Europaudvalget 2022
KOM (2022) 0652
Offentligt
2639143_0001.png
EUROPEAN
COMMISSION
Brussels, 29.11.2022
SWD(2022) 366 final
COMMISSION STAFF WORKING DOCUMENT
EU Drone Sector state of play
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
‘A Drone Strategy 2.0 for a Smart and Sustainable Unmanned Aircraft Eco-System in
Europe’
{COM(2022) 652 final}
EN
EN
 kom (2022) 0652 - Ingen titel
Table of Contents
1
2
3
3.1
3.2
3.3
4
4.1
Introduction ....................................................................................................................................... 3
Scope of the strategy ......................................................................................................................... 5
Consultation Strategy ....................................................................................................................... 6
Roadmap summary result analysis ...................................................................................................... 6
Open Public Consultation ................................................................................................................... 7
Informal Drone Experts Group and Drone Leaders’ Group report ..................................................... 7
EU drone policy up to now (“Drone Strategy 1.0”) ....................................................................... 7
Formulating a policy ........................................................................................................................... 7
4.1.1
Communication for “A new era for aviation Opening the aviation market to the
civil use of remotely piloted aircraft systems (RPAS) in a safe and sustainable
manner” .............................................................................................................................. 7
4.1.2
High Level Drone Conferences in Riga (2015), Warsaw (2016), Helsinki
(2017), Amsterdam (2018) ................................................................................................. 8
4.1.3
Communication for “an Aviation Strategy for Europe” ..................................................... 8
4.1.4
Communication for a “Sustainable and Smart Mobility Strategy – putting
European transport on track for the future”........................................................................ 9
4.1.5
Communications on “the EU Security Union Strategy” and “Counter-Terrorism
Agenda” ............................................................................................................................. 9
4.1.6
Communication for an “Action Plan on synergies between civil, defence and
space industries”, including a “Drones Technologies” Flagship ...................................... 10
4.1.7
Communication on “the New EU Urban Mobility Framework” and publication
of Urban Air Mobility guidelines ..................................................................................... 10
4.1.8
Communication on a “Roadmap on critical technologies for security and
defence” and “Versailles” Declaration ............................................................................. 10
4.1.9
Joint Communication on the “the Defence Investment Gaps Analysis and Way
Forward” .......................................................................................................................... 11
Developing and implementing a regulatory framework ................................................................... 12
4.2.1
Adoption of Regulation (EU) 2018/1139 on common rules in the field of civil
aviation (2018) ................................................................................................................. 12
4.2.2
Adoption of detailed implementing rules allowing effective drone operations
and the development of industry standards ...................................................................... 12
4.2.2.1
‘Open’ category ............................................................................................................... 13
4.2.2.2
‘Specific’ category ........................................................................................................... 14
4.2.2.3
‘Certified’ category .......................................................................................................... 14
4.2.3
Adoption of a regulatory framework for the provision of U-space services .................... 15
Research & Innovation on drones and related systems ..................................................................... 16
4.3.1
Single European Sky ATM Research (SESAR)............................................................... 16
4.3.2
European Climate, Infrastructure and Environment Executive Agency (CINEA) ........... 17
4.3.3
European defence research and innovation ...................................................................... 18
Presentation of the EU drone eco-system today ........................................................................... 19
The elements of the eco-system ........................................................................................................ 19
Drone services offered today ............................................................................................................ 20
5.2.1
Aerial operations .............................................................................................................. 20
5.2.2
Innovative air mobility ..................................................................................................... 20
4.2
4.3
5
5.1
5.2
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
Office: DM24 05/123 - Tel. direct line +32 229-95146
[email protected]
 kom (2022) 0652 - Ingen titel
2639143_0003.png
5.3
6
6.1
6.2
Drones as an emerging sector of the economy .................................................................................. 21
The potential benefits of a viable drone eco-system in Europe ................................................... 22
Growth and Jobs ............................................................................................................................... 22
Decarbonisation and circular economy ............................................................................................. 25
6.2.1
Decarbonisation ............................................................................................................... 25
6.2.2
Circular economy ............................................................................................................. 28
Digitalisation ..................................................................................................................................... 28
Vision and strategic objectives ....................................................................................................... 30
Vision ................................................................................................................................................ 30
Strategic objectives ........................................................................................................................... 31
SMART objectives ........................................................................................................................... 31
The elements of a thriving EU drone eco-system in 2030 ............................................................ 32
Building the European drone services market................................................................................... 32
8.1.1
Improving airspace capabilities (U-space development and integration with Air
Traffic Management) ....................................................................................................... 33
8.1.2
Facilitating Aerial Operations .......................................................................................... 35
8.1.3
Developing Innovative Air Mobility ................................................................................ 37
8.1.4
Ensuring societal acceptance............................................................................................ 38
8.1.5
Promoting the human dimension (knowledge, training, competences) ............................ 40
Strengthening European civil, security and defence industry capabilities and synergies ................. 42
8.2.1
Providing funding and financing ...................................................................................... 42
8.2.2
Identifying strategic technology building blocks ............................................................. 44
8.2.3
Enabling testing and demonstrations................................................................................ 45
8.2.4
Driving for common standards......................................................................................... 46
8.2.5
Increasing counter-UAS capabilities and system resilience ............................................. 48
Action Plan ...................................................................................................................................... 53
Synopsis consultation report .......................................................................................................... 56
Introduction ....................................................................................................................................... 56
Feedback to the Roadmap ................................................................................................................. 57
Open Public Consultation (OPC) ...................................................................................................... 61
Drone Leaders’ Group (DLG)........................................................................................................... 66
Targeted surveys and Interviews....................................................................................................... 66
Targeted consultations – presentation of responses .......................................................................... 67
6.3
7
7.1
7.2
7.3
8
8.1
8.2
9
A
A.1
A.2
A.3
A.4
A.5
A.6
Page 2 / 86
 kom (2022) 0652 - Ingen titel
2639143_0004.png
COMMISSION STAFF WORKING DOCUMENT
EU Drone Sector state of play
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
‘A Drone Strategy 2.0 for a Smart and Sustainable Unmanned Aircraft Eco-System
in Europe’
1
I
NTRODUCTION
This Staff Working Document accompanies the Communication from the Commission on ‘A
Drone Strategy 2.0 for a Smart and Sustainable Unmanned Aircraft Eco-System in Europe’,
which sets out the actions needed to ensure that a drone eco-system is deployed in the European
Union in a way that supports the goals of the European Green Deal
1
, the digital transformation of
the European Economy and of the Sustainable and Smart Mobility Strategy
2
. The actions set out
in the Communication should ensure safe, smart, resilient, inclusive and clean drone operations in
the European Union.
The development of drones (unmanned aircraft systems) services supported by a competitive
industry can strongly support Europe’s twin transition to a green and digital economy and
contribute to the post-COVID 19 recovery as well as the future resilience of the EU economy.
From daily commuting, goods delivery to the development of a wide spectrum of new
applications and services, drones can become an enabler of our economic and social life and a
driving force of the further digitalization of the European economy.
The European Green Deal is a new growth strategy for the EU, which calls for the reduction of
greenhouse gas emissions in all sectors of the economy, including transport and the protection of
the human health. In this context, the transport system as a whole should be made smart and
sustainable. The Communication on the European Green Deal announced therefore a strategy for
sustainable and smart mobility, which was adopted by the Commission in December 2020. In the
Sustainable and Smart Mobility Strategy, the Commission announced its intention to adopt a
Drone Strategy 2.0 in 2022 to reap the full potential offered by drones to contribute to the
safeguarding of a well-functioning single market. Drone applications can also strongly contribute
to the digital transformation of many businesses and help to meet Europe’s Digital Strategy
3
targets.
In order to enhance the competitiveness of the European drone eco-system as well as Europe’s
security and defence capabilities, the Commission adopted in February 2020 an ‘Action plan on
1
https://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1588580774040&uri=CELEX%3A52019DC0640
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020DC0789
https://eur-lex.europa.eu/resource.html?uri=cellar:12e835e2-81af-11eb-9ac9-
01aa75ed71a1.0001.02/DOC_1&format=PDF
2
3
Page 3 / 86
 kom (2022) 0652 - Ingen titel
2639143_0005.png
synergies between civil, defence and space industries’
4
, and which includes a ‘EU Drones
Technologies Flagship’ project aiming at reaping synergies between the civil, including counter-
drones technologies, and military use of drones. This Action Plan also identifies autonomous
systems including drones as a critical technology for which Europe needs to achieve
technological sovereignty. These objectives were reinforced by the Versailles Declaration
adopted by the Member States in March 2022
5
which marked the EU decision to take more
responsibility for its security and take further decisive steps towards building its European
sovereignty, reducing our dependencies and designing a new growth and investment model for
2030. In this respect, the Declaration addressed three key dimensions, first, enhance security and
defence capabilities, second, reduce energy dependencies; and third build a more robust
economic base. Among those measures, the Member States agreed to foster synergies between
civilian, defence and space research and innovation, and invest in critical and emerging
technologies and innovation for security and defence. They also agreed to take measures to
strengthen and develop EU’s defence industry, including SMEs.
To reach its goals, the EU needs to ensure the safe and efficient development of a drone
ecosystem, addressing related societal concerns such as safety, security, privacy and
environmental protection, while simultaneously nurturing a sustainable economic environment
for the European drone industry to grow. Although EU citizens expressed generally positive
attitudes to new forms of air mobility, a study
6
led by the European Union Aviation Safety
Agency (EASA) has shown that safety and noise pollution are on top of EU citizens’ concerns, in
a list that also includes cybersecurity risks and the potential impact on wildlife. Therefore, there
are many other issues beyond safety that must also be addressed in order to ensure the social
acceptance of drones, such as environmental and privacy issues.
In 2014 and 2015, the Commission adopted respectively a Communication on a new era for civil
aviation
7
and the Aviation Strategy for Europe
8
which highlighted that safety is crucial to the
successful integration of drones in the airspace as well as the development of this industry and
the services and applications enabled by drones.
The Aviation Strategy for Europe set an objective to establish a basic legal framework for the
safe development of drone operations in the EU and to prepare more detailed rules that allow
drone operations and the development of industry standards. This regulatory framework is now
largely in place.
New actions are needed at EU level because the drone sector is developing rapidly with new
innovative ways of using drones emerging at a fast pace requiring an assessment of the regulatory
and enabling framework to ensure that these new services can thrive in the EU internal market
and globally. Related technologies such as radiofrequency communication
9
, Artificial
Intelligence
10
, advanced sensors and improvements in power sources are opening new prospects.
4
Communication for an “Action Plan on synergies between civil, defence and space industries”,
adopted in February 2021 including a “Drones Technologies” Flagship.
https://www.consilium.europa.eu/media/54773/20220311-versailles-declaration-en.pdf
EASA Study on the societal acceptance of Urban Air Mobility
https://www.easa.europa.eu/sites/default/files/dfu/uam-full-report.pdf
in
Europe
2021,
5
6
7
8
9
10
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52014DC0207&from=EN
https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A52015DC0598
https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=celex%3A32014L0053
https://digital-strategy.ec.europa.eu/en/library/proposal-regulation-european-approach-artificial-
intelligence
Page 4 / 86
 kom (2022) 0652 - Ingen titel
2639143_0006.png
Drones are used as daily tools in ever broadening, data-demanding economic sectors such as
agriculture, construction, surveillance, filming, healthcare, energy, environment, public safety
and security. Future perspectives include the use of drones, for example, as platforms for
communication hubs or weather or pollution monitoring. Drones are also both users and enablers
of Global Navigation Satellite System (GNSS) services, they can be used to complement
Copernicus imaging, as well as to complement Secure Connectivity services. Conversely, the fact
that customised drones can also be used for illegal purposes should be addressed.
In the transport sector, the use of drones for deliveries is already tested in many countries. First
pilot trials in passenger transport in Europe are expected to take place within the next few years.
At the same time, it is important that Europe safeguards its open strategic autonomy in this area,
as recognised in the “Action plan on synergies between civil, defence and space industries”
11
.
Against this background, the existing strategy from 2015 has been overtaken by these new
developments and a new strategy is needed at EU level to provide a forward-looking vision for
the future holistic development of the sector.
This Staff Working Document gives an overview of the Commission services’ assessment of the
challenges that the drone sector faces as well as the analysis and data underpinning the new
Drone Strategy 2.0. With that, it aims to support the entire drone eco-system, including cities,
regions and Member States in the development of drone activities for mobility and services.
2
S
COPE OF THE STRATEGY
The term “drone” is the layman term for “Unmanned Aircraft Systems” which means an
unmanned aircraft and the equipment to control it remotely.
The term “Urban Air Mobility” has been increasingly referred to in the context of new Urban
Mobility initiatives. Due to the lack of a definition and in line with the regulatory operation
centric approach, EASA has developed the notion of Innovative Aerial Services (IAS). IAS
correspond to the set of operations and/or services that are of benefit to citizens and to the
aviation market and that are enabled by new airborne technologies – the operations and/or
services include both the transportation of passengers and/or cargo and aerial operations (e.g.
surveillance, inspections, mapping, telecommunication networking). IAS can be further divided
into “aerial operations” (surveillance, inspection, imaging, …), as well as a whole new emerging
market called Innovative Air Mobility (IAM)
12
(including international, regional and urban air
mobility).
11
12
https://ec.europa.eu/info/sites/info/files/action_plan_on_synergies_en_0.pdf
The concept of Innovative Air Mobility (‘IAM’) is to accommodate operations with novel aircraft
designs (that do not automatically fall under one of the known categories, but which have VTOL
capabilities for take-off and landing, specific (distributed) propulsion features, can be operated in
unmanned configuration, etc.), that are conceived to offer a new air mobility of people and cargo, in
particular in congested (urban) areas, based on an integrated air and ground-based infrastructure. IAM
describes a diverse array of aircraft types (such as manned and unmanned), whose designs are enabled
by ongoing innovations particularly in the areas of hybrid and electrification of propulsion systems,
energy storage, lightweight materials, digitalisation and automation. These innovations have made
possible an array of novel designs spanning multi-rotor, tilt wing, tilt-rotor, powered wing, offering
short take-off and landing (STOL) through to vertical take-off and landing (VTOL) capabilities.
Page 5 / 86
 kom (2022) 0652 - Ingen titel
2639143_0007.png
Innovative Aerial Services
Innovative Air Mobility
Aerial
Operations
Urban
Air Mobility
Regional
Air Mobility
International
Air Mobility
Innovative Aerial Services
For further reference in the following text, the term ‘drones’ will be used to cover all vehicles
involved in Innovative Aerial Services including manned eVTOL, as well as Unmanned Aircraft
Systems used in the defence sector. However, as explained in the Drone Strategy 2.0, the purpose
is not to address the conditions of operations of military drones, but rather seeks to identify areas
of cross-fertilisation whereby defence projects may benefit from innovative developments of
SMEs for civilian drones and that civil aeronautics benefit from developments in the field of
defence.
3
C
ONSULTATION
S
TRATEGY
As part of its consultation strategy, the Commission announced in the roadmap for the
preparation of the Drone Strategy 2.0 the launching of an online Open Public Consultation
(OPC), desk research as well as targeted stakeholder consultations in the context of a preparatory
Fact finding study
13
. Consultation tools used for collecting information for the study included
surveys/questionnaires, interviews, stakeholder workshop and meetings of the informal drone
expert group. The targeted consultations also included consultations of the defence community
by Commission services to explore civil/military synergies in the development of drone
technologies.
The
stakeholders
that
have
been
identified
included
national
competent
authorities/administrations, drone operators and producers, U-space and air navigation service
providers, local rural and urban communities, airport operators, and relevant European
associations.
3.1 Roadmap summary result analysis
The Commission published the intention to develop the Drone Strategy 2.0 on the website “Have
your Say”, together with the roadmap for the Drone Strategy 2.0
14
. 45 comments were received
on the roadmap in the period between 4 June and 2 July, 2021. The analysis of the comments
received to the Roadmap is available in Annex A.
13
14
Fact finding study preparing a “Drone Strategy 2.0”, Final report”, 2022, Ecorys
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13046-A-Drone-strategy-20-
for-Europe-to-foster-sustainable-and-smart-mobility_en
Page 6 / 86
 kom (2022) 0652 - Ingen titel
2639143_0008.png
3.2 Open Public Consultation
Citizens and organisations were invited to contribute to the online public consultation which was
open between 8 October 2021 and 31 December 2021. A total of 258 comments were received.
The analysis of the comments can be found in Annex A.
3.3 Informal Drone Experts Group and Drone Leaders’ Group report
The Commission also used its existing consultation platforms for the development of the Drone
Strategy 2.0, notably the Informal Drone Experts Group
15
. In addition, in order to give a high-
level steer to the development of the Drone Strategy 2.0, the Commission created on an ad hoc
basis a ‘Drone Leaders’ Group’. In total, the Drone Leaders’ Group held four meetings between
October 2021 and April 2022, collecting the views of its 26 members representing all core
stakeholder groups whether from the national authorities, EU agencies, manned or unmanned
aviation. The Group also organised three hearings with the members of the Informal Drone
Experts Group addressing the following issues:
Hearing 1 on Urban Air Mobility (cargo/passengers) and U-space (held on 18 February 2022)
Hearing 2 on Enhancing drone services including the SME dimension (held on 25 February
22)
Hearing 3 on Developing Civil-Defence industry synergies and technology building blocks
(held on 8 March 2022).
