Callum Holland from the Future Safety and Innovation Team discusses the UK CAA’s proposed policy on unlocking beyond visual line of sight (BVLOS) drone operations using an Atypical Air Environment.

We hear how this could work in practice and how your views can help shape the final policy.

You can share your views and learn more by visiting:

Atypical air environments – Proposed Policy - Civil Aviation Authority - Citizen Space (caa.co.uk)

Welcome to the CAA Drone Safety podcast.

Hello, everybody, and welcome to the Drone Safety podcast from the UK Civil Aviation Authority. I'm Jonathan Nicholson from the Communications team. And today it's quite a groundbreaking episode, I guess something that a lot of the commercial larger drone operators have been looking for for quite some time to be able to do in the UK. And that is a version of every day beyond visual line of sight flying. Now standard rules for UK and most of the world drone flying is that in most cases, the person flying the drone has to be able to physically see the drone. That's because they need to be able to separate it from other things that are flying. particularly low flying other aircraft, military helicopters, military fast jets, small private aircraft, balloons, hang gliders, emergency helicopters, such as air ambulances, and police, helicopters, all of these things are operating right down to ground level. So, we need to be able to safely separate drones from other aircraft. So that's why that kind of visual line of sight requirement has always been in place. But a breakthrough for a lot of operations that people want to do with drones would be that ability to do scalable routine, beyond visual line of sight operations. And I'm pleased to say we're joined today by Callum Holland from the CIA's drone and innovation teams. And Callum is going to talk us through a new consultation that we're just putting out that will actually hopefully set that in place. So hi, Callum. Hi,

Jonathan, how you doing really excited to be here and talk about what is, you know, flagship policy from from a future flight perspective?

Yeah, I mean, it really is something that we've been working through for a while and industry is looking for. So, this actual sort of version of BVLOS and beyond visual line of sight flying is called an atypical air environment. And lots of people may not have heard about that, or might not be 100% sure what it is. So, can you explain to us what that is, please?

Yeah, of course. I mean, firstly, sort of pick apart some of the challenges of this journey towards routine scalable beyond visual line of sight operations. The UK has always been really clear, we want integration, we don't want to sort of continue what we've been doing up until this point of segregating UAS from conventional aviation, we want to get into place where we all integrated and sharing the airspace safely. One of the key challenges with that, especially in the short term is kind of an absence of both quantitative and non-cooperative detect and avoid systems. We're looking at now a scaled adoption of electronic conspicuity, which is going to help feed into that. And of course, within control arms of airspace, sort of improvements, and advancements in air traffic management service provisions to integrate UAS into all volumes of airspace. Now, that's a journey we're going on. And we're working incredibly hard on it. We all are, but both as a regulator, but as an industry as well. But what can we do, practically, in the meantime, to get innovators operating beyond visual line of sight in an integrated way, where we are impacting as little as reasonably practicable, other users. And this is where the concept of an atypical air environment comes in. So, it's a really quick sort of recognition that this is not about creating a separate classification of airspace. It's a recognition that there are certain volumes of air space across the UK, that due to their proximity to certain sort of pieces of ground infrastructure might be a railway, it might be a power line might be a building that you're less likely to encounter conventionally prior to aviation. It's not an absolute, it's just less likely. And we can use that less likely. And we've done sort of modelling on this and really in-depth risk assessments to date internally, as well as involving external stakeholders on this, we can use that sort of principle of you're less likely to encounter conventional aviation, to allow a UAS to operate beyond visual line of sight with some additional mitigations on top of it, which we'll talk about. Yeah,

that's brilliant. Thank you. So, this is something we're just about to consult on. And I particularly come back to your point there about integration rather than segregation because we are a small country with a small amount of airspace and an awful lot of airspace users doing all very different things at different heights, different purposes and with varying levels of equipment. And I think it's always worth remembering that when we talk about integration and wanting to do that we don't have the space to segregate all these people out. So, what specifically are we consulting on? So, you mentioned obviously there will be the a typical principle is that these are drones operated very close to the thing that they're probably looking at inspecting to reduce the risk. But what are the elements of the consultation? Is there?

Yeah, so this is really exciting. We are consulting on our entire proposed policy position on the adoption and recognition of an atypical our environment. So, it's currently a 12 page document, it outlines not only what would be reasonably considered or may reasonably consider native cloud environments, we talk about some of the challenges of operating within one some additional considerations that an operator might need to employ, as well as some additional risk mitigations that we would expect to be used when operating within a native cloud environment. On top of that, it's also a consultation, not just for those that will use atypical air environments, but for stakeholders that might be impacted by the use of atypical air environments, so other users, so you've already touched on them, you know, the military, the police search and rescue GA, there's a whole suite of stakeholders that will be impacted to some degree by the adoption of this policy, and we're really keen to get their views. Now, that doesn't mean in the process of developing this policy has been done in the absence of those views. Now's the time to consult the entire community, those that are going to utilise atypical and those that might be impacted as a result of its adoption. And that's really what we're consulting on. So, we have the policy. What we're consulting on is what we intend to adopt, we'll run this for six weeks, reflect on the comments, hopefully with the intention of some point in the near future, formally adopting the policy so people can begin using it.

