatory framework and 
to  be  in  the  position  to  smoothly  manage  SORA  approvals,  EASA  has  developed  a  number  of 
tools to assist competent authorities implementing EU regulations correctly and on time, which 
include  guidance  documents,  implementation  plans,  expert  groups,  explanatory  documents, 
training, organising workshops and holding online meetings. Competent authorities should have 
the necessary competences that reflect the highly digital and automated nature of the technologies 
underpinning drone operations and U-space services provision as well as the necessary number of 
regulatory experts in drones and drone operations at both local and national authorities’ level to 
address industry needs. 

60  https://ec.europa.eu/social/main.jsp?catId=1415&langId=en  

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8.2  Strengthening European civil, security and defence industry capabilities 

and synergies 

The EU industrial policy61 stresses the importance of reinforcing Europe’s industrial and strategic 
autonomy  and  supporting  the  development  of  key  enabling  technologies  that  are  strategically 
important for Europe’s industrial future. By seeking synergies between civil, space and defence 
industries in EU programmes, the EU will make more effective use of resources and technologies 
and  create  economies  of  scale. The  Action  Plan  on synergies  between civil,  defence and  space 
industries identifies the  drone technologies as  critical technologies for  the  EU and  calls  for the 
need  to  ‘identify  areas  of  cross-fertilisation,  so  that  defence  projects  benefit  from  innovative 
developments  emerging  from  SMEs  active  in  the  field  of  civilian  drones  and  that  civil 
aeronautics benefit from developments in the field of defence’. 

8.2.1  Providing funding and financing 

The  European  Commission  has  funded  various  drones-related  research  projects  through  its 
successive R&D Framework Programmes. The support for research in the drone sector has been 
substantial  in  the  past  and  critical  for  an  early  deployment.  320  projects  relating  to  the  drone 
sector  were  conducted  under  Horizon  2020,  with  a  total  budget  of  almost  980  million  euros 
invested  in  the  development  or  use  of  drones  for  innovative  applications.  This  effort  will  be 
further  latest  framework  being  the  current  Horizon  Europe  programme.  In  May  2019,  SESAR 
Joint  Undertaking  launched  an  open  call  for  exploratory  projects  with  the  framework  of  the 
SESAR 2020 Research and innovation programme covering drone technologies such as U-space 
and  more  recently,  one  of  the  specific  objectives  of  SESAR  3  Joint  Undertaking    will  be  to 
develop  a  research  and  innovation  ecosystem  covering  the  entire  ATM  and  U-space  airspace 
value chains allowing to build the Digital European Sky defined in the European ATM Master 
Plan,  enabling  the  collaboration  and  coordination  needed  between  air  navigation  services 
providers and airspace users to ensure a single harmonised Union ATM system for both manned 
and unmanned operations. 

In addition, there is a need to secure support and buy-in from the  military community (in their 
roles  as  air  navigation  service  providers  (ANSPs),  airport  operators,  airspace  users  and 
regulators) in relation to SESAR 3 JU activities and the ATM Master Plan. In particular, areas of 
common interest include the ATM Master Plan, regulations, space-based systems, the integration 
of  unmanned  aerial  systems,  cybersecurity  threats  and  vulnerabilities  of  ATM,  and  the 
development of aviation/ATM standards. 

Public  financing  and  R&D  funding  should  support  projects  that  are  geared  towards  further 
automation and sustainability. Infrastructure associated with U-space and IAM implementation, 
including the landing site and charging infrastructure, should be considered for eligibility within 
traditional  EU  infrastructure  funding  pathways.  Funding  should  also  focus  on  multi-mode 
infrastructures  where  aviation  could  benefit  from  energy  (i.e.  hydrogen  to  power  drones)  and 
telecom  cross-fertilisation. Eligibility  requirements for  public  funding  should  be  adapted  to  the 
new competitive market framework and should include a robust business plan. 

In  2020,  the  EIB  Group  adopted  the  Climate  Bank  Roadmap  2021-2025,  withdrawing  support 
from  conventionally  fueled  aircraft.   The  European  Investment  Bank  (EIB)  can  finance  drone 
projects  aligned  with  the  Climate  Bank  Roadmap  (i.e.  deployment  of  zero  emission  drones)  in 
areas  such  as  civil  protection,  deliveries,  medical  supplies,  surveillance,  using  a  wide  range  of 
adapted financial products such as loans or venture debt.  

61  COM(2020) 102 final, COM(2021) 350 final 

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The  EIB  and  other  international  financing  institutions  also  provide  a  broad  range  of  technical 
assistance services to IAM projects at different stages of the market-based project life cycle. The 
handout European Drone Investment - Advisory Platform” was jointly launched by the European 
Commission and the EIB to support innovation and investment in drones. The handout maps out 
the advisory and financial products that can potentially be used to support investments in drones 
depending  on  the  area  of  investment  and  the  maturity  of  the  market.  The  EIB  monitors  the 
evolution of the drone sector in particular for Urban Air mobility and U-space providing funding 
and technical assistance including for infrastructures that will enable drone operations. The EIB 
also produced a guide to finance for drone projects, which helps promoters, among other things, 
to develop a structured approach to assess air mobility projects, identify missing components and 
outline  sources  of  funding,  and  prepare  clearly  defined  requests  for  technical  assistance  and/or 
financing. The InvestEU Advisory Hub which complements the InvestEU Fund is supporting the 
identification, preparation and development of investment projects across the European Union. 

Due to the immaturity of the wider IAM market in the European Union, it is difficult to assess 
whether there is a lack of available financing or a lack of financeable projects. According to the 
EIB, engagement with some key European cities appears to indicate the latter, as many projects 
are lacking a robust business case including an appraisal of required funding or how such funding 
may be sourced. 

Most IAM projects are still at the R&D phase, funding needs for UAM projects are ranging from 
the  development  of  living-lab  for  drone  operators  to  test  their  technology  and  business  model 
(e.g.  medical  deliveries,  transfer  of  patient  via  eVTOL,  ground  infrastructure,  etc.)  to  the 
development  of  the  U-space  system.  Beyond  venture  capital,  the  most  relevant  financial 
instruments are still research funding (specifically through research grants). 

In addition to these funding programmes by European and national bodies and agencies, there is 
also access to funding to venture capital investors that can accelerate the deployment of drones 
and U-space. However, according to the EIB, due to the immaturity of IAM applications, most of 
the investments are focused on the vehicles rather than infrastructure and services. 

The  European  Defence  Fund  (EDF)62  incentivises  and  supports  collaborative,  cross-border 
research and development in the area of defence. The Fund will increase the EU’s technological 
edge  and  develop  the  capabilities  that  are  key  for  the  strategic  autonomy  and  resilience  of  the 
Union and its Member States and the protection of its citizens. Complementing and amplifying 
Member States’ efforts, the Fund promotes cooperation among companies and research actors of 
all  sizes  and  geographic  origin  in  the  EU.  In  doing  so,  it  will  integrate  further  the  European 
defence technological and industrial base, develop industrial skills and competencies as well as 
the innovation potential of Europe’s industry. 

Through  the  EDF  and  its  precursor  programmes,  the  Preparatory  Action  on  Defence  Research 
(PADR) and the European Defence Industrial Development Programme (EDIDP), the European 
Commission has funded and aims to further fund various drone-related projects in the framework 
of defence research and development projects. The PADR (2017-2019) programme funded two 
research topics on technological enablers for drone operations (EU grant together € 3 million). In 
the  EDIDP  (2019-2022)  programme  seven  development  projects  up  to  a  grant  value  of  €  189 
million, including Counter-UAS, are funded. In EDF 2021, a total of five projects are selected for 
funding that contain drone relevant research and development (EU grant together € 87,3 million) 
.EDF 2022 calls for proposal include three drone-related topics. 

62  https://defence-industry-space.ec.europa.eu/eu-defence-industry/european-defence-fund-edf_en  

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As  presented  in  Chapter  4.3,  the  Commission  is  funding  and  financing  drone  R&I  through 
number  of  different  programmes.    These  programmes  continue  providing  support  under  the 
current 2021-2027 MFF as well as defence-related R&D with new EFD instrument.  

The  increased  size  of  funding  which  is  delivered  through  a  variety  of  EU  programmes  and 
instruments presents opportunities for synergies that could reduce risk of duplication and provide 
more user-friendly opportunities for financing (e.g. grants, public procurement, guarantees) while 
safeguarding at the same time that promising projects funded at an early phase are not starved of 
funding  before  they  are  deployed.  It  is  necessary  to  seek  coherence  and  enhance  the 
complementarity between the relevant EU programmes to increase efficiency of investments and 
effectiveness of results, thus bringing better value for EU money by maximising the exploitation 
of EU funded R&D projects in civil, security and defence sectors. 

Further coordination could also be pursued on national research activities with the help of EASA 
on  UAS/UAM  to  ensure  that  there  are  no  gaps  and  to  ensure  cross  sharing  of  results  from 
research activities. 

8.2.2  Identifying strategic technology building blocks 

Remaining  at  the  cutting  edge  of  technological  development  is  critical  for  ensuring  Europe's 
prosperity,  security  and  way  of  life.  The  new  technologies  are  transforming  the  security  and 
defence  sectors  at  a  faster  pace  than  ever  before  and  blurring  the  dividing  line  between  the 
civilian and military domain.  

In her 2019 political guidelines63, President von der Leyen underlined that ‘it is not too late for 
Europe  to  achieve  technological  sovereignty  in  some  critical  technology  areas’.  The  2020  EU 
industrial  strategy64  stated  that  Europe’s  strategic  autonomy  is  about  reducing  dependence  on 
others  on  critical  technologies.  They  also  provide  Europe’s  industry  with  an  opportunity  to 
develop  its  own  markets,  products  and  services  which  boost  competitiveness.’  The  EU  will 
therefore  support  the  development  of  critical  technologies  that  are  strategically  important  for 
Europe. 

As stated in the Roadmap for Critical Technologies for security and defence65, ‘lack of foresight 
on  the  future  importance  of  technologies  is  in  part  to  blame  for  some  of  the  EU’s  existing 
strategic dependencies on third countries, e.g. on remotely piloted systems’. 

Based on the Report of the Drone Leaders Group, ‘the availability of the required components, 
vehicles and systems in Europe is a core condition for developing a competitive and autonomous 
European drone services sector. It is necessary to ensure that the drone manufacturing industry 
will  have  a  reliable  supply  of  essential  parts  and  financial  and  technical  resources  to  develop 
and manufacture state-of-the-art products’. 

Although  Europe  has  a  developed  drone  industry,  significant  part  of  production  of  drones  and 
critical  components  take  place  outside  Europe.  For  example,  such  key  components  such  as 
batteries,  propellers,  electric  engines  and  sensors,  are  commonly  produced  in  Asia,  i.e.,  China, 
Singapore and Taiwan. Nowadays, the shortage of raw material, such as microchips, electronic 
components and IT hardware has highlighted the fact that Europe is dependent on Asian suppliers 
on  components  and  know-how.  To  minimise  this  dependency,  the  EU  industry  should  strongly 
consider manufacturing drone components in Europe and organise itself accordingly. 

63  https://ec.europa.eu/info/sites/default/files/political-guidelines-next-commission_en_0.pdf  

64  COM(2021) 350 final 

65   COM(2022) 61 final 

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Identifying which critical technologies make a decisive contribution to key capabilities can help 
to decide: (i) which technologies are important for technological sovereignty (i.e. where there is a 
need  to  reduce  the  risk  of  dependence);  and  (ii)  where  combined/coordinated  support  from 
different  EU  programmes  and  instruments  can  address  such  challenges.  To  strengthen  its 
technological  sovereignty,  the  EU  and  its  Member  States  must  maintain  a  strong  industrial 
competence and, where possible, seek leadership in these critical technologies.  

Alongside the critical technologies, the following aspects should be taken into account: 

 

 

the drone value chains, including the security of supply of critical components and materials 
that are important building blocks for competitive and autonomous industry; 
related research and testing infrastructure, which is key for standardisation and certification. 

Therefore, a  Strategic  Drone Technology  Roadmap  identifying  critical  drone technologies such 
as  AI,  robotics,  semi-conductors,  hybrid  and  electric  propulsion  systems,  safe,  secure  and 
resilient  C2  link  and  energy  storage,  batteries  and  cloud  technologies  should  be  defined  at  EU 
level, in collaboration with the Observatory of Critical Technologies set up by the Commission 
under the Action Plan on synergies between defence, space and civil industries.  

In particular, the roadmap should further set out as priorities for Research and innovation in the 
area of: 

  detect and Avoid (DAA) technological development to allow a greater degree of automation, 
inside  and  outside  U-space  airspace,  working  alongside  standardisation  bodies,  such  as 
EUROCAE, and the global framework governed by ICAO. 

  European  strategic  technologies,  such  CNS  supporting  UAS  operations  in  the  specific 
category and safe, secure and resilient C2 link (satellite based C2L solutions for IFR RPAS) 
for  drone  operations  in  the  certified  category.  Equivalent  performance  requirements  should 
be demonstrated during the respective civil and military certification paths. 

Critical technologies are bound to change as new technologies emerge. Therefore, the Roadmap 
should be monitored by the Observatory and reviewed periodically in order to identify the latest 
needs as well for reviewing the previously established priorities.  

8.2.3  Enabling testing and demonstrations 

Live testing and demonstrations are key to harnessing, developing, and accelerating the take-up 
of the most cutting-edge technological solutions to manage drones and innovative air mobility.  

The SESAR Joint Undertaking (SJU) is managing a portfolio of very large-scale demonstrations 
aimed  at  making  aviation smarter  and  more  sustainable,  and  paving  the  way  for  innovative  air 
mobility (IAM) in Europe. A sizeable portion of the demonstrations specifically address the safe 
and secure integration of drones, building on the outcomes of previous SESAR U-space research, 
with the first  related call  dating  back  to  2016. The  demonstrators  are  a  key  tool  to support  the 
SESAR  JU’s  vision  of  delivering  the  Digital  European  Sky,  matching  the  ambitions  of  the 
European Commission’s European Green Deal, Digital Europe and the recently launched strategy 
on smart and sustainable mobility. 

The Digital Sky Demonstrators take place in live operational environments and put to the test (on 
a  very  large  scale)  the  technological  solutions  necessary  to  deliver  the  Digital  European  Sky. 
Demonstrations can also lead directly to implementation, which has been the case in the island 
city  of  Tromsø,  Norway.  Following  real-life  trials  by  partners  in  SESAR’s  GOF2.0  project66, 

66  https://gof2.eu/ 

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VLOS unmanned inspection flights are now permitted within the town, despite being within the 
5km exclusion zone of Tromsø Airport. 

Still,  in  many  SESAR  U-space  demonstrations,  it  has  become  apparent  that  testing  and 
demonstrations become more complicated, as more new technologies are tested. Current aviation 
regulations do not yet cover live flights by autonomous vehicles or air taxis, for example, which 
makes it very difficult for advanced research to progress. Very large demonstration projects are 
for instance also confronted to the problems already mentioned in 8.1.2 above, which may delay 
the  operational  approval  operations  and  make  the  regulatory  authorisation  process  longer  and 
more  expensive  than  it  is  reasonable  in  the  context  of  demonstration  projects  with  individual 
flights and no immediate commercial pay-back. 

EASA  should,  in  addition  to  reviewing  the  scope  of,  and  requirements  for  drone  design 
verifications, develop specific guidelines to support the application of the SORA methodology to 
operations conducted for the purpose of test, experimentation or demonstration, and consequently 
facilitate live testing and demonstrations in the context of the current regulatory framework. 

Alongside  development  of  the  regulatory  environment,  it  would  also  be  useful  for  the 
Commission to set up a network on drone civil-defence testing centres. It would also be useful to 
creates a network of such test and demonstration sites across Europe that allow stakeholders to 
try new concepts and technologies in a safe airspace and ground volume. Such a network should 
allow for more generic sites all the way to very specialised sites, depending on the technical need, 
and contribute to the establishment of European digital innovation hubs, as envisaged by the EU 
industrial strategy, which can act as one-stop-shops for companies to access technology testing 
and showcase innovative solutions for the civil, defence and space markets. 

Moreover, since airspace and airfield facilities are at a premium, maximum use should be made 
of  military  facilities  to  enable  dual-use  of  defined  airspace  volumes  as  well  as  to  promote 
harmonised testing between civil, military and space operators. 

8.2.4  Driving for common standards 

Standards  play  a  major  role  in  defragmenting  markets  and  helping  industry  in  achieving 
economies  of  scale.  The  development  and  implementation  of  research  and  innovation  agendas 
including  through  standardisation  is  essential  for  EU  competitiveness.  The  Commission  gives 
strong  support  to  the  market  uptake  of  innovation,  in  particular  to  supporting  standardisation 
through  research  and  putting  science  into  standards.  Standardisation  activities  are  an  essential 
channel for the market adoption of research results and for the diffusion of innovations. Creating 
EU-wide  standards  and  promoting  them  on  a  worldwide  level  is  also  a  vital  component  of  the 
global competitiveness of the EU economy in general. 

