One of the most promising areas in aviation development is the use of drones (Raj et al. 2017). Many organisations and researchers define drones as unmanned aircraft (OECD 2018; Nelson & Marrinan 2018; Raj et al. 2017). These machines vary in size and may include large aircraft, which are big and complex as conventional aircraft, or smaller drones, which are often sold as consumer electronics products. Based on their multiple uses and relative affordability, drones have become increasingly popular in private and commercial spaces. Consequently, many parts of the world have reported increased uses of drones for social or economic reasons (OECD 2018).
The United Arab Emirates (UAE) has similarly reported increased use of drones in the country (Raj et al. 2017). This trend has captured the attention of authorities because of the safety and security concerns drones pose to aviation safety (OECD 2018; Nelson & Marrinan 2018). More importantly, there are doubts regarding how drones could be integrated into the country’s airspace because they pose a threat to the safe operation of manned aircraft (Raj et al. 2017).
The biggest hurdles associated with the integration of passenger and cargo drones into the UAE airspace are the lack of on-board pilots to control the machines and the manufacturers’ use of complex operating systems to manage their operations (Raj et al. 2017). The integration of passenger and cargo drones in the UAE airspace is further complicated by changing avionic standards and continuous software updates, which underpin the manufacture and use of the equipment (Raj et al. 2017).
Based on these challenges, there is a clamour in the UAE for drones to aspire to higher safety standards (Raj et al. 2017). This paper provides a framework for integrating drones into the UAE airspace. Key sections of this case study explore the current state of regulations governing drone use in the UAE and provide the analysis of the aviation system and the place of drones in it. The regulatory environment informing drone use in the UAE is explained below.
Current Regulations for Drones in the UAE and Comparative Global Laws
The initial foundations of the legal environment surrounding the use of drones in the UAE were hinged on the 2015 Federal Resolution No. 2 of UAE aviation laws (Nelson & Marrinan 2018). From this piece of legislation, the UAE General Civil Aviation Authority (the GCAA) was developed as one of the primary body of laws governing the use of drones in the country. This legislative piece largely defines drones as unmanned aerial systems (Nelson & Marrinan 2018). An extract of the law also defines drones as “an aircraft and its associated elements which are operated with no pilot on board” (Nelson & Marrinan 2018, p. 2).
Generally, drones in the UAE are classified according to two criteria: user subclass and weight. The user subclass is further categorised into two types – people who use drones for private purposes (usually, leisure and sports) and people who use drones for commercial reasons, such as media houses (Nelson & Marrinan 2018). The GCAA sets out different criteria governing the use of drones for each subclass. For example, private drone users are not supposed to capture data using audio or video devices attached to their drones, while those in the commercial subcategory require prior approval to use their drones (Nelson & Marrinan 2018).
In addition to the federal laws governing the use of drones, the UAE also has emirate-specific laws outlining the use of these unmanned aircraft. For example, through the Executive Council Resolution No. 4 of 2017, Dubai requires all drone users to obtain permission from the Dubai Civil Aviation Authority (DCAA) before using their drones (Nelson & Marrinan 2018).
GCAA rules governing the use of drones in the UAE perform the same legislative task as other sets of laws governing drone use in other jurisdictions. For example, the Federal Aviation Administration (FAA) sets out the rules for the use of drones for private and commercial purposes in America (U.S. Department of Transportation, 2018). Like GCAA regulations, FAA rules also classify drones according to their weight.
For example, the FAA rules apply to drones that are less than 55 pounds (U.S. Department of Transportation, 2018). One of the main premises for FAA implementation is the stipulation to avoid manned aircraft and the careless use of drones for public or private purposes (U.S. Department of Transportation 2018). The law also requires users to keep their drones within their sight, at a maximum allowable attitude of 400 feet, and operate them at a speed of 87 knots (U.S. Department of Transportation 2018). Similar to the UAE, the FAA rules in the United States (U.S) require users to register their drones before use and seek certification before flying (U.S. Department of Transportation 2018).
In Europe, the laws governing the use of drones are fragmented. However, the European Aviation Safety Agency (2018) is the main regulatory body governing their use. Similar to the GCAA and the FAA, the EASA requires drone users to register with authorities before operating their machines. However, exceptions are made to users who operate drones that are lighter than 250 grams (European Aviation Safety Agency, 2018). Unlike the GCAA and FAA, EASA gives a lot of room for European member states to define prohibited areas where drones cannot be flown. Therefore, it is important for users to check local listings governing drone use to know where they can fly the drones.
Although the above-mentioned laws largely outline the use of drones in the UAE and other parts of the world, the UAE laws have specific limitations regarding the use of these unmanned aircraft. For example, commercial users of drones are supposed to have mandatory minimum insurance of AED3.67 million, without which drone use is not permitted (Nelson & Marrinan 2018). Plans are also underway to impose a minimum insurance cover for private users as well (Nelson & Marrinan 2018).