The Drone Leaders’ Group delivered a report including its Vision for the Drone Sector in 2030,
identified key performance indicators and identified the main obstacles (and solutions) for the
development of the EU drone services market. The most cited obstacles were: societal issues
(privacy, security, noise and visual nuisances); technology (absence of standards, immature
technologies, problems of integration); regulation (‘specific’ and ‘certified’ categories, vertiports,
rules of the air, ATM-UTM integration); lack of investment and funding; and market issues
(access to airspace, fragmentation). The Vision proposed by the Drone Leaders Group and a list
of SMART performance indicators are presented in paragraph 7.1 below and the full report of the
Drone Leaders’ Group is available in the Appendix of the synopsis consultation report.
4
EU
DRONE POLICY UP TO NOW
(“D
RONE
S
TRATEGY
1.0”)
4.1 Formulating a policy
4.1.1 Communication for “A new era for aviation Opening the aviation market to
the civil use of remotely piloted aircraft systems (RPAS) in a safe and
sustainable manner”
The European Summit of 19 December 2013 called for action to enable the progressive
integration of drones into civil airspace from 2016 onwards. This Communication focused on
drones for civil use and responded to the call of the European manufacturing and service industry
to remove barriers to the introduction of RPAS in the European single market. It set out the
15
Commission
Expert
group
(E03533).
https://ec.europa.eu/transparency/expert-groups-
register/screen/expert-groups/consult?lang=en&groupID=3533.
Page 7 / 86
 kom (2022) 0652 - Ingen titel
2639143_0009.png
Commission's views on how to address drone operations in a European level policy framework
which would enable the progressive development of the commercial drone market while
safeguarding the public interest. The regulatory action and the related research and development
efforts were to be built on existing initiatives involving a number of actors: the European
Aviation Safety Agency, the national Civil Aviation Authorities, the European Organisation for
Civil Aviation Equipment (EUROCAE), EUROCONTROL, the SESAR Joint Undertaking
(SJU), the European Defence Agency, the European Space Agency, the drone manufacturing
industry and operators.
4.1.2 High Level Drone Conferences in Riga (2015), Warsaw (2016), Helsinki
(2017), Amsterdam (2018)
The Riga Drone Declaration of 2015 stated that drones need to be treated as new types of aircraft
with proportionate rules based on the risk of each operation and EU rules for the provision of
drone services should be developed quickly as well as technologies and standards ensuring the
full integration of drones in the European airspace.
The Warsaw Drone Declaration of 2016 called for the swift development of a drone ecosystem
that is simple to use, affordable, commercially, and operationally friendly, yet capable of
addressing all societal concerns such as safety, security, privacy and environmental protection.
The Declaration also called for the safety rules to be kept simple, proportionate to the risk of the
operation, performance-based, future-proofed, and based on global standards. Calling for urgent
action on the airspace dimension, in particular the development of the concept of a U-space, a set
of digital services enabling the safe scaling up of routine drone operations, the development of
the U-Space was mentioned for the first time in a Declaration.
The Helsinki Drone Declaration of 2017 supported the adoption of the new EASA Basic
Regulation as providing the foundation for a European legislative framework for drone services.
The growing fragmentation along national boundaries of the EU drone services market was also
noted with concerns, indicating the urgent need for close cooperation between European and
national authorities. The Declaration called for the opening of the drone services market and in
particular, the introduction of competition between U-Space providers to ensure that services are
delivered at the best possible cost-benefit ratio while allowing fair and timely access to airspace
for drone operators.
The Amsterdam Drone Declarations of 2018 called for a push towards integrated smart mobility
and fair access to all dimensions of public space, inviting cities and regions, also within the Smart
Cities initiative, to co-create with the citizens the public conditions and the infrastructure for
integrated air and ground smart mobility solutions to flourish and for the timely delivery of the
U-space regulatory framework.
4.1.3 Communication for “an Aviation Strategy for Europe”
In 2015, the Commission adopted its Communication on “an Aviation Strategy for Europe”
highlighting the fact that while safety is crucial it cannot be looked at in isolation. In this
Communication, drone technologies were considered as a major opportunity both for the
European aeronautical manufacturing industry, especially for small and medium sized
enterprises, and for the many aviation and non-aviation businesses that will be able to integrate
drones into their activities and increase their efficiency and competitiveness. The Commission
stated its intention to propose a basic legal framework for the safe development of drone
operations in the EU, as part of the new basic aviation safety Regulation replacing Regulation
Page 8 / 86
 kom (2022) 0652 - Ingen titel
2639143_0010.png
216/2008 and tasked the European Union Aviation Safety Agency with preparing more detailed
rules allowing the drone operations and the development of industry standards.
4.1.4 Communication for a “Sustainable and Smart Mobility Strategy – putting
European transport on track for the future”
In its 2020 Sustainable and Smart Mobility Strategy, the Commission addressed the future
challenges and opportunities for European mobility and the transport sector. From daily
commuting to the proper functioning of global supply chains, mobility is an enabler of our
economic and social life. As the second-largest area of expenditure for European households, the
transport sector contributes 5% to European GDP and directly employs around 10 million
workers. Whilst mobility brings many benefits for its users, it is not without costs for our society.
By far, the most serious challenge facing the transport sector is to significantly reduce its
emissions and become more sustainable. At the same time, this transformation offers
opportunities for better quality of life, and for European industry across the value chains to
modernise, create high-quality jobs, develop new products and services, strengthen
competitiveness and pursue global leadership as other markets are moving fast towards zero-
emission mobility.
In its Sustainable and Smart Mobility Strategy, the Commission announced its intention to adopt
a Drone Strategy 2.0 in 2022 setting out possible ways to guide the further development of this
technology and its regulatory and commercial environment. .
4.1.5 Communications on “the EU Security Union Strategy” and “Counter-
Terrorism Agenda”
In 2020, the Commission also adopted two Communications which both introduced new policy
actions to counter possible threats that drones could pose. The EU
Security Union Strategy
16
and
Counter-Terrorism
Agenda
17
stated that the threat of non-cooperative drones is a serious
concern in Europe that needs to be addressed. In the Counter-Terrorism Agenda in particular, the
Commission committed to look into the possibility of releasing an EU handbook for securing
cities from non-cooperative drones This initiative has expanded and will now include “Protection
against Unmanned Aircraft Systems – Handbook on Counter-UAS for Critical Infrastructure and
Public Spaces” and “Protection against Unmanned Aircraft Systems – Handbook on Principles
for Physical Hardening of Buildings and Sites”.
The Commission introduced the Directive on the resilience of critical entities (CER Directive)
18
in December 2020. This directive will reflect the priorities of the EU Security Union Strategy and
address a wide range of non-cyber threats against critical entities and their infrastructure. It will
cover eleven sectors, including the transport sector. The proposed Directive on the resilience of
critical entities will introduce obligations on Member States and critical entities to conduct risk
assessments and on critical entities to take technical, security and organisational measures to
ensure their resilience against identified risks. Because of their nature, the threat of non-
cooperative drones will be an integral part of their risk assessments.
16
17
COM(2020) 605 final of 24 July 2020
COM (2020) 795 final of 9 December 2020
COM(2020) 829 final of 16 December 2020. The European Parliament and the Council reached
political agreement on the proposed Directive on 28 June 2022 (Security Union (europa.eu)
18
Page 9 / 86
 kom (2022) 0652 - Ingen titel
2639143_0011.png
4.1.6 Communication for an “Action Plan on synergies between civil, defence and
space industries”, including a “Drones Technologies” Flagship
The Commission adopted in February 2021 a Communication for an “Action Plan on synergies
between civil, defence and space industries”
19
, including a flagship project for EU drone
Technologies aimed to enhance the competitiveness of EU industry in this critical technology
area. This Communication aimed to promote the competitiveness of the European drone eco-
system, as well as, Europe’s defence capabilities, by reaping synergies between the civil and
military use of drones. It highlighted that the flagship project forms part of an overall ambition to
be further set out in the “Drone Strategy 2.0”. This Action Plan also identifies autonomous
systems including drones as a critical technology for which Europe needs to achieve
technological sovereignty.
4.1.7 Communication on “the New EU Urban Mobility Framework” and
publication of Urban Air Mobility guidelines
To support the transition to cleaner, greener, and smarter mobility, in line with the objectives of
the European Green Deal, the Commission adopted in November 2021 four proposals that will
modernise the EU’s transport system
20
. By increasing connectivity and shifting more passengers
and freight to rail and inland waterways, by supporting the roll-out of charging points, alternative
refuelling infrastructure, and new digital technologies, by placing a stronger focus on sustainable
urban mobility, and by making it easier to choose different transport options in an efficient
multimodal transport system, the proposals will contribute to putting the transport sector on track
to cutting its emissions by 90%.
The new framework announced a more ambitious approach to sustainable urban mobility
planning (SUMPs)
21
and related indicators. Such new and integrated approaches to using and
managing urban space includes urban air mobility (e.g. drones).
This complements the proposal for revised guidelines for the Trans-European Transport Network,
according to which the largest 424 EU cities on the TEN-T network should adopt a sustainable
urban mobility plan by 2025 and collect relevant data.
To provide guidance on Urban Air Mobility (UAM) as specific topic related to Sustainable Urban
Mobility Planning, UIC² – the UAM Initiative Cities Community or EU’s Smart Cities
Marketplace – released a practitioner briefing in December 2021
22
.
4.1.8 Communication on a “Roadmap on critical technologies for security and
defence” and “Versailles” Declaration
The roadmap on critical technologies for security and defence
23
, adopted in February 2022, is
part of a number of Commission-led initiatives in areas critical for defence and security within
the European Union. It is a concrete step towards a more integrated and competitive European
19
20
21
22
https://ec.europa.eu/info/sites/info/files/action_plan_on_synergies_en_0.pdf
https://ec.europa.eu/commission/presscorner/detail/en/ip_21_6776
https://www.eltis.org/resources/tools/sump-self-assessment-tool
https://ec.europa.eu/info/eu-regional-and-urban-development/topics/cities-and-urban-
development/city-initiatives/smart-cities_en
COM(2022) 61 final
23
Page 10 / 86
 kom (2022) 0652 - Ingen titel
2639143_0012.png
defence market, particularly by enhancing cooperation within the EU, thereby building scale,
mastering costs and enhancing operational effectiveness. The Commission thus provides input in
the run-up to the EU Strategic Compass on Security and Defence.
The Roadmap outlines a path to enhance the competitiveness and resilience of the EU security
and defence sectors, notably by:
inviting Member States to contribute actively to the Observa
tory of critical technologies
currently being established;
encouraging dual-use research and innovation at EU level.
Two preliminary case studies have been carried out so far, including one on the defence
technology area of autonomous systems.
The “Versailles Declaration”
24
, adopted by the heads of EU Member States, emphasised the need
to foster synergies between civilian, defence and space research and innovation, and invest in
critical and emerging technologies and innovation for security and defence.
4.1.9 Joint Communication on the “the Defence Investment Gaps Analysis and
Way Forward”
The analysis of defence investment gaps and the way forward
25
, adopted in May 2022, is a
response by the Commission and the High Representative to a task given by the European
Council at the Versailles Summit. It presents an analysis of the defence investment gaps, and
propose further measures and actions necessary to strengthen the European defence industrial and
technological base, including defence related drone activities. It also responds to the call made in
the context of the Conference of the Future of Europe for stronger EU action in defence.
The Joint Communication presents a new level of ambition to build a stronger Europe in defence.
It focuses in particular on the joint acquisition of military equipment, on strategic defence
programming to set clearer priorities, and on the support to the European industrial base,
including the strengthening of the European defence R&D framework, the European Defence
Fund (EDF).
The joint communication proposes to work on strategic short-, medium- to long-term capabilities
to improve Europe’s defence capabilities. These include development and operationalisation of
the medium-altitude “Eurodrone” (MALE RPAS) – which forms part of PESCO and EDF
projects. Also, in the short- to medium-term developing and procuring counter drone-capabilities
and weaponised medium-sized drones are identified as priorities.
24
https://www.consilium.europa.eu/en/press/press-releases/2022/03/11/the-versailles-declaration-10-11-
03-2022
JOIN(2022) 24 final
25
Page 11 / 86
 kom (2022) 0652 - Ingen titel
2639143_0013.png
4.2 Developing and implementing a regulatory framework
4.2.1 Adoption of Regulation (EU) 2018/1139 on common rules in the field of civil
aviation (2018)
The adoption of the new EASA Basic Regulation
26
repealing Regulation (EC) 216/2008 was a
landmark for the implementation of an EU wide drone policy. The new Regulation extended the
scope of EU competence to all drones, irrespective of their weight or size, including the design,
production, maintenance and operation of unmanned aircraft, their engines, propellers, parts and
non-installed equipment, as well as the equipment to control unmanned aircraft remotely. The
operation-centric approach reflects the fact that drones can be used for a large number of
missions (recreational, exploration, delivery, etc.) that all display different levels of risks for
other airspace users. This complexity could not be reflected by a framework only based on
criteria such as weight. The operation-centric approach also ensures that new developments are
not hampered by unnecessarily heavy and costly rules and procedures, which is in line with the
Commission's Better Regulation approach. The new EASA Basic Regulation gave the
Commission the legal power to adopt implementing and delegated acts in order to implement the
essential requirements contained in the Regulation and guarantee a high and uniform level of
civil aviation safety.
4.2.2 Adoption of detailed implementing rules allowing effective drone operations
and the development of industry standards
In line with the operation centric approach embedded in Regulation 2018/1139, the EU drone
regulatory framework should therefore be able to address safety and security concerns of
different types of drones and operations, keeping in mind the risk level of the operation.
Accordingly, the Commission adopted in 2019 two Regulations: Commission Delegated
Regulation 2019/945
27
on unmanned aircraft systems and on third-country operators of
unmanned aircraft systems and Implementing Regulation 2019/947
28
on the rules and procedures
for the operation of unmanned aircraft.
Limited to outdoor operations, Implementing Regulation 2019/947 applies since 31 December
2020. It lays down detailed provisions and conditions for the operation of drones, including the
requirements to qualify as a remote pilot, minimum age of the pilot, requirements regarding the
drones' airworthiness requirements, risk assessments, cross border operations, registration of the
drone and its operator and competent authority. Regulation 2018/1139 introduces an approach to
safety rules proportionate to the risk of the operation conducted by the aircraft. This approach is
reflected in Article 3 of the Commission Implementing Regulation (EU) 2019/947. This article
defines 3 categories of UAS operations, ‘open’, ‘specific’ and ‘certified’, corresponding to three
26
Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common
rules in the field of civil aviation and establishing a European Union Aviation Safety Agency, and
amending Regulations (EC) No 2111/2005, (EC) No 1008/2008, (EU) No 996/2010, (EU) No
376/2014 and Directives 2014/30/EU and 2014/53/EU of the European Parliament and of the Council,
and repealing Regulations (EC) No 552/2004 and (EC) No 216/2008 of the European Parliament and
of the Council and Council Regulation (EEC) No 3922/91. OJ L 212, 22.8.2018, p. 1
Commission Delegated Regulation (EU) 2019/945 of 12 March 2019 on unmanned aircraft systems
and on third-country operators of unmanned aircraft systems, OJ L 152, 11.6.2019, p. 1
Commission Implementing Regulation (EU) 2019/947 of 24 May 2019 on the rules and procedures for
the operation of unmanned aircraft, OJ L 152, 11.6.2019, p. 45
27
28
Page 12 / 86
 kom (2022) 0652 - Ingen titel
2639143_0014.png
levels of risks (low, medium, high). They are addressed by three different set of rules, all
including a combination of rules on the design of the UAS and on its operations.
The conversion of existing authorisations, certificates and declarations issued under the previous
(nationally applicable) regulations could take place until 31 December 2022. A limited number of
provisions will apply as from 1 January 2024, e.g. European Standard Scenarios or the use of
drones in the Open category (linked to the creation of appropriate European standards).
Commission Implementing Regulation 2019/947 allows Member States to further specify certain
elements such as the minimum age for remote pilots and geographical zones for safety, security,
privacy, and environmental reasons. Member States may:
prohibit certain or all drones operations, request particular conditions for certain or all drones
operations or
request a prior operational authorisation for certain or all drones operations;
subject drone operations to specified environmental standards;
allow access to certain drone classes only;
allow access only to drone equipped with certain technical features, in particular remote
identification systems or geo awareness systems.
Commission Delegated Regulation 2019/945 entered into force in June 2019 and was
immediately applicable. It lays down the technical requirements relating to the unmanned aircraft
itself. More specifically, this act lays down the regulation on:
the product requirements for the design and manufacture of drone;
the obligations of economic operators, importers, and distributors;
the definition and requirement of presumption of conformity as well as the type of drone
whose design, production and maintenance shall be subject to certification;
making drones intended for use in the 'open' category and remote identification add-ons;
third country drone operators when they conduct drone operation pursuant to Implementing
Regulation 2019/947 within the single European sky airspace.
Under Commission Implementing Regulation 2019/947, national competent authorities must
establish and maintain registration systems for drones, whose design is subject to certification
and for drone operators whose operation may present a risk to safety, security, privacy, and
protection of personal data or the environment.
On visual and noise pollution, limits reflecting the state of the art in the market have been
introduced for small drones with a weight of less than 4 kg and which may be flown close to
people by virtue of Regulation (EU) 2019/945. These limits will become even lower over time. In
addition, further local noise constraints can be set in respect of ‘UAS geographical zones’.
Directive 2002/49/EC on noise also imposes to all agglomerations of more than 100.000 people
to prepare action plans to manage and limit the noise from air operations including drones.