The contribution of standardisation to Framework Programmes (FP) for Research and Innovation 
of the European Union dates back to the early nineties under FP4 (the Standards, Measurement 
and Testing Subprogram (SMT)) and FP5. In later Framework Programmes,  including Horizon 
2020, standardisation became a horizontal support tool relevant across all research areas. Horizon 
Europe,  the  new  Framework  Programme  for  Research  and  Innovation  for  the  period  of  2021-
2027, will support valorising R&I results through standardisation to the highest possible extent. 

The  impact  of  the  digitalisation  cannot  be  underestimated  when  it  comes  to  standardisation. 
Aviation moves from a human-centric system - where safety ultimately depends on pilots and air 
traffic controllers – towards an information-centric system, where highly automated aircraft can 
fly safely based on information flowing on mobile telecommunication networks. As the aviation 
and  mobile  telecommunication  worlds  converge,  the  need  for  Information  and  Communication 
Technology (ICT) standards will increase in aviation. This is particularly observable in the field 

Page 46 / 86 

 
 
of drones and unmanned aircraft traffic management solution, which are a laboratory for digital 
aviation solutions. 

U-space  service  providers  should  be  able  to  use  a  range  of  connectivity  tools,  including  the 
existing  telecom  equipment.  When  using  telecom  infrastructure  for  command-and-control 
purposes,  drone  stakeholders  should  be  able  to  use  standards  developed  by  the  appropriate 
standardisation  organisation,  including  ICT  or  joint  standards.  The  importance  of  such 
collaboration  between  ICT  and  aviation  industrial  organisations  is  illustrated  by  the  Aerial 
Connectivity  Joint  Activity,  an  initiative  between  the  Global  UTM  Association  and  the  GSM 
Association. 

As  we  progress  towards  the  Digital  European  Sky,  and  in  accordance  with  the  Action  Plan  on 
synergies  between  civil,  defence  and  space  industries,  it  is  vital  that  standardisation  cover  all 
airspace users, including the military, drones and HAO. The concept of dual-use standards was 
introduced in the 2012 Action Plan for an innovative and competitive Security Industry67, which 
recommended  that  the  development  of  'hybrid  standards',  i.e.  standards that  apply  both  to  civil 
and defence technologies, should be actively pursued in areas where technologies are the same 
and  application  areas  are  very  similar.  This  was  further  reinforced  in  the  2021  Action  Plan  on 
synergies  between  civil,  defence  and  space  industries68,  calling  for  the  development  of  hybrid 
technological standards and best practices applicable across the civil and defence sectors. 

Such ‘best practices’ could include the development of standard scenarios of dual use nature for 
the  specific  category  such  as  scenarios  Beyond  Visual  Line  of  Sight  (BVLOS)  and  above  500 
feet  (or  without  altitude  limitation)  which  could  facilitate  civil  and  military  operations  such  as 
cargo  and  emergency  delivery  of  goods,  surveillance  over  land  and  sea,  reconnaissance  for 
disasters  scenario  and  ferry  flights.  Deeper  collaboration  between  the  key  stakeholders  such  as 
EASA,  EDA  and  competent  national  civil  and  military  authorities  in  the  development  of  such 
scenarios could lead to savings in time and better use of limited pools of experts. 

Much current military standardisation activity for  drones is already aiming to be undertaken by 
civil  standardisation  organisations  such  as  EUROCAE,  so  that  civil  and  military  platforms  can 
safely  inter-operate  in  the  same  airspace.  Research  and  demonstration  projects  should  not  only 
seek to ensure that all drone standardisation, when appropriate, meets the needs of both civil and 
military  airspace  users,  but  also  mechanisms  should  be  investigated to  improve  standardisation 
practices  by  learning  from  and  re-using,  where  possible,  military  standardisation  processes  and 
agencies.  The  scope  of  such  standardisation  should  include  all  relevant  technologies,  including 
Integrated CNS, DAA and automation. 

To  coordinate  such  standardisation  activities,  the  European  Commission  established  the 
European  UAS  Standardisation  Coordination  Group  (EUSCG)69,  a  joint  coordination  and 
advisory  group  coordinating  the  drone-related,  including  U-space,  standardisation  activities 
across  Europe,  and  essentially  stemming  from  the  EU  regulations  and  EASA  rulemaking 
initiatives. The membership of EUSCG is composed of: 

  AeroSpace and Defence Industries Association of Europe (ASD) 
  ASD-STAN 
  ASTM (Europe) 
  Drone Manufacturers Alliance Europe 
  Drone Alliance Europe 

67  COM(2012) 417 

68  COM(2021) 70 

69  https://www.euscg.eu/ 

Page 47 / 86 

 
 
                                                      
  EASA 
  EUROCAE 
  EUROCONTROL 
  European Commission 
  European Defence Agency (EDA) 
  European Standardisation Organisations (ESOs): CEN, CENELEC, ETSI 
  Global UTM Association (GUTMA) 
 
 
  SAE 
  SESAR JU 

ISO 
JARUS 

The  EUSCG  is  supported  by  the  work  of  the  AW-Drones  Horizon  2020  project70,  which  is 
developing  an  open  repository  of  unmanned  aircraft  standards  and  validating  the  suitability  of 
technical standards to comply with existing regulation for drone operations. 

Finally, relevant actors such as EASA, EDA, EUROCAE and national military authorities should 
be encouraged to further harmonize certification requirements for civil and military applications 
towards  those  set  by  EASA  while  considering  military  specificities  and  existing  military 
certification standards. 

8.2.5  Increasing counter-UAS capabilities and system resilience 

Counter-drone 

New technologies can offer valuable opportunities but may also pose emerging threats that need 
to be addressed. The growing use of drones is no exception to this rule, as they can be misused to 
target  public  spaces,  individuals  and  critical  infrastructure71.  While  the  EU  has  regulated  the 
legitimate  use  of  drones,  there  are  no  specific  EU  rules  and  guidelines  on  countering  their 
unauthorised, as well as the use for criminal or terrorist purposes. The rapid pace of innovation 
and easy access to these devices as well as the components to make them, means that the threat is 
likely to grow – as also shown by the substantial use of civil drones in armed conflicts around the 
world. 

Preventing  the  unauthorised  use  of  drones  in  our  societies  is  also  necessary  to  allow  the 
legitimate use of drones to reach its full potential. Protecting our societies against malicious and 
non-cooperative  drones  also  requires  access  to  affordable  and  reliable  counter-measure 
technologies that enable flexible solutions adapted to the threat level and the operating situation. 
It  is  not  possible  to  have  a  standardised  “one-fit-all”  approach  to  counter  drone  (C-UAS) 
measures, as some technological solutions may not fit in an urban or crowded environment while 
they  may  be  adequate  to  protect  e.g.  critical  infrastructures.  Moreover,  it  is  important  to  have 
appropriate  legal  frameworks  in  place  to  implement  procedures,  provide  clear  authority  to 
intervene  and  facilitate  collaboration  between  stakeholders  which  are  not  always  used  to  work 
together (esp. law enforcement, aviation, operators and, manufacturers). 

Commercial drones can be used for legal and illegal activities, by citizens and businesses but also 
by criminals, terrorists or hostile state actors. The majority of drone users, however, are likely to 

70  https://www.aw-drones.eu/ 

71  The threat of UAS using explosives was investigated by the JRC (Larcher M, Karlos V, Valsamos G, 

Solomos G: Scenario study: drones carrying explosives, JRC107683, 2018). 

Page 48 / 86 

 
 
                                                      
be compliant with the rules and regulations, and notably licensed professional remote pilots are 
typically  aware  of  the  applicable  legislation  and  technical  limitations.  Nevertheless,  clueless, 
careless,  and  criminal  drone  users  are  responsible  for  the  numerous,  if  not  daily,  incidents 
involving drones across the EU. 

Both the 2020 EU Security Union Strategy72 and Counter-Terrorism Agenda73 clearly state that 
the threat of non-cooperative drones is a serious concern in Europe that needs to be addressed. In 
relation  to  the  Counter-Terrorism  Agenda  in  particular,  the  Commission  intends  to  release  in 
2023  handbooks  on  “Protection  against  Unmanned  Aircraft  Systems  –  Handbook  on  Counter-
UAS  for  Critical  Infrastructure and  Public  Spaces” and  “Protection  against  Unmanned  Aircraft 
Systems – Handbook on Principles for Physical Hardening of Buildings and Sites”. 

The Directive on the resilience of critical entities (CER Directive)74 will introduce obligations on 
Member  States  and  critical  entities  to  conduct  risk  assessments  and  for  critical  entities  to  take 
technical, security and organisational measures to ensure their resilience against identified risks. 
These assessments may include the risk posed by  non-cooperative drones. 

Many  Member  States  are  still  addressing  the  challenge  of  making  available  the  necessary 
budgets,  adapting  or  creating  the  necessary  regulatory  framework  and  identifying  the  right 
(technical)  solutions  to  be  able  to  cope  with  the  different  threat  situations  of  non-cooperating 
drones. 

To support Member States the JRC and its drone project will review processes and interactions 
between stakeholders and the use technologies and how these technologies can be combined into 
solutions, which can be used to ensure the security of citizens and critical infrastructure.  

One part of the drone project is the creation of a living lab with a C-UAS solution implemented 
that will be open to stakeholders to investigate counter UAS solution aspects and how these can 
be  applied  in  real.  The  living  lab  implementation  will  be  designed  so  that  it  can  be  used  as  a 
guide to comply with the legally required Geel site protection (Class 1 Nuclear installation). 

More  specifically  in  the  area  of  aviation,  drone  incidents  may  endanger  aircraft  and  their 
occupants.  Most  occurrences  have  been  reported  during  approach/landing  and  take-off/climb, 
which are the most critical phases of a flight. To better understand the vulnerability of manned 
aircraft to drone strikes, EASA is managing a project supported by Horizon 2020 that is expected 
to  run  until  June  2023.  Besides  these  physical  risks,  drones  can  also  cause  economic  and 
operational  damages.  The most  severe  drone-related disruptions  took  place  at  London  Gatwick 
Airport  between 19  and  21  December  2018.  Following  reports of drone  sightings,  the  airport’s 
runway  was  closed  which  led  to the  cancellation  of  approximately  1,000  flights  and  impacting 
140,000 passengers. This incident is estimated to have cost the industry up to EUR 64 million. A 
2020 study75 suggests that if Frankfurt airport had to be closed for a continuous 48-hour period 
due to drone sightings, it would cost EUR 3 million to the airport and another EUR 34 million to 
the airlines. Incidents of a smaller scale can also cause significant cost, particularly if they lead to 

72  COM(2020) 605 final of 24 July 2020 

73  COM (2020) 795 final of 9 December 2020 

74  COM(2020)  829  final  of  16  December  2020.  The  European  Parliament  and  the  Council  reached 

political agreement on the proposed Directive on 28 June 2022 (Security Union (europa.eu)) 

75  Wendt, P., Voltes-Dorta, A., & Suau-Sanchez, P. (2020). Estimating the costs for the airport operator 
and airlines of a drone-related shutdown: an  application to Frankfurt international airport.  Journal of 
Transportation Security, 1–24. 

Page 49 / 86 

 
 
                                                      
the  closure of the runway.  For  the ten largest  European  airports, the  delay  cost  of  a  30-minute 
runway closure is estimated to range from EUR 325,000 to EUR 514,00076. 

For  the  time  being,  EU  legislation  contains  no  explicit  provision  specifically  addressing  the 
threats  posed  by  drones  at  and  around  airports.  Article  38  of  the  EASA  Basic  Regulation77 
contains  a  general  obligation  for  aerodrome  operators  to  “monitor  activities  and  developments 
which may cause unacceptable safety risks to aviation in the surroundings of the aerodrome” and 
to “take the necessary measures to mitigate those risks in as far as this lies within their control”. 
Regulation (EC) No 300/200878 dealing with aviation security contains no specific provision on 
drones.  

The  Commission  has  been  supporting  Member  States  in  addressing  the  threats  from  non-
cooperative drones since 2016. The scope of the Commission’s counter-UAS work covers a wide 
range  of  activities  aimed  at  enhancing  Member  States’  capabilities  in  this  area,  based  on  the 
following six pillars: 

Community-
building & 
information 
sharing

European 
Program for 
C-UAS 
systems testing

Practical 
guidance & 
support

Research & 
innovation

Funding 
suppport

Legislative 
measures

1.  Community building and information sharing 

On  a  regular  basis  (every  6  months),  workshops  are  organised  by  the  Commission  with 
representatives  from  Member  States,  EU  Institutions,  EU  Agencies,  EU-funded  projects, 
International Organizations and partner third countries. This has led to a continuous engagement 
of all stakeholders, facilitating also significantly their operational and practical cooperation.  

To  this  end,  the  Commission  has  also  set  up  a  dedicated  Counter-UAS  Interest  Group  (shared 
drive  with  limited  access  to  registered  stakeholders)  which  currently  has  almost  300  members. 
This  platform  is  regularly  updated  and  hosts  all  kind  of  open-source  and  non-sensitive 
information on the topic. Twice a year a newsletter is produced and shared with the members of 
the interest group. 

There  is  an  ongoing  cooperation  with  NATO  through  cross-briefings  and  mutual  staff 
participation in dedicated counter-UAS workshops and exercises. 

2.  European Programme for counter-UAS systems testing 

This  programme  has  been launched to  develop a  common  methodology  for  evaluating  systems 
that  can  be  used  by  law  enforcement  and  security  authorities  to  detect,  track  and  identify 
potentially  malicious  drones.  The  programme  is  supported  by  the  Courageous79  project,  which 
started in April 2021 and is funded by the EU Internal Security Fund–Police. There are regular 
stocktaking meetings where outcomes are shared with Member States as well as selected partner 
countries and international organisations. 

76  European Union Aviation Safety Agency, Drone Incident Management at Aerodromes, 8 March 2021 

77  Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common 

rules in the field of civil aviation and establishing a European Union Aviation Safety Agency 

78  Regulation  (EC)  No 300/2008  of  the  European Parliament  and  of  the  Council  of  11  March  2008  on 

common rules in the field of civil aviation security; and secondary legislation 

79  https://courageous-isf.eu/ 

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3.  Practical guidance and support 

The Commission is also compiling EU best practices with a view to develop practical guidance 
material, in particular, ”Protection against Unmanned Aircraft Systems – Handbook on Counter-
UAS  for  Critical  Infrastructure and  Public  Spaces” and  “Protection  against  Unmanned  Aircraft 
Systems – Handbook on Principles for Physical Hardening of Buildings and Sites”. 

4.  Research and innovation 

Based on projects from the EU security research programme, such as ALFA80 and ALADDIN81 
(funded  under  Horizon  2020),  as  well  as  ISF-funded  projects  such  as  Skyfall,  Courageous  and 
DroneWise82, the Commission is identifying and sharing regularly relevant deliverables amongst 
EU  stakeholders.  Moreover,  through  its  JRC  laboratories  and  Living  Labs,  the  Commission  is 
offering  the  possibility  for  testing  and  supporting  pilot  projects.  Stakeholders  can  use  these 
facilities to demonstrate policy impact and needs, as well as to develop processes, procedures and 
solutions83. 

5.  Financial support 

Through the security research programme, as well as the Internal Security Fund (Police) for the 
period  2014-2020,  the  EU  co-funded  the  development  of  Counter-drone  tools,  knowledge  and 
technologies.  This  effort  will  continue  in  the  current  Horizon  Europe  programme,  the  Internal 
Security Fund (ISF) and the Border Management and Visa Instrument (BMVI) component of the 
Integrated Border Management Fund (IBMF). These programmes are complimentary as Horizon 
Europe strengthens research and innovation, while the ISF and BMVI focuses on a wide range of 
practical  applications  for  law  enforcement  and  border  management,  such  as  the  acquisition  of 
equipment,  promoting  and  developing  training  schemes  and  ensuring  administrative  and 
operational coordination and cooperation.  

This financial support  is  made available  through  national  programmes  (shared management)  or 
through  Union  actions  supporting  transnational  initiatives  (direct  management).  With  regard  to 
research  and  innovation  related  measures,  funding  is  also  available  under  the  Horizon  Europe 
programme. 

6.  Legislative measures 

In the EU, there are currently no specific counter-drone rules, which set a common harmonised 
framework  for  Member  States  authorities,  operators  and  manufacturers.  As  the  need  for  an 
effective  prevention  of  the  unauthorised  use  of  drones  and  drone  technologies  is  constantly 
growing, the Commission is working towards EU counter-drone guidelines and examine the need 
for legislative measures.. 