Another limitation regarding the use of drones in the UAE is the legal requirement preventing people from using drones in no-fly-zone areas. Through GCAA’s UAE Drone Fly Zone Map, users can ascertain which areas in the country they should fly their drones (Nelson & Marrinan 2018). Nonetheless, the decision regarding where to fly these drones is partly informed by a proper understanding of the country’s aviation ecosystem and the place of drones in it.
Analysis of the Aviation Ecosystem and the Place of Drones in the UAE
The UAE airspace is among the busiest in the Middle East because the country is a major aviation hub in the region. Therefore, air traffic standards in the UAE are at par with international laws because many flights land and take off from the country. Air traffic management is one of the safety aspects of the UAE aviation ecosystem because, without it, the UAE could lose its competitiveness in the region or cause major air traffic disasters.
In the UAE, the traffic of manned aircraft is often managed at a centralised location operated by air traffic controllers; however, the same is not witnessed in drone use. To overcome this challenge, large drones could be remotely piloted through a centralised structure similar to that used in the conventional aviation industry (OECD 2018). Comparatively, the traffic of smaller drones could be improved by automating air traffic management. Although these recommendations are elaborate, they are likely to have the greatest effect in the UAE when the use of drones increases. This way, it may make more economic sense to implement them in the future, as opposed to setting up a current traffic management infrastructure, which may not have the intended effect because of the low number of drones in use.
Based on the above insights, there is a consensus among the UAE and international aviation experts that aviation safety standards for drone use should be comparable with the same aviation standards governing aviation safety in manned aircraft (Nelson & Marrinan 2018; European Aviation Safety Agency 2018). This consensus is defined by the principle of the equivalent level of safety (ELOS) (Nelson & Marrinan 2018). The ELOS may be achieved using qualitative or qualitative assessment techniques. Although the ELOS requirements are important in improving the level of safety standards for drone use, it may be difficult to correctly understand ELOS requirements that should be adopted.
The place for drones in this environment is protected by the need to introduce the concept of “targeted level of safety.” The concept should be designed with the view of introducing an acceptable number of minimum collisions per flight hour, which could lead to human death (Nelson & Marrinan 2018). Modelling the framework through end-to-end system performance could improve safety standards in this regard. Given the fundamental differences in safety standards associated with managing drones and manned aircraft, the UAE could also introduce new standards of managing overall system performance.
For example, Nelson and Marrinan (2018) propose that a rate of loss of communication could be introduced as a safety measure in addition to traditional reactive metrics used in the UAE aviation sector. Nonetheless, such recommendations have been adopted in reference to the improvement of interoperability dynamics of drones. Understanding how to integrate drones in the UAE airspace exemplifies the importance of improving the airworthiness of these unmanned aircraft in the country.
Framework for Safe Integration of Drones
The concept of airworthiness is primarily focused on the need to make flights safer. This is why Nelson and Marrinan (2018) define the concept as the suitability of aircraft to make safe flights. The process of improving the airworthiness of drones largely stems from a review of drone operations, its associated manufacturing processes, and design.
The design of drones, which are used in the UAE, is largely premised on manufacturer specifications. Since drones are electronic gadgets, there is a need to merge product specifications and the country’s consumer laws. Particularly, the design specifications of drones should align with existing laws governing the manufacturing and production of consumer products in the UAE market (Bennett et al. 2014). The standard market should be premised on the drone class, such as 1A, 2A, or 3A. Each class category should have a list of acceptable and unacceptable procedures that consumers should find in the product package. The class of drones concerned should communicate which areas they can be used and the level of competence they need to meet to operate the machines.
To improve the endurance of drones, the devices could be made using animal imitation where aero dynamism mimics insects and animals. For example, the drone design could be improved to include flapping animal wings (Bennett et al. 2014). The Nano Hummingbird is another type of drone that has adopted the same design, but its model is yet to be implemented in different countries. The integration of such drone designs could significantly improve the functionality of the unmanned aircraft. For example, Bennett et al. (2014) suggest that employing the flapping-wing design could improve the functionality of drones for stealth purposes.
The design of drones could also mimic animal designs by using sensors to improve visibility above ground using compound-eye optics, as suggested by Bennett et al. (2014). Particularly, miniature optic-flow sensors could be used in drone designs to mimic insects, which have compound eyes, such as houseflies. These design modifications would make them more efficient and reliable.
From a manufacturing perspective, the safety features of drones could be improved to increase their reliability. For example, manned aircraft are built to be efficient and can take longer flights without being refuelled. However, drones do not have that enduring power because of low battery life. Advances in manufacturing technology could be made to power these machines using light and efficient fuels, such as hydrogen.
At the same time, proper technology for cooling should also be used to increase the number of hours drones can stay airborne. This recommendation stems from a book authored by Bennett et al. (2014), which reported that the number one cause of drone failure was overheating. Solar-electric unmanned drones could also be developed as part of research into the development of more efficient and user-friendly drones. This recommendation aligns with the sustainability goals of the global aviation sector, which is to reduce the reliance on fossil fuel use.
