Aviation strategy — Remotely Piloted Aircraft Systems: Initial Appraisal of a European Commission Impact Assessment

14-04-2016

This note seeks to provide an initial analysis of the strengths and weaknesses of the European Commission's Impact Assessment on Safe Development of Drone  Operations. The main strengths of the IA are its solid information base, including the three supporting studies, as well as the presentation of the results of the public consultation throughout, and the examination of options against the proportionality criterion according to the new Better Regulation guidelines.However, the range of options considered appears to be rather limited, and descriptions are so general that it is very difficult to assess and compare them; for example, the criteria for categorising drone risks, and the question of how the certificates will be issued and by whom, are not explained at all. The IA reiterates throughout that several issues, such as drone risk categorisation, or factors defining an operation-centric approach to regulating drones, will be topics for new impact assessments accompanying future delegated acts. The absence of some more insight concerning the likely content of the measures to be adopted through delegated acts or for the use of such delegated acts is regrettable. Nevertheless, the categorisation of risks (what is a high or low risk operation) could have been explained in more detail, as not every aspect of drone rules is likely to depend only on technological development.A better illustrated and explained problem description, as well as more detailed descriptions of the policy options, would have contributed to better and clearer understanding of the impacts of the new proposal, especially for a reader who may not be familiar with existing civil aviation safety rules.

This note seeks to provide an initial analysis of the strengths and weaknesses of the European Commission's Impact Assessment on Safe Development of Drone  Operations. The main strengths of the IA are its solid information base, including the three supporting studies, as well as the presentation of the results of the public consultation throughout, and the examination of options against the proportionality criterion according to the new Better Regulation guidelines.However, the range of options considered appears to be rather limited, and descriptions are so general that it is very difficult to assess and compare them; for example, the criteria for categorising drone risks, and the question of how the certificates will be issued and by whom, are not explained at all. The IA reiterates throughout that several issues, such as drone risk categorisation, or factors defining an operation-centric approach to regulating drones, will be topics for new impact assessments accompanying future delegated acts. The absence of some more insight concerning the likely content of the measures to be adopted through delegated acts or for the use of such delegated acts is regrettable. Nevertheless, the categorisation of risks (what is a high or low risk operation) could have been explained in more detail, as not every aspect of drone rules is likely to depend only on technological development.A better illustrated and explained problem description, as well as more detailed descriptions of the policy options, would have contributed to better and clearer understanding of the impacts of the new proposal, especially for a reader who may not be familiar with existing civil aviation safety rules.