In  aviation,  following  the  Gatwick  incident,  an  EASA-led  Task  Force  developed  a  manual 
entitled  “Drone  Incident Management  at  Aerodromes”.  Completed  in March 2021,  this  manual 
contains non-binding guidance and recommendations helping airports and authorities to prepare, 
respond and recover from drone incidents. While these guidelines were favourably received by 
the sector, their non-binding nature makes them insufficient to mitigate a threat that is likely to 
grow as drones become more ubiquitous and capable.  

80  Advanced Low Flying Aircrafts Detection And Tracking https://cordis.europa.eu/project/id/700002  

81  Advanced 

hoListic 

Adverse 

Drone 

Detection, 

Identification 

Neutralization 

https://cordis.europa.eu/project/id/740859 

82  https://www.projectskyfall.org, https://courageous-isf.eu and https://dronewise-project.eu 

83 https://joint-research-centre.ec.europa.eu/pilot-living-labs-jrc_en 

Page 51 / 86 

 
 
                                                      
Furthermore,  to  address  the  gap  on  legislation  related  to  the  threats  posed  by  drones  at  and 
around  airports,  the  aviation  security  legislation  needs  to  be  amended  to  ensure  that  aviation 
authorities and airports manage the risks posed by drones. It would not need to prescribe specific 
measures but set a general obligation to manage risks, with the exact measures being determined 
at the national or local level based on a risk-assessment. This approach  would best account for 
the  specificities  of  each  airport  and  the  various  risk-levels  that  may  exist  across  the  EU. 
Moreover,  certain  mitigating  measures,  particularly  those  that  involve  the  use  of  detection 
technologies,  have  a  significant  cost  which  makes  them  more  suitable  for  large  or  higher-risk 
airport.  As  an  illustration,  it  is  estimated  that  it  could  cost  around  EUR  500  million  to  equip 
Germany’s 16 busiest airport with drone detection systems.  

The Commission will continue providing operational, technical and financial support to Member 
States,  as  outlined  above.  In  addition,  the  Commission  will  specifically  outline,  through  a 
Communication  to  be  presented  in  the  first  half  of  2023,  the  EU’s  future  policy  on  countering 
drones.  This  includes  taking  stock  of  existing  projects,  best  practices  and  available  reliable 
technologies for tracking, identifying and neutralising drones adapted to the concrete threat level 
and operating environment, as well as presenting the Commission’s strategic vision in this field, 
which is characterised by the lack of a clear EU legal framework. 

Resilience 

Drones  and  related  control  units  are  highly  advanced  and  complex  platforms  running  various 
different  digital  processes  that  control  -automated  or  remotely  -  the  drone  or  its  payload,  store 
and transmit data, broadcasting identification, and so on. Like any similar system, a drone and its 
control unit is vulnerable to hacking and misuse. In 2020, security research firms revealed that, 
without a knowledge of drone operators, a major drone manufacturer located outside of the EU 
could  collect  information  through  the  control  application  installed  to  the  operators’  phone,  and 
even  silently  update  the  application,  thus  leaving  it  open  for  further  vulnerabilities.  While  this 
feature  might  not  have  been  introduced  with  malicious  intentions  by  the  manufacturer,  it  still 
demonstrates the difficulties of ensuring that a drone is fully controlled by its owner or operator 
and that the collected data remain safely in their hands. Security vulnerabilities could also lead to 
hijacking of a drone with aim to use it for criminal purposes. 

The Commission should work towards defining criteria which can be used to identify, or label, 
trusted drones. The voluntary label could be issued by a relevant Authority after a manufacturer 
has  provided  evidence  that  a  specific  drone  fulfils  the  criteria.  Such  criteria  could  be,  for 
example,  provision  of  a  secured  communication  link,  secure  identification,  use  of  open-source 
code, transparent software upgrades or protection against GNSS spoofing. It should build on and 
be compatible with the ongoing work to develop horizontal cybersecurity legislation. The label 
would  make  it  possible  for  any  end-user  to  purchase  such  trusted  drones  in  confidence. 
Furthermore,  it  would  benefit  not  only  drone  operators  but  also  all  entities  responsible  for  the 
monitoring the use of airspace. For example, a relevant authority could require such trusted drone 
label from all drones operating in a restricted airspace, subsequently helping to separate legally 
operated drones from illegal ones. 

Voluntary labelling would not only improve the security of drones, but it could serve as useful 
marketing  tool  for  the  European  drone  industry  which  is  generally  targeting  more  high-end 
professional drone market. 

In  a  longer  term,  the  European  Union  should  assess  the  need  to  set  a  condition  that  drones 
acquired by the EU through public procurements meet the security requirements set in the trusted 
drone label. 

Page 52 / 86 

 
 
 
9  ACTION PLAN  

The following action plan is based on the vision and strategic objectives, as described in Chapter 
7. It covers some of the recommendations and suggestions of actions to be taken by the European 
Commission which were collected during the consultation phase of the preparation of the Drone 
Strategy 2.0.  

In addition to action by the Commission, other stakeholders, as described in this document, are 
also required to play their part, ranging from European entities, such as EASA and the European 
Investment Bank, to national authorities, including ministries and regulatory bodies, regional and 
local  governments,  military  and  law  enforcement  bodies,  as  well  as  private  entities  such  as  U-
space service providers and manned and unmanned aviation industry alike. 

List of Actions and means to be implemented by the European Commission to further build 
the European drone services market  

Action  
-  adopt amendments to the Standardised 
European Rules of the Air and the Air 
Traffic Management/Air Navigation 
Services Regulation to safely integrate 
drone and piloted eVTOL operations.  

-  promote coordinated research on 
integrated Communication, Navigation 
and Surveillance technologies.  

-  adopt new European standard scenarios 
for low to medium risk aerial operations.  

-  adopt rules for the ‘certified’ category 
of drone operations and the operational 
requirements applicable to manned 
VTOL-capable aircraft.  
-  adopt rules for the design and 
operations of vertiports under the scope of 
EASA Basic Regulation.  

-  develop balanced economic and 
financial requirements for drone operators 

Means  

Putting forward proposal to amend the Standardised 
European Rules of the Air (Regulation 
(EU)923/2012)84, and common requirements for 
providers of ATM/ANS (Regulation (EU)2017/373)85, 
to allow safe, orderly, and efficient drone operations in 
the ‘specific’ and ‘certified’ category, and piloted 
eVTOL operations.  
The research undertaken at EU level in the following 
fields should be coordinated: CNS (ICNS) 
technologies, including all current CNS technologies 
used for ATM, but also those needed to support U-
space, IAM, drone integration and Higher Airspace 
Operations, including technologies from other 
domains, such as the telecommunications and the 
space industries.  
There are currently 2 European standard scenarios 
annexed to Regulation (EU) 2019/947, further 
standard scenario should be developed in order to 
allow commercial drone operators to declare their 
operations instead of seeking a prior authorisation.  
New common rules for the ‘certified category’ and 
VTOLs should be rolled out covering the certification 
of aircraft, of operators and remote pilots.  

A new regulatory framework applicable to the design 
and operations of vertiports under the scope of EASA 
Basic Regulation will facilitate the development of 
intermodal transport.  
Regulation (EC) 1008/2008 should ensure fair market 
access for new drone operators with more suited 

84  Commission  Implementing  Regulation  (EU)  No  923/2012  of  26  September  2012  laying  down  the 
common rules of the air and operational provisions regarding services and procedures in air navigation 
(OJ L 281 13.10.2012, p. 1) 

85  Commission  Implementing  Regulation  (EU)  2017/373  of  1  March  2017  laying  down  common 
requirements  for  providers  of  air  traffic  management/air  navigation  services  and  other  air  traffic 
management network functions and their oversight (OJ L 62, 8.3.2017, pp. 1-126) 

Page 53 / 86 

 
 
 
                                                      
in the context of its legislative proposal to 
revise Regulation (EC) 1008/2008.  

-  fund the creation of an online platform 
support a sustainable IAM 
implementation by authorities, cities, 
industry and stakeholders.  

-  adopt training and competences 
requirements for remote pilots and pilots 
of VTOL aircraft.  

economic and financial conditions and consider using 
other instruments to adequately protects the strategic 
autonomy of the EU when necessary.  
As a pilot project proposed by the European 
Parliament, the Commission will fund the creation of a 
sustainable IAM Hub by EASA as an online platform 
that supports authorities, cities, industry and 
stakeholders with the implementation of UAM;  
New skills and competences such as those of drone 
specialists should be developed to ensure that remote 
pilots have the requisite level of knowledge and skills 
in line with continuous advancing technological 
development.  

List of Actions and means to be implemented by the European Commission in order 
to strengthen European civil, security and defence industry capabilities and 
synergies  

Action  

Means  

The drone sector is still at is early stages requiring 
further financial support for R&I in order to reach 
economically sustainable maturity.  

-  continue to provide funding for R&I on 
drones and their integration into the 
airspace under the Horizon Europe 
programme and the European Defence 
Fund.  
-  set up a coordinated series of calls of 
existing EU instruments and EIB loans to 
support a new flagship project on ‘drone 
technologies.’ 

-  consider possible amendments to the 
existing financing/funding framework to 
ensure a consistent approach in support of 
dual-use research and innovation to improve 
synergies between civil and defence 
instruments. 

In implementation of relevant proposals in the 
Synergies Action Plan and the Analysis of defence 
investments gaps meant to support critical 
technologies and industrial capacities by developing 
strategic projects, -  set up a coordinated series of 
calls of existing EU instruments and EIB loans to 
support a new flagship project on ‘drone 
technologies’ that can prove the concept of synergies 
along the pathway from R&D to deployment 
through public procurement.  
In order to facilitate exchanges between civilian and 
defence communities, especially in the area of 
critical technologies, -  prepare an approach for 
encouraging dual-use RTD&I at EU level to be fully 
implemented in the medium to long term across EU 
programmes and instruments. This work will also 
feed into the mid-term evaluation of relevant sectoral 
programmes.  
A Strategic Drone Technology Roadmap should 
further set out priorities for R&I, identifying critical 
strategic drone technologies such as AI, detect and 
Avoid (DAA) robotics, semi-conductors, hybrid and 
electric propulsion systems, safe, secure and resilient 
Command and Control link and energy storage, 
batteries and cloud technologies should be defined at 
EU level, in collaboration with the Observatory of 
Critical Technologies.   
Coordinating a European approach to ensure that 
radio frequencies and protected spectrum are 
available for drone operations, in cooperation with 
EUROCONTROL at ICAO and ITU level.  
-  set up an EU network on civil-defence  Developing a network of joint civil-defence 

-  develop a Strategic Drone Technology 
Roadmap in order to identify priority areas 
to boost research and innovation, reduce 
existing strategic dependencies and avoid 
the emergence of new ones.  

-  coordinate a common approach with the 
aim of providing sufficient radio 
frequencies spectrum for drone operations.  

Page 54 / 86 

 
 
  
 
  
drone testing centres to facilitate exchanges 
between civilian and defence sectors.  

- encourage all relevant actors to further 
harmonise certification requirements for 
civil and military applications towards those 
set by EASA while considering military 
specificities and standards.  

-  adopt new standard scenarios for civil 
operations that could facilitate 
corresponding military use cases.  
-  adopt a counter-UAS package.  

-  adopt an amendment to the aviation 
security rules aiming to ensure that aviation 
authorities and airports increase their 
resilience when faced with the risks posed 
by drones. 
-  define criteria for a voluntary “European 
Trusted Drone” label. 

collaborative field-testing of drone demonstrators 
and in this context seeking deeper cooperation 
between civil and military with the aim to optimise 
the use of restricted airspaces for civil and military 
trials. This would create a flying-safe space to “test 
& share” and allow gaining flight hour experience to 
prove safety under a “fly-before-certify” approach.  
EASA, EDA, EUROCAE and national military 
authorities should further harmonise certification 
requirements for civil and military applications 
towards those set by EASA while considering 
military specificities and existing military 
certification standards. To the extent possible, this 
should be done within existing structures such as 
EUSCG.  
Further European standard scenarios for the specific 
category for operations could have both military and 
civil applications such as surveillance drones.  
The package could include, but not limited to, 
actions to continue the ongoing dedicated support to 
MS; a Commission Communication announcing 
work towards EU counter-drone guidelines; 
increased efforts in the protection of critical 
infrastructure and public spaces by publishing a 
handbook on the matter; technical guidance on the 
physical protection principles of infrastructure 
against drones; an enlarged technical expert group 
on voluntary standards to cover counter-drone 
solutions  
This legislative amendment should not prescribe 
specific measures but rather contain a general 
obligation to manage the risks in order to take into 
account of the different risk levels that exists at 
different airports.  
The label would be granted for cybersecurity 
approved drones in the ‘open’ and ‘specific’ 
categories. It should build on and be compatible with 
the ongoing work to develop horizontal 
cybersecurity legislation.  

Page 55 / 86 

 
 
  
 
A  Synopsis consultation report 

A.1  Introduction 

The stakeholder consultation matrix below provides an overview of how 12 defined stakeholder 
groups  have  been  consulted,  i.e.,  through  interviews  (scoping,  targeted),  survey,  stakeholder 
meetings  and  Open  Public  Consultation  (OPC)  by  the  external  contractor.  Stakeholders  for 
interviews  and  survey  were  selected  in  close  consultation  with  the  Commission.  The  OPC 
enabled the participation of citizens. 

Stakeholder group 

Scoping 
interviews 

Targeted 
interviews 

Targeted 
Survey 

Stakeholder 
meetings 

OPC 

National and regional 
authorities 

European institutions and 
relevant agencies 

Military and Law 
enforcement 

Commercial and non -
commercial aircraft 
operators 

Drone operators, service 
providers and users 

Airport operators and 
ANSPs 

U-space providers 

Manufacturing industry 

Inter-governmental 
organisations and networks 

NGOs  

Research and academia 

Citizens 

Total 
respondents 

number 

of 

Source: Ecorys 

1 

2 

1 

1 

5 

6 

2 

1 

4 

2 

3 

3 

1 

1 

2 

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

25 

198 

3* 

258 

Five  stakeholders  were  selected  for  scoping  interviews,  one  national  authority;  two  from  EU 
institutions;  one  drone  manufacturer  and  one  stakeholder  representing  research  and  academia. 
The  result  provided  insights  on  main  issues,  which  together  with  desk  research  established  the 
basis for drafting the questionnaire survey, and the OPC. 

Page 56 / 86 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The  members  of  the  Informal  Drone  Experts  Group  were,  invited  to  submit  their  views  on  the 
following topics on the occasion of three hearings on: 

  Urban Air Mobility (cargo/passengers) and U-space   
  Enhancing UAS services including the SME dimension 
  Developing Military/Civil synergies and technology building blocks 

A.2  Feedback to the Roadmap 

Feedback on the DS2.0 roadmap public consultation includes 45 written contributions provided 
by  14  companies/business organisations;  10  Business  associations;  8  citizens  (of  which  7 from 
EU); 6 NGOs; 4 Public authorities and 3 research institutions. 

A.2.1  Context & Problem the initiative aims to tackle 

  All  contributors  agreed  that  -  if  regulated  properly  -  drones  have  the  potential  to  generate 
societal,  economic,  and  environmental  benefits.  They  noted  that  this  will  depend  on  the 
development of a new strategy that reflect changes and promote safe and responsible drone 
operations  and  addresses  related  societal  concerns  such  as  safety,  security,  privacy  and 
environmental protection.  

  All  of  them  acknowledged  that  the  growth  of  UAV  activity  must  be  addressed  urgently  in 
order  to  preserve  the  safety  of  manned  aircraft  and  to  foster  the  promotion  of  the  drone 
industry. 

  They  welcomed  the  roadmap  and  shared  the  EC’s  view  that  the  development  of  a  thriving 
and  competitive  drone  industry  can  accelerate  Europe’s  transition  to  green  and  digital 
economy, observing that Europe requires a strategy aligned with the latest developments and 
the needs and concerns of their citizens.  

A.2.2  Objectives 

Contributions welcomed the objectives identified by the EC. Notably, 

Safety, security, and privacy of people in the air and on the ground  

  The  EC  consideration  on  the  importance  of  the  safety  objective  was  acknowledged  by  the 
majority of stakeholders and the ambitions to develop a safe and efficient drone ecosystem 
under  the  forthcoming  Drone  Strategy  2.0.,  to  ensure  the  right  balance  between  safety, 
security, and other societal concerns, was praised. 

