This paper describes the position of Europe’s professional pilots on the standards and rules necessary for the safe use of drones in EASA’s ‘Open’ category. Acknowledging the potential this technology has for innovation and benefit to society, it is absolutely critical that the technology is introduced safely, in particular with regard to existing manned aviation – a future accident involving drones in which people are seriously harmed will do far more damage to the industry’s development than carefully thought out, effective, efficient regulation. The following points summarise this paper.

The safety of human beings is paramount

It must always be the case that real people, whether in the air or on the ground, have their safety prioritised over the ability or right to operate a drone. It must be born in mind that most drones in the Open category will be mass market consumer products, may have significantly different capabilities in a few years, and any regulation needs to deal with this. This cannot happen without proper risk assessment, especially of midair collision risk.

Design requirements for the physical performance capability of drones in the Open category

There is a compromising lack of scientific and engineering research on the effects of drone collisions with aircraft. This must be conducted as a matter of urgency to assess and refine these or any other proposed technical standards. They include:

1. Maximum achievable distance from pilot of less than 500m horizontally and 50m in height;
2. Auto avoidance of restricted areas e.g. by geo-fencing, or transponder technology;
3. Auto recovery in the event of loss of control;
4. Weight limited to 500g, subject to density, frangibility and part weight specifications that would prevent catastrophic damage to manned aviation;
5. Maximum speed to allow control, recognition and limit kinetic energy;
6. Colour, visibility and lighting standards to allow visual recognition and avoidance;
7. Marking and registration of the drone to allow tracing of pilot/operator.

Operational requirements for drones in the Open category:

1. Unilateral obligation to avoid manned aviation;
2. Operation restricted to Visual Line of Sight (VLOS);
3. No operation in the vicinity of third persons without their consent, or crowds;
4. No operation in areas with manned aviation (e.g. accident sites, operational traffic areas);
5. Appropriate training / education of the drone pilot prior to operation;
6. Operation only for recreational purposes. Commercial operation should be dealt with in the Specific or Regulated category.

Mandatory insurance, non-punitive safety reporting obligations, and stricter rules for commercial operations all need to be part of the package too.