Yeah, perfect. That would be great. So apart from the airspace angle, which is obviously really important, is there anything in the consultation specifically about what would be potentially required for the people flying the drone, and also the drone itself?

Yeah, so we have, I don't think this will come as a surprise to many really complex, very populated airspace within the United Kingdom. On top of that, where we have, you know, the standardised European rules of the air is specifically our minimum height requirements. SERA, that 5005 F. We have authorised and permitted deviation from those minimum height requirements outlined within Rs 414 96, I believe. So, we have lower level airspace where we can have lots of other air users. And we've already touched on them, including general aviation, including the military, the police search and rescue as well as us. So very congested airspace, because of that relying on this principle of operating close to infrastructure alone doesn't suitably mitigate the risk. So, we have a residual risk that we need to mitigate with additional mitigation. So, what we're proposing, first of all, I point out, this is policy guidance. So, it's not prescriptive, were putting out there what we think might be reasonable for an operator to consider that might support them in getting an operational authorization to operate BV loss within the native cloud environment. And operator, as is the case for any safety case is free to propose their views. And it will be for the CA to assess that. So, our guidance is suggesting that the operator adopts a form of adjuvant constituting. So, monitoring. We already have our joint statement published between the DFT and CAA on operating ADSB 1090, as well as sort of 978 from an RPAS perspective. So, we've put some guidance in there about how we would want the operator to consider utilising electronic conspicuity. Because of some additional concerns with operating beyond visual line of sight, outside of segregated airspace within controlled airspace, we would also require a form of coordination from the relevant air traffic control service provider. On top of that, we've had some residual concerns from a couple of the stakeholders who might not be able to interrogate electronic constituting that might be operating at very low level. And that proposal was that they would support the adoption of high intensity anti-collision lighting onboard the UAE to help in the visual constitutive, the UAE for those other users. So, there's some guidance in there around the adoption and recognition of high intensity anti-collision lighting used onboard the UAE and many operators that are flying Think beyond visual line of sight today, we'll be well aware of that. And the other consideration within the policy guidance is at containment of the UAE. So, if we are relying on operating within a native glare environment as being the primary mitigation against the midair collision risk, we need to be reasonably assured that the aircraft is going to stay within scope of that operational volume and is not going to stray outside the bounds of it. And therefore, your containment needs to be addressed. So, whatever that might be an onboard software based geo catering functions, for example, it's for the operator to propose, but we would like to see something like that. Because fundamentally, what we're trying to enable here is a form of scaled beyond visual line of sight activity outside of segregated airspace, with the absence of a requirement for detecting the void function, and therefore staying within that operational volume is critical. So, there are sort of high level recommendations within the policy document. As I said, that's what the UK ca might reasonably be expected to see from an operator and the submission of a safety case. But that doesn't mean there are going to be certain areas where the mitigations need to be increased, there might be scope to flex them. In other places, it really depends on the specific operational volume where the operator intends to fly.

Yeah, that sounds absolutely sensible. And we have to keep remembering that, although we absolutely want this to happen. And we want to enable all the innovation safety comes first. And it always will. And we need to make sure that all users are safe. So, sounds very sensible. So obviously, a lot of users also operate in other nations. So compared to other countries, is our A typical proposal different? Is it more restrictive? How do we fit in with the rest of the world in this area?