  EHA  noted  that  safety  was  a  priority  especially  for  helicopter  operations  dealing  with 
emergencies,  as  they  must  be  able  to  identify  potential  incoming  and  colliding  drones  and 
engage in safe avoidance manoeuvres. To this end, it called for a number of amendments to 
the existing regulations.  

  Wing  expressly  welcomed  the  adoption  of  the  risk-based  SORA  process  for  evaluating 
complex operations, helping to ensure that different operations meet a common target level 
of  safety.  It  noted  that  supporting  diverse  operations  will  depend  on  performance-based 
approaches  to  regulation,  recognizing  new  and  innovative  ways  to  achieve  a  high  level  of 
safety.  

  Complementing  the  welcomed  EC’s  considerations  on  the  safety  objective,  IAOPA 
suggested that the EC should address the liability aspect of drone integration. It complained 
that  currently  a  serious  lack  of  liability  persisted  when  a  UAV  caused  damage  and 
maintained that strict liability for drones’ operators needed to apply in case of collision. The 

Page 57 / 86 

 
 
Association also suggested that education aspect  was for UAV operators further addressed, 
implementing consistent training programs with the aim of maximising the safety of people 
in  the  air  and  increase  awareness  of  the  relevant  legal  framework.  Regarding  privacy,  it 
argued  that  the  strategy  should  put  forward  specific  measures  to  enforce  the  respect  of 
European citizens’ privacy outlined in the already adopted legislation. 

  CANSO  voiced  concern  for  the  lack  of  explicit  reference  to  the  need  for  a  comprehensive 
policy  package  that  includes  the  scalable  integration  of  UAS/UAM  with  manned  aviation 
operations as an important success factor. 

  The  Czech  Association  of modellers contended  that  a  less  strict  regime  for  aircraft  models 
should be part of the Drone 2.0 Strategy plan, due to inter alia, their reduced impact on safety 
and security and on privacy. 

  Omega stressed that the most crucial aspect that required a deep and radical change is the U-
space,  which  should  be  based  on  the  rethinking  of  privileges  already  established  in  the  air 
space.  

  The  Swiss  Federal  Office  of  Civil  Aviation  noted  that  whereas  the  roadmap  pointed  to  a 
broad selection of potential societal concerns, positive societal and political externalities such 
as drone applications contributing to the digital transformation of businesses should also put 
forward to ensure a fair presentation of the issue.  

  One citizen and UECNA complained that noise control was not mentioned in the Roadmap 
and  feared  that  the  development  of  drones,  especially  in  the  mobility  and  transport  sector, 
may have a negative impact on citizens health. 

Guarantee their widest possible social acceptance 

  All contributions mentioning social acceptance endorsed this EC objective, as the low social 

acceptance of drones is seen as a major challenge.  

  GAMA  stressed  the  need  for  supporting  the  societal  but  also  the  local  administration 
acceptance  of  UAS  operations  in  urban  and  non-urban  areas  and  for  Regional/Urban  Air 
Mobility.  

  All  called  for  effectively  engaging  and  consulting  incubators  local  communities  from  the 
outset, to increase public acceptability, accelerate the ecosystem’s implementation in cities, 
and  inform  on  drone  regulatory  developments.  They  insisted  on  the  need  for  a  better 
communication  (e.g.  investing  in  proactive  campaigns)  to  and  engagement  with  citizens, 
explaining the drones benefits for the society, while addressing the related concern that affect 
social acceptance (from privacy to affordability to environmental and noise concerns).  

  ACI  EUROPE  complained  that  a  number  of  projects  with  significant  potential  to  foster 
development  of  UAS  services  struggled  to  get  off  the  ground  due  to  lack  of  support  from 
local,  regional  and/or  national  authorities,  partly  due  to  the  slow  evolution  of  regulations 
and/or tried and tested (as well as certified) technology and its use cases. It hence called for 
an official European endorsement for companies or consortia working on demonstrators / test 
flights aiming to demonstrate the feasibility of UAS, operational procedures and use cases to 
secure the necessary support from competent local/national authorities. 

  The  Drone  Office  company  and  UAV  DACH  e.V.  suggested  that  the  Strategy  expressly 
stressed  the  positive  impact  on  end-users'  industries  and  citizens,  thus  tackling  the  social 
acceptance hurdle.  

Address obstacles to the development of new drone applications and transport services and to 
the competitiveness of this industry 

  Concerns  were  raised  for  the  lack  of  support  of  regional  and/or  national  authorities  to 

projects with significant potential to foster development of UAS services.  

  EREA found the link missing with multimodality and link with city infrastructure observing 
that the infrastructure in the city (including vertiports) will need to change to support drone 

Page 58 / 86 

 
 
operations. To reach EC’s goal of developing new types of services and capabilities along the 
value  chain,  multimodality  was  deemed  key,  linking  drones  to  other  transport  modes  and 
their infrastructure.  

  SKYPORTS  particularly  emphasised  the  necessity  to  further  develop  the  framework  to 
enable  permanent,  commercial  drone  delivery  operations  at  scale  as  well  as  addressing  all 
aspects of advanced air mobility.  

  DRONEA  welcomed  the  adoption  of  the  Sustainable  and  Smart  Mobility  Strategy  and  its 
Action  Plan,  which  introduced  the  Concept  of  Green  and  Digital  transformation  in  a 
European  perspective,  considering  them  as  valuable  complements  that  will  enable  drones 
contribute to a new Level of sustainable services and transport. 

  HHLA Sky listed a number of precise obstacles to be addressed, as remaining regulatory and 
organizational  challenges  to  realize  our  drone  economy’s  full  potential,  starting  from  the 
need to contribute to the implementation of the European Green Deal. 

Synergies between civil, defence and space industries 

  Contributions  welcomed  that  the  roadmap  addressed  civil/defence  and  space  synergies,  C-
UAS & military use of drone as part of the Strategy. Also the fact that counter-drone systems 
are explicitly named in the document was positively perceived.  

  Mixing military and commercial use of drones was identified as a main risk in this regard, as 
it could be counterproductive for social acceptance. To avoid that, it was stressed the need to 
carefully  distinguish  the  civil  and  military  use  of  drones  in  the  strategy,  but  also  to  foster 
close cooperation between military and civilians and include the space sector for the targeted 
consultation (WING).  

Ensure legal and technical certainty based on a harmonised EU approach / Support technical 
harmonisation  

  Harmonisation  was  welcomed  as  it  ensured  that  a  drone  operator  from  one  Member  State 
could operate in another as easily as in the country in which it is based. DMAE argued that 
harmonisation is not yet achieved. 

  EBF stressed the need of preventing different modus operandi in different EU countries and 
was concerned that U-space, if left to the MS,  would end up creating competition between 
operators  because  of  the  different  national  legislations.  It  hence  called  for  more  central 
guidance. 

  Boeing believed that an international perspective was key, so as to ensure the greatest levels 
of harmonisation possible – ensuring that any framework facilitates the free flow of products 
and services.  

  GAMA  pointed  out  that  the  Strategy  should  support  the  development  of  the  required 
infrastructure,  including  vertiports  and  U-space-enabling  ATM  capabilities,  in  a  consistent 
way across the EU. 

  Stichting Space53 and KNVvL stressed that national differences in (interpretation of) rules 
and  legislation  withhold  cross-border  business.  The  latter  complained  that  differences 
between countries  would not be solved with the new rules and pointed out that differences 
between  the  countries  still  existed,  especially  in  the  zoning  and  prices  of  the  various 
applications,  level  of  cooperation  between  military  and  civilians.  It  therefore  called  for 
clarification.  

Increase cooperation between stakeholders 

  RATP  Group  welcomed  the  objective  of  increased  cooperation,  emphasising  that  new 
governance  models are  needed to set  to  launch  the UAM  industry  and  address  its  complex 
and  interdisciplinary  needs.  Collaboration  between  manufacturers  and  industrial  partners, 
urban public transport operators, infrastructure providers and regulatory authorities and urban 

Page 59 / 86 

 
 
policies  makers  is  a  must.  These  open  pluri-disciplinary  collaborations  are  key  in  ensuring 
the ecosystem launch based on the safest and most secure operational levels. 

Support research and infrastructure initiatives  

  Research 

institutions  particularly  welcomed 

the  objective  of  supporting  research, 
highlighting the need to provide access to test sites in multiple locations, hence providing the 
possibility  for  gathering  field  experience  in  the  controlled  environment  and  enhance  safety 
level and public acceptance.  

  The use of simulations and flight test centres as well as pilot scenarios was deemed essential 
to ensure a sustainable and safe air mobility. It was highlighted the need to foster the use of 
existing test centres and the creation of new test sites, support pilot projects to accelerate the 
phase  of  market  introduction  of  technologies,  provide  a  mechanism  for  technology  transfer 
from Research Establishment to Research Industry, in particular to SMEs, as well as to adjust 
research infrastructure to UAS test-need according to new regulations.  

  RATP  Group  purported  that  in  order  to  transition  between  testing  vehicles  prototypes  and 
flight demonstration into operating a network of vehicles at scale by 2030, real life areas or 
incubators were needed. 

  Stichting  Space53  observed  that  the  Strategy  2.0  should  create  the  conditions  for  research, 

development and application of drone technology without unnecessary limitations. 

Proposing new legislation 

  Some  contributors  identifed  areas  for  legislative  actions:  EuroUSC  Italia  ltd  suggested  that 
the  Strategy  should  complete some  aspects not  yet  fully  covered  to implement  the existing 
regulations and other Union's policies. To this end, it proposed a number of amendments to 
the existing framework. 

  Skyports, DJI, and DMAE recommended that the Strategy should focus, inter alia, on further 
developing  the  conditions  and  framework  for  the  operation  of  UAS  in  the  Specific  and 
Certified categories, exploring how manned and unmanned aviation could coexist in the same 
airspace in the short term, particularly at low levels, and ensuring the regulatory framework 
remained risk-based and simple in approach. 

  DMAE and AME also listed some regulatory gaps/major issues to be addressed. 
  According to ITG, the forecasts for civil drones’ traffic should be updated frequently in order 
to provide a reliable and accurate view at short, medium and long term and the elaboration of 
AMCs and  guidance material must be speeded up in order to deploy U-space as well as to 
develop  vehicles  compliant  with  the  high-standard  performance  levels  required  for  safe 
operations. 

  GAMA mentioned the need to focus new rules on increase automation and AI. 
  EREA  contended  that  rules  for  emergency/landing  spots  requirements  were  necessary,  as 
well as minimization of risk for people & infrastructures on the ground in case of accidents 
by adopting a clear complete framework of norms (prescriptions) and derived procedures. It 
also  called  for  assessments  on  the  environmental  impact  and  sustainability  of  drone 
operations to ensure that drone industry was circular.  

  UAV DACH e.V., ITG, Lukasiewicz, and one EU citizen called for a simplification of UAS 
certification  and  of  the  procedures  to  request  permission  to  carry  out  validations,  as  the 
current  requirements  made  it  difficult  to  conduct  proper  tests  in  controlled  urban 
environments. 

Page 60 / 86 

 
 
A.2.3  Better regulation: Consultation of citizens and stakeholders & Evidence base 

and data collection 

  The  engagement  of  stakeholders  for  the  Roadmap  is  widely  welcomed.  All  contributors 
appreciated the opportunity to provide their feedback on the proposed Roadmap and wished 
to  assist  with  future  stages  of  its  development,  often  demanding  to  be  included  in  the 
consultation process announced in the document. 

  CER  noted  that  it  was  of  utmost  importance  to  involve  the  drone  users  in  the  regulatory 
process  in  order  to  ensure  the  return  of  experience  of  the  particular  domain  being 
appropriately  and  comprehensively  taken  into  account  and  fully  understand  the  market,  its 
needs and problems.   

  EUROCONTROL  expressed  concern  that  the  study  as  described  in  the  Roadmap  was  too 
narrowly  focused  and  called  for  actions  to  ensure  that  a  drone  operator  from  one  Member 
State could operate in another as easily as in the country in which it is based.  

A.3  Open Public Consultation (OPC) 

The  aim  of  the  Open  Public  Consultation  was  to  collect  views  of  stakeholders  on  drone 
operations and drone services and to identify possible policy options for the Drone Strategy 2.0. 

The public consultation was launched on 8 October and stayed opened until 31 December 2021.  

Overall, 258 contributions were submitted, 126 by individuals and 132 by organisations. Most of 
the answers were submitted by respondents from Estonia (43: 17%), Germany (41: 16%), Italy 
(33: 13%) and Belgium (26:10%). 

Respondents  were asked  to  indicate  in  which category  they  are  engaged.  “EU  citizen”  was the 
largest  participating  group  with  48%.  “Company/business  organization”  (25%)  was  the  second 
largest participating category, while “Business association” and “Public authority” jointly came 
as 
the  replies.  The  category  of 
largest  participating  category  with  5,86%  of 
“Academic/research Institution” followed closely with 5,08%. 

third 

Respondents  were  asked  to  indicate  in  which  sector(s)  they  are  engaged.  Choosing  multiple 
sectors was permitted. 

‘Individuals’ was the largest participating group with 19% of the respondents. ‘Drones Operator’ 
was  the  second  largest  group  with  17%,  closely  followed  by  ‘Drone  Pilot’  with  13,5%.  The 
following  categories:  ‘Aircraft  design,  manufacturing,  or  maintenance’,  ‘Non-Governmental 
Organisations’,  Research 
aviation’, 
organisation/university/consultancy’, 
Stakeholder/industry association’, and ‘Aviation professional (working in the aviation industry as 
a pilot, crew member, controller, etc.)’ – collected similar shares ranging between 6 and 5 % of 
respondents.  

‘Recreational 

Sectors 

Individuals 

Drone Operator 

Drone Pilot 

Aircraft design, manufacturing, or maintenance 

Non Gov Organisations/Research organisation/university /consultancy 

Recreational aviation 

Stakeholder/industry association 

Replies 

109 

99 

78 

37 

34 

33 

32 

Page 61 / 86 

 
 
Aviation professionals (pilot, crew member, controller, etc.) 

Aerial work 

Commercial Air Transport 

Training organisation for aviation professionals 

Local or Regional authorities 

U-space service providers 

Air navigation service providers 

Qualified entity, or other organisation officially recognized by the NAA 

Aerodrome operators 

Business Aviation  

Common Information Service providers 

National regulators 

Telecom operator 

31 

23 

18 

16 

15 

11 

9 

9 

8 

7 

7 

5 

2 

The  questionnaire  had  60  questions  of  which  53  were  compulsory  and  7  were  optional. 
Generally,  the  structure  was  a  series  of  closed  questions  followed  by  optional  open-ended 
questions to specify the answers provided in the closed questions. 

The questionnaire was divided into three subtopics: 

(1)  Conditions  to  allow  new  forms  of  smart  and  sustainable  mobility  and  aerial  services, 

including their social acceptance. 

(2)  Assessment of the current drone regulatory framework. This subtopic was divided between 
the assessment for the ‘open’ category, for ‘specific’ category and finally for both the ‘open’ 
and ‘specific’ categories. 

(3)  Additional issues to be addressed in the Strategy. 

Each subtopic was presented to the respondents with a preceding section explaining the present 
situation  and  introducing  the  rationale  behind  the  questions.  At  the  end  of  each  subtopic,  the 
respondents were given the opportunity to provide further feedback through a free-form text box 
if the so wished.  

The  comments  collected  in  this  consultation  have  been  summarised  and  structured  in  order  of 
appearance in the questionnaire. Opinions outlined in the present report do not necessarily reflect 
the view of the Commission. 

A.3.1  Presentation of responses 

A.3.1.1  Conditions  to  allow  new  forms  of  smart  and  sustainable  mobility  and  aerial 

services, including their social acceptance 

There was a consensus that safety (98%) and privacy (89%) should be priority. 

However, a majority (59%) of respondents believed that the general public did not have sufficient 
access to safety and security information related to the use of drones. 

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In addition, there was widespread support (79%) that the general public should be more informed 
on  the  environmental  aspects  related  to  the  use  of  drones  (noise  pollution,  visual  disturbances, 
etc.). 

A majority of the responders (65%) disagreed that drone operations should initially involve only 
non-commercial operations (e.g. air ambulances, disaster relief, firefighting, crowd control, etc.). 

A  majority  of  the  respondents  (54%)  disagreed  that  companies  were  sufficiently  informed  of 
efficiency gains provided by drone services. 

A  majority  of  the  respondents  (71%)  agreed  that  urban  air  mobility  could  provide  good 
alternatives  to  ground  transportation for  goods,  persons  and  should  always  be  integrated  in the 
overall mobility offer proposed to the public. 

A large majority of the respondents (83%) stressed that pilot projects should be run in parallel in 
different cities across the EU to enhance public trust. 

There was widespread support (67%) that disturbance by noise perception, perceived vibrations 
and visual disturbances would negatively impact social acceptance. 