On emissions, Regulation (EU) 2019/945 imposes that small drones must be powered by
electricity. If managed properly, drone operations, particularly in urban area, can contribute to the
reduction of air pollutants, rather than causing additional adverse health effects for the citizens.
‘Open’ category
4.2.2.1
4.2.2.1
The operations in the ‘open’ category are performed with drones with a Maximum Take Off
Mass of 25kg, marked with a Class Identification Label, complying with the technical
requirements set out in Regulation 2019/945, always maintaining a Visual Line of Sight between
the drone and the remote pilot and at a maximum altitude of 120 meters. They present the lowest
Page 13 / 86
 kom (2022) 0652 - Ingen titel
2639143_0015.png
risk of operations and therefore do not require any prior operational authorisation, nor an
operational declaration by the drone operator.
‘Specific’ category
4.2.2.2
4.2.2.2
If one of the conditions of the ‘open’ category cannot be met, the operation is considered as
riskier than allowed under the 'open' category and must then comply with either the ‘specific’ or
the ‘certified’ category conditions, depending on the level of the risk. If the operations falls in the
‘specific’ categories, the drone operators has several possibilities:
First, to carry out a full operational risk assessment (Specific Operation Risk Assessment
(SORA)) on which basis the competent authority may grant an operational authorisation.
Secondly, submit an operational declaration of compliance with so-called European ‘standard
scenarios’ (as defined in Annexes of Regulation 2019/947) to the competent authority. Such a
declaration to the competent authority must contain:
administrative information about the drone operator;
a statement that the operation satisfies the operational requirement of a standard scenario;
the commitment of the drone operator to comply with the relevant mitigation measures;
confirmation by the drone operator that an appropriate insurance cover will be in place, if
required by Union or national law.
Once the competent authority has confirmed receipt of a complete declaration, the operation may
take place.
Thirdly, a light UAS (Unmanned Aircraft System) operator certificate (LUC) which gives the
privilege to the Drone operator to start operations without requiring a prior authorisation.
In the situation where an operator intends for the operation to take place partially or entirely in
the airspace of a Member State other than the one of registration, the drone operator must provide
the competent authority of the Member State of the intended operation with an application
including: (1) a copy of the operational authorisation granted (in the initial Member State); and
(2) the location(s) of the intended operation and eventual mitigation measures.
The competent authority of the sought Member State will assess the intended operation and
operational authorisation granted by the initial Member State and can then provide confirmation
that the operation may be undertaken.
In the event where a declaration of compliance has been made to another competent authority
than the one of the member state where the operation would take place, then the operator
provides the competent authority of the member state of the intended operation with a copy
thereof, as well as a copy of the confirmation of receipt and completeness.
‘Certified’ category
4.2.2.3
4.2.2.3
The ‘certified’ category of operations presents the highest risk and therefore are subject to stricter
safety requirements and conditions in order to ensure the highest level of safety which require the
certification of the drone and the certification of the operator, as well as – where applicable – the
licensing of the remote pilot.
These conditions are applicable as soon as the operation is conducted in any of the following
conditions:
over assemblies of people;
involving the transport of people;
Page 14 / 86
 kom (2022) 0652 - Ingen titel
2639143_0016.png
involving the carriage of dangerous goods, that may result in high risk for third parties in
case of accident;
Or if the drone has a characteristic dimension of 3 metre or more so as to mitigate the risks
for third parties in case of accident.
This category should allow a development of a whole new market called Innovative Air Mobility
(IAM) (international, regional and Urban Air Mobility (UAM)) to emerge with a use of new
types of vehicles, including drones. IAM would represent a major development for the transport
of freight and people, particularly within or out of urban environments that can contribute to
reduce emissions and increase road safety, while providing new services to all communities.
4.2.3 Adoption of a regulatory framework for the provision of U-space services
Fulfilling one of the policy objectives set in the Sustainable and Smart Mobily Strategy, the
Commission adopted on 6 April 2021 an initial regulatory framework for U-Space, consisting of
three Implementing Regulations (EU) 2021/664, (EU) 2021/665 and (EU) 2021/666
29
. The U-
space framework, which will be applicable as from 26 January 2023, will ensure the scaling up of
routine drone operations in designated geographical zones while ensuring the safety of both
people on the ground and traditional users of the airspace.
It introduces new services for drone operators, allowing them to carry out more complex and
longer-distance operations, particularly in congested, low-level airspace (below 120m), and when
out of sight. The three U-space regulations cover the roles and responsibilities of the various
entities involved in the definition of U-space, the provision of U-space services, and the
minimum necessary services required for manned and unmanned aircraft to operate within the U-
space.
The intent of the U-space regulations is to ensure that any drone operator planning flights in U-
space is required to subscribe to one of the U-space service providers (USSPs). Flights may only
be performed after a flight authorisation has been requested and issued. The three main (new)
actors from a transaction perspective are: the drone operators willing to provide a drone service
to a customer; the USSP (enabling the drone operation); and finally, the Common Information
Service. Peripheral actors include Air Navigation Service Providers (ANSPs) who will continue
to provide air navigation services for manned aircraft, while USSPs provide U-space services for
drones. ANSPs must collaborate with USSPs (on a price for service basis) to ensure flight
authorisations are coordinated and to exchange information about the airspace designations.
Member States have full authority on the designation of U-space and decide how their airspace
should be accessed and restricted. In addition to the four baseline services required by the U-
space regulation, Member States can require USSPs to provide additional U-space services to
support safe and efficient drone operations.
29
Commission Implementing Regulation (EU) 2021/664 of 22 April 2021 on a regulatory framework for
the U-space (OJ L 139, 23.4.2021, p. 161)
Commission Implementing Regulation (EU) 2021/665 of 22 April 2021 amending Implementing
Regulation (EU) 2017/373 as regards requirements for providers of air traffic management/air
navigation services and other air traffic management network functions in the U-space airspace
designated in controlled airspace (OJ L 139, 23.4.2021, p. 184).
Commission Implementing Regulation (EU) 2021/666 of 22 April 2021 amending Regulation (EU)
No 923/2012 as regards requirements for manned aviation operating in U-space airspace (OJ L 139,
23.4.2021, p. 187)
Page 15 / 86
 kom (2022) 0652 - Ingen titel
2639143_0017.png
4.3 Research & Innovation on drones and related systems
A large number of collaborative research and innovation projects addressing drones and
Innovative Air Mobility, as disruptive fields of aviation, have been funded at EU level through
various Commission research and innovation frameworks:
Horizon 2020,
which was the EU's research and innovation funding programme from 2014-
2020 with a budget of nearly €80 billion. It included specific topics
30
that funded
transnational research projects researching, developing and testing drones for specific
capabilities, from transport to civil protection to law enforcement and border management.
Horizon Europe
31
, which succeeded Horizon 2020 and is EU’s key funding programme for
research and innovation for 2021-2027 with a budget of €95.5 billion.
Connecting Europe Facility for Transport,
which is supporting investments in building
new transport infrastructure in Europe or rehabilitating and upgrading the existing ones.
Between 2021 and 2027 the European Climate, Infrastructure and Environment Executive
Agency will manage €25.81 billion to support transport infrastructure projects throughout the
EU and beyond.
The European Defence Industrial Development Programme (EDIDP),
which, with a
financial envelope of €500 million for 2019-2020, was the first ever EU grant programme
targeting capability development and co-financing the joint development of (new and
upgrading of existing) defence products and technologies. EDIDP was one of precursor
programmes of the European Defence Fund.
The European Defence Fund (EDF),
which, with a budget of close to €8 billion for 2021-
2027, promotes cooperation among companies and research actors of all sizes and geographic
origin in the Union, in research and development of state-of-the-art and interoperable defence
technology and equipment.
Those projects addressing drones, including Innovative Air Mobility, are advancing the state of
the art in multidisciplinary areas such as autonomous flights for transport monitoring, aerial
means for search and rescue, and automated electric mobility. They are developing new know-
how and are testing innovative solutions that help to make transport safer, more resilient and
more environmentally friendly.
Public concerns about drones and IAM are also addressed. Research and innovation helps drones
and IAM not only to become more safe and secure, quiet, and green but also more accessible,
affordable, and acceptable by the public.
4.3.1 Single European Sky ATM Research (SESAR)
In 2017, the European Commission mandated the SESAR JU to coordinate all research and
development activities related to U-space and drone integration. In 2017, the SESAR JU
published the U-space Blueprint, setting out the vision and steps for the progressive deployment
of U-space services from foundation services to fully-integrated operations. This was followed by
the 2020 edition of the European ATM Master Plan, which incorporated a drone roadmap.
30
See for example research and innovation under the EU civil security innovation and security research
programme:
https://home-affairs.ec.europa.eu/policies/internal-security/innovation-and-security-
research_en#:~:text=EU%20security%20research%20is%20one,anticipating%20tomorrow's%20threat
s
https://ec.europa.eu/info/funding-tenders/find-funding/eu-funding-programmes/horizon-europe_en
31
Page 16 / 86
 kom (2022) 0652 - Ingen titel
2639143_0018.png
In 2017 and 2018, the SESAR JU launched 19 exploratory research projects and demonstration
projects aimed at researching the range of services and technological capabilities needed to make
U-space a reality. The projects brought together some 25 European airports, 25 air navigation
service providers, 11 universities, more than 65 start-ups and businesses, as well as 800 experts,
working in close cooperation with standardisation and regulatory bodies, including EUROCAE
and EASA.
In the Horizon 2020 framework, the EU has invested €44 million into research and development
through SESAR JU, namely €9 million for “exploratory research”, €30 million for “industrial
R&D” and €5 million for “very large demonstrators”. Overall, by the start of 2018, the EU had
provided grants for more than €400 million to drone related projects (covering both civil and
military projects), 90% of which correspond to the 7th Framework and Horizon 2020
Programmes
32
.
In May 2019, SESAR JU launched an open call for exploratory projects within the framework of
the SESAR 2020 research and innovation programme. The call covered a wide range of topics
and aims at fostering new and innovative ideas to transform air traffic management in Europe.
The SESAR 3 JU was set up in 2021 to build on the work and achievements of earlier SESAR
research and innovation programmes (SESAR 1 and SESAR 2020) and accelerate the market
uptake of innovative solutions through a portfolio of demonstrators and a fast-track mechanism.
It is co-funded by the European Union through the Horizon Europe research and innovation
programme and industry as follows:
Horizon Europe - EUR 600 million
Eurocontrol – up to EUR 500 million (in-kind and financial contributions)
Industry - EUR 500 million minimum (in-kind and financial contributions)
In addition, the Digital European Sky programme will benefit from funding for its demonstrators
from the Connecting Europe Facility (in coordination with CINEA) to the value of at least EUR
200 million.
4.3.2 European Climate, Infrastructure and Environment Executive Agency
(CINEA)
CINEA also managed a cluster of drone and IAM projects under the EU Research and Innovation
programme Horizon 2020, combining several aeronautical disciplines together with cross-cutting
areas to test and advance the pre-deployment of drones and new urban air vehicles in very
different environments
33
. This comprehensive approach includes the efficient integration with
urban infrastructures, with energy and communication networks and with other transport modes.
In addition to the Horizon 2020 and Horizon Europe programmes, CINEA also implements other
key EU programmes such as the Connecting Europe Facility (CEF) for deployment of
infrastructures, including for transport at large and air traffic management (ATM). In close
cooperation with the SESAR Joint Undertaking, a call for proposals was launched under CEF in
2021, containing provisions for a series of Digital European Sky Demonstrators. The future
demonstrators are a key tool to support the vision of delivering the Digital European Sky. A total
32
https://ec.europa.eu/info/research-and-innovation/funding/funding-opportunities/funding-programmes-
and-open-calls/horizon-2020_en
https://cinea.ec.europa.eu/publications/drones-and-sustainable-urban-air-mobility-uam_en
33
Page 17 / 86
 kom (2022) 0652 - Ingen titel
2639143_0019.png
budget of EUR 60 million is earmarked for the future demonstrators, which are expected to be
launched in 2022 and to run until 2025.
One of the CEF Digital European Sky topics is “U-space and urban air mobility”. To unlock the
potential of the drone economy and enable urban air mobility (UAM) on a wide scale, a new air
traffic management framework for low-altitude operations needs to be put in place. Known as U-
space, the framework foresees a set of new services relying on a high level of digitalisation and
automation of functions and specific procedures designed to support safe, efficient and secure
access to airspace for large numbers of drones. As such, U-space is an enabling framework
designed to facilitate any kind of routine mission, in all classes of airspace and all types of
environments - even the most congested.
4.3.3 European defence research and innovation
Drones have been actively used in the defence sector over the last decades as well. The
Commission launched in 2016 the European Medium Altitude Long Endurance Remotely Piloted
Aircraft System (MALE RPAS) programme to ensure EU’s sovereignty in the field of
Intelligence, Surveillance, Target Acquisition and Reconnaissance (ISTAR) and to foster the
European Defence Technological and Industrial Base (EDTIB). As part of the direct award
project within the European defence industrial development (EDIDP)
34
work programme, this
project led by four European entities (Airbus Defence and Space, Leonardo and Dassault
industrial partners), received an EU contribution of €100 million for a total cost of €300 million.
The European Defence Fund, for which the EDIDP was a predecessor, is a powerful instrument
to boost industrial Defence cooperation throughout Europe and increase EU’s technological edge
and develop the capabilities that are key for the strategic autonomy and resilience of the Union.
EDIDP had a budget of €500 million for 2019-2020, to be compared to the €8 billion from the
EU budget dedicated to the European Defence Fund for 2021-2027. This means that the EU will
become one of the top 3 defence research investors in the world.
4-8% of this budget will be set aside to support innovative disruptive technologies for defence
that will boost Europe’s long-term technological leadership and contribute to high-end defence
products. One category of actions considered is called “Digital Transformation” and includes
calls and topics related to unmanned aircraft.
Coherence with other EU initiatives is key and the Action Plan on synergies between civil,
defence and space industries complements the European Defence Fund with the aim to avoid
unnecessary duplication, enhance complementarity and ensure cross-fertilisation between civil,
security and defence.
The emergence of new types of platforms, from micro drones to larger drones, as well as the
current development of MALE, offer an opportunity to foster synergies with sustainable and
smart mobility objectives, improve the competitiveness of European industry and strengthen
Europe's strategic autonomy in this key technical domain. This also represents an excellent
opportunity for civil-military cooperation since many of the technological building blocks
building up these systems, such as Detect and Avoid, autonomy, datalinks, electro-optical sensors
and other payloads are paradigmatic cases of dual-use enabling technologies, which ideally
should also have European origins.
34
The European Defence Industrial Development Programme (EDIDP) was a two-year programme
(2019- 2020) of the European Commission aiming at supporting the joint development of defence
technologies and products.
Page 18 / 86
 kom (2022) 0652 - Ingen titel
2639143_0020.png
5
P
RESENTATION OF THE
EU
DRONE ECO
-
SYSTEM TODAY
5.1 The elements of the eco-system
The Drone Value Chain includes many actors which are coming from the transport sector and
beyond. To present the drone value chain, distinctions should be made between the
systems/products put in place to enable drones to operate safely and securely; and the services (or
groups of services) that drones can deliver to the end-customers, as presented in the figure below:
The drone eco-system
In more details, the B2B drone value chain includes several segments which are all interlinked:
Drone operators (service provider) performing Innovative Aerial Services;
IAM operators offering innovative transport services;
Drone manufacturers which produce the hardware. This activity may also include the
assembly of some components produced by third parties;
Producers of other payloads to be integrated to the drones, e.g., for filming, inspection, cargo,
monitoring or measuring purposes;
Technology providers for the platform who develop equipment and software systems whether
for communication, control of the flight, situational awareness, or to enable specific or
autonomous operations);
Distributors selling or renting finished drone to third companies;
Ground infrastructure operators such as vertiports and airports;
Air traffic management suppliers (e.g. ANSPs, U-space service providers, Common
Information Service Providers);
Telecommunication infrastructure providers, as well as navigation and surveillance
infrastructure providers.
These actors are grouped in the following drone market segments:
Drone services market: primarily service providers and customers. The drone services market
facilitates access to all industries as the final customer and eventually provides most societal
value. For example: by safely operating drones for data gathering or inspections, data is
delivered into value chains in sectors like agriculture, construction, security, etc., where it
can be processed and analysed for specific purposes. The key point is: the drone is a data
gathering instrument in a longer value chain that includes other technological applications to
make best use of the data collected.
Drone operations market: primarily drone technology developers and drone users/pilots. The
drone operations market is the tool to deliver transport for passengers or cargo as well as to
deliver drone services where the drone becomes a link in a full value chain.
Page 19 / 86
 kom (2022) 0652 - Ingen titel
2639143_0021.png
Enabling services and infrastructure market: primarily associated with the implementation of
U-space services, and enabling service/infrastructure providers. The enabler for automated
longer distance, scalable drone operations and drone services. This enabler should be as cost-
effective as possible, while providing fair access to airspace for a diversity of drone operators
from across the EU.
Each individual link of the value chain needs in principle to be competitive to allow access by all
industries potentially benefitting from drone operations and services, as well as final customers,
and ultimately to provide societal value.
5.2 Drone services offered today
As introduced in section
2
, drone operations can be classified in two main groups:
(1) Aerial Operations - in this case, drones are used as daily tools in ever broadening fields such
as inspection (pipe line, rail, windmill maintenance), agriculture, mapping, architecture,
constructions, real estate, energy, environment and public safety (firefighting, search and
rescue, border patrol, local law enforcement);
(2) Innovative Air Mobility – where drones and electric Vertical Take Off and Landing aircraft
(eVTOL) are used for the transport of people and cargo.