The operationalisation of drones in the UAE should follow developments proposed in Europe regarding the use of such machines. These developments suggest that drone use should be largely categorised into open and specific categories (European Aviation Safety Agency 2018). In the open category, the risk of drone use determines whether permission should be sought in the use of drones, or not. This type of specification could be applied to private drone users who do not need to be subjected to the rigorous regulatory requirements concerning drone use in the UAE.
Comparatively, the specific category should be left to commercial drone users who should seek prior approval from authorities to use the unmanned aircraft. The authorities should approve the use of drones after undertaking an operational risk assessment plan, as recommended by the European Aviation Safety Agency (2018). Exceptions could be made in situations where the user’s declaration for the use of drones is sufficient, or when the drones do not meet the weight threshold.
Another area of operation that could be improved is the training and licensing of drone operators. This view stems from the fact that the main assumption about safety in aviation is the fact that pilots can always take over steering functions whenever there is a system failure. To do so, pilots often undergo rigorous training to prepare them to handle situations better when such system failures occur. At the same time, aviation authorities have set up procedures in place that would help the same pilots and aircrew to manage a system failure. Comparatively, unmanned aviation relies solely on artificial intelligence to avoid system failures (Raj et al. 2017).
The UAE could make an effort to align certification and licensing guidelines for drone users with mimicking safety and competency standards seen in the aviation industry. For example, safety guidelines taught to pilots could similarly be taught to drone users. Although this recommendation could improve the safety standards of drone use, the UAE may need to align its licensing procedures for drone use with other jurisdictions, such as Europe and America, which are considering harmonising their licensing procedures to be in the same level as the operational risks of drones.
Based on the relatively low number of drones operating in the UAE, it is important for authorities to undertake a regulatory review in phases to make the process less burdensome to the public. The recommendations highlighted in this paper aim to improve some of the major annexes of the International Civil Aviation Organisation (ICAO). Broadly, there are 19 annexes. They include personnel annexing, rules of the air, meteorological services, aeronautical charts, units of measurement, operation of aircraft, aircraft nationality and registration marks, airworthiness of aircraft, facilitation, aeronautical telecommunications, air traffic services, search and rescue, aircraft accident and incident investigation, aerodromes, aeronautical information services, environmental protection, security, the safe transportation of dangerous goods by air, and safety management (SKYBRARY 2017).
The above-mentioned recommendations relate to annexe 2 (rules of the air), annexe 6 (operation of aircraft), annexe 8 (airworthiness of aircraft), annexe 11 (air traffic services), annexe 17 (security), and annexe 19 (safety management).
Although the recommendations highlighted in this paper underpin the relationship between the recommended actions for drone use in the UAE and the 19 annexes of the ICAO, the UAE could experience a regulatory conundrum if it maintains a restrictive policy for drone use in the country. The restrictive legal environment for drone use departs from a basic premise of aviation, which presumes that drones can be effectively regulated under national aviation regulatory frameworks. For example, the prohibition against operating drones in the UAE’s urban areas departs from conventional wisdom in aviation policies, which grant authority to manned aircraft to fly over cities and urban centres. The difference in the implementation of the law means that issues relating to public safety are dominant in the use of drones more than manned aircraft.
Based on the above insights, a regulatory conundrum emerges in the UAE because safety concerns surrounding the use of drones are automatically mitigated by the low attitude in which the drones fly. Manned aircraft are not allowed to fly at such low altitudes (OECD 2018).
This requirement presents an opportunity for the UAE aviation authorities to develop a “drone airspace.” However, regulators may be hesitant to embrace such an idea because of the lack of a properly functioning autonomous collision avoidance system in drone manufacturing. At the same time, there is little proof that drone-to-drone communication systems are reliable and that they would minimise the risk of collisions in the first place (OECD 2018). There is also doubt about the ability of drones to stay electronically connected to their pilots because of communication limitations (OECD 2018). Since drones are likely to cover greater distances in the future, the most economically viable way to maintain the competitive advantage of drones is to make them fully autonomous.
A paradox also emerges in the UAE aviation industry relating to the limitations imposed on drone usage because it limits the possibility of real-life experiences occurring and authorities learning from the same through evidence-based approaches. Integrating drones into the UAE airspace could help to address this problem by providing ground for future policy improvements in drone use through proven case studies and incidence reports.
Private and public users of drones in the UAE are already showing enthusiasm for the use of the unmanned aircraft. However, the UAE regulatory environment needs to be more transparent and simple for everyone to understand. Indeed, current regulations surrounding drone use in the UAE need to be reviewed to make sure they do not undermine innovation and limit the benefits that UAE citizens could realise from the use of drones. Overall, the future of drone use in the aviation sector will continue to be promising because these unmanned aircraft are lighter, smaller, and have a better power-to-weight ratio compared to manned aircraft. Therefore, adopting the recommendations highlighted in this paper could help to improve the airworthiness of drones in the UAE.
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