There  was a  general  opinion  (88%)  that  drone  companies  should  closely  work  with  regulators, 
local governments and communities to ensure community engagement. 

A  large  majority  of  the  participants  (78%)  agreed  that  regulatory  measures  should  ensure  that 
noise related issues are addressed (corridors for drone, hours limits, size of drones, etc.). 

A large majority of the participants (84%) also stressed that regulatory measures should ensure 
that drones are compatible with EU privacy law. 

A  majority of the participants  (58%) disagreed on the statement that every city could currently 
easily accommodate vertical take-off and landing operations. 

A  majority  of  the  respondents (74%) supported  the  idea  that  urban  design  development  should 
start taking into account drone operations in order to facilitate their operations. 

There was widespread support (74%) that there was a need to develop new types of intermodal 
infrastructures, including vertiports, to support Urban Air Mobility operations. 

Respondents  highly  agreed  (87%)  with  the  statement  that  cooperation  mechanisms  between 
various level of authorities should be established for authorisation of operation of drones in urban 
area. 

A  large  majority  of  the  participants  (84%)  considered  that  U-space  airspace  services  (e.g. 
network  identification  service,  a  geo-awareness  service,  an  Unmanned  Aircraft  System  (UAS) 
flight authorisation service and a traffic information service) should allow the safe integration of 
manned and unmanned aircraft operations. 

A  majority  of  the  participants  (72%)  supported  the  statement  that  U-space  airspace  services 
should be available in every urban area. 

There  was  a  general  (89%)  agreement  that  drone  services  would  have  an impact  on skills,  and 
new training offers adapted to the smart mobility and drone services should be made available. 

90  respondents  provided  additional  input  in  the  open-ended  question.  Many  respondents  (10) 
pointed  to  the need  to  create an adequate testing  environment  and flight  approval  mechanisms. 
On U-space, some respondents expressed the views that measures were needed to ensure safety 
and  solve  externalities  while  other  expressed  the  concern  that  such  measures  would  be  overly 
restrictive. A few respondents also raised the question of the costs of the integration of drones in 
the airspace and the interaction with existing airspace users.  

Page 63 / 86 

 
 
A.3.1.2  Assessment of the current regulatory framework 

A.3.1.2.1  The  Drone  Regulations  (R945/R947)  from  the  perspective  of  operations  in 

‘Open’ category 

A majority of the participants (65%) considered that the new drone Regulations had contributed 
to clarify the conditions of operations for small drones of less than 25 kg. 

A majority of the responders (60%) agreed that that the national registration system was easy to 
use. 

46%  of  the  participants  disagreed  or  strongly  disagreed  that  the  provision  of  drone  safety 
information by the competent authorities and guidance was sufficient while 42% of participants 
agree or strongly agreed on this. 

A majority of the respondents (61%) shared a view that transition measures allowing the use of 
non C-class label drones were useful. 

Most  respondents  (62%)  agreed  that  drones  meeting  the  requirements  of  the  Open  Category 
would be available. 

A small majority of the participants (51%) considered that definition of drone geographical zones 
was appropriate 

A  majority  of  the  respondents  (65%)  shared  the  view  that  the  EU  drone  legislation  provided 
adequate protection to citizens from risks and concerns related to safety and security. 

A majority of the participants (60%) considered that the EU drone legislation provide adequate 
protection to citizens from risks and concerns related to privacy. 

Most of the participants (55%) considered the EU drone legislation provide adequate protection 
to citizens from risks and concerns related to noise. 

Most  of  the  respondents  (55%)  agreed  that  Provisions  regarding  remote  pilot  competency  for 
recreational operations were easy to apply 

70 respondents provided additional input in the open-ended question. A majority of respondents 
pointed to a lack of Guidance Material and harmonized implementation of the Regulations across 
Member  States.  In  addition,  respondents  indicated  that  geographical  zones  were  not  ready  in 
many  Member  States.  Respondents  pointed to the  issues  with standardisation  and  CE  marking. 
Respondents indicated the lack of knowledge of the Regulation among drone users, resulting in 
the  need  to  reinforce  pilot  competency,  through  communication  and  improved  training.  In 
addition, guidelines on safety should be accompanied with physical protection mechanisms.  

A.3.1.2.2  The  Drone  Regulations  (R945/R947)  from  the  perspective  of  operations  in 

‘specific’ category 

46% of the respondents agreed that the new drone regulations were fit for conducing professional 
activities while 34% disagreed with this. 

42% of the participants considered that all types of drone services could be fitted under the drone 
regulations while 36% disagreed with this. 

A majority of the participants (60%) considered that the procedure for receiving an authorisation 
for a drone operation was not easy. 

36%  of  the  respondents  disagreed  that  drone  operators  from  one  Member  State  could  easily 
operate in another Member State while 34% agreed with this statement. 30% had no opinion. 

40%  of  the  responders  disagreed  that  the  availability  of  drones/equipment  meeting  the 
requirements of the ‘Specific Category’ was adequate while 33% agreed with this statement. 26% 
had no opinion. 

Page 64 / 86 

 
 
44%  of  the  responders  considered  that  the  provisions  regarding  remote  pilot  competency  for 
professional operations were adequate. 33% disagreed while 23% had no opinion. 

A majority of respondents agreed that the drones rules provided adequate protection to citizens 
from risks and concerns related to safety 

There  was  a  general  agreement  that  drone  rules  provided  adequate  protection  to  citizens  from 
risks and concerns related to security. 

A majority of stakeholders also agreed that drones rules provided adequate protection to citizens 
from risks and concerns related to privacy. 

A  majority of respondents disagreed on the statement that the system of declarations under the 
light UAS Operator Certificate could be used easily. 

59 respondents provided additional input in the open-ended question. Respondents pointed to the 
lack  of  drone  equipment  meeting  the  requirements  of  the  ‘specific’  category,  notably  SAIL  III 
and  IV.  Respondents  expressed  concerns  regarding  the  implementation  of  the  Regulation  and 
varying interpretations among Member States. In addition, respondents pointed to the issue faced 
by  operators  to  obtain  authorization  for  flight-tests  outside  the  Member  State  of  registration. 
Finally,  respondents  notified  issues in obtaining  a light  UAS  operator  certificate  and  suggested 
that  the  Drone  Strategy  2.0  should  envisage  faster  authorisation  procedures  with  Standard 
Scenarios.  

A.3.1.2.3  Other  issues  in  relation  to  the  ‘Open’  and  ‘Specific’  categories  in  the  drones 

regulation 

66  respondents  provided  additional  input.  Some  respondents  indicated  that  the  Regulations 
should  to  be  reviewed  once  they  will  have  been  fully  implemented.  Other  participants  stressed 
that  UAS  operations  for  research  and  testing  ought  to  be  better  considered  in  the  Regulations. 
Respondents  recalled  the  need  to  focus  on  local  and  regional  authorities’  role  in  facilitating 
operations.  Respondents  also  recalled  the  need  to  accelerate  the  creation  of  industry  standards, 
facilitate the obtention of a Light UAS Operator Certificate. Respondents also pointed to security 
risks  stemming  from  airspace  segregation  and  the  necessity  of  creating  convergence  between 
Unmanned  Aircraft  System  Traffic  Management  (UTM),  U-space  and  classic  Air  Traffic 
Management (ATM).  

A.3.1.2.4  Additional issues to be addressed by the forthcoming Drone Strategy 2.0 

A majority of the responders (59%) supported the statement that the use of renewable and clean 
energy should be obligatory. 

A majority of respondents (54%) stated that the environmental impact of drone operations (noise, 
emissions, visual nuisances) was not adequately assessed nor addressed. 

There  was  a  strong  support  (85%)  on  that  the  drone  industry  should  be  subject  to  circular 
economy principles (reuse of batteries and recycling of equipment). 

A  majority  of  the  respondents  (61%)  agreed  that  drones  may  posed  issues  on  ethical  values  in 
certain cases (e.g. use of Artificial Intelligence). 

A  large  majority  of  the  participants  (82%)  agreed  that  rules  for  emergency/landing  spots 
requirements should be established. 

A  majority  of  the  respondents  (73%)  agreed  that  there  was  a  need  to  generate  synergies  and 
technology transfer between Small and Medium Enterprises. 

A  large  majority  of  the  participants  (90%)  agreed  that  use  of  new  Information  Technologies 
should be assessed in terms of cyber security. 

Page 65 / 86 

 
 
In  addition  to  the  closed  questions,  57  respondents  provided  additional  input.    There  was  a 
contrast  between  respondents  who  supported  the  inclusion  of  sustainability  requirements  and 
respondents who considered that introducing such requirements would generate burden of costs 
that  would  hinder  the  development  of  the  sector.  As  a  third  way,  respondents  suggested  to 
“encourage” rather than making such sustainable requirements mandatory. Respondents recalled 
the importance of developing harmonised standards, notably for emergency landing sites and for 
vertiports. Respondents noted the importance of addressing cybersecurity threats, AI technology 
and 5G interference. Respondents pointed to the need to identify UAS in a drone digital network 
to enable remote identification and the exchange of navigational data.  

A.4  Drone Leaders’ Group (DLG) 

In the wake of the preparation of a ‘A Drone Strategy 2.0 for a smart and sustainable unmanned 
aircraft eco-system in Europe’ and in addition to the regular channels of communication, such as 
the Drone Informal Experts Group, the Commission called on a group of  representatives from 26 
organisations  and  trade  associations  including  Drone  manufacturers,  U-space  Airspace  Service 
Providers,  drone  operators,  manned  aviation,  European  Parliament,  NAA’s,  UIC²,  EASA, 
SESAR JU, EUROCONTROL, EDA to give a high-level steer to the development of the Drone 
Strategy 2.0 and provide recommendations for its drafting.  

The  DLG  developed  a  High-Level  Vision  and  an  ambitious  pathway,  with  concrete  objectives 
articulated over 8 thematic areas in order make Europe a global leader in this area. It concluded 
its  activities  on  26  April  2022  delivering  a  report  containing  a  number  of  findings  and 
recommendations which is available here: 

Drone Leaders’ Group supports preparation of Drone Strategy 2.0 (europa.eu). 

A.5  Targeted surveys and Interviews 

The  targeted  survey  conducted  by  the  external  contractor  was  open  for  two  months,  with  the 
launching date on 29 October 2021 and the survey closing on 31 December 2021. A longlist of 
respondents  was  selected  and  invited  to  participate  in  the  survey.  In  addition,  the  survey  was 
distributed by some associations (for example: ACI Europe and CANSO) to their members. This 
resulted  in  a  total  of  198  registered  responses  of  which  103  respondents  completed  the  full 
survey.  

The survey provided a broad geographical coverage, with respondents from all over Europe. The 
following  countries  were  well  represented  (>  5  respondents):  Belgium,  Switzerland,  Italy, 
Lithuania,  and  Germany.  The  survey  also  obtained  several  responses  beyond  Europe,  from 
organisations located in the United Kingdom, United States and Turkey.  

The  responses  provided  a  good  coverage  of  the  stakeholder  groups.  Responses  came  from 
national authorities (41); manufacturing industry (40); drone operators (22); NGOs (18); airport 
operators (17); military (15); research and academia (13); air navigation service providers (12); 
aircraft  operators  (11);  U-space  providers  (9);  staff  associations  (7);  EU  institutions  (5);  law 
enforcement (4) and inter-governmental institutions and networks (2). 

A total of 25 targeted interviews were carried out by the external contractor, as presented in the 
Table below, reflecting the distribution over the stakeholder groups. The results of the interviews 
were used to complement the survey results, as input for the analysis. 

Stakeholder group 

Interviews 

National and regional authorities 

Italian Civil Aviation Authority 

Page 66 / 86 

 
 
Stakeholder group 

Interviews 

BMVI (Germany) 

Ministry of Infrastructure and Water 
Management (The Netherland) 

Portuguese Civil Aviation Authority  

Norwegian Civil Aviation Authority  

PSE S.A. (Polish Government) 

Military and Law enforcement 

Defence Forces Ireland 

Commercial and non-commercial aircraft 
operators 

Drones4sec 

European Air Sports 

Drone operators, service providers and users 

European Aerospace Cluster Partnership  

Platform Unmanned Cargo Aircraft 
(PUCA) 

Drone Alliance Europe 

Wing 

Alliance for New Mobility Europe 

Airport operators and Air Navigation Service 
Providers (ANSPs) 

U-space providers 

Manufacturing industry 

CANSO 

ACI Europe 

GUTMA 

Unifly 

Droniq 

DMAE 

Lilium 

Thales 

Non-Governmental Organisations (NGOs) 

Accirculate SPRL 

Research and academia 

Joint Research Centre (JRC) 

Drones Observatory at Politecnico di 
Milano 

A.6  Targeted consultations – presentation of responses 

A.6.1  European drone ecosystem, value chains and business models 

The drone industry and related services are developing rapidly across the entire drone ecosystem. 
These  developments  in  the  drone  ecosystem  might  open  new  prospects  for  using  drones  and 
thereby result in different value chains and business models. These developments are taking place 

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in  a  policy  environment  that  is  focused  on  drones  contributing  to  the  digitalisation  of  the  EU 
economy and providing a safe and sustainable mode of transport, for both persons and goods. 

A.6.1.1  Trends and developments 

A.3.1  presents  the  results  of  the  question  “what  trends  and  developments  are  accelerating  the 
evolution of the drone market in Europe?”86 These trends and developments are sorted on a high 
to low impact. Participants expected slightly to highly positive impact from all developments that 
the sector is facing. Respondents  expected the highest impact from technological developments 
(83% of the respondents, 123 out of 148) and the development of a regulatory framework (73%, 
108 out of 148) of the drone market in Europe.  

A.6.1.2  Opportunities in the European drone ecosystem 

The  drone  industry  stakeholders  were  asked  to  shed  their  light  on  the  growth  opportunities  of 
different use cases (see A.3.1).87 The growth opportunities per use case are sorted from high to no 
growth. The results revealed on the one hand that respondents expect the highest growth in the 
following  three  use  cases:  inspection  (83%,  119  out  of  143),  public  mission  (80%,  115  out  of 
143)  and  surveillance  (79%,  113  out  of  143).  On  the  other  hand,  the  majority  of  respondents 
(62%, 88 out of 142) expected either limited (51%, 72 out of 142) or no growth (11%, 16 out of 
142) in the field of person mobility.  

Participants  were  also  given  the  option  to  fill  in  the  category  ‘other’  and  provide  their  growth 
expectation.  Several  respondents  (n  =  5)  indicated  that  high  growth  is  also  expected  in  the 
entertainment industry (e.g. filming, photography, etc) and environmental monitoring (n = 3).  

A.6.1.3  Barriers in the European drone ecosystem  

The  stakeholder  consultation  process  indicated  several  barriers  that  the  European  drone 
ecosystem  is  facing  nowadays.  The  targeted  survey  has  identified  the  comparative  strengths  of 
the  EU drone industry  and  scored the  factors  listed below  on  EU  competitive  (dis)advantage.88 
Highest in this respect was the presence of an enabling regulatory framework (47%) and lowest 
was  the  effective  civil-military  collaboration  (18%).  A  large  number  of  respondents  perceived 
these factors as neither an advantage nor disadvantage, ranging from respectively 22% (24 out of 
108)89  to  45%  (50  out  of  108)90.  When  asked  whether  existing  or  foreseen  value  chains  create 
dependencies  to  third  States91,  a  substantial  number  of  respondents  (44%,  39  out  of  88)  were 
neutral  on  dependencies  to  third  States.  Stakeholders  explained  that  business  development  is 
rather irrespective of geography, but directly linked to the service and product capabilities. Also, 

86   DS  2.0  Targeted  Survey  (2022),  Questions  8:  In  your  view,  what  trends  and  developments  are 

accelerating the evolution of the drone market in Europe? 

87   DS  2.0  Targeted  Survey  (2022),  Questions  9:  “In  your  view,  what  is  the  growth  potential  for  drone 

applications in the sectors and fields that are listed below?” 

88   DS 2.0 Targeted Survey (2022), Questions 17: “What are the comparative strengths of EU industry in 

drones compared to global competition?” 

89   Related to an enabling regulatory framework. 

90   Related to technology readiness. 

91   DS  2.0  Targeted  Survey.  Question  25:  “Are  the  existing  or  foreseen  value  chains  creating 

dependencies to third states?” 

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the  economic  system  has  (to  a  large  extent)  outsourced  the  production  of  parts  and  materials 
outside Europe. The supply chain of drones is thereby similar to other technology sectors.  

A.6.2  Regulatory framework 

A.6.2.1  General setting 

Stakeholders generally agreed that further development and implementation of the EU regulatory 
framework is needed to contribute to delivering the objectives of the DS 2.0. The strategy should 
be  focused  on  equalising  and  minimising  drone  related  rules  and  legislation  across  the  EU, 
without leaving too much space for Member States to divert from the EU principles92. 