5.2.1 Aerial operations
The drone services market related to aerial operations is well established and includes the
following mature use cases, with a confirmed or very short term expected commercial viability:
Data collection, for example: aerial photography and data collection for scientific research;
Surveillance, providing aerial security and monitoring;
Surveying, inspection and maintenance, for example: improving urban planning; measuring
building energy efficiency, allowing servicing of infrastructure in particular in environments
where safety is a concern;
Entertainment or advertising, for example: using a drone swarm to replace fireworks
displays.
This is by no means an exhaustive list and other use cases are developing rapidly and are
expected to become commercially viable with 2 to 5 years, for instance:
Precision agriculture: monitoring of crops, spraying, environmental protection, planting, etc;
Emergency and other public services, including police, firefighting as well as natural disaster
response.
5.2.2 Innovative air mobility
Innovative Air Mobility covers use cases related to the transport of goods and people. Those use
cases show considerably less maturity and longer term expected commercial viability compared
to most aerial operations.
Indeed, we are at the dawn of small parcel delivery services by drone, with pioneer
implementations existing in Europe (e.g. “Manna” drone delivery service near Dublin, Ireland, or
“Wing” drone delivery service near Helsinki, Finland), and medical transport is also developing
fast (transport of medical samples between hospitals and laboratories, delivery of prescriptions to
remote areas…). However, operations related to the transport of people – or heavier cargo - have
yet to materialise.
Page 20 / 86
 kom (2022) 0652 - Ingen titel
2639143_0022.png
High noise levels, lack of helipads availability and high operational costs can explain the lack of
success of passenger transport by helicopter so far. Recently though, the interest in Urban Air
Mobility has been reinforced by the development of small, electrically powered Vertical Take-
Off and Landing (eVTOLs) aircraft. An eVTOL aircraft is a type of manned or unmanned aircraft
that uses electric power to hover, take-off and land vertically, without the use or need for a
runway. In an initial phase, these vehicles will have a qualified pilot on board. In a later stage, it
will then be possible to have the drone remotely piloted (from the ground) or even proceed to
fully automated flights (remove the pilot on board or on the ground).
Passenger drones may be used within large and sprawling urban areas as part of a new Urban Air
Mobility approach, or to connect cities with regions that are either difficult to access by surface
transport or lack the infrastructure or scale necessary to support traditional forms of aviation.
Although the capabilities of these aircraft have been improved significantly, there are still
performance issues that need to be addressed, linked for example to the batteries and range
limitations, as well as social acceptance. Furthermore, their financial viability also depends on
several conditions like the targeted level of safety, the fact that the first phase of commercial
operations will be carried out with a pilot on board, initial higher costs related to the OEMs
production and maintenance, traffic management and operational constraints related to social
acceptance and which are examined in Chapter 8 below.
5.3 Drones as an emerging sector of the economy
The EIB monitors the evolution of the drone sector in particular for Urban Air mobility and U-
space and provides funding and technical assistance including for infrastructures that will enable
drone operations. However, as found by the EIB, most private sector entities in the drone
ecosystem are small scale and some are yet without a robust business plan in place to achieve
commercial operations. There is a reliance on central funds, grants and venture capital to invest
in research and development projects. All of this suggests a need to mature the industry capability
rapidly, which requires having funding and financing mechanisms available to suit each part of
the cycle and avoid falling into the first ‘valley of death’, as shown in the Figure below:
(Source: European Investment Bank)
Financial cycle of a business
Page 21 / 86
 kom (2022) 0652 - Ingen titel
2639143_0023.png
The European Investment Bank Guide to Finance for Drone Projects maps out the advisory and
financial products that can potentially be used to support investments in drones, depending on the
area of investment and the maturity of the market.
35
The EIB itself identified a lack of products
covering vehicles, associated technologies and enablers and maintenance during the early
commercialisation stage. These areas might be covered by venture capital activities.
Venture capital is more abundant outside of Europe, with the US leading the world in drone
venture capital investment. The majority of investments are focused on drone operations (e.g.
drone hardware) rather than enabling systems and end services.
36
There is an incentive for
European start-ups to move to the US to seek venture capital funding for their projects.
37
Europe
also lags behind both the US and China in total investment in drone services and number of
vehicles respectively. A constraint faced worldwide is that investment in this immature industry
is a high risk and long-term horizon investment. The projected development of the drone market
in the future suggests profitability in various applications by 2040, but timescales remain
imprecise and perhaps speculative. The main issue is the lack of established business models for
drone services, which means any business who wants to invest in drone services needs to be
willing to sustain losses for a relatively long amount of time while the market matures
38
.
6
T
HE POTENTIAL BENEFITS OF A VIABLE DRONE ECO
-
SYSTEM IN
E
UROPE
6.1 Growth and Jobs
There is a variety of studies on the current and future expected market size of the drone market.
Based on an analysis of the available studies and forecast, the estimated amount of the
commercial value of drones in 2030 ranges between € 10,3 billion and € 20,4 billion, with the
most likely outcome being € 14,5 billion, with an associated CAGR of 12.3%, as presented in the
figure below:
35
36
https://www.eib.org/attachments/publications/eib_guide_to_finance_for_drone_projects_en.pdf
.
McKinsey estimated in 2017 that start-ups had attracted more than $3 billion in funding to explore
drone applications. About half of the investment was aimed at vehicle development:
https://www.mckinsey.com/industries/travel-logistics-and-infrastructure/our-insights/commercial-
drones-are-here-the-future-of-unmanned-aerial-systems.
See for example German start-up Lilium, which is aiming to offer a UAM service in New York by
2025.
See for example Wing, which has successfully implemented drone deliveries in Helsinki, but relies
predominantly on finances from the large multinational parent company Alphabet who generally has a
high technology risk appetite.
37
38
Page 22 / 86
 kom (2022) 0652 - Ingen titel
2639143_0024.png
Source: Drone Strategy 2.0 Fact-Finding Study, Ecorys
Estimated commercial value of drones (in EUR billion) in Europe
Furthermore, a recent study by the JRC
39
, currently being updated to include more scenarios and
to compare the EU situation with the US one, has shown that the existing land-use patterns in the
EU can ensure financial viability of drone delivery services in most cities. In addition, as shown
in the next figure, the research shows that as soon as the demand for freight deliveries by drones
increases, the number of financially viable drone “nests” in the EU could be substantially higher
than in the US (due to the land-use pattern of EU cities) thus representing a potentially more
interesting market:
Number of estimated economically viable drone delivery nests as a function of Market
Penetration (MP) for EU and US for a box cost of 0 and 0.5 euro.
39
https://etrr.springeropen.com/articles/10.1186/s12544-019-0368-2
Page 23 / 86
 kom (2022) 0652 - Ingen titel
2639143_0025.png
In general drone services are providing automated solutions, which have an impact on
employment. These effects could work both ways (negative or positive) and likely in parallel.
According to a recent study by the International Transport Forum (ITF), drones will increase
productivity in some sectors. Businesses may also replace human centric tasks using other
justifications, for example safety benefits associated with inspection of dangerous infrastructure.
In practice a combination of both people and drones will likely be used over the short to medium
term. As with all technological changes in the workplace, learning or reskilling programs would
facilitate transitions in the labour market. Apart from employment effects related to the changing
business models, drones could also create new tasks.
Predictions with varying geographic scale and timelines are available for the potential number of
operational drones show:
A current baseline (2020) of between 100,000 – 200,000 commercial drones in use in
Europe;
A commercial drone fleet of between 400,000 – 800,000 in Europe in 2030 (with higher
probability that it is closer to the lower bound).
According to SESAR (2016), there is substantial job creation expected (such as localised
operations, pilots, insurers and others). One might expect a large opportunity for jobs in the
software development/automation and telecommunications /data industries. In total, the sector is
conservatively expected to create roughly 100.000 direct jobs. When including wider
employment effects (so called indirect effects), the total number of jobs at a European level rises
to between 250.000 and 400.000 jobs towards 2035.
40
To provide an idea of the potential number of jobs in the EU in 2030 the support study took the
employee productivity figure used by SESAR JU in their drone outlook study and scaled it based
on updated market predictions. The figure applied is 100.000 euro per employee. The study has
determined a low, medium and high scenario, which have a similar growth rate as the market
value predictions. In the medium scenario, the total number of direct employees is estimated at
around 145.000 in Europe in 2030. The results are presented visually in the Figure below:
Source: Drone Strategy 2.0 Fact-Finding Study, Ecorys
Estimated number of (direct) employees in Europe (x 1.000 employees)
40
SESAR JU (2016), European Drones Outlook Study.
Page 24 / 86
 kom (2022) 0652 - Ingen titel
2639143_0026.png
Indirect effects are retrieved from macroeconomic multipliers produced by the OECD
41
. The
relevant multipliers from sectors such as computer related activities, electrical machinery, etc.
range between 1.9 and 3.0. The multipliers provide a simple method for determining indirect
employment impacts based solely on the expected level of direct employment impacts. Using
these multipliers the external study suggests that the total employment impact of the drone
industry (direct and indirect) should range between 200.000 to 600.000 additional employees in
2030.
6.2 Decarbonisation and circular economy
6.2.1 Decarbonisation
Decarbonising transport remains one of the major challenges ahead in order to mitigate climate
change. Globally, roughly 25% of the greenhouse gas (GHG) emissions are emitted by fuel
combustion from transport. And as of today, the sector remains dependent on oil for 92% of its
energy demand.
42
In the EU, transport emissions represent around 25% of the EU’s total greenhouse gas emissions.
A clear path is needed to achieve a 90% reduction in transport-related greenhouse gas emissions
by 2050, in line with the European Green Deal objectives. Although emissions reduction is
possible across almost all drone use cases, the emissions reduction potential is mostly associated
with logistics and passenger transport.
A number of drone applications are powered through electric propulsion (and other emerging
technologies) providing a decarbonised alternative to current modes of transport and therefore
supporting the Paris Agreement and the European Green Deal objectives to achieve net zero
emissions. Drones have the potential to contribute to the decarbonisation and modernisation of
the transport and mobility system, addressing its negative impact on the environment and
improving the safety and health of European citizens.
However, while drones are emission free the production of electricity may generate emissions.
Most drones are powered by electricity and produce zero tailpipe emissions creating no direct
(scope 1) greenhouse gas emissions, as combustion engine drones will likely not be used in the
future. This means they can immediately contribute to reduce net greenhouse gas emissions. All
drones will consume energy creating indirect (scope 2) emissions. The amount of energy used
and subsequently the amount of scope 2 emissions will depend on the design of the drone, its
payload, the energy mix used for electricity production, and the method of electricity
transmission to the battery. The production and scrapping of drones at the end of their lifespan
will also consume energy and produce indirect (scope 3) emissions. The net emissions of drones
compared to traditional modes of transport will depend on the specific use case, the local context
and the source of energy supply.
Given the forecasted fast drone development in the future, the environmental impact of drones
must be given high consideration and requires further research. Expected environmental impacts
will especially arise from the manufacturing, the utilization, and the waste streams of drone
41
42
OECD STAN Database for Structural Analysis (ISIC Rev. 4): For selected industries factor is
determined by division of "Production (gross output)" by "Number of persons engaged (total
employment)".
International Transport Forum (2021), Ready for Take-Off? Integrating Drones into the Transport
System.
Page 25 / 86
 kom (2022) 0652 - Ingen titel
2639143_0027.png
products and of the related infrastructure as well as by the development of drone operations in
metropolitan areas, which will entail the development of suitable network of vertiports.
Drones have the potential to reduce energy use especially if sustainable use of batteries is
mandated. Transport-related CO
2
and other emissions could be reduced (e.g. last mile transport
for low weight goods when energy comes from sustainable sources) in comparison to traditional
modes of transport. On the other hand, there is clearly a debate about negative externalities
43
that
might be realised with the further scaling of drone activity (such as noise related impacts).
44
These environmental impacts on noise, air pollution and wildlife are further addressed in chapter
8.1.4 below.
The potential emissions reduction for drone delivery were estimated in the support study by
means of a “quick scan” analysis. The following methodological steps were taken to determine
the potential emissions reduction for goods delivery:
Step 1: Determining the commercial value of good delivery services and share of goods
delivery within the estimated economic value of the European drone industry;
Step 2: The added value (expressed in euro p. eVTOL unit) of delivery drones is estimated;
Step 3: Assessing the number of delivery drones towards 2030;
Step 4: Estimating the number of potential drone deliveries and freight potential by assuming
the average productivity of delivery drones;
Step 5: Retrieving the emissions key figures from existing literature;
Step 6: Providing an estimated bandwidth of the potential emissions reduction from drone
delivery services by determining the expected modal shift (e.g. electric van, diesel van, cargo
bike and drone).
By replacing cargo deliveries and last-mile express deliveries from traditional means of transport
to drone services, the emissions reduction potential is estimated at around 120,000 ton CO2 in
2030 in Europe. The results (and bandwidths associated with the analysis) are presented in the
figure below.
43
Externalities occur when producing or consuming a good cause an impact on third parties not directly
related to the transaction.
International Transport Forum (2021).
44
Page 26 / 86
 kom (2022) 0652 - Ingen titel
2639143_0028.png
(Source: Ecorys)
Source: Drone Strategy 2.0 Fact-Finding Study, Ecorys
Potential emission reduction for drone deliveries (in ton CO2)
Several scientific studies in the field of the impact on the level of CO2 emissions from drone
deliveries have been performed. Besides the impact in the drone delivery domain, there is also
impact on decarbonisation expected in other applications and sectors. For example, drones might
be used instead of high emissions vehicles in some agricultural practices such as spraying or
planting. The findings from several studies (non-limitative) can be briefly described as follows:
Park, J., Kim, S., & Suh, K. (2018)
45
studied the environmental impact of drones compared
to motorcycle delivery and differentiating between urban and rural areas. The results showed
that global warming potential (GWP) per 1 km delivery by drone was one-sixth of a
motorcycle delivery. In addition, the particulates produced by drone delivery were half that
of motorcycle delivery. The researchers conclude that the actual environmental impact
reduction in case of delivery distance was 13 times higher in a rural area than in an urban
area. When increasing the use of environmentally friendly electricity systems, for instance
solar and wind power, this could further enhance the environmental effects of a drone
delivery system.
Borghetti, et al (2022)
46
investigated the viability of last-mile delivery drones in Milan,
where they used stated preference survey and financial analysis. Findings show a high
propensity by end users to use last-mile delivery by drones can be successfully used to
deliver small and light packages, reducing environmental and social impacts, and ensuring
profits for the transport provider. In light of the financial viability of last-mile delivery
drones, they could be a solution to reduce traffic congestion and CO2 emissions.
WING investigated – by means of ex-ante and ex-post studies – the effects of drone
deliveries to society. One of these studies are performed by Gaia Consulting Oy
47
, which
studied the potential benefits of drone deliveries in Finland. The benefits are expressed for
Park, J., Kim, S., & Suh, K. (2018). A comparative analysis of the environmental benefits of drone-
based delivery services in urban and rural areas. Sustainability, 10(3), 888.
Borghetti, F., Caballini, C., Carboni, A., Grossato, G., Maja, R., & Barabino, B. (2022). The Use of
Drones for Last-Mile Delivery: A Numerical Case Study in Milan, Italy. Sustainability, 14(3), 1766.
Gaia Consulting Oy (2021), Potential Benefits of Drone Deliveries in Helsinki.
45
46
47
Page 27 / 86
 kom (2022) 0652 - Ingen titel
2639143_0029.png
local businesses, consumers and society. Societal benefits are expressed via the reduction of
vehicle kilometers travelled by road (equal to a reduction of 11 million km); reducing CO
2
emissions (reduction of 2.000 t CO
2
); reducing road accidents (38 less road accidents). For
local businesses and consumers, the benefits are linked to lower delivery costs (45% lower
costs) and the connectivity (expressed via delivery reach and product variety).
6.2.2 Circular economy
The development of a drone value chain should also give careful consideration to circular
economy aspects. The risks associated to the lack of raw materials are concrete and the EU
cannot accept being dependent on external support for the implementation of this key technology.
On the other hand, this issue may represent a significant opportunity for the European industry
for developing the drone industry, building competitive advantage on environmental
sustainability and Circular Economy. The waste of electronics components must be avoided and
the drone’s end-of-life opportunities should and could be more effectively and efficiently
addressed now at the beginning of the fast-emerging drone sector.
Moreover, when looking at drones we cannot focus only on the airborne segment. To execute
their tasks, drones require dedicated ground infrastructures. The same Circular Economy
considerations apply to the ground segment as drone operations spread across the territory.
6.3 Digitalisation
The development of Innovative Aerial Services and the digital transformation go hand in hand.
Drone technology and its multiple applications are based on a high level of digitalisation and
automation, as described below. At the same time, drones can deliver accurate and actionable
data to improve operational workflows, streamline processes and contribute to finding digital
solutions in a wide variety of use cases, such as agriculture, construction, mining, surveillance,
and inspection.
Embracing digital technologies has become essential for many businesses to remain competitive
in an ever increasingly interconnected economy. Digital technologies and products have also the
potential to lower the environmental footprint of the economy and lead to higher energy and
material efficiencies.
The 2030 Digital Compass
48
identified five key industrial ecosystems for digital transformation:
Manufacturing;
Health;
Construction;
Agriculture; and
Mobility.