Yeah, so I think initially, within the policy document, we're going to propose what might be reasonably expected to be considered an atypical environment. And I'll give those figures to you now, it's within 30 metres or 100 feet of any building or structure, it's within 15 metres or 50 feet of any permanent linear structure, you know, for example, a railway or a power line. And then the third one is within the confines of private property, or the height not exceeding 15 metres, which is 50 feet, where you have the permission of the landowner. So, the example there is sort of perimeter inspection and security. I think initially, that will appear pretty restrictive, just sort of being transparent there. We have significant challenges within the UK, specifically pertaining to where we've authorised and permitted other users to operate in that low level airspace. So, within Rs 414 96. Therefore, that including the fact that this is the first time, we're doing this in a scaled way, so we've got a journey to go on in terms of how this policy is used, how it's adopted, how it's implemented by industry, I think we've are beginning from a conservative position. And we'll look to expand sort of beyond that as things get used. We learn more, both as a regulator and as industry. So initially, I think the, it will be considered conservative, in terms of how our definitions, compare and contrast to other countries around the world. There are countries and National Aviation Authorities that have less prescriptive adaptations of a native cloud environment. And that's because their airspace is different. It's not as congested, there might not be the authorization and permission to deviate from the standard European rules of the air, like we have in the UK. So that's the rationale, why we've come to these distances and these conclusions in this position after it's about 18 months of internal work, including sort of select members of industry, and not just sort of the drum community, also other our users. Some really detailed assessment of the data, assessment of the overall risk picture and listening to those stakeholders has led us to these distances. So, we're happy that initially although may appear conservative, are distances that we can manage the risk of, like I said to other users to prevent that midair collision risk of getting to an acceptable level outside of segregated airspace in the absence of detect and avoid functioning. I guess my steer would be, we will move on from this as we learn together as a community but both regulator and industry as we have access to more enabling technologies. As we see a wider adoption of electronic conspicuity, for example, these figures may be able to be expanded on. But for now, I think the initial take will be, it seems a bit conservative, but it's better than what we've got. Now,

that makes absolute sense. And, you know, as we say, there's other airspace users involved here. If their situation changes with the technology they use, and we always say we keep all our regulations and the constant review to make sure they're, they're fit for purpose. So that's the process that we would put in place anyway, as time goes on, and things change. So even if they are slightly conservative, and again, safety comes first. So, there's going to be some big advantages here for operators of things they can go and do on an everyday basis that they can't do now. I wondered if you could give us an example or a couple of examples of things where you think people would be able to go and do if this comes to fruition, which we hope it will, after the consultation? What can they do that they an example they can't do now?

Yeah, so this is where things get really exciting for me as having spent time in industry working on beyond visual line of sight projects, it's really difficult for me personally not to get sort of overexcited about this, because I can sort of see that the value it's going to bring to organisations and sort of the industry is that there's going to open up as a result of it. So, beyond the obvious utilising infrastructure like powerlines, and railways, you clearly have the inspection element there. So, the surveying inspection of those pieces of infrastructure, you're also from a practice a railway perspective, going to enable the industry to scale their activities around the spraying of things like weed killer, to clear the railway lines. On top of that, when we talk about drone delivery, be that consumer goods or health care, you can use the A typical policy and the recognition of a typical environment, so sort of transit your aircraft. So perhaps you're operating between two hospitals? Well, if there's a power line that runs between the two of them, and you can get into that atypical environment and out of the atypical environment in an appropriate way, well, you can transit that aircraft, you know, across the power line or across the railway, with the appropriate permissions and everything else that we've already begun to talk about. So, I think we're going to begin seeing sort of a scaled use of that type of activity as well. So, this isn't just about enabling service inspection, which is absolutely is, I think there's also a lens here around delivery, both consumer and medical and other applications as well. The other really interesting one, too, we've seen a lot of technological development around sort of drone in the box solutions, where you can have a drone on that particular site. And with some level of automated function can conduct things like perimeter inspections. So actually, not flying particularly far away from it sort of takeoff location, and perhaps the remote pilot. So, operating over environment that would be considered beyond the visual line of sight of the remote pilot. Well, you know, we've put some consideration in that if you're operating at height, not exceeding 15 metres, and you have the permission of the landowner. And the reason that the permission is important is because that will support some deconfliction. And ensuring that if there's a field that a GA, our user isn't going to come in London, it because it's also used to sort of, you know, it's an unlicensed aerodrome, perhaps, or there might be conventionally piloted rotary operations taking place naturally as a helicopter landing site. So, the only other side of the property, this is why the permission element is important. So that's you have sort of security, individuals with this drone in the box capability. The potential is that they can operate these perimeter checks with this drone in the box solution, beyond visual line of sight without having to go through segregated airspace and everything else that comes with that. It's quite probable that they can operate that under an atypical environment. So, I think it's going to open up a whole swathe of industry, not just to new applications, but beginning to realise and scale existing applications that are just waiting for a piece of policy like this.

Yeah. And there's some really exciting stuff there that people could get out and do. So, although the quite restrictive for sort of distances and heights, et cetera, I'm assuming that we've spoken about other airspace users, there's going to be some impact on those as well. And that's why we're keen that they respond to this consultation as well. Could we talk about that?