A.6.2.2  Implementation  of  Regulation  1139/2018,  Regulation  945/2019,  and  Regulation 

947/2019  

According to a wide majority (71%, 141 out of 198) of the respondents of the targeted survey, the 
Regulations facilitated the development of the drone industry and market. However, there are still 
issues  to  be  complied  with  and  requirements  are  considered  complex;  some  remarks  made  by 
respondents were reported as such: 

 

It takes a lot of time for national authorities to implement the regulations; the framework is 
incomplete until Acceptable Means of Compliance (AMC) and Guidance Material (GM) are 
available.  

  Airworthiness assessment need to be pushed down to Member State level again93. 
  Enhancement  of  capacities  of  national  authorization  bodies  and  strengthening  of  the 

governance framework are needed 94  

It is widely agreed among respondents of the survey that the new basic aviation safety regulatory 
framework and the detailed rules for unmanned aircraft design and operation guarantee the safe 
operation of drones (65% ,128 out of 198). Only 8% (15 out of 198) of stakeholders consulted 
disagree.  Drone  operators  active  in  the  Open  Category  consulted  through  the  OPC,  widely 
recognised positive impacts of the Regulations on the drone industry and market being: having 
clarified the conditions of operations for small drones of less than 25 kg (66%, 170 out of 258, 
agree); providing useful transition measures allowing the use of non-C-class label drones (61%, 
157  out  of  258,  agree);  defining  appropriate  drone  geographical  zones  (52%,  134  out  of  258, 
agree); providing adequate protection to citizens from risks and concerns related to safety (66%, 
170  out  of  258,  agree),  security  (65%,  167  out  of  258,  agree),  privacy  (60%  ,  154  out  of  258, 
agree), noise (55%, 142 out of 258, agree). 

A.6.2.3  Regulations on U-space (664/2021, 665/2021, 666/2021)  

Around  two  thirds  of  stakeholders  (63%,  124  out  of  198)  consulted  with  the  targeted  survey 
considered that Regulations on U-space will facilitate the development of the drone industry and 
market.  Existing  obstacles  in  the  implementation  of  the  new  framework  were  underlined  as 
follows:  the  Regulations  have  not  provided  sufficient  clarity  on  the  future  evolution  of  the 

92   As indicated by a Manufacturer and two Drone Service Providers. 

93   Drone Service provider. 

94   Drone Association and Drone Service Operator. 

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Unmanned  Aircraft  System  Traffic  Management  (UTM)  service  provision  framework  with 
specific reference to U-space in controlled airspace, since safety risk is being managed through 
the segregation of manned and unmanned operations with different respective airspace managers. 
There is no clear legal basis for designation of a single provider of common information services 
on which safe operations – manned and unmanned – can be based95 . Air Traffic Control should 
be  given  the  mandate  to  provide  separation  for  drone  flights;  the  U-space  Regulations  in  their 
current versions are not designed to enable scalable traffic. The focus on strategic pre-planning, 
which ensures that only one drone operation at a time can take place, is not a viable solution for 
drone  operations  in  greater  numbers  96￼.  According  to  a  National  Authority  interviewed  and 
‘Other’ stakeholders, the intervention of EASA is necessary, at a framework level, while leaving 
some flexibility and room for manoeuvre to Member States. For instance, common criteria, at the 
level of AMCs should be defined by EASA, to implement Art. 15 of Regulation 2019/947 and 
request  the  setting  of  geo-zones  in  a  harmonised  way,  but  then  the  specific  decisions  on  geo-
zones should be left to Member States. 

A.6.2.4  Technological challenges 

Drone  Service  providers  consulted  (interviews,  written  contributions)  generally  consider  the 
European regulations too strict and complicated to enable easy implementation of experimental 
activities. The application processes and the technical requirements are too high in certain areas, 
procedures  are  too  lengthy  and  cost  burdensome.  The  lagging  of  the  development  in  the 
regulation of use cases that are more interesting from the business case point of view is remarked. 
More specifically, further development of the rules framework to enable permanent, commercial 
drone delivery operations at scale as well as addressing all aspects of advanced air mobility, is 
needed.  Regulations  should  be  used  to  create  a  climate  for  innovation.  National  differences  in 
(interpretation  of)  rules  and  legislation  withhold  cross-border  business97.  It  was  also  remarked 
that  EASA  should  become  responsible  for  certification  and  operation.  A  clear  and  complete 
framework of norms (prescriptions) and derived procedures are deemed necessary to be adopted 
to  regulate  emergency/landing  spots  requirements,  so  as  to  minimize  risks  for  people  and 
infrastructures on the ground in case of accidents. A military aviation authority consulted through 
the targeted survey, pointed out that AMC and GM for Type 1 ops / 'SORA for certified category 
are still missing. 

A.6.2.5  Military/Civil coordination and cooperation on drones 

Stakeholders  consulted  through  the  targeted  survey  were  generally  unaware  (61%,  120  out  of 
198) and did not know 15%, 29 out of 198 disagreed) whether Member States and third countries 
with a considerable drone industry have a regulatory framework enabling civil-defence synergies. 
Stakeholders  interviewed  stressed  out  that  drone  regulations  (2019/945  and  2019/947)  are  not 
contributing  to  the  alignment  and  use  of  synergies  between  civil  and  defence  industry;  UTM 
services  and  design  of  airspace  are  not  conceived  to  fit  both  military  and  civil  applications98. 
Some  of  the  stakeholders  interviewed99  mentioned  that  the  military  interests  on  drone  are 
expected to remain very high in the future and military investments will most likely continue to 

95   A Service Provider. 

96   Drone Association. 

97   Airport operator, Drone Service Provider, Research Institute. 

98   A representative from the manufacturing sector. 

99   NGOs and other Strategic Business consultants. 

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grow.  They  stated  that  the  military  have  also  expressed  a  keen  interest  on  Environmental 
Sustainability  and  Circular  Economy  and  this  could  represent  an  opportunity  for  including  the 
drone  sector  (EDA  is  very  active  in  this).  With  regard  to  the  use  of  drones  for  EU  border 
surveillance  needs,  Regulation  (EU)  2019/1896  enhances  the  mandate  of  the  European  Border 
and  Coast  Guard  Agency  (‘Frontex’)  with  respect  to  external  border  control.  The  EU  should 
explore the possibility of bringing flights carried out in the public interest by EU agencies (such 
as Frontex) within the scope of Regulation (EU) 2018/1139. 

A.6.2.6  Other regulatory challenges 

Enquired as to whether the existing regulatory framework restricts the drone industry and market, 
37% (73 out of 198) of the respondents to the survey, indicated this as an obstacle which hinders 
lawful  drone  use,  29%  (57  out  of  198)  mentioned  unclear  allocation  of  liability  and  insurance 
rules, insufficient level of protection on privacy and data (15%, 29 out of 198), insufficient level 
of protection of the environment (12%, 23 out of 198), and not being able to maintain a high level 
of safety and security (12% 23 out of 198). OPC respondents confirmed that further actions are 
needed  at  the  regulatory  level  in  the  following  areas:  to  improve  the  cooperation  of  drone 
companies  with  regulators,  local  governments  and  communities  to  ensure  community 
engagement (88%, 227 out of 258); address noise related issues (corridors for drone, hours limits, 
size of drones, etc.(78%, 201 out of 258); ensure compatibility with EU privacy law (84%, 216 
out of 258); allow urban design development to take into account drone operations (74% 190 out 
of 258); establish cooperation mechanisms between various level of authorities for authorisation 
of operation of drones in urban area (87%, 224 out of 258), . 

OPC respondents recommended the following regulatory actions:  

  Ensure a regulatory framework which fosters innovation, enable confidence in business and 

public-support decisions, and ensures safety and security. 

  Consider  the  Circular  Economy,  in  particular  on  Critical  Raw  Materials  (CRMs)  and  Rare 
Earth Elements REEs (REEs) and Waste (e.g. End-Of-Life Vehicle, Waste Electronics). 

  Work on GDPR regulations and anti-drone systems. 
  Provide regulatory and funding certainty to the emerging mobility industry. 
  Reach  a  first  step  of  regulation  to  enable  first  levels  of  business  services;  regulate  share 

airspace use. 

Stakeholders100  stated  that  rules  in  place  on  environment  protection  do  not  seem  to  cope  with 
environmental concerns linked to the use of drones. An interview with a stakeholder revealed that 
the expected major direct and long-term environmental impacts of the drone industry are not yet 
sufficiently  and  properly  addressed  by  the  European  legislation  and  the  industry  standards.  In 
particular  concerning  the  need  of  alignment  of  the  drone  sector  to  the  Circular  economy 
principles.  

In relation to obstacles identified in the EU wider regulatory framework having an impact on the 
deployment of drones, market operators interviewed and consulted through the survey expressed 
concerns  about  the  existing  privacy  frameworks  (GDPR),  which  does  not  consider  drones  and 
non-consented  data  collection101;  the  Product  Liability  Directive  which  is  considered  a 

100   Interviews  with  Service  providers  and  other  stakeholders  (business  and  strategic  consultants),  and 

respondents to the Survey and OPC, 

101   A drone service operator. 

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cumbersome instrument that does little in relation to new technologies and increasing relevance 
of software102.  

Respondents  stated  that  the  Regulations  should  permit  the  use  application  of  drones  to  the 
phytopharmaceuticals  sector,  which  would,  in  their  opinion,  be  a  major  step  forward  for  smart 
farming, thus towards compliance with the European Green Deal103.  

A.6.3  Technology building blocks 

A.6.3.1  Technological development and components 

The targeted survey shows that supporting technological development is ranked third  (65%, 79 
out of 122) in terms of priority action areas for the development of the DS 2.0. Over half (54%, 
36  out  of  67)  of the survey  respondent  considered  that technological  requirements are  required 
today to improve drone operators. The top 5 technological drone components mentioned by the 
survey respondents were: detect and avoid (80%, 49 out of 81); flight control systems (70%, 43 
out of 61); command and control link (67%, 41 out of 61); embedded AI platforms (62%, 38 out 
of 61); and GNSS (59%, 36 out of 61).  

A.6.3.2  Barriers towards technological development 

Barriers to technological development were identified as a mix of technological aspects (maturity 
level  too  low,  reliability),  production  aspects  and  legal  aspects  related  to  the  use  of  the 
technologies, operational problems and new needs. Some barriers mentioned were as follows:  

  Difficulties to develop, implement and deploy technologies that need regulations to be used; 
BVLOS and counter drones are two technologies that are often mentioned by stakeholders104.  
  Technical  requirements  are  not  harmonized  between  countries,  both  in  civil  and  military 

domains. This is seen as a competitive disadvantage for European companies. 

  Having  different  standards,  including  in  the  civil  and  military  markets,  results  in  market 

limitations. 

  Technical requirements are too complex, there is a need to simplify requirements105.  
  Having different standards in the civil and military market results in market limitations. 
  Raw material shortage, electronic parts mostly, is considered by stakeholders as a barrier106. 

A.6.3.3  Civil-military collaboration 

28 % (16 out of 58) of the respondents to the targeted survey both agreed and disagreed (equal 
score)107  that  there  are  barriers  to  the  development  of  dual-use  drone  technology.  Respondents 
often  mention  the  lack  of  common  standards  between  the  civil  and  military  world  as  a  current 
barrier.  Besides  barriers,  recommendations  were  made  by  survey  respondents.  In  general, 

102   Other (Business Strategic consultants, Research Academy. 

103   Other: Farmers Association. 

104   See OPC, DS 2.0 Targeted Survey (2022), 

105   Ministry of Transport from European Member State. 

106   OPC. 

107   The balance (44%, 26 out of 58 did not know).  

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stakeholders stated that drone technology has often been pioneered in military settings; providing 
valuable  input  for  civil-military  collaboration.  The  vast  majority  (68%,  40  out  of  59)  of 
respondents  consider  that  military  technology  development  would  benefit  civil  technological 
development.  The  following  military  to  civil  technology  transfers  were  mentioned:  counter-
drones, communications, sensors, DAA, swarming and UTM. On the other hand, 62% (36 out of 
59) of the respondents mentioned that the military sector could benefit from civil technological 
developments.  

Multiple stakeholders in the targeted survey mentioned that although the background and culture 
(between the civil and military sectors) may be different, civil-military collaboration could bring 
benefits to both sides. The following recommendations  were made by stakeholders: (i) mandate 
an organisation to take the lead in the standardisation process of technical requirements, with the 
objective  to  bring  interoperability;  (ii)  exchanges  of  hardware  parts  from  military  systems  and 
dual use civil-military hardware could reduce the costs on both sides by increasing the production 
capabilities; and (iii) grant innovation military budgets only if the targeted technologies are for 
dual use. 

A.6.3.4  Future considerations for technological developments 

  Stakeholders indicated a range of considerations for future technological developments108109: 
  Many  comments  from  the  survey  respondents  focused  on  the  need  to  developing 
technologies  and  the  associated  regulatory  framework  in  parallel,  as  these  aspects  are 
interrelated 

  Stakeholders  indicated  that  the  development  of  the  EU  drone  industry  and  market  is 
dependent  on  external  components  and  know-how.  As  such,  the  EU  is  lacking  strategic 
autonomy  (45%  agreed  or  strongly  agreed,  44  out  of  98,  while  21%  disagreed  or  strongly 
disagreed, 21 out of 98). 

  The current lack of standards needs to be addressed in order to support economic activities 

 

and promote interoperability. 
In  order  to  further  develop  drones  as  means  of  passenger  transport,  the  following 
technological  developments  should  be  pursued:  propulsion,  situation  awareness  systems, 
advanced detection and collision avoidance with existing flying objects. 

  Stakeholders indicated the need to focus on innovative projects where on-board fused data is 
developed.  This  will  help  several  fields,  such  as  surveillance  (detection,  cross-cueing)  and 
reduce datalink weakness (mix between GNSS, cellular, radar). 

  BVLOS is an important aspect that needs to be further developed to facilitate use cases, such 
as inspections,  surveillance  and transport  of  goods. These use  cases  are  currently  restricted 
because of risks related to low altitude and high-speed flights. 

A.6.4  System resilience and non-cooperative drones  

Drones are a new, fast-growing, and affordable technology, which pose various risks and are of 
major public concern due to potential unsafe operation, damage to people and property.110 Almost 

108   Many considerations  were  mentioned in  the  targeted  survey,  with a dedicated section on technology 

building blocks.  

109   This constitutes a selection of future considerations mentioned by stakeholders in the targeted survey. 

110   OPC. 

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all  stakeholders111  were  aware  of  the  risks  and  threats  that  non-cooperative  drones  pose. 
Unauthorized drone flights remain a problem, especially around commercial airports, and critical 
infrastructures.  They  endanger  passengers  and  aircraft  crews  and  can  lead  to  short-term 
disruptions of air traffic, closures of entire airspaces or airports, and even to the total loss of an 
aircraft.  Unauthorized  drone  flights  in  the  approach  and  departure  areas  of  an  airport  pose  the 
greatest potential hazards and risks.  There are cyber and physical security issues that are being 
addressed effectively enough in traditional aviation but pose many challenges for drones. Drones 
can  easily  bypass  existing  security  measures  applicable  to  aviation  security.  Protecting  drones 
from  cybersecurity  risks  is  another  important  challenge  since  they  can  be  targets  for  a  cyber-
attack themselves just as they risk being used as potential attack vector.112 

A.6.5  Main threats of drones 

The  main  threats  and/or  risks  posed  by  non-cooperative  drones  were  perceived  to  be  those  of 
‘illegal and criminal intent’ with 72% (71 out of 89 responses) of respondents indicating the risks 
arising  from  these uses. The  risks from  reckless  use and terrorist attacks  were  lower  with  63% 
(62 out of 89) and 62% (61 out of 89) respectively. On the other hand, 56% (55 out of 89) of the 
respondents  suggested  that  amateur  use  was  also  a  risk  posed  by  non-cooperative  drones. 
However,  there  was  no  clear  distinction  amongst  the  respondents  between  reckless  use  and 
amateur use.  