Out of these, at least four (health, construction, agriculture, and mobility) have the potential to
directly benefit from the introduction of aerial operations and innovative air mobility to drive
changes in their respective sector, as illustrated by the drone-use cases listed in 5.2. But other
ecosystems could also reap benefits from synergies with the technological development brought
by drones, in particular in the fields of automation and artificial intelligence.
48
2030 Digital Compass: the European way for the Digital Decade, COM(2021) 118 final, Brussels,
9.3.2021
Page 28 / 86
 kom (2022) 0652 - Ingen titel
2639143_0030.png
This digital transformation will not only concern industrial ecosystems but also affect public
services, and enable an efficient, holistic, and easy access to public services to all citizens. Here
again drone services have the potential to support this transformation by connecting remote
communities and ensuring the continuity of public services.
The contribution of drones to the digitalisation of the economy is not limited to drone services
provided to industrial and public sectors but extends across the whole drone value chain. Drone
operations and enabling services have indeed the potential to be instrumental in the digitalisation
of aviation.
First, drone vehicles are catalyst for innovation in aviation. They are not only spurring the
electrification of aviation and the development of more sustainable aircraft, but they are also
advancing automation and connectivity at an unprecedented speed in air transport.
Autonomous flight technology should enable accurate operations (including detection and
avoidance of other vehicles and obstacles) without any involvement of human operations. Also
here, the drone operations market is expected to act as a catalyst for the development of aviation,
functioning as an enabler of innovation and digitalisation.
The standard SAE J3016 developed for road vehicles
49
is commonly used as basis when
assessing the level of automation within drones. The standard defines six levels from no
automation to full automation.
Currently, due to restrictions in permitted level of flight automation, the use of drones still faces
limitations. Nevertheless, drones are applied at various levels of autonomy, as illustrated in the
figure below. Drones are applied at low automation degree in inspection & maintenance; location
& detection; photography and filming, and monitoring. At partial automation degree, drones are
used in mapping; spraying & seeding, measuring; and surveying. At degree of conditional
automation, drones are used in mapping, delivery and surveying. Initial steps are taken in high
automation in the case of photography and filming.
A enabling service such as U-space, the set of digital services and operational procedures
designed to support a safe, efficient, and secure access to airspace for large numbers of drones,
can be an accelerator of the ATM innovation life cycle, facilitating faster, lower risk adoption of
new technologies or approaches (automation, AI, cloud, etc.) in manned aviation.
Such disruptive innovations can reduce innovation cycles from about 30 years that are typical in
traditional aviation to about 5-10 years. To achieve this, the development and deployment of the
integration of drones into the airspace, and in particular the development and implementation of
U-space services, may be used as a ‘laboratory’ that can support faster life cycles in the manned
aviation environment, and ultimately the implementation of the digital European sky
50
.
The digital European sky leverages the latest digital technologies to transform Europe’s aviation
infrastructure enabling it to handle the future growth and diversity of air traffic safely and
efficiently, while minimising environmental impact. In doing so, these technologies enable the
system to become more modular and agile, while building resilience to disruptions, traffic growth
and diversity of air vehicles
51
. Drones, relying on an operations-centric approach and a
digitalised system, can be a catalyst towards increased levels of digitalisation of the entire
aviation system, currently still relying on a human-centric approach, for example in ATM.
49
50
51
https://www.sae.org/standards/content/j3016_202104/
Strategic Research and Innovation Agenda - Digital European Sky, SESAR Joint Undertaking, 2020.
Digital European Sky – Blueprint, SESAR Joint Undertaking, 2020.
Page 29 / 86
 kom (2022) 0652 - Ingen titel
2639143_0031.png
7
V
ISION AND STRATEGIC OBJECTIVES
7.1 Vision
Setting out a vision involves on the civil side to cater for the situation of three different but
interlinked markets: Aerial Operations, Innovative Air Mobility and U-Space services as
described above. The drone eco-system also includes the defence/military dimension, as both
sides stand to benefit from technological synergies.
This vision, developed by the Drone Leaders Group (see A.4) for 2030, can be formulated as
follows:
By 2030 drones and their required eco-system will have become an accepted part of
the life of EU citizens and Member States.
They will be used to provide numerous services to the benefits of diversified civilian
and defence end-users, including EU citizens, organisations, States, and industry.
These aerial operations will include emergency services, inspections, and surveillance,
using drones as flying Internet of Things (IoT) platforms to gather data, as well as for
the delivery of goods.
Innovative Air Mobility (IAM) services will also have started to provide regular people
transport services in various European cities and for some regional connections,
initially using aircraft with a pilot on board but with the aim to fully automate their
operations. Drone services will effectively integrate or complement existing
transportation systems and contribute to the decarbonisation of the transport system,
while minimising their impact on the environment throughout their life cycle. Urban
Air Mobility (UAM) will have started to become a part of the future urban multimodal
intelligent mobility ecosystem and the infrastructure enabling these services will be
widely deployed and integrated.
A wide spectrum of distinct types of drones and use cases will coexist in the future. The
EU legislator, the Commission, the European Union Aviation Safety Agency (EASA)
and the Member States all have an institutional responsibility to safeguard the safety,
security and efficiency of their operations. They will ensure that all drone services are
provided in a manner that ensures safety, security, privacy, and affordability, in line
with citizens’ expectations and addressing their concerns. Drones used for the
transport of people and goods will be particularly oriented to the achievement of
publicly accessible services, thus creating benefits for citizens and local communities.
The current U-space regulatory framework will have been completely rolled out in a
seamless EU market. Additional advanced U-space services will support large scale
highly automated and digitally connected affordable, safe, secure, and environmentally
friendly unmanned aircraft operations in several Member States. The integration
between manned and unmanned traffic in the same airspace will have been initiated,
inside and outside U-space airspace.
The EU drone industry will become viable, and accessible to EU citizens and
businesses with an active participation of actors of all sizes, including a variety of
diversified SME’s, fostering collaboration between all actors, and broadening the
spectrum significantly beyond the limited number of global multinational stakeholders.
Civil-defence industry synergies will be systematically identified and exploited. They
will benefit both sectors. They will improve the competitiveness of European industry
Page 30 / 86
 kom (2022) 0652 - Ingen titel
2639143_0032.png
and strengthen Europe's strategic autonomy, by allowing Member States to rely on
competitive UAS technology of European origin.
The drone eco-system thus created will provide jobs, promote, and protect European
technological know-how and allow for growth opportunities for the EU economy as a
whole, enabling European companies, including new SMEs to grow and flourish as
global leaders.
This was the basis for the Commission vision spelled out in the Drone Strategy 2.0 for a Smart
and Sustainable Unmanned Aircraft Eco-System in Europe.
7.2 Strategic objectives
As set in the Commission roadmap for the Drone Strategy 2.0
52
, the following elements are part
of the strategic objectives of this strategy:
The strategy should foster the uptake of this innovative technology in Europe, while establishing
the right balance between safety, security, health protection and other societal concerns, and a
sustainable economic environment.
The safety, security, health protection and privacy of people in the air and on the ground remains
the priority. In addition, the future policy framework should provide an innovative, cost-efficient
and market-led business environment for the development and take-up of new drone services and
technologies within the EU’s internal market. It should also guarantee their widest possible social
acceptance.
The Drone Strategy 2.0 should provide a comprehensive policy package and address obstacles to
the development of new drone applications and transport services and to the competitiveness of
this industry. As outlined in the Action Plan on synergies between civil, defence and space
industries, reaping synergies between the civil, security and defence use of drones and related
technologies, including counter-drones’ solutions, can be an important success factor.
The ambition of the strategy is therefore to further develop the drone sector, in light of the
European Green Deal, Smart and Sustainable Mobility Strategy, Digital Strategy and other Union
policies.
7.3 SMART objectives
The Drone Leaders’ Group proposed a number of SMART (Specific Measurable Achievable
Reasonable Time-bound) objectives to be used to measure progress on achieving the above
Vision and the targets to be reached by 2030. In this regard, the Group agreed on the following
set of objectives:
Number of cities/regions that will be served by IAM regular commercial services (Target for
2030: at least 45 in the EU and at least one per Member State)
Number of Member States where emergency health services (medical samples, defibrillators,
air ambulances) will be provided using drones (Target: services used in at least 20 Member
States)
Use of European U-spaces Airspace by commercial drone flight operations (Target: at least
100.000 a day)
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13046-A-Drone-strategy-20-
for-Europe-to-foster-sustainable-and-smart-mobility_en.
52
Page 31 / 86
 kom (2022) 0652 - Ingen titel
2639143_0033.png
Number of EU Member States where advanced U-space Services (additional to those defined
in the current regulatory framework) are operational in at least one U-space. (Target: at least
6 Member States)
Number of USSPs designated in each U-space airspace (Target: at least 2)
Safety level achieved (Target: the ratio between the number of accidents vs the number of
drone flights is as low as required for manned aviation)
Aerodromes falling under the EASA Basic Regulation, cities with over 100.000 inhabitants,
and critical infrastructures will have assessed the security risk related to drone incidents and
put in place procedures and measures that will protect them from such incidents proactively
and reactively (Target: 100%)
Number of assessments run by the EIB “European Drone Investment - Advisory Platform”
and number of loan agreements granted by European Investment Bank (EIB) to drone sector
stakeholders (Target: increased percentage respectively of 10%, year on year)
Carbon emissions of urban and regional IAM operations (Target: 0%)
The civil and military drone technology used in Europe will be designed and/or produced in
Europe (Target: at least 50% of total value of drones used in Europe)
Number of Universities / Technical Schools that offer drones subjects or specialisations
(Target: at least 40 in the EU and one per Member States).
Turnover in the overall drone eco-system and its contribution to EU GDP (Target: at least €
15 billion)
8
T
HE ELEMENTS OF A THRIVING
EU
DRONE ECO
-
SYSTEM IN
2030
8.1 Building the European drone services market
As mentioned, the drone sector is composed of several different dimensions including State
activities (including security, military and rescue-services), non-commercial use (hobby), and
commercial activities (including hardware and software developments, maintenance, the
provision of infrastructures such as vertiports).
The current EU legal framework already offers many possibilities for the operation of small
drones used for recreational or professional purposes. However, the feedback received during the
consultation process showed that the current regulatory framework does not sufficiently support
the scaling up of commercial drone operations, particularly for some of the most promising use
cases. Furthermore, the current framework, for instance, does not allow the transport of people.
There is thus a need to define further regulatory requirements, notably in urban areas.
Whilst economic players from across the whole drone industry and beyond are joining forces to
develop drone activities, it requires addressing several obstacles to make them become a reality
by 2030.
The regulatory dimension is only one aspect of these challenges faced by the Drone sector, which
comes across the 10 different areas identified in the Drone Strategy 2.0. The first steps to address
them was to define a clear vision. The high-level vision set out above is providing the foundation
for the next steps to be taken at EU level to develop a viable drone eco-system in Europe.
Page 32 / 86
 kom (2022) 0652 - Ingen titel
2639143_0034.png
8.1.1 Improving airspace capabilities (U-space development and integration with
Air Traffic Management)
The provision of air traffic service follows the demand for air transport and other airborne
operations. Since the beginning of aviation, this demand has generally seen a pattern of growth.
Whenever ATM is not able to deliver capacity where and when it is needed, traffic limitation
measures are taken to continue to ensure safety, causing rapid increases in delays and thereby a
deterioration in environmental and cost efficiency and the achievement of airspace user needs.
As the drone service market continues to grow and take shape in Europe, the pressure is on to
make sure that these air vehicles are safely and securely integrated into our already busy airspace.
Transforming infrastructure to support such operations is critical to harnessing the potential of
the sector, unlocking market growth, jobs and services to EU citizens. But a simple adaptation of
our current air traffic management system is not enough; accommodating these air vehicles in the
numbers forecasted required a new approach.
Therefore, to unlock the potential of the drone economy and enable innovative air mobility on a
wide scale, a new ATM paradigm was developed to safely cater for a high level of expected low-
altitude unmanned operations. This concept, referred to as U-space, includes new digital services
and operational procedures and its development had already announced in 2017.
U-space is a set of services and procedures relying on a high level of digitalisation and
automation of functions to support safe, efficient and secure access to airspace for large numbers
of drones. It provides an enabling framework to support routine drone operations and addresses
all types of missions including operations in and around airports.
As mentioned in section 4.2.3 above, the European Commission adopted in 2021 the U-space
package - three regulations that together create the conditions necessary for both drones and
manned aircraft to operate safely in section of our airspace known as the U-space.
These regulations introduce new services for drone operators, allowing them to carry out more
complex and longer-distance operations, particularly in congested airspace, and when out of
sight. U-space creates and harmonises the conditions needed for manned and unmanned aircraft
to operate safely, to prevent collisions between drones and other aircraft, and to mitigate the risks
of drone traffic on the ground.
U-space is expected to provide the means to manage safely and efficiently high-density traffic at
low altitudes involving heterogeneous unmanned vehicles, including operations overpopulated
areas and within controlled airspace. Ultimately, U-space will have to integrate seamlessly with
the ATM system to ensure safe and fair access to airspace for all airspace users, including IAM
flights departing from airports.
The current U-space Regulation identifies an initial set of U-space services required to implement
an initial U-space environment. In order to enhance U-space deployment to support IAM, it is
necessary to continue research and development in accordance with the European ATM Master
Plan (MP) vision, and the Roadmaps to achieve this as described in the Strategic Research and
Innovation Agenda (SRIA) for the Digital European Sky. The first SESAR 3 JU Digital Sky
Demonstrators addressing U-space will focus on direct support for the deployment of initial
services, in support of the U-space Regulation. In parallel, research should continue to develop
the overall concept of operations for U-space and IAM, both in terms of service definition and in
the supporting technologies, in order to deliver more advanced services. This development should
be designed to increasingly consider the ATM and U-space environments together so that, by the
time the full U-space environment is deployed, the two environments will have become one, fully
integrated air environment seamlessly encompassing small drones, IAM, ATM, RPAS and
Higher Airspace Operations (HAO).
Page 33 / 86
 kom (2022) 0652 - Ingen titel
2639143_0035.png
The introduction of new types of aerial vehicles within the airspace requires ensuring a fully
collaborative approach between all actors with the objective of ensuring an efficient interface
between U-space and ATM, as well as avoiding airspace fragmentation. An efficient U-space–
ATM interface is required to enable an adequate, robust and timely exchange of U-space
information services between various U-space stakeholders such as drone and IAM operators,
USSPs, ATM service providers, data service providers, aeronautical data providers and
authorities. The relevant solutions are expected to have a positive impact on access and equity,
enabling seamless ATM / U-space high-density automated and fully digitalised operations
managed in close cooperation with UAS/IAM fleet operators.
In a longer term, a fully integrated ATM / U-space CONOPS definition is required to cover
seamless operations inside and outside controlled airspace, further defining the interface between
ATM and U-space, as well as examining the corresponding information exchange concept and
requirements. Information exchange will be critical to enable a safe convergence of U-space and
ATM. The possibility of a fully integrated airspace without segregation between U-space and
ATM users is the ultimate goal.
A fully integrated ATM / U-space ecosystem without segregation between U-space and ATM
operations also requires the setting up of common fundamental enablers. Some of these enablers
include the definition of a common altitude reference system (CARS), separation minima, safe
operating distances from buildings and fundamental aviation tenets, such as airspace
classification.
The need to revise the rules of the air becomes necessary to consider the specificities of
unmanned traffic in general, as well as of mixed traffic (unmanned and manned). Such work has
been initiated by EASA, as part of the process of establishing a comprehensive set of new
regulations to enable operations of UAS in the ‘certified’ category and aircraft with VTOL
capability to deploy the potential of the IAM. Systems allowing drones to have a capability to
“detect and avoid” (DAA) and/or “sense and avoid” (SAA) other aircraft do not exist yet and
EASA objective is to develop them in accordance with a European harmonised set of validated
standards adapted to the European airspace and working in all airspace classes. Therefore, there
is a need to use strategic and tactical mitigation means offered by the ATM/U-space system in a
first phase until these systems are available, provided that the traffic and traffic complexity is
such that safe operations can be guaranteed.
Always keeping safety as the primary goal, further work will be required on enablers for
automation and autonomy for U-space and IAM. In this framework, a critical aspect of the
integration will be the role of humans, particularly regarding the high level of automation that
will be delivered by U-space services and the known automation disparity between ATM and U-
space. IAM integration in the ATM / U-space ecosystems is also a specific research topic, as well
as the challenge of how to support the transition from piloted vehicles to IAM/autonomous
operations. Of course, the evolution of the ATM / U-space convergence will need to be
synchronised and coordinated with the development of IAM services and the certification of IAM
vehicles. Special consideration should be given to the operational limitations of these new
vehicles and how U-space and ATM can contribute to their operational safety by protecting their
operations in contingency and non-nominal situations.
As research continues in each thread, lessons from one environment should be applied to each of
the others such that the final environment is safe, economically viable and environmentally
sustainable. This will contribute to making aviation smarter and more sustainable, and delivering
the Digital European Sky.
On the topic of Communication, Navigation and Surveillance (CNS), the SRIA of the SESAR3
JU clearly describes the transformation from three separate CNS domains into one integrated
CNS (ICNS) environment. This includes all current CNS technologies used for ATM, but also
Page 34 / 86
 kom (2022) 0652 - Ingen titel
2639143_0036.png
those needed to support U-space, IAM, RPAS integration and HAO. The research programme, as
envisaged in the SRIA, should look to ICNS as the mechanism by which all airspace users can
inter-operate safely, while reducing costs and environmental impact through rationalisation and
multi-use of existing and developmental technologies. This integration should include
technologies from other domains, such as the telecommunications and the space industries, and
should address increased connectivity through digital communications as well as the more
conventional elements. Research and demonstration under this Action should address both
technological issues and the specific performance and certification requirements of all relevant
technologies that arise from the evolving U-space and IAM domains.