Absolutely. So, of course, we need to hear back from the community that are going to be using this policy. So the UAS community, we need to hear back what they think, what they think is appropriate, what they think perhaps isn't appropriate. And listen from their experiences. What we're also acutely aware of is that this policy will have an impact on the use of airspace for other air users. So the military that please search and rescue general aviation, they are going to have to move into a space where they recognise that you may have a UAS operating outside of any airspace restriction, or segregation, beyond visual line of sight of the remote pilot within these atypical environments, so it's going to have to be a journey for them to recognise that we're moving in this space. And that might form part of their risk assessment moving forward when they operate. So, to get their views on how they think their operations are going to be impacted as a result of that is absolutely critical for this consultation. And that's something I think we're going to push really hard on, to ensure that our responses aren't just from the community that are going to use this policy, but those that might be impacted as a result of the adoption of this policy. Yeah,

and I think when those are the users quite rightly, respond, I think is important as well, they recognise what the limitations on the drone are. So, you know, you mentioned just how close it needs to be to the infrastructure or whatever it's working with. And those are really tight, close distances, aren't they? So, I think people, if they're responding as other airspace users, I think is really important. They recognise that, isn't it?

Yeah, absolutely. We are adopting new technologies, new ways of doing things, it is happening. A good example of that is in the sort of the UAS space, there are now ways of doing things with UAS that are societally beneficial, that are good for the economy can be conducted safely can be conducted more efficiently, perhaps with less cost of conventional techniques. So that is the direction we're heading. We want to do it in an integrated way, where the impact to existing our users is mitigated as far as reasoning practicable, there is going to have to be an element of recognition that adoption by other users, we're trying to do it in a way where the impact is minimised. So, although there might be the additional burdens, perhaps a strong word for other users to consider that, but actually, I'm operating, I'm using this this power line for navigation, hopefully not that kind of the 50 feet that we're proposing. But we're using this power line for navigation. Actually, if I do see a UAS down there, that's Dow routine, it's allowed and the CA have properly thought through the risk and implications of enabling that technology that that that movement of that UAS and knowing that will feed into existing our users risk assessment, how they think about things before they take off and during flight, and especially on sort of approach and landing. So, getting their views. And to make clear, we've already canvassed a significant proportion of that community to get to the point where we are today prior to public consultation. So, one of the other things is, I wouldn't want any individual to think that this policy was written in isolation, this proposed policy was written in isolation, of considering other users. It wasn't. We have consulted other users in the development of this, now's the right time to canvass it publicly and give everybody an opportunity to give their views.

Excellent. And when it's live, it will be on our consultations website, which is consultations.caa.co.uk. And what happens then, Callum, as soon as it's live on there, and the consultations run, what's the next steps?

Yeah, so we're going to run it for six weeks, we think it's really important that we give the community enough time to digest it. It's not a long document. It's 12 pages of which about six of that is substantive text. There is a period of reflection post consultation where we review the comments that we've had. That really depends on how many comments we have that the nature of the comments on how long it will take to review them. But you're all going well, best case scenario is those comments are listened to review, the policy is amended if appropriate, and then published, and becomes formally adopted guidance within the UK for operators to utilise what we will also be doing at the same time is running a bit of a comms campaign to get the message out there to other stakeholders that we will be doing this. One of the things we think it's incredibly important with this policy, unlike other US policy around BB loss in the past, where it was predominantly focused on segregation. Therefore, other than the fact that we are restricting the use of that airspace from other air users, which is a significant consideration for us, once the operations live, other than the fact that other air users can't operate within that segregated volume of airspace, that safety risk is minimised. With a typical, this is integrated, it's not segregated, there is no detecting the void function. So, getting the message out there to other air users that this is the direction of travel we're heading in, we see is actually one of our main risk mitigations awareness, awareness itself is a mitigation to risk. So, there will be a campaign that that's targeting, you know, general aviation, military, police search and rescue and all of the other air users out there that may be operating in close proximity to in a typical environment, there's going to be a targeted comms campaign as well. So, in summary, post consultation, review the comments, reflect on the feedback, intention to publish as soon as we can, in a safe way, alongside a targeted sort of comms campaign to all of those uses that we've already identified.

Brilliant. And that's kind of what we would do for most sort of significant changes anyway, isn't it so keeping to the process we would do so that's great, and very exciting. And hopefully, we'll see some good progress and people can start doing these things safely. So once the consultation we were just talking to Callum about there is live, we will put a link to it in the notes for this podcast. We're keen to hear from everybody involved, affected airspace, users, etc. So please, if you have a view, put it through the consultation. So, thank you, Callum. I'm sure you'll keep us posted on this one. And we'll come back and talk about it again, once the consultation is finished. And we've got other things to say on it, and hopefully introducing it in the future. If there's anything you'd like us to cover on this podcast, or you've got any views or anything, really for us at all on the job safety world, then drop us a line. The email is drone podcast@cia.co. UK, and thanks very much for listening, and we'll see you next time. Thank you.

Thanks for listening. This is CAA Drone Safety.