A.6.6  Types of risks  

As  regards  types  of  risks  and  levels  of  threats,  it  was  suggested  that  these  are  the  'inability  of 
operators to decode, comprehend and comply to the overly complex EASA regulations; system 
failures,  untrained  pilots  or  even  an  unsafe  condition  for  flights;  espionage,  state  sponsored  as 
well as Inability to comply to overly complex EASA regulations.113 The main consequence of the 
threats around airports and other critical infrastructures is the disruption of activities/air traffic, 
with 92% (90 out of 98) of respondents  indicating such consequence, while the second highest 
consequence 54% (53 out of 98) was interference.114 

As regards the threat trends and patterns, the survey respondents 46% (37 out of 81) stated that 
the threat levels have increased over the past three years with 32% (26 out of 81) suggesting that 
the threat level stayed the same and 15% (12 out of 81) stating that the threat has significantly 
increased. Only 7% (6 out of 81) mentioned that the threat level has decreased. The trends in the 
increase  of  the  threat  level  were  mainly  due  to  drones  being  much  for  accessible  amongst  the 
population  hence  more  incidents  of  reckless  and  amateur  use  are  administered  as  well  as 
professionals  not  abiding  by  the  rules  set.  Stakeholders  also  mentioned  that  the  ‘number  of 
incidents with drones interfering in air traffic at airports rose tremendously’ and an increase of 
near misses between helicopters and drones are seen.115116117 

111   OPC, Interviews and DS 2.0 Targeted Survey (2022), 

112   Views from OPC, interviews and DS 2.0 Targeted Survey (2022), 

113   DS 2.0 Targeted Survey (2022), 

114   DS 2.0 Targeted Survey (2022), 

115   European Aerospace Cluster Partnership (EACP). 

116   Research Institutes. 

117   DS 2.0 Targeted Survey (2022). 

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A.6.6.1  Barriers 

Almost  half  of  the  respondents  48%  (26  out  of  54)  suggested  that  there  are  either  technical  or 
legal,  or technical  and  legal  barriers  to  using  certain  types  of  technological  solutions  to  detect, 
track,  identify,  neutralise,  and  mitigate  threats  from  non-cooperative  drones.  These  are  mostly 
said  to  be  regulations  that  prevent  the  use  of  technologies.118  Stakeholders  stated  that  current 
regulations  that  allow  very  light  and  small  drones,  make  it  harder  to  provide  them  with  more 
reliable  technical  systems  (such  as  the  lack  of  efficient  and  mature  detect  and  avoid  systems). 
Furthermore, technical regulations, requirements and means of compliance are not fully existing 
in the detect and avoid solutions areas, especially for AI based systems. It was also envisaged that 
it  is  quite  challenging  to  control  air  space  where  large  aircraft  are  operating.  Therefore,  all 
activities in this domain should be well coordinated.  

A.6.6.2  Impacts  

The  consultation  results  showed  that  there  are  indeed  potential  impacts  of  the  limitations  in 
mitigating the threat and risks of non-cooperative drones. For example, the limitation might result 
in  a  ‘slower  adoption  of  drone  services’119,  as  well  as  drone  jamming,  spoofing  and  guns.120 
Furthermore, there were concerns that due to the strict regulatory framework, new drone-related 
protective technology onboard of helicopters can’t yet be installed.121  

A.6.6.3  Capacity of current EU regulation 

that  regulations  need 

Only 18% of the respondents (9 out of 51) mentioned that the current policies and regulations are 
either sufficient or very sufficient to mitigate the threat from non-cooperative drones, with 22% 
(11 out of 51) suggesting that the current policies/regulations are insufficient and 12% (6 out of 
51) saying they are extremely insufficient. The respondents mentioned the need for neutralisation 
of  non-cooperative  drones  as  the  detection  is  not  sufficient  to  secure  facilities.122  Furthermore, 
stakeholders  said 
to  mature  on  various  aspects  (for  example, 
communication, environmental, security etc.)123 Accordingly, 52% of the respondents (37 out of 
71) mentioned that an EU regulatory intervention is needed to help mitigate the threats posed by 
non-cooperative  drones  around  critical  infrastructure,  while  only  10%  (7  out  of  71)  stated  that 
such  an  intervention  is  not  needed.124  As  regards  soft  measures  used,  almost  all  stakeholders 
stressed  the  importance  of  the  implementation  of  soft  measures  such  as  awareness  campaigns 
71%  (12  out of  17 respondents),  better  coordination and information  sharing  platforms  53% (9 
out  of  17),  the  use  of  various  apps  41%  (7  out  of  17),  and  other  measures  such  as  patrolling, 
equipment for signal blocking.  

A.6.6.4  Opportunities and good practices 

118   DS 2.0 Targeted Survey (2022) and Interviews. 

119   Aerospace, defence and security company. 

120   Views from airports. 

121   An air rescue representative  

122   An Industry representative. 

123   ADR; Air navigation services; CAA; Aviation Security Department  

124   DS 2.0 Targeted Survey (2022). 

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The consultation phase revealed that over half of the respondents 56% (10 out of 18 respondents) 
were  not  able  to  identify  some  good  practices  that  are  used  at  the  EU  level  which  can  help 
mitigate the threat posed by non-cooperative. Only 17% (3 out of 18) mentioned that there were 
some good practices used in some Member States.125 As regards specific training offered for law 
enforcement  or  relevant  authorities  in  drone  detection/tracking/identification  and  neutralisation 
17%  (9  out  of  54)  of  the  respondents  mentioned  that  their  Member  State  offers  such  training, 
which is in line with the rapid technological development of the drones market, while half of the 
respondents 50 % ( 27 out of 54) said there was not such a training.  

A.6.7  Developing airspace capabilities: U-space development and integration with 

ATM 

A.6.7.1  Importance, opportunities and challenges 

Around two thirds (68%, 102 out of 150) of the respondents in the targeted survey identified air 
traffic management (ATM) systems, supporting drones as potentially having a high impact (the 
most  severe  category)  on  the  evolution  of  the  drone  market  in  Europe.126  U-space  is  viewed 
generally  as  a  critical  enabler  for  realisation  of  drone  market  projections  in  Europe  by  all 
stakeholder groups.127 

A.6.7.2  Governance arrangements 

Stakeholders contended that the regulatory framework as well as the upcoming DS 2.0 should put 
a stronger emphasis on the multi-level governance dimension of drone and U-space regulation. In 
general  industry  and  national  government  stakeholders  are  content  with  the  Commission  (as  a 
multinational political body) steering EASA to deliver technically sound proposals.128 One of the 
points raised here is that the Commission plays an important role in making sure that even during 
implementation of critical systems, drone policy remains integrated with all relevant EU policies, 
in  particular  associated  with  the  digitalisation/  automation  and  decarbonisation  agendas.129 
Metropolitan governments and local authorities indicated that they should be involved directly in 
setting up U-space systems, geographical drone zones and operational requirements.130 Industry 
stakeholders  seem  particularly  focused  on  the  role  of  the  EU  regulatory  framework  avoiding 
fragmentation  in  implementation.131  Stakeholders  also  talk  about  the  important  role  of  the 

125   For  example,  the  EASA  repository  data  base  as  well  as  annual  training  sessions  with  the  law 

enforcement authorities (police, gendarmeries) are being provided by some Member States. 

126   DS 2.0 Targeted Survey (2022) and Interviews. 

127   October 2021 Drone Leaders Group meeting; November 2021 Drone Expert Group meeting;  DS 2.0 

Targeted Survey (2022); interviews with a global UTM representative body. 

128   National and regional authority respondent to the DS 2.0 Targeted Survey (2022) 

129   An  NGO,  national  and  regional  authority,  manufacturing  industry  and  multiple  drone  operators, 
service  providers  and  users  respondents  to  the  to  the  DS  2.0  Targeted  Survey  (2022);  supported  by 
participants at the October 2021 Drone Leaders Group meeting 

130   Position papers and interviews with a global UTM representative body 

131   In written responses and during the meeting of the October 2021 Drone Leaders Group 

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Commission in encouraging and facilitating cooperation during implementation between Member 
States.132 

The role of competition in U-space is a key discussion.133 At least one U-space provider and one 
national regulator questioned the potential for service provider competition in the short term (i.e. 
close to 2023) given the current high barriers to entry.134 There is a desire (particularly from the 
private sector actors) for simple and efficient rules.135 They recognise competition as a key driver 
of:  technological  innovation;  the  effective  introduction  of  technologies  from  outside  of  the 
traditional aviation sector; and price setting.136 

A.6.7.3  Funding and financing 

Following  on  from  governance  and  regulatory  discussions  are  views  on  future  funding  and 
financing.  Stakeholders  (especially  those  directly  involved  in  U-space  implementation  efforts) 
stated  that  more  central  sources  of  funding  are  needed  to  facilitate  roll  out  of  U-space  in  the 
timeframes  identified  by  regulator.137  Moreover,  they  indicated  the  need  for  funding  and 
financing  streams  to  target  technological  development  and  innovation  practices  outside  the 
traditional  aviation  sector.138  There  is  a  group  of  policymakers  at  the  national  level  and 
researchers  who  are  particularly  interested  in  defining  payment  U-space  service  payment 
systems, optimal prices/fees, revenue models and the costs to regulators.139 These discussions are 
generally  immature  and  focus  on  the  relationship  between  service  price,  market  development 
(towards potential) and levels of innovation in drone services. 

A.6.7.4  Identified benefits 

The  opportunity  at  the  centre  of  ongoing  U-space  conversations  is  the  shift  from  air  traffic 
control centric approaches to operations centric (automated) approaches, although the details of 
integration  with  existing  ATM  remains  a  key  issue.140  Most  groups  of  stakeholders  see  the 
openness of the system as fundamentally important and very different to the natural monopolies 

132   In  written  responses  from  U-space  service  providers  and  during  the  meeting  of  the  October  2021 

Drone Leaders Group 

133   October 2021 Drone Leaders Group meeting; November 2021 Drone Expert Group meeting;  DS 2.0 
Targeted  Survey  (2022)  and  Interviews;  interviews  with  a  global  UTM  representative  body  and  U-
space service providers involved in implementation activity. 

134   November 2021 Drone Expert Group meeting and interviews with U-space service providers 

135   Interviews with U-space service providers, infrastructure  managers and  a global UTM representative 

body 

136   October 2021 Drone Leaders Group meeting; November 2021 Drone Expert Group meeting; DS 2.0 
Targeted  Survey  (2022);  interviews  with  U-space  service  providers,  infrastructure  managers  and  a 
global UTM representative body 

137   DS  2.0  Targeted  Survey  (2022);  interviews  with  U-space  service  providers  involved  in  early 

implementation activities around cities and ports in particular 

138   Interviews  with  a  global  UTM  representative  body  and  with  U-space  service  providers  involved  in 

early implementation activities around cities and ports in particular 

139   See for example: independent policy research discussed in the European Parliament in 2021 

140   October 2021 Drone Leaders Group meeting; November 2021 Drone Expert Group meeting;  DS 2.0 
Targeted Survey (2022); interviews with a global UTM representative body and with U-space service 
providers 

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that  have dominated  ATM.141  Traditional  aviation  sector  stakeholders  (e.g.  ANSPs)  tend to see 
the implementation of U-space differently to new service providers (in particular software based) 
entering the market. There is an ongoing discussion amongst stakeholders about whether UTM 
should  deliver  services  to  an  ATM  level,  or  whether  that  is  an  overly  narrow  and  restrictive 
collective ambition in particular in urban environments.142 

Discussions about the  benefits  of  U-space  generally  take  two  forms.  The first is  the safety  and 
security benefits associated with having defined procedural and spatial practices.143 The second is 
the  role  of  U-space  in  facilitating  the  realisation  of  value  at  the  drone  service  level.144  These 
discussions  make  the  identification  and  explanation  of  ‘value’  associated  with  U-space 
implementation  complicated.  An  underlying  issue  is  the  desire  for  appropriate  designation  by 
Member  States  in  order  to  prevent  U-space  being  allocated  where  it  does  not  bring  any 
significant  added  value  in  safety,  security,  privacy  or  environment  terms.145  Effective 
implementation of U-space is seen as a critical activity in determining the actual economic value 
added,  including  the  transition  from  viewing  drones  as  transport  to  viewing  drones  as  an 
integrated  service  in  the  value  chains  of  companies.146  Stakeholders  (in  particular  USSPs  and 
drone operators in fledgling U-space activities) imply the transition can only occur if automated 
BVLOS is effectively regulated and priced.147 

The long-term opportunities associated by stakeholders with U-space implementation are aligned 
with  those  identified  in  current  policy  and  regulatory  frameworks.  Stakeholders  specifically 
identify the need for U-space to facilitate: 

  U-space as infrastructure: enabling and prioritising a diversity of operations148 
  Airspace  taxonomy  and  classification  based  on  environmental  footprint  and  market 

potential149 

  The  iterative  roll  out  of  connected  corridors  with  a  principle  of  achieving  an  environment 
where  operations  can  start  from  anywhere  (appropriate)  and  can  end  anywhere 
(appropriate)150 

141   Written  submissions;  free  text  comments  in  the  DS  2.0  Targeted  Survey  (2022);  interviews  with  a 

global UTM representative body and with U-space service providers. 

142   Written  submissions;  free  text  comments  in  the  DS  2.0  Targeted  Survey  (2022);  interviews  with  a 
global UTM representative body and with U-space service providers (in particular those who come at 
the business opportunity from a non-conventional aviation/ software development perspective) 

143   See the majority of SESAR JU and EASA communications in particular. 

144   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

providers. 

145   DS 2.0 Targeted Survey (2022), in particular responses from national and regional authorities. 

146   See  for  example:  position  papers  from  U-space  service  providers  and  independent  policy  research 

discussed in the European Parliament in 2021. 

147   Interviews with U-space service providers and survey responses from drone service providers. 

148   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

providers. 

149   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

providers. 

150   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

providers. 

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  An  environment  where  a  U-space  provider  safely  manages  an  operation  from  beginning  to 
end, using all details on the operator, the aircraft and the operation that a digital system can 
generate151 

  A  requirement  for  all  aircraft  and  operators  to  remain  connected  with  the  system  and 

visible152 

  Collection and management of valuable data related to drone operations and services153 
  Sharing of information where relevant for safety reasons and exchanging information to de-

conflict exclusively with relevant U-space service providers154 

  Full automation where services are digitalised so operations are de-conflicted strategically.155 

A.6.7.5  The necessary transition to mature U-space 

The  dominant  stakeholder  view  is  that  early  U-space  applications  will  develop  as  relatively 
isolated ‘bubbles’, but  over  time  these  bubbles  will  need to  be  connected  into more  significant 
corridors  and  areas  making  use  of  existing  infrastructure  and  sympathetic  natural  forms  (e.g. 
waterways).156 Stakeholders identify the need for a clear plan on the iterative roll out of U-space 
from  this  perspective.  Stakeholders  busy  with  understanding  the  content  and  regulations  while 
implementing them identified that some early applications of U-space are being pursued in very 
complicated (often urban) areas and they questioned whether these complicated applications were 
indeed a good starting point.157 

Some of the short-term opportunities and challenges identified were: 

  Developing  a  whole  of  sector  understanding  of  how  U-space  best  rolls  out  and  scales, 
including  where  it  is  possible  now  and  where  it  should  not  be  applied  (e.g.  remote 
agriculture)158 

  Defining  the  relationship  (procedures)  between  ATM  and  UTM  and  establishing  dynamic 
airspace  management  –  in  some  rare  cases  UTM  was  perceived  as  a  direct  competitor  to 
ATM159 

  Clarity  on  USSP  certification  processes  and  how  multinational  businesses  might  be 

encouraged160 

151   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

providers. 

152   DS 2.0 Targeted Survey (2022); content from European Institutions and relevant agencies. 

153   Interviews with U-space service providers; October 2021 Drone Leaders Group meeting. 

154   DS  2.0  Targeted  Survey  (2022);  content  from  European  Institutions  and  relevant  agencies;  written 

responses and interviews with a global UTM representative body. 

155   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

providers. 

156   European  agency  during  the  November  2021  meeting  of  the  Informal  Drone  Expert  Group;  written 
responses and interviews with a global UTM representative body and with U-space service providers; 
DS 2.0 Targeted Survey (2022) free text response from an NGO. 

157   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

providers. 

158   DS 2.0 Targeted Survey (2022) free text response from an NGO and a national and regional authority. 

159   DS  2.0  Targeted  Survey  (2022)  free  text  response  and  a  national  and  regional  authority  during  the 

October 2021 meeting of the Drone Leader Group. 