8.1.2 Facilitating Aerial Operations
As mentioned in Chapter 2 above, the terms “Aerial Operations” refers to the use of new aerial
technologies and services provided to customers for other purposes than the transport of people
and freight. These small drones equipped with advanced sensors and AI technologies can be
deployed in diverse sectors such as construction, railways, ports, agriculture, energy, public
safety, security, filming, insurance, real estate, transport of small payload, etc.
Companies’ drone programmes can be either outsourced to third companies offering specialised
drone services or partially developed in-house, using leased fully tested material from third
company suppliers or finally, they can be fully developed internally. In this case, it may also
require buying hardware, software and consulting services at an initial higher cost for their
implementation. The aerial operations eco-system is largely composed of Small and Medium
Enterprises providing hardware, software and services to commercial drone operators (see
description in chapter 5.2.1 above.
Most companies which are developing drone programmes chose to do it internally and to a large
extent operations are conducted in visual line of sight. In fact, despite the risk-based operation-
centric approach underpinning the development of the regulatory framework for drones, one of
the key challenges faced by companies in the commercial drone sector is to be able to build up
drone programmes based on fully autonomous drone operations in beyond visual line of sight
conditions.
As highlighted in the Communication, one of the missing regulatory elements at a European level
is to perform operations at both end of the drone operations’ risk spectrum in the ‘specific’
category. On the one hand, for simple low risks operations in Beyond Line of Sight Operations or
Extended Visual Line of Sight, which are not falling under the ‘open’ category and are not yet
subject to a European standard scenario, there is a need to develop further European Standard
Scenarios. On the other hand, for more risky operations there is a need to develop methodologies
and procedural mechanisms which can facilitate the granting of an operational authorisation from
the competent authority.
Whenever operations do not fall under the ‘open’ category, drone operators must carry out a risk
assessment to determine under which category the operation will fall, ‘specific’ or ‘certified’.
Many stakeholders highlighted the complexity of conducting this risk assessment and the fact
that the operation approval granting process might be a lengthy one and its outcome uncertain.
This is in particular the case if the level of robustness of any of the operational safety objectives
linked with the drone design is considered “medium”, as the national competent authority could
in this case require a full design verification of the drone by EASA.
One of the possibilities to facilitate the launching of a low-risk operation in the ‘specific’
category is that the operation falls under a European Standard Scenario as it would suffice for
UAS operators to submit an operational declaration of compliance to the competent authority.
Page 35 / 86
 kom (2022) 0652 - Ingen titel
2639143_0037.png
The widespread consultations with industry stakeholders highlighted the need to improve some
regulatory aspects related to the ‘specific’ category, as pending the development of new
European standard scenarios, drone operators have to undertake the SORA in order to receive an
authorisation from the competent authority which is perceived to be more cumbersome and may
generate some business uncertainty. One of the risks for the drone operator is that the competent
authority may reach the conclusion that the operation should be performed under the conditions
of the ‘certified’ category instead of the ‘specific’ category, which requires the certification of the
aircraft, the operators and the remote pilot as applicable.
As a large part of commercial operations performed by drones are presenting a low to a medium
risk, more efforts could be made to facilitate use-cases in the ‘specific’ category of drone
operations. Indeed, in some cases, requirements to permit operational authorisations are
considered as disproportionate to the level of risks from both an operational and financial point of
view. The same also applies to the testing and demonstration of new types of aerial operations for
which the requirements are considered as too restrictive. The SORA mitigation requirements to
reach Specific Assurance and Integrity Levels (SAIL) category III, even using proven and
reliable systems, are difficult to reach without a drone redesign and could be reviewed.
The administrative burden related to the operational authorisation process could be alleviated by
developing further European standard Scenarios and pre-defined risk assessments. However, at
this stage, only two European Standard Scenarios have been developed. Further developing this
regulatory approach will also support the inclusion of Small and Medium Enterprises in the drone
operations market. In addition, new European Standard Scenarios could also address specific
needs related to State or military operations and maritime surveillance activities.
Consequently, the development of standard scenarios can enable rather complex operations to be
safely incorporated in the airspace with a minimum of formalities. At this stage, already two
standard scenarios have been adopted
53
: (1) STS-01 – VLOS over a controlled ground area in a
populated environment, and (2) STS-02 – BVLOS with Airspace Observers over a controlled
ground area in a sparsely populated environment. Considering that a large part of Aerial
Operations are presenting a low to a medium risk, the conditions for the ‘specific’ category of
drone operations could be alleviated by developing further European Standard Scenarios and pre-
defined risk assessments
54
.
Further, to support the development of urban and higher risk operations in the ‘specific’ category,
EASA should review its AMC/GM for the specific category of operations to ensure that design
verification requirements, and their application by national competent authorities, are
proportionate with the risk of the operations in the ‘specific’ category. Particular attention should
be paid to the required scope of the design verification (full drone design, mitigation means
and/or enhanced containment functions).
53
Commission Implementing Regulation (EU) 2020/639 of 12 May 2020 amending Implementing
Regulation (EU) 2019/947 as regards standard scenarios for operations executed in or beyond the
visual line of sight, OJ L 150, 13.5.2020, p. 1.
European standard scenario (STS) and the pre-defined risk assessment (PDRA) aims to facilitate
respectively the declarative and the permit application process by drone operators by ensuring that the
risk assessment has already been performed in accordance with the SORA methodology for some low
to medium risk operations performed in the ‘Specific category’.
54
Page 36 / 86
 kom (2022) 0652 - Ingen titel
2639143_0038.png
8.1.3 Developing Innovative Air Mobility
Drones are no longer limited to small, electric rotor aircraft commonly used by recreational users
or commercially, and have the potential to replace conventional piloted aircraft. eVTOL aircraft
in particular have opened a whole new range of possible mobility services to urban and sub-urban
local communities. As drone technology has advanced, the identified potential use cases
involving manned eVTOLs have rapidly expanded, particularly for public services such as
emergency medical transport and evacuation, air taxi or deliveries. In addition to intra-urban or
sub urban eVTOL aircraft using vertiports on top of buildings and other dedicated landing pads,
there are also fixed wings type of drones which offer longer range connectivity. These operations
are falling under the 'certified' category and should be subject to the same safety levels as manned
aviation. Therefore, drone operators, remote pilots and drones (including manned VTOL aircraft)
should be subject to uniform rules and procedures. The remaining significant technical and safety
regulatory gaps which are preventing such ‘certified’ operations to be performed should be
addressed by new regulatory rules addressing the certification of aircraft, as well as the approval
of the drone operator and the remote pilot licence by the competent authority.
New aircraft types are coming onto the market with alternative propulsion and new vehicle
designs, all increasingly automated and remotely piloted. These have the potential to meet the
demand for alternative modes of transportation in large cities or rural area, and the challenge of
reducing noise and CO² emissions (green propulsion and optimized designs). Urban Aerial
Mobility thus offers to local decision-makers the opportunity to rethink their mobility and land
development planning by giving their territorial development projects a new orientation,
reconvert the existing means of transport and improve the quality of life of their populations.
Several studies estimate that impact of Innovative Air Mobility on overall travelling time,
particularly over congested road traffic to be positive. These services can be seen from multiple
angles:
Air taxi services based on a wide network of point-to-point travel often associated with
eVTOLs and similar to current road taxis.
Scheduled air passenger transport following pre-determined routes, regular schedules,
and a network of stops throughout the city, complementing existing ground public
transport.
Drones could potentially deliver small payloads faster to the customer (B2C) for example
by reducing the number of pickups and thereby save time;
According to studies, in a city like Helsinki, drones for consumers could deliver orders 35 - 75
percent faster, depending on the scenario. The impact on time savings as a result of reduced pick-
ups in this area is estimated at approximately 1.5 million hours. In addition, delivery costs
(incurred by service providers) will likely reduce by up to 45 per cent in case of instant deliveries
compared to conventional methods of delivery.
55
This would clearly lead to a reduction in
consumer costs for delivered goods.
The addition of aerial mobility in the city's landscape gives urban planning authorities an
additional dimension to play with. This opportunity will require new tools, new skills and will
open up a new field of decisions to be made, supporting a gradual transformation over a period of
at least five to ten years. In the short term, the most useful developments will emerge through
gradual homogenic integration as cities continue to modernise themselves, and only in agreement
with the local authorities and communities.
55
Gaia Consulting Oy (2021), Potential Benefits of Drone Deliveries in Helsinki.
Page 37 / 86
 kom (2022) 0652 - Ingen titel
2639143_0039.png
IAM eVTOL operations require some physical infrastructure assets such as vertiports and other
landing paths, including embarking and disembarking facilities, such as lockers or other storage
facilities, for package deliveries as well as charging stations. Vertiports are a key enabler for the
IAM concept and city authorities
56
are increasingly starting to include drone transport into their
urban development plans. Vertiports should be open large multi-landing locations that have
support facilities (including charging infrastructure, support personnel, etc.) for multiple eVTOL
companies. A regulatory framework for vertiports and other ground infrastructure should be
developed, and a particular attention should be given to ensure appropriate interface with
aerodromes, interoperability, and open access of equipment to ground infrastructures by drone
operators and environmental impacts. In this regard, the regulatory framework should ensure that
those ground infrastructures do not become proprietary and follow the same open model as
airports and heliports.
Over time, drones for transport can be expected to affect land use and property values, both
positively and negatively. Where drones are perceived to provide benefits, property values are
likely to increase, but where they are perceived to be an annoyance (e.g. due to noise, visual
disturbance or privacy concerns), property values are likely to decrease.
Drones may also affect land use patterns, as improved accessibility may create an incentive for
people or businesses to move away from dense urban areas.
Although drones have the potential to improve many aspects of our society and economy, the
realisation of these benefits will depend on putting into place a good foundation. The question of
market access of drone operators has to be addressed at EU level. Currently, the economic and
financial conditions to obtain a Community Air Carrier operating licence are set out in
Regulation (EC) 1008/2008
24
. This Regulation covers the transport of passengers, cargo and mail
and is therefore also potentially applicable to drone operators. However, these rules, which were
originally designed to cover large Commercial Air Transport undertakings, might be
disproportionate for drone operators. A review of this Regulation should ensure fair market
access and establish common requirements which are more suited to the economic and financial
situation of drone undertakings. The use of existing tools such as the Union framework for
screening of foreign direct investment (FDI)
57
could avoid hindering the development of IAM by
removing barriers to access to venture capital.
With careful management, drones could improve access to places of opportunities (such as jobs,
health care, education) and contribute to a safer, more efficient and more sustainable transport
system. However, they have also the potential to increase noise, vibration and other
environmental impacts while exacerbating inequality in the transport system if they are not
managed carefully.
8.1.4 Ensuring societal acceptance
Drone in general and IAM services in particular may only emerge if local communities and their
representatives subscribe to them. A study led by EASA showed that “EU citizens initially and
spontaneously express a positive attitude towards and interest in UAM; it is seen as a new and
attractive means of mobility and a majority is ready to try it out”
58
. The social benefits of drone
56
https://civitas.eu/urban-air-mobility
57
Regulation (EU) 2019/452 of the European Parliament and of the Council of 19 March
2019 establishing a framework for the screening of foreign direct investments into the Union, OJ
L 79I , 21.3.2019, p.1.
58
EASA, “Study on the societal acceptance of Urban Air Mobility in Europe”, May 19, 2021
Page 38 / 86
 kom (2022) 0652 - Ingen titel
2639143_0040.png
operations should be highlighted as they would justify support from national and local public
authorities to further their development. The main benefits which can secure public acceptance
would first and foremost be emergency medical transport, transport of medical products and other
first aid and rescue applications. The point-to-point transport of people for example, in the
context of city centre-airport or port links, are another useful application which could support the
acceptability of for example the siting of drone vertiports and other specific infrastructures
located close to residential areas, as IAM would provide improved connectivity.
It is clear that the fact that the drones operated at a low and medium altitude over populated areas
also raise safety concerns. EU citizens want to limit their own exposure to all possible risks,
whether related to safety, noise, security and environmental impact (including the protection of
the wildlife), as well as other concerns related for instance to cyber-security. Furthermore, on the
economic side, the issue of affordability is of key importance. IAM should not be seen as a
service for a small part of the population only. Public acceptance will also be based on the price
of the service offered by IAM operators.
59
As highlighted in the EASA study, the environmental impacts of drones are both positive and
negative. Besides the noise aspect, drones may also have negative impacts on wildlife and
generate visual disturbance. All these impacts will need to be clearly identified and carefully
managed.
According to the EASA study, the acceptability of intra-urban and inter-city drone operations
involving goods delivery and air taxi would require addressing in priority:
high safety level;
noise;
environmental impact (including greenhouse gas emissions) and the impact on wildlife;
security and, in particular, protection from cyber-attacks from such autonomous devices;
In terms of safety, EASA and national aviation authorities have a duty to ensure the safety of
flights, operations and passengers for both drones and manned aircraft. The overall objective
which has been set for drones is to achieve the same level of safety as in manned aviation. EU
aviation safety rules provide a framework to ensure that this goal can be achieved. It also implies
regular audits and inspection, oversight by the competent authorities in order to guarantees the
initial and ongoing airworthiness of aircraft and the entities operating them.
As mentioned in chapter 1.5.2.3 above, similar to manned aviation, drone manufacturers will
have to obtain a certificate of airworthiness ensuring the safety of passenger and cargo transport
operations, initially with a pilot and later for autonomous operations. The drone operators will
have to obtain an Air Operator Certificate or its equivalent for eVTOL aircraft operators and
remote pilot will have to hold a licence similar to airline pilots. These regulatory developments
will have to be addressed in the coming years as explained in the Communication.
Noise is a key factor which has been highlighted as a major obstacle to drone integration. This is
due not only to the actual noise drones produce (often a high-pitched tone), but also to the ways
in which noise is perceived – such as disruption of people’s tranquillity and people’s familiarity
with and acceptance levels of drones, or surrounding noise levels). In cities, the ambient noise
levels of conventional vehicles may make drone noise less apparent if flown along main roads at
very low altitude. However, their proximity to residential areas, and the increasing uptake of
59
“Seat
prices as presented today range from less than €100 (RATP ADP) to €300 or €400 (ADP target
for the 2024 Olympics). The profitability horizon of an air mobility service when announced is quite
distant (after 2050).”
Air and Space Academy, AAE Dossier 53 2022, “The viability of electric urban
transport aircraft”.
Page 39 / 86
 kom (2022) 0652 - Ingen titel
2639143_0041.png
quieter electric ground vehicles, may make drones more noticeable and create strong, localised
pushback as the market expands. To help avoiding this, the Commission will fund the
development by EASA of an online platform as a “pilot project Sustainable IAM Hub” that will
provide support to authorities, cities, industry and other stakeholders for IAM implementation.
This European cross-sectorial governance platform for IAM should enable engagement,
alignment, and coordination between the different stakeholders. Furthermore, when developing
the IAM regulatory framework, EASA could examine possible alleviations for specific use cases
or operations that would be in the direct interest of the public. EASA should also continue the
development of suitable drone and eVTOL noise modelling methodologies, which should be
taken into account by the Commission for the next amendment of Annex II of the Environment
Noise Directive for the purposes of adapting common noise assessment methods to scientific and
technical progress.
Unsurprisingly drone noise primarily depends on the drone model and payload, as well as on the
operating state or the flight manoeuvre. Drone noise annoyance strongly depends on the sound
pressure level, which is the same as for other transportation noise sources. Comparisons of drones
to other transportation noise sources are still scarce, which seems to be a large gap in
understanding the potential impact. The Environmental Noise Directive should take account of
IAM developments to counter misapprehensions about drone potential noise impact. Rather than
attempting to drive acceptance from the public for unacceptable noise and visual disruption,
focus should instead be on how to make civil drones more acceptable, through technological
improvement. This would be in conjunction with the creation of exchange platforms between
industry and neighbourhood associations and give industry operational experience and
opportunity to develop technologies and testing methodology to evaluate noise in an urban
operating environment, as well as give regulators valuable feedback on the adequacy of rules.
Regarding environmental aspect, the EASA study highlighted in particular the perception that
drones can negatively impact wildlife and protected nature areas. Like for noise, scientific papers
specifically evaluating the effects of drones on wildlife are also scarce but increasing. The impact
on wildlife (even in urban areas) is an increasingly important consideration as drone activity
scales up. Among different animal types, birds, especially in larger groups, are the most sensitive
to drones. Flightless birds and large birds are more likely to be disturbed than smaller ones.
Terrestrial mammals are overall less reactive to drones than birds. Given the low altitude at
which small drones operate, drones may also interact with local fauna, generating a new type of
anthropogenic disturbance that has not yet been systematically evaluated.
On cybersecurity too, it is increasingly apparent that low and medium altitude overflights of
populated areas are perceived as a threat, hence the strong focus on the vulnerability to cyber-
attack of these aircraft systems and controls. This aspect is covered under chapter 8.2.4 below.
8.1.5 Promoting the human dimension (knowledge, training, competences)
Changes in skills requirements are most visible in sectors that are strongly influenced by the
digitalisation of their operations, notably in air transport. To realise the full potential of drones,
the private sector is not only developing the drones themselves, but also the technologies needed
to support their integration into the transport system. Drones need to integrate not only the
aviation system, but also the transport system and society more broadly. This requires input from
experts in new technology fields and other transport sectors beyond aviation; and experts from
both aviation and from outside the sector need to understand the regulatory environment and
culture of both aviation and other transport policy fields, such as urban transport planning.
