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Contributed on December 8, 2020

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[Call for Inputs] National Unmanned Aircraft System (UAS) Traffic Management Policy

Blog: NASSCOM Official Blog

Ministry of Civil Aviation (MoCA) released the Discussion Draft of the National Unmanned Aircraft System (UAS) Traffic Management Policy (UTM Policy) on 30 November 2020. Public consultation on the UTM Policy is open until 30 December 2020.

NASSCOM solicits member inputs on the UTM Policy. Please send your inputs to komal@nasscom.in  latest by 23^rd December 2020 to enable NASSCOM to make a timely submission to the MoCA.

The post below gives an overview and a brief analysis of the UTM Policy.

Background and Context:

The Directorate General of Civil Aviation (DGCA) released the draft Unmanned Aircraft System Rules, 2020 (UAS Rules)  for public consultation on 2 June 2020. NASSCOM submitted its feedback to DGCA in July 2020. The final version of UAS Rules is expected to be released soon.

In a move aimed at creating necessary infrastructure and systems required for UAS operations in India, MoCA has issued Discussion Draft of UTM Policy. UAS Traffic Management systems play a vital role in scaling UAS operations while managing the safety of the airspace. This policy is drafted under the overarching framework of the Draft UAS Rules 2020 and in the unlikely event of any incongruence; the Draft UAS Rules 2020 shall prevail.

Highlights of UTM Policy:

1. Scope: The policy document focuses on UAS Operations typically below 1000 feet above ground level (AGL) and addresses increasingly complex UAS operations primarily within uncontrolled (Class G) airspace (defined below) and while moving between designated controlled (Class B, C, D and E) airspace and uncontrolled airspace environments. It also introduces UA Operational scenarios that include Beyond Visual Line of Sight (BVLOS) operations in different classes of airspaces.
2. Objective: The primary objective of this policy document is to define how various UA Operational Scenarios will be enabled in the low-level airspace using the UTM Ecosystem and the Regulatory System referred to as the DigitalSky Platform. This document captures the interaction of various stakeholders with the DigitalSky Platform. This document will also further identify a vision and a roadmap for enabling future UA operational scenarios in all airspaces while addressing aviation security concerns and measures to mitigate them based on threat and risk assessments.
3. Roles & Responsibilities: Stakeholders may perform various roles in the UTM Ecosystem. In one scenario they may be creating new information for the UTM Ecosystem whereas in another scenario they may be consuming information generated by other stakeholders. Also, a single stakeholder may perform both types of functions in different scenarios.
4. UTM Architecture: The UTM Architecture creates an interface to the DigitalSky Platform via various UTM Service Providers and is primarily divided into the following components: DigitalSky Platform, UTM Service Providers, UAS Supplementary Service Providers, UAS and Remote Pilots, Government Stakeholders and General Public. Each component provides specific user interfaces and APIs for stakeholders to interact with the UTM Ecosystem and perform their primary functions while ensuring the safety and security aspects related to UAS Operations in India.
5. Real-time Identification (RIT) and Tracking of UAS: RIT is the functionality of a UAS to broadcast its identity and location directly in the airspace around itself through various technologies like Bluetooth/Wi-Fi or through the internet by connecting to a UTM Service Provider. The ability to identify and track a UAS flying in the Indian airspace will prove to be a very important capability while enabling high density, complex UAS operations. RIT of the UAS would enable sharing of the identity of the UAS and its location to other airspace owners and people on the ground. This would empower various stakeholders of the UTM Ecosystem by providing situational awareness about UAS. Also, RIT functionality will enable law enforcement agencies to identify and locate UAS.
6. UTM Operational Scenarios:

• Scenario 1: Flying for Testing or Recreational Purposes or in Enclosed Premises- As the purpose of such operations is specific and such operations can be conducted in designated areas, the UTM ecosystem may propose a framework for identification of designated sites as testing sites or recreational sites where UAS can be flown for testing or recreational purposes. In such cases, airworthiness certification may not be mandatory for all classes of UAS and the participation of such UAS, operating in the designated sites, in the UTM Ecosystem for this operational scenario may be voluntary. However, it may require compliance with other standard operating procedures as defined by the regulator from time to time.
• Scenario 2: Flying within Visual Line of Sight (VLOS) in Uncontrolled Airspace- A vast variety of commercial applications like surveying, mapping, agriculture spraying, cinematography would be carried out in uncontrolled airspace. UAS operations for such use cases are limited to visual line of sight with the remote pilot always in command. Further, flying in uncontrolled airspace significantly reduces the risk of a potential conflict with manned aircraft. However, the risk posed to ground assets is not mitigated. Such operational scenarios may mandate general airworthiness certification and requirement of standard equipment on board the UAS for participation in the UTM ecosystem.
• Scenario 3: Flying Beyond Visual Line of Sight (BVLOS) in Uncontrolled Airspace- Capabilities of Scenario 2 will be expanded to accommodate large scale applications like large scale surveying and mapping, long-range surveillance, linear asset inspection, etc. The volume of such UAS operations would also be high. In this scenario, the remote pilot would be in command of the UAS or would be able to at least take control of the UAS whenever required. Flying in uncontrolled airspace would again reduce the risk of a potential conflict with manned aircraft. Such operational scenarios may mandate a higher level of airworthiness certification in combination with additional on-board equipment pertinent for safe BVLOS operations and for participation in the UTM ecosystem.
• Scenario 4: Flying within Visual Line of Sight (VLOS) in Controlled Airspace- Airspaces over major metro cities fall in the controlled airspace and here are huge requirements of conducting UAS Operations for multiple use cases. Airworthiness requirements for this scenario may be similar to Scenario 1 with additional CNS equipment requirements for ATM systems.
• Scenario 5: Flying Beyond Visual Line of Sight (BVLOS) in Controlled Airspace– Scenario 4 may be extended for use cases like pipeline monitoring, power line inspection, etc for BVLOS operations in controlled airspace. Airworthiness requirements for this scenario may be similar to Scenario 2 with additional CNS equipment requirements for ATM systems.
• Scenario 6: Flying in No-Fly Zones– Flying over strategic installations like government administration buildings, defence installations, police and paramilitary installations, reserve forests, industrial assets of national significance may pose additional risk. In such operational scenarios, additional clearances from a safety, security and environmental perspective may be prescribed by the regulator.
• Scenario 7: Autonomous Operations- Autonomous operations help manage complex use cases like patrolling around sensitive areas, long-range deliveries, regular inspections of assets. Such use cases may require special airworthiness certification with a focus on higher reliability of the UAS, sophisticated Detect and Avoid systems and redundancy of flight-critical components. Filing of flight path and flight intent prior to the operation may be mandated by the regulator. Further, the regulator may mandate Bi-Modal control capabilities on the UAS for taking over control and command of the Autonomous UAS in case of emergencies.
• Scenario 8: Night Operations- The ability to operate at night is a crucial requirement for applications such as security and surveillance, emergency response. UAS with flight critical subsystems dependent on daylight may not be permitted for night operations. If the remote pilot uses visual reference or camera feed, in daylight, for control or navigation of the UAS, then such UAS may also not be permitted for night operations. Additional security and environment-related operating conditions may be mandated by the regulator.
• Scenario 9: Unmanned Aerial Mobility- Unmanned Aerial Mobility may follow conventional airworthiness standards of manned aircraft with additional equipment and operational requirements, some of which are as suggested below:

-pre-flight safety video

-real-time tracking

-two-way communication capabilities with the passenger(s) for contingencies

-alarm system to alert passengers and uninvolved persons in case of contingencies

-flight path information for the passenger

• Scenario 10: Swarming- UAS swarms may help increase the efficiency of conventional UAS operations like search and rescue operations. However, depending on the nature of swarm operations they may pose different complexities. Different ways of blocking airspace, identification of each UAS and the swarm as a whole, bimodal communication with each UAS and the swarm as a whole, submission of flight logs, etc maybe some of these. Due to the complexity of this operational scenario, it may be further defined in subsequent versions of this document.
• Scenario 11: Payload Management- Certain UAS operations like logistics UAS, spraying UAS or fuel-powered UAS may involve discharging of payloads in flight or consumption of fuel during operations. The maximum take-off weight of the UAS will vary in such operational conditions. In addition, many UAS are designed to carry a variety of payloads with different weights. This may present the need to certify airworthiness for a range of maximum take-off weights and different payload configurations. Further, the UAS, in any case, may not exceed its maximum take-off weight and the characteristics of the payloads being carried by the UAS should be pre-approved. Additional considerations should be made for clearing airspace when a payload is dropped or discharged from a UAS.

7. Development of UTM Business Rules- Provision of UTM service shall be based on common business rules applicable to UTM Service Providers (UTMSPs). Such business rules are required to ensure safety and security of UA operations conducted through UTMSPs and also to ensure safety and security of uninvolved persons and property, thereby reducing the risk of collateral damage to an acceptable level.
8. UTM Deployment Plan- The density of UAS operations and types of UAS Operations may vary in different geographical locations. Some locations may have a high density of operations whereas other remote locations may not have any operations at all. Also, some UAS operations may be relatively complex in nature due to the technology advancement and special requirements of the business case. Thus, different airspaces may have different levels of UAS traffic management requirements and the deployment plan of UTM services in India would play a key role in effectively managing UAS operations. Three primary strategies are generally considered while planning deployment of UTM systems in any country: ‘Single UTM Per Region Strategy’, ‘Multiple UTMs Per Region Strategy’ and ‘Hybrid Strategy’.

NASSCOM is analysing the UTM Policy in detail. Kindly email your inputs to komal[at]nasscom[dot]in by 23^rd  December 2020.

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