160   Interviews with U-space service providers. 

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  The  data  exchange  between  ANSPs  and  USSPs  needs  to  become  more  open  and 

standardised161 

  Systematically building competencies in key institutions (e.g. CAAs) to facilitate the shift, in 
particular  as  it  relates  to  introduction  and  coordination  of  new  technologies;  coordinating 
with  local  authorities;  accepting  SORAs;  certifying  USSPs;  automating  validation  and 
monitoring162 

  Better cooperation between stakeholder groups (including military) and more fora to identify 
to  develop  new 

implementation, 

including 

and  share  best  practices  on  U-space 
competencies163 

  Providing  more  support  for  city  governments  and  local  actors  to  understand  U-space 

opportunities, their role in realising them and what other cities or regions are doing164 

  Working  closely  with  U-space  service  providers  to  make  sure  they  are  future  proofing  by 
considering the needs of all potential drone services (in particular urban air mobility)165 
  More  effort  to  accept  and  integrate  non-aviation  standards/  processes  in  particular  from  IT 

sector166 

  Better  encouraging,  exploiting  and  reusing  the  current  IT  know  how  from  cloud  and 

cybersecurity167 

  Being  clear  about  how  to  apply  risk  management  processes  in  a  much  wider  range  of 

operations168 

  Better defining the role of U-space in ‘fairness’, including what fairness means to regulators 
(rules  and  mechanism  for  airspace  allocation,  who  will  be  prioritised,  to  which  conditions, 
and when)169 

A.6.8  Developing Urban Air Mobility and Regional Air Mobility; including ground 

infrastructure 

A.6.8.1  Specific benefits and challenges 

Urban  air  mobility  (UAM)  is  considered  to  be  a  good  alternative  for  both  ground  transport  of 
goods  and  persons;  71%  (183  out  of  257)  of  the  respondents  of  the  OPC  indicated  that  UAM 

161   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

providers. 

162   Written  content  from  European  institutions  and  relevant  agencies  confirmed  in  interviews  with  U-

space service providers. 

163   October 2021 Drone Leaders Group meeting; November 2021 Drone Expert Group meeting confirmed 

in written work from a European agency. 

164   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

provider. 

165   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

provider. 

166   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

provider. 

167   Written  responses  and  interviews  with  a  global  UTM  representative  body  and  with  U-space  service 

provider. 

168   Written content from a European agency. 

169   DS 2.0 Targeted Survey (2022) free text response from an NGO. 

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being a good alternative for transport of goods. This percentage is lower (56%, 143 out of 257) 
for  transport  of  persons.170  This  pattern  is  confirmed  by  responses  from  the  targeted  survey, 
indicating combined positive perception for transportation of goods 73% (75 out of 103) and for 
passengers 59% (61 out of 103).171 

Main benefits related to the transportation of goods and persons, according to the targeted survey, 
included:  the  ability  of  drones  to  service  remote  areas  (93%,  95  out  of  102);  increased 
productivity (69%, 70 out of 101); reducing local emissions (67%, 68 out of 102); and access to 
goods  (56%,  57  out  of  101).  For  transportation  of  persons,  the  following  main  benefits  were 
mentioned:  faster  reaction  on  emergencies  scores  highest  (87%,  90  out  of  104),  followed  by 
access to less accessible areas (71%, 72 out of 102), reducing traffic congestion (55%, 57 out of 
103), reducing local emission (53%, 55 out of 103) and changing land-use patterns (48%, 49 out 
of 103).172 

The  top  three  challenges  for  transportation  of  goods,  according  to  the  targeted  survey,  were 
identified as: increased noise pollution (64%, 65 out of 101); increased visual pollution (55%, 56 
out of 101) and increased privacy concerns (46%, 46 out of 101). For transportation of persons, 
the  top  three  concerns  or  risks  were:  noise  pollution  (63%,  63  out  of  101);  increased  visual 
pollution (55%, 56 out of 101) and safety and security concerns of the persons transported (39%, 
39 out of 101).173 

Perceptions on noise, vibration and visual disturbances negatively impact the societal acceptance 
of UAM. The OPC indicated that 60% (154 out of 257) of respondents agreed to this (negative 
impact on societal acceptance), while 27% (69 out of 257) disagree.174 Societal acceptance was 
frequently mentioned by stakeholders as a potential barrier. Based on this, means are proposed to 
improve  societal  acceptance,  for  example  through  testing  and  pilots  and  developing  platforms 
and  collaboration  mechanisms.  On  societal  acceptance,  a  social  contract  in  which  citizens  are 
consulted  was  proposed175,  involving  also  local  governments  and  citizens  to  deal  with  issues, 
such as noise, privacy and safety. 

Specific challenges were mentioned to further develop and scale up UAM. For instance, the lack 
of support from local, regional and national authorities, and their reluctance often linked to slow 
evolution of regulations and tried and tested technologies. 176 This also applies to U-space, which 
has advanced in terms of having a regulatory basis and technology developed, but at the moment 
is still in a testing stage and not yet applied in full in an urban setting. It is expected that in time, 
the perceived benefits of UAM or drone services in general, as perceived by society, will increase 
and  the  perceived  risks  will  be  reduced,  for  example  by  making  less  noisy  and  safer  drones, 
paving the way for a large-scale application of drones. 177  

170   DS 2.0 OPC (2022), Matrix 7 and 8 (combined agree and strongly agree). 

171   DS 2.0 Targeted Survey (2022), Question 54 and 55. 

172   DS 2.0 Targeted Survey (2022), Question 56 and 57. 

173   DS 2.0 Targeted Survey (2022), Question 58 and 59. 

174   DS  2.0  OPC  (2022),  Matrix  2  (combined  score  on  agree  and  strongly  agree  and  combined  score  on 

disagree and strongly disagree 

175   By a representative organisation of the advanced air mobility (AAM) sector. 

176   According to a representative from the airport sector. 

177   According to a representative from the U-space sector. 

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A.6.8.2  Ground infrastructure and U-space 

There is general consensus that there is a need to develop new types of infrastructures, including 
vertiports, to develop UAM. The OPC indicated that 76% (195 out of 257) of respondents either 
agreed  or  strongly  agreed  to  this  need  and  14%  (35  out  of  257)  disagree.178  The  OPC  also 
revealed that it takes effort to develop such infrastructure. On the question that “every city can 
easily accommodate vertical take-off and landing operations”, 59% (150 out of 256) disagreed or 
strongly disagreed, while only 7% (17 out of 256) agreed.179  

74% (190 out of 256) of OPC respondents agreed or strongly agreed - against 7% (18 out of 258) 
disagreeing  -  that  urban  design  development  should  consider  drone  operations.  180  A 
stakeholder181 pointed out that infrastructure is needed in cities (vertiports, vertistops) to support 
drone  operations,  which  is  not  an  easy  topic,  given  the  fact  that  it  involves  noise  and  public 
acceptance. Moreover, decisions need to be taken on the location and type of infrastructure and 
number of vertiports needed. The vast majority of stakeholders of the OPC, 73% (187 out of 257) 
of  respondents  agreed  or  strongly  agreed,  against  15%  (39  out  of  257)  disagreed  or  strongly 
disagreed - consider that U-space services should be available in every urban area.182 

A.6.8.3  Platforms, collaboration and communication mechanisms 

A strong majority of respondents to the OPC - 89% (228 out of 255) agreed or strongly agreed 
that  cooperation  mechanisms  should  be  established  for  authorisation  of  operation  of  drones  in 
urban  areas.  183  Involvement  of  authorities  and  collaboration  mechanisms  were  mentioned  by 
many  stakeholders  as  a  prerequisite  for  development  of  UAM.  For  example,  it  is  proposed  to 
incentivise local authorities to take part in developing a vision (on drone operations). This could 
result in government procurement to fund innovative solutions. Another stakeholder suggested to 
involve European cross sectoral players to support UAM adaptive roadmaps that are supported 
by the industry, Member States, local authorities, and the Commission. 184  

A.6.8.4  Testing sites and pilots 

A strong majority of stakeholders in the OPC, 84% (214 out of 255) agreed or strongly agreed, 
that pilot projects should be run in parallel in different European cities to enhance public trust. 185 
The link between testing sites and/or pilots and public trust or societal acceptance is made by a 
number of stakeholders. For example, a stakeholder representing aviation organisations indicated 
that there is a need to provide access to test sites in multiple locations. Test sites are the enabling 
factor for unmanned technology development, both digital infrastructure and vehicle technology. 
Providing  the  possibility  for  gathering  field  experience  in  the  controlled  environment  could 

178   DS 2.0 OPC (2022), Matrix 17. 

179   DS 2.0 OPC (2022), Matrix 15. 

180   DS 2.0 OPC (2022), Matrix 16. 

181   A representative from the research sector in aviation. 

182    DS 2.0 OPC (2022), Matrix 20. 

183    DS 2.0 OPC (2022), Matrix 12. 

184   A representative active in UTM. 

185    DS 2.0 OPC (2022), Matrix 10. 

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enhance  safety  level  and  public  acceptance.  A  stakeholder  representing  airports  suggested  to 
create  a  European  endorsement  for  organisations  working  on  testing  sites  top  demonstrate  the 
feasibility of drones and their use cases and by doing so, help secure the necessary support from 
local and national authorities. This stakeholder indicated that the Urban Air Mobility Initiative & 
Network  of  demonstrators  is  an  effective  tool  to  promote  awareness,  as  well  as  to  develop 
technology and know-how for safe drone operations in suburban and urban spaces. A European 
transport operator stated that prior to scaling up urban air vehicles deployment and assuming their 
integral part within a multi-modal transportation ecosystem, the social acceptability of this new 
ecosystem is crucial. By effectively engaging and consulting incubators local communities from 
the  outset  and  integrating  their  feedback  into  the  development  of  this  transportation  solution, 
UAM stakeholders would bring the ecosystem a step closer to achieving public acceptance and 
accelerating the ecosystem’s implementation in cities. 

A.6.9  Societal acceptance and dealing with externalities 

The  perception  of  a  general  public  interest  is  a  determining  factor  for  acceptance:  stakeholder 
indicate that use cases where a benefit for the community can be perceived, such as the delivery 
of  medical  or  emergency  transport  or  the  contact  with  remote  areas,  are  seen  as  the  most 
promising use of UAM.  

Civil  drones  are  generally  thought  of  having  an  impact  that  stretches  into  three  main  areas: 
surveillance,  pollution  (noise  and  visual),  and  safety.  Regarding  surveillance,  civil  drones 
represent a presence in the sky that captures data from people and places. In the OPC, 89% (229 
out of 257) of the respondents said privacy should be a priority, and 85% (218 out of 255) agreed 
that regulatory measures should ensure that drones are compatible with EU privacy law.186 The 
data  collected  by  drones  can  have  many  forms:  video,  picture,  sound,  thermal  record, 
geolocation,  etc.  Any  understanding  of  the  surveillance  that  drones  pose  need  to  consider  not 
only the platform itself, but also the other payloads than can be used: cameras, thermal cameras, 
sound  sensors,  radars,  internet  beaming  applications,  etc.  Additionally,  drones  are  big  data 
collection platforms that contribute to the global data economy.  

Regarding  pollution,  civil  drones  pose  two  main  problems.  Firstly,  they  contribute  to  visual 
pollution.  Secondly,  they  produce  disturbing  sounds  that  are  a  source  of  sound  pollution.  78% 
(201  out  of  257)  OPC  respondents  agreed  that  regulatory  measures  should  ensure  that  noise 
related issues are addressed (corridors for drone, hours limits, size of drones, etc).187 Both forms 
of pollution refer mainly to the drones themselves, but also to the infrastructure that enables them 
to fly188. This pollution has some implications also in terms of wildlife, given that they interfere 
with bird flocks and other forms of livelihood.  

Finally, as drone technology has proliferated, concerns have grown regarding the potential safety 
and security threat that it poses. In the OPC, 98% (252 out of 257) of the respondents said that 
safety should be a priority.  189 Drones can cause all sorts of accidents and they can be used for 
criminal purposes of all types, from smuggling of good to industrial espionage, from harassment 
to surveillance, from politically motivated action to terrorism. All these risks are exponentiated 
by the problems associated with the technology that is meant to address non-cooperative drones, 

186    DS 2.0 OPC (2022), Matrix 2 and 14. 

187    DS 2.0 OPC (2022), Matrix 13. 

188   Written contribution. 

189    DS 2.0 OPC (2022), Matrix 1. 

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i.e.  counter-drone  technology  –  a  technology  that  is  often  not  fully  effective  and  that  faces 
hurdles with respect to legality, coordination, planning, and safety.  

In the 2021 EASA study, safety and noise pollution are on top of EU citizens’ concerns, in a list 
that also includes cybersecurity risks and the potential impact on wildlife.190  

Respondents and interviewees highlighted potential positive societal impacts such as commercial, 
industrial,  and  environmental  opportunities  that  can  be  leveraged  and  can  be  both  direct  and 
indirect. Direct opportunities emerge from potential for speeding up commerce and deliveries and 
open up new business cases, including air mobility. Regarding industrial, there is the expectation 
that  a  developed  drone  industry  requires  qualified  jobs  and  triggers  technological  development 
and R&D. As for environmental, the idea is that future forms of urban air mobility can reduce 
traffic congestion and the use of fossil fuels in certain use cases, therefore reducing the general 
carbon footprint of metropolitan areas.  

It is crucial that public and private institutions collaborate in the development of risk mitigation 
and  response  strategies  to  minimize  the  risks.  Importantly,  and  considering  the  technology’s 
evolution, this collaboration should be unfolded on a permanent, regular basis. Current EU efforts 
in  carrying  out  this  societal  engagement  are  praise-worthy  and  should  be  reinforced.191  As 
happens in other areas, there is a potential for the EU to become a standard setter in the area of 
technology regulation.  

The issue of technology acceptance is not a binary one. Indeed, the citizens make nuanced and 
deliberate  decisions  depending  upon  the  context.  The  boundary  between  acceptable  and 
unacceptable civil drone development are defined by how serious the benefits are, and who the 
user is.  

The integration of drones in society into the existing air and ground infrastructure must respect 
residents’ quality of life and the cultural heritage of old European cities. To reiterate what was 
mentioned above, considering the big impact that new forms of air mobility will have on society, 
it is fundamental that the whole civil society, and not only end-users, participate in the regulatory 
process. Finally, regulators and legislators should consider the full spectrum of the surveillance 
issues raised by the integration of civil drones in the airspace, beyond the mere visual and sound 
data  collection.  Rather,  civil  drones  need  to  be  considered  big  data  collection  systems  that  are 
integrated with other technologies and participate in the global marketization of data.  

The  DS  2.0  should  do  more  than  highlight  risks  and  obstacles,  but  equally  –  if  not  more  – 
important for societal acceptance, the strategy should illustrate the benefits of drones in society; 
citizens are not fully aware of the positive benefits of drones192. 

A.6.10 Developing knowledge, training staff and building competence 

A.6.10.1  Changing skills needs and building competence 

A strong majority of stakeholders of the OPC - 89% (230 out of 257) agreed or strongly agreed 
that  drone  services  will  have  an  impact  on  skills  and  new  training  offers  adapted  to  the  smart 

190   European  Union  Aviation  Safety  Agency  (2021)  Study  on  the  societal  acceptance  of  Urban  Air 
in  Europe.  Available  at:  https://www.easa.europa.eu/sites/default/files/dfu/uam-full-

Mobility 
report.pdf.  

191   Interview with European civil aviation authority. 

192   Written contribution, industry representative. 

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mobility and drone  services should be made available.193 Individual stakeholders confirmed the 
need  for  training  while  a  European  drones  association  pointed  out  the  differences  in  training 
between manned and unmanned aviation. A stakeholder representing workers in aviation stressed 
the need for an EU pilot training by developing a syllabus for drone pilots, as well as an adequate 
training programme. Apart from drone operations, stakeholders mentioned a range of domains in 
which capacity needs to be developed such as, legal capacity to deal with implementation of new 
legislation.  A  drone  operator  indicated  the  need  to  invest  in  skilled  workforce  at  National 
Authorities  and  ANSPs  and  provide  funding  for  key  enabling  technologies  and  Technology 
Readiness  Level  (TRL)  research.  A  European  Civil  Aviation  Authority  indicated  the 
development  of  a  roadmap  (2021-2030)  including  competences  development  and  training 
activities in line with technological and regulatory evolution.  

A.6.10.2  A dedicated Research and Innovation action 

Around two thirds (69%, 82 out of 119) of the respondents to the targeted survey were supportive 
of a dedicated Research and Innovation (R&I) action in support of the development of drones.194 
These included, improvement of drone and remote-control technology; protection of geographic 
zones and airports; enhancing the potential use of drones; training and education; protection of 
the environment; the regulatory framework to make use cases easier. Apart from what should be 
covered,  stakeholders  indicated  that  the  results  of  research  projects  are  not  always  optimally 
used.195  Moreover,  the  focus  of  such  a  dedicated  R&I  action  would  need  to  be  carefully 
coordinated  with  other  initiatives,  such  as  SESAR  3,  in  order  to  avoid  overlaps  or  parallel 
research programs not converging.196 

193   DS 2.0 OPC (2022), Matrix 21. 

194   Whereas 12% (14 out of 119) of the respondents do not agree to such an action and 19% (23 out of 

119) does not know. 

195 Drone operator 

196   According to a representative from the U-Space sector. 

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