Page 40 / 86
 kom (2022) 0652 - Ingen titel
2639143_0042.png
This will require new competency profiles. Digitalisation and automation are at the core of the
drone operations development and is already affecting employment in this sector. The
development of skills and competence will a key factor to maintain European leadership by
ensuring that the different drone segments can cope with complex regulatory requirements, i.e.
certification of drone operators, SORA, certification of Common Information Services and U-
space service providers. Without a highly educated, qualified and experienced workforce on the
ground and in the air, operational safety cannot be achieved. The qualification level of a
sufficient number of pilots for the initial phase of eVTOLs and remote pilots for the control unit
could pose a recruitment and training problem if the number of e-VTOLs increases. The
autonomy or remote control of e-VTOLs envisaged in the future could provide part of a solution
to this problem but there is a need for the sector to keep pace with the needs as drone operations
will increase.
To ensure that remote pilots have the requisite level of knowledge and skills in line with
continuous advancing technological development, Commission initiatives could be used like the
“European Skills Agenda for sustainable competitiveness, social fairness and resilience” and its
flagship action: the “Pact for Skills” aims to gather industry, private and public entities, which
could support the Drone ecosystem and the digitalisation priorities identified in the Sustainable
and Smart Mobility Strategy (see 4.1.4). These partnerships can build on the “Blueprint for
sectoral cooperation on skills”
60
for gathering sectoral skills intelligence, mapping key
occupation needs, defining occupational profiles and developing training programmes.
The sector should develop and enhance competency-based training such as those of drone
specialists. Initially, the ‘certified’ category will involve two different types of pilot licences. One
for flying a ‘VTOL aircraft’ with an on-board pilot and one for flying an ‘unmanned aircraft’ as a
remote pilot who may control one drone at a time, or control simultaneously several drones, also
of different types and from different operators. Training should also be given as a priority to IAM
operators’ personnel in view of future autonomous operations.
The EU sectoral social dialogue as well as partnerships between research, universities and
industry on education could provide a framework to develop a joint approach to the social
challenges related to digitalisation, training requirements and professional qualifications.
Education and training programmes specific to drone technologies, the regulatory framework and
the integration of SUMP’s activities should be set up in all Member States. Such academic and
vocational programmes across Europe would foster the competences and technological progress
but also increase the public awareness and acceptance of drone utility.
To support the implementation by Member States of the newly created regulatory framework and
to be in the position to smoothly manage SORA approvals, EASA has developed a number of
tools to assist competent authorities implementing EU regulations correctly and on time, which
include guidance documents, implementation plans, expert groups, explanatory documents,
training, organising workshops and holding online meetings. Competent authorities should have
the necessary competences that reflect the highly digital and automated nature of the technologies
underpinning drone operations and U-space services provision as well as the necessary number of
regulatory experts in drones and drone operations at both local and national authorities’ level to
address industry needs.
60
https://ec.europa.eu/social/main.jsp?catId=1415&langId=en
Page 41 / 86
 kom (2022) 0652 - Ingen titel
2639143_0043.png
8.2 Strengthening European civil, security and defence industry capabilities
and synergies
The EU industrial policy
61
stresses the importance of reinforcing Europe’s industrial and strategic
autonomy and supporting the development of key enabling technologies that are strategically
important for Europe’s industrial future. By seeking synergies between civil, space and defence
industries in EU programmes, the EU will make more effective use of resources and technologies
and create economies of scale. The Action Plan on synergies between civil, defence and space
industries identifies the drone technologies as critical technologies for the EU and calls for the
need to ‘identify areas of cross-fertilisation, so that defence projects benefit from innovative
developments emerging from SMEs active in the field of civilian drones and that civil
aeronautics benefit from developments in the field of defence’.
8.2.1 Providing funding and financing
The European Commission has funded various drones-related research projects through its
successive R&D Framework Programmes. The support for research in the drone sector has been
substantial in the past and critical for an early deployment. 320 projects relating to the drone
sector were conducted under Horizon 2020, with a total budget of almost 980 million euros
invested in the development or use of drones for innovative applications. This effort will be
further latest framework being the current Horizon Europe programme. In May 2019, SESAR
Joint Undertaking launched an open call for exploratory projects with the framework of the
SESAR 2020 Research and innovation programme covering drone technologies such as U-space
and more recently, one of the specific objectives of SESAR 3 Joint Undertaking will be to
develop a research and innovation ecosystem covering the entire ATM and U-space airspace
value chains allowing to build the Digital European Sky defined in the European ATM Master
Plan, enabling the collaboration and coordination needed between air navigation services
providers and airspace users to ensure a single harmonised Union ATM system for both manned
and unmanned operations.
In addition, there is a need to secure support and buy-in from the military community (in their
roles as air navigation service providers (ANSPs), airport operators, airspace users and
regulators) in relation to SESAR 3 JU activities and the ATM Master Plan. In particular, areas of
common interest include the ATM Master Plan, regulations, space-based systems, the integration
of unmanned aerial systems, cybersecurity threats and vulnerabilities of ATM, and the
development of aviation/ATM standards.
Public financing and R&D funding should support projects that are geared towards further
automation and sustainability. Infrastructure associated with U-space and IAM implementation,
including the landing site and charging infrastructure, should be considered for eligibility within
traditional EU infrastructure funding pathways. Funding should also focus on multi-mode
infrastructures where aviation could benefit from energy (i.e. hydrogen to power drones) and
telecom cross-fertilisation. Eligibility requirements for public funding should be adapted to the
new competitive market framework and should include a robust business plan.
In 2020, the EIB Group adopted the Climate Bank Roadmap 2021-2025, withdrawing support
from conventionally fueled aircraft. The European Investment Bank (EIB) can finance drone
projects aligned with the Climate Bank Roadmap (i.e. deployment of zero emission drones) in
areas such as civil protection, deliveries, medical supplies, surveillance, using a wide range of
adapted financial products such as loans or venture debt.
61
COM(2020) 102 final, COM(2021) 350 final
Page 42 / 86
 kom (2022) 0652 - Ingen titel
2639143_0044.png
The EIB and other international financing institutions also provide a broad range of technical
assistance services to IAM projects at different stages of the market-based project life cycle. The
handout European Drone Investment - Advisory Platform” was jointly launched by the European
Commission and the EIB to support innovation and investment in drones. The handout maps out
the advisory and financial products that can potentially be used to support investments in drones
depending on the area of investment and the maturity of the market. The EIB monitors the
evolution of the drone sector in particular for Urban Air mobility and U-space providing funding
and technical assistance including for infrastructures that will enable drone operations. The EIB
also produced a guide to finance for drone projects, which helps promoters, among other things,
to develop a structured approach to assess air mobility projects, identify missing components and
outline sources of funding, and prepare clearly defined requests for technical assistance and/or
financing. The InvestEU Advisory Hub which complements the InvestEU Fund is supporting the
identification, preparation and development of investment projects across the European Union.
Due to the immaturity of the wider IAM market in the European Union, it is difficult to assess
whether there is a lack of available financing or a lack of financeable projects. According to the
EIB, engagement with some key European cities appears to indicate the latter, as many projects
are lacking a robust business case including an appraisal of required funding or how such funding
may be sourced.
Most IAM projects are still at the R&D phase, funding needs for UAM projects are ranging from
the development of living-lab for drone operators to test their technology and business model
(e.g. medical deliveries, transfer of patient via eVTOL, ground infrastructure, etc.) to the
development of the U-space system. Beyond venture capital, the most relevant financial
instruments are still research funding (specifically through research grants).
In addition to these funding programmes by European and national bodies and agencies, there is
also access to funding to venture capital investors that can accelerate the deployment of drones
and U-space. However, according to the EIB, due to the immaturity of IAM applications, most of
the investments are focused on the vehicles rather than infrastructure and services.
The European Defence Fund (EDF)
62
incentivises and supports collaborative, cross-border
research and development in the area of defence. The Fund will increase the EU’s technological
edge and develop the capabilities that are key for the strategic autonomy and resilience of the
Union and its Member States and the protection of its citizens. Complementing and amplifying
Member States’ efforts, the Fund promotes cooperation among companies and research actors of
all sizes and geographic origin in the EU. In doing so, it will integrate further the European
defence technological and industrial base, develop industrial skills and competencies as well as
the innovation potential of Europe’s industry.
Through the EDF and its precursor programmes, the Preparatory Action on Defence Research
(PADR) and the European Defence Industrial Development Programme (EDIDP), the European
Commission has funded and aims to further fund various drone-related projects in the framework
of defence research and development projects. The PADR (2017-2019) programme funded two
research topics on technological enablers for drone operations (EU grant together € 3 million). In
the EDIDP (2019-2022) programme seven development projects up to a grant value of € 189
million, including Counter-UAS, are funded. In EDF 2021, a total of five projects are selected for
funding that contain drone relevant research and development (EU grant together € 87,3 million)
.EDF 2022 calls for proposal include three drone-related topics.
62
https://defence-industry-space.ec.europa.eu/eu-defence-industry/european-defence-fund-edf_en
Page 43 / 86
 kom (2022) 0652 - Ingen titel
2639143_0045.png
As presented in Chapter 4.3, the Commission is funding and financing drone R&I through
number of different programmes. These programmes continue providing support under the
current 2021-2027 MFF as well as defence-related R&D with new EFD instrument.
The increased size of funding which is delivered through a variety of EU programmes and
instruments presents opportunities for synergies that could reduce risk of duplication and provide
more user-friendly opportunities for financing (e.g. grants, public procurement, guarantees) while
safeguarding at the same time that promising projects funded at an early phase are not starved of
funding before they are deployed. It is necessary to seek coherence and enhance the
complementarity between the relevant EU programmes to increase efficiency of investments and
effectiveness of results, thus bringing better value for EU money by maximising the exploitation
of EU funded R&D projects in civil, security and defence sectors.
Further coordination could also be pursued on national research activities with the help of EASA
on UAS/UAM to ensure that there are no gaps and to ensure cross sharing of results from
research activities.
8.2.2 Identifying strategic technology building blocks
Remaining at the cutting edge of technological development is critical for ensuring Europe's
prosperity, security and way of life. The new technologies are transforming the security and
defence sectors at a faster pace than ever before and blurring the dividing line between the
civilian and military domain.
In her 2019 political guidelines
63
, President von der Leyen underlined that ‘it
is not too late for
Europe to achieve technological sovereignty in some critical technology areas’.
The 2020 EU
industrial strategy
64
stated that Europe’s strategic autonomy is about reducing dependence on
others on critical technologies. They also provide Europe’s industry with an opportunity to
develop its own markets, products and services which boost competitiveness.’ The EU will
therefore support the development of critical technologies that are strategically important for
Europe.
As stated in the Roadmap for Critical Technologies for security and defence
65
, ‘lack
of foresight
on the future importance of technologies is in part to blame for some of the EU’s existing
strategic dependencies on third countries, e.g. on remotely piloted systems’.
Based on the Report of the Drone Leaders Group, ‘the
availability of the required components,
vehicles and systems in Europe is a core condition for developing a competitive and autonomous
European drone services sector. It is necessary to ensure that the drone manufacturing industry
will have a reliable supply of essential parts and financial and technical resources to develop
and manufacture state-of-the-art products’.
Although Europe has a developed drone industry, significant part of production of drones and
critical components take place outside Europe. For example, such key components such as
batteries, propellers, electric engines and sensors, are commonly produced in Asia, i.e., China,
Singapore and Taiwan. Nowadays, the shortage of raw material, such as microchips, electronic
components and IT hardware has highlighted the fact that Europe is dependent on Asian suppliers
on components and know-how. To minimise this dependency, the EU industry should strongly
consider manufacturing drone components in Europe and organise itself accordingly.
63
64
65
https://ec.europa.eu/info/sites/default/files/political-guidelines-next-commission_en_0.pdf
COM(2021) 350 final
COM(2022) 61 final
Page 44 / 86
 kom (2022) 0652 - Ingen titel
2639143_0046.png
Identifying which critical technologies make a decisive contribution to key capabilities can help
to decide: (i) which technologies are important for technological sovereignty (i.e. where there is a
need to reduce the risk of dependence); and (ii) where combined/coordinated support from
different EU programmes and instruments can address such challenges. To strengthen its
technological sovereignty, the EU and its Member States must maintain a strong industrial
competence and, where possible, seek leadership in these critical technologies.
Alongside the critical technologies, the following aspects should be taken into account:
the drone value chains, including the security of supply of critical components and materials
that are important building blocks for competitive and autonomous industry;
related research and testing infrastructure, which is key for standardisation and certification.
Therefore, a Strategic Drone Technology Roadmap identifying critical drone technologies such
as AI, robotics, semi-conductors, hybrid and electric propulsion systems, safe, secure and
resilient C2 link and energy storage, batteries and cloud technologies should be defined at EU
level, in collaboration with the Observatory of Critical Technologies set up by the Commission
under the Action Plan on synergies between defence, space and civil industries.
In particular, the roadmap should further set out as priorities for Research and innovation in the
area of:
detect and Avoid (DAA) technological development to allow a greater degree of automation,
inside and outside U-space airspace, working alongside standardisation bodies, such as
EUROCAE, and the global framework governed by ICAO.
European strategic technologies, such CNS supporting UAS operations in the specific
category and safe, secure and resilient C2 link (satellite based C2L solutions for IFR RPAS)
for drone operations in the certified category. Equivalent performance requirements should
be demonstrated during the respective civil and military certification paths.
Critical technologies are bound to change as new technologies emerge. Therefore, the Roadmap
should be monitored by the Observatory and reviewed periodically in order to identify the latest
needs as well for reviewing the previously established priorities.
8.2.3 Enabling testing and demonstrations
Live testing and demonstrations are key to harnessing, developing, and accelerating the take-up
of the most cutting-edge technological solutions to manage drones and innovative air mobility.
The SESAR Joint Undertaking (SJU) is managing a portfolio of very large-scale demonstrations
aimed at making aviation smarter and more sustainable, and paving the way for innovative air
mobility (IAM) in Europe. A sizeable portion of the demonstrations specifically address the safe
and secure integration of drones, building on the outcomes of previous SESAR U-space research,
with the first related call dating back to 2016. The demonstrators are a key tool to support the
SESAR JU’s vision of delivering the Digital European Sky, matching the ambitions of the
European Commission’s European Green Deal, Digital Europe and the recently launched strategy
on smart and sustainable mobility.
The Digital Sky Demonstrators take place in live operational environments and put to the test (on
a very large scale) the technological solutions necessary to deliver the Digital European Sky.
Demonstrations can also lead directly to implementation, which has been the case in the island
city of Tromsø, Norway. Following real-life trials by partners in SESAR’s GOF2.0 project
66
,
66
https://gof2.eu/
Page 45 / 86
 kom (2022) 0652 - Ingen titel
2639143_0047.png
VLOS unmanned inspection flights are now permitted within the town, despite being within the
5km exclusion zone of Tromsø Airport.
Still, in many SESAR U-space demonstrations, it has become apparent that testing and
demonstrations become more complicated, as more new technologies are tested. Current aviation
regulations do not yet cover live flights by autonomous vehicles or air taxis, for example, which
makes it very difficult for advanced research to progress. Very large demonstration projects are
for instance also confronted to the problems already mentioned in 8.1.2 above, which may delay
the operational approval operations and make the regulatory authorisation process longer and
more expensive than it is reasonable in the context of demonstration projects with individual
flights and no immediate commercial pay-back.
EASA should, in addition to reviewing the scope of, and requirements for drone design
verifications, develop specific guidelines to support the application of the SORA methodology to
operations conducted for the purpose of test, experimentation or demonstration, and consequently
facilitate live testing and demonstrations in the context of the current regulatory framework.
Alongside development of the regulatory environment, it would also be useful for the
Commission to set up a network on drone civil-defence testing centres. It would also be useful to
creates a network of such test and demonstration sites across Europe that allow stakeholders to
try new concepts and technologies in a safe airspace and ground volume. Such a network should
allow for more generic sites all the way to very specialised sites, depending on the technical need,
and contribute to the establishment of European digital innovation hubs, as envisaged by the EU
industrial strategy, which can act as one-stop-shops for companies to access technology testing
and showcase innovative solutions for the civil, defence and space markets.
Moreover, since airspace and airfield facilities are at a premium, maximum use should be made
of military facilities to enable dual-use of defined airspace volumes as well as to promote
harmonised testing between civil, military and space operators.
8.2.4 Driving for common standards
Standards play a major role in defragmenting markets and helping industry in achieving
economies of scale. The development and implementation of research and innovation agendas
including through standardisation is essential for EU competitiveness. The Commission gives
strong support to the market uptake of innovation, in particular to supporting standardisation
through research and putting science into standards. Standardisation activities are an essential
channel for the market adoption of research results and for the diffusion of innovations. Creating
EU-wide standards and promoting them on a worldwide level is also a vital component of the
global competitiveness of the EU economy in general.
The contribution of standardisation to Framework Programmes (FP) for Research and Innovation
of the European Union dates back to the early nineties under FP4 (the Standards, Measurement
and Testing Subprogram (SMT)) and FP5. In later Framework Programmes, including Horizon
2020, standardisation became a horizontal support tool relevant across all research areas. Horizon
Europe, the new Framework Programme for Research and Innovation for the period of 2021-
2027, will support valorising R&I results through standardisation to the highest possible extent.
The impact of the digitalisation cannot be underestimated when it comes to standardisation.
Aviation moves from a human-centric system - where safety ultimately depends on pilots and air
traffic controllers – towards an information-centric system, where highly automated aircraft can
fly safely based on information flowing on mobile telecommunication networks. As the aviation
and mobile telecommunication worlds converge, the need for Information and Communication
Technology (ICT) standards will increase in aviation. This is particularly observable in the field
Page 46 / 86
 kom (2022) 0652 - Ingen titel
2639143_0048.png
of drones and unmanned aircraft traffic management solution, which are a laboratory for digital
aviation solutions.
U-space service providers should be able to use a range of connectivity tools, including the
existing telecom equipment. When using telecom infrastructure for command-and-control
purposes, drone stakeholders should be able to use standards developed by the appropriate
standardisation organisation, including ICT or joint standards. The importance of such
collaboration between ICT and aviation industrial organisations is illustrated by the Aerial
Connectivity Joint Activity, an initiative between the Global UTM Association and the GSM
Association.
As we progress towards the Digital European Sky, and in accordance with the Action Plan on
synergies between civil, defence and space industries, it is vital that standardisation cover all
airspace users, including the military, drones and HAO. The concept of dual-use standards was
introduced in the 2012 Action Plan for an innovative and competitive Security Industry
67
, which
recommended that the development of 'hybrid standards', i.e. standards that apply both to civil
and defence technologies, should be actively pursued in areas where technologies are the same
and application areas are very similar. This was further reinforced in the 2021 Action Plan on
synergies between civil, defence and space industries
68
, calling for the development of hybrid
technological standards and best practices applicable across the civil and defence sectors.
Such ‘best practices’ could include the development of standard scenarios of dual use nature for
the specific category such as scenarios Beyond Visual Line of Sight (BVLOS) and above 500
feet (or without altitude limitation) which could facilitate civil and military operations such as
cargo and emergency delivery of goods, surveillance over land and sea, reconnaissance for
disasters scenario and ferry flights. Deeper collaboration between the key stakeholders such as
EASA, EDA and competent national civil and military authorities in the development of such
scenarios could lead to savings in time and better use of limited pools of experts.
Much current military standardisation activity for drones is already aiming to be undertaken by
civil standardisation organisations such as EUROCAE, so that civil and military platforms can
safely inter-operate in the same airspace. Research and demonstration projects should not only
seek to ensure that all drone standardisation, when appropriate, meets the needs of both civil and
military airspace users, but also mechanisms should be investigated to improve standardisation
practices by learning from and re-using, where possible, military standardisation processes and
agencies. The scope of such standardisation should include all relevant technologies, including
Integrated CNS, DAA and automation.
To coordinate such standardisation activities, the European Commission established the
European UAS Standardisation Coordination Group (EUSCG)
69
, a joint coordination and
advisory group coordinating the drone-related, including U-space, standardisation activities
across Europe, and essentially stemming from the EU regulations and EASA rulemaking
initiatives. The membership of EUSCG is composed of:
67
68
69
AeroSpace and Defence Industries Association of Europe (ASD)
ASD-STAN
ASTM (Europe)
Drone Manufacturers Alliance Europe
Drone Alliance Europe
COM(2012) 417
COM(2021) 70
https://www.euscg.eu/
Page 47 / 86
 kom (2022) 0652 - Ingen titel
2639143_0049.png
EASA
EUROCAE
EUROCONTROL
European Commission
European Defence Agency (EDA)
European Standardisation Organisations (ESOs): CEN, CENELEC, ETSI
Global UTM Association (GUTMA)
ISO
JARUS
SAE
SESAR JU
The EUSCG is supported by the work of the AW-Drones Horizon 2020 project
70
, which is
developing an open repository of unmanned aircraft standards and validating the suitability of
technical standards to comply with existing regulation for drone operations.
Finally, relevant actors such as EASA, EDA, EUROCAE and national military authorities should
be encouraged to further harmonize certification requirements for civil and military applications
towards those set by EASA while considering military specificities and existing military
certification standards.
8.2.5 Increasing counter-UAS capabilities and system resilience
Counter-drone
New technologies can offer valuable opportunities but may also pose emerging threats that need
to be addressed. The growing use of drones is no exception to this rule, as they can be misused to
target public spaces, individuals and critical infrastructure
71
. While the EU has regulated the
legitimate use of drones, there are no specific EU rules and guidelines on countering their
unauthorised, as well as the use for criminal or terrorist purposes. The rapid pace of innovation
and easy access to these devices as well as the components to make them, means that the threat is
likely to grow – as also shown by the substantial use of civil drones in armed conflicts around the
world.
Preventing the unauthorised use of drones in our societies is also necessary to allow the
legitimate use of drones to reach its full potential. Protecting our societies against malicious and
non-cooperative drones also requires access to affordable and reliable counter-measure
technologies that enable flexible solutions adapted to the threat level and the operating situation.
It is not possible to have a standardised “one-fit-all” approach to counter drone (C-UAS)
measures, as some technological solutions may not fit in an urban or crowded environment while
they may be adequate to protect e.g. critical infrastructures. Moreover, it is important to have
appropriate legal frameworks in place to implement procedures, provide clear authority to
intervene and facilitate collaboration between stakeholders which are not always used to work
together (esp. law enforcement, aviation, operators and, manufacturers).
Commercial drones can be used for legal and illegal activities, by citizens and businesses but also
by criminals, terrorists or hostile state actors. The majority of drone users, however, are likely to
70
71
https://www.aw-drones.eu/
The threat of UAS using explosives was investigated by the JRC (Larcher M, Karlos V, Valsamos G,
Solomos G: Scenario study: drones carrying explosives, JRC107683, 2018).
Page 48 / 86
 kom (2022) 0652 - Ingen titel
2639143_0050.png
be compliant with the rules and regulations, and notably licensed professional remote pilots are
typically aware of the applicable legislation and technical limitations. Nevertheless, clueless,
careless, and criminal drone users are responsible for the numerous, if not daily, incidents
involving drones across the EU.
Both the 2020 EU
Security Union Strategy
72
and
Counter-Terrorism Agenda
73
clearly state that
the threat of non-cooperative drones is a serious concern in Europe that needs to be addressed. In
relation to the Counter-Terrorism Agenda in particular, the Commission intends to release in
2023 handbooks on “Protection against Unmanned Aircraft Systems – Handbook on Counter-
UAS for Critical Infrastructure and Public Spaces” and “Protection against Unmanned Aircraft
Systems – Handbook on Principles for Physical Hardening of Buildings and Sites”.
The Directive on the resilience of critical entities (CER Directive)
74
will introduce obligations on
Member States and critical entities to conduct risk assessments and for critical entities to take
technical, security and organisational measures to ensure their resilience against identified risks.
These assessments may include the risk posed by non-cooperative drones.
Many Member States are still addressing the challenge of making available the necessary
budgets, adapting or creating the necessary regulatory framework and identifying the right
(technical) solutions to be able to cope with the different threat situations of non-cooperating
drones.
To support Member States the JRC and its drone project will review processes and interactions
between stakeholders and the use technologies and how these technologies can be combined into
solutions, which can be used to ensure the security of citizens and critical infrastructure.
One part of the drone project is the creation of a living lab with a C-UAS solution implemented
that will be open to stakeholders to investigate counter UAS solution aspects and how these can
be applied in real. The living lab implementation will be designed so that it can be used as a
guide to comply with the legally required Geel site protection (Class 1 Nuclear installation).
More specifically in the area of aviation, drone incidents may endanger aircraft and their
occupants. Most occurrences have been reported during approach/landing and take-off/climb,
which are the most critical phases of a flight. To better understand the vulnerability of manned
aircraft to drone strikes, EASA is managing a project supported by Horizon 2020 that is expected
to run until June 2023. Besides these physical risks, drones can also cause economic and
operational damages. The most severe drone-related disruptions took place at London Gatwick
Airport between 19 and 21 December 2018. Following reports of drone sightings, the airport’s
runway was closed which led to the cancellation of approximately 1,000 flights and impacting
140,000 passengers. This incident is estimated to have cost the industry up to EUR 64 million. A
2020 study
75
suggests that if Frankfurt airport had to be closed for a continuous 48-hour period
due to drone sightings, it would cost EUR 3 million to the airport and another EUR 34 million to
the airlines. Incidents of a smaller scale can also cause significant cost, particularly if they lead to
72
73
COM(2020) 605 final of 24 July 2020
COM (2020) 795 final of 9 December 2020
COM(2020) 829 final of 16 December 2020. The European Parliament and the Council reached
political agreement on the proposed Directive on 28 June 2022 (Security Union (europa.eu))
Wendt, P., Voltes-Dorta, A., & Suau-Sanchez, P. (2020). Estimating the costs for the airport operator
and airlines of a drone-related shutdown: an application to Frankfurt international airport. Journal of
Transportation Security, 1–24.
74
75
Page 49 / 86
 kom (2022) 0652 - Ingen titel
2639143_0051.png
the closure of the runway. For the ten largest European airports, the delay cost of a 30-minute
runway closure is estimated to range from EUR 325,000 to EUR 514,000
76
.
For the time being, EU legislation contains no explicit provision specifically addressing the
threats posed by drones at and around airports. Article 38 of the EASA Basic Regulation
77
contains a general obligation for aerodrome operators to “monitor
activities and developments
which may cause unacceptable safety risks to aviation in the surroundings of the aerodrome”
and
to “take
the necessary measures to mitigate those risks in as far as this lies within their control”.
Regulation (EC) No 300/2008
78
dealing with aviation security contains no specific provision on
drones.
The Commission has been supporting Member States in addressing the threats from non-
cooperative drones since 2016. The scope of the Commission’s counter-UAS work covers a wide
range of activities aimed at enhancing Member States’ capabilities in this area, based on the
following six pillars:
Community-
building &
information
sharing
European
Program for
C-UAS
systems testing
Practical
guidance &
support
Research &
innovation
Funding
suppport
Legislative
measures
1. Community building and information sharing
On a regular basis (every 6 months), workshops are organised by the Commission with
representatives from Member States, EU Institutions, EU Agencies, EU-funded projects,
International Organizations and partner third countries. This has led to a continuous engagement
of all stakeholders, facilitating also significantly their operational and practical cooperation.
To this end, the Commission has also set up a dedicated
Counter-UAS Interest Group
(shared
drive with limited access to registered stakeholders) which currently has almost 300 members.
This platform is regularly updated and hosts all kind of open-source and non-sensitive
information on the topic. Twice a year a newsletter is produced and shared with the members of
the interest group.
There is an ongoing cooperation with NATO through cross-briefings and mutual staff
participation in dedicated counter-UAS workshops and exercises.
2. European Programme for counter-UAS systems testing
This programme has been launched to develop a common methodology for evaluating systems
that can be used by law enforcement and security authorities to detect, track and identify
potentially malicious drones. The programme is supported by the
Courageous
79
project, which
started in April 2021 and is funded by the EU Internal Security Fund–Police. There are regular
stocktaking meetings where outcomes are shared with Member States as well as selected partner
countries and international organisations.
76
77
European Union Aviation Safety Agency, Drone Incident Management at Aerodromes, 8 March 2021
Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common
rules in the field of civil aviation and establishing a European Union Aviation Safety Agency
Regulation (EC) No 300/2008 of the European Parliament and of the Council of 11 March 2008 on
common rules in the field of civil aviation security; and secondary legislation
https://courageous-isf.eu/
78
79
Page 50 / 86
 kom (2022) 0652 - Ingen titel
2639143_0052.png
3. Practical guidance and support
The Commission is also compiling EU best practices with a view to develop practical guidance
material, in particular, ”Protection against Unmanned Aircraft Systems – Handbook on Counter-
UAS for Critical Infrastructure and Public Spaces” and “Protection against Unmanned Aircraft
Systems – Handbook on Principles for Physical Hardening of Buildings and Sites”.
4. Research and innovation
Based on projects from the EU security research programme, such as ALFA
80
and ALADDIN
81
(funded under Horizon 2020), as well as ISF-funded projects such as Skyfall, Courageous and
DroneWise
82
, the Commission is identifying and sharing regularly relevant deliverables amongst
EU stakeholders. Moreover, through its JRC laboratories and Living Labs, the Commission is
offering the possibility for testing and supporting pilot projects. Stakeholders can use these
facilities to demonstrate policy impact and needs, as well as to develop processes, procedures and
solutions
83
.
5. Financial support
Through the security research programme, as well as the Internal Security Fund (Police) for the
period 2014-2020, the EU co-funded the development of Counter-drone tools, knowledge and
technologies. This effort will continue in the current Horizon Europe programme, the Internal
Security Fund (ISF) and the Border Management and Visa Instrument (BMVI) component of the
Integrated Border Management Fund (IBMF). These programmes are complimentary as Horizon
Europe strengthens research and innovation, while the ISF and BMVI focuses on a wide range of
practical applications for law enforcement and border management, such as the acquisition of
equipment, promoting and developing training schemes and ensuring administrative and
operational coordination and cooperation.
This financial support is made available through national programmes (shared management) or
through Union actions supporting transnational initiatives (direct management). With regard to
research and innovation related measures, funding is also available under the Horizon Europe
programme.
6. Legislative measures
In the EU, there are currently no specific counter-drone rules, which set a common harmonised
framework for Member States authorities, operators and manufacturers. As the need for an
effective prevention of the unauthorised use of drones and drone technologies is constantly
growing, the Commission is working towards EU counter-drone guidelines and examine the need
for legislative measures..
In aviation, following the Gatwick incident, an EASA-led Task Force developed a manual
entitled “Drone Incident Management at Aerodromes”. Completed in March 2021, this manual
contains non-binding guidance and recommendations helping airports and authorities to prepare,
respond and recover from drone incidents. While these guidelines were favourably received by
the sector, their non-binding nature makes them insufficient to mitigate a threat that is likely to
grow as drones become more ubiquitous and capable.
80
81
Advanced Low Flying Aircrafts Detection And Tracking https://cordis.europa.eu/project/id/700002
Advanced
hoListic
Adverse
Drone
https://cordis.europa.eu/project/id/740859
Detection,
Identification
Neutralization
82
83
https://www.projectskyfall.org, https://courageous-isf.eu and https://dronewise-project.eu
https://joint-research-centre.ec.europa.eu/pilot-living-labs-jrc_en
Page 51 / 86
 kom (2022) 0652 - Ingen titel
2639143_0053.png
Furthermore, to address the gap on legislation related to the threats posed by drones at and
around airports, the aviation security legislation needs to be amended to ensure that aviation
authorities and airports manage the risks posed by drones. It would not need to prescribe specific
measures but set a general obligation to manage risks, with the exact measures being determined
at the national or local level based on a risk-assessment. This approach would best account for
the specificities of each airport and the various risk-levels that may exist across the EU.
Moreover, certain mitigating measures, particularly those that involve the use of detection
technologies, have a significant cost which makes them more suitable for large or higher-risk
airport. As an illustration, it is estimated that it could cost around EUR 500 million to equip
Germany’s 16 busiest airport with drone detection systems.
The Commission will continue providing operational, technical and financial support to Member
States, as outlined above. In addition, the Commission will specifically outline, through a
Communication to be presented in the first half of 2023, the EU’s future policy on countering
drones. This includes taking stock of existing projects, best practices and available reliable
technologies for tracking, identifying and neutralising drones adapted to the concrete threat level
and operating environment, as well as presenting the Commission’s strategic vision in this field,
which is characterised by the lack of a clear EU legal framework.
Resilience
Drones and related control units are highly advanced and complex platforms running various
different digital processes that control -automated or remotely - the drone or its payload, store
and transmit data, broadcasting identification, and so on. Like any similar system, a drone and its
control unit is vulnerable to hacking and misuse. In 2020, security research firms revealed that,
without a knowledge of drone operators, a major drone manufacturer located outside of the EU
could collect information through the control application installed to the operators’ phone, and
even silently update the application, thus leaving it open for further vulnerabilities. While this
feature might not have been introduced with malicious intentions by the manufacturer, it still
demonstrates the difficulties of ensuring that a drone is fully controlled by its owner or operator
and that the collected data remain safely in their hands. Security vulnerabilities could also lead to
hijacking of a drone with aim to use it for criminal purposes.
The Commission should work towards defining criteria which can be used to identify, or label,
trusted drones. The voluntary label could be issued by a relevant Authority after a manufacturer
has provided evidence that a specific drone fulfils the criteria. Such criteria could be, for
example, provision of a secured communication link, secure identification, use of open-source
code, transparent software upgrades or protection against GNSS spoofing. It should build on and
be compatible with the ongoing work to develop horizontal cybersecurity legislation. The label
would make it possible for any end-user to purchase such trusted drones in confidence.
Furthermore, it would benefit not only drone operators but also all entities responsible for the
monitoring the use of airspace. For example, a relevant authority could require such trusted drone
label from all drones operating in a restricted airspace, subsequently helping to separate legally
operated drones from illegal ones.
Voluntary labelling would not only improve the security of drones, but it could serve as useful
marketing tool for the European drone industry which is generally targeting more high-end
professional drone market.
In a longer term, the European Union should assess the need to set a condition that drones
acquired by the EU through public procurements meet the security requirements set in the trusted
drone label.
Page 52 / 86
 kom (2022) 0652 - Ingen titel
2639143_0054.png
9
A
CTION
P
LAN
The following action plan is based on the vision and strategic objectives, as described in Chapter
7. It covers some of the recommendations and suggestions of actions to be taken by the European
Commission which were collected during the consultation phase of the preparation of the Drone
Strategy 2.0.
In addition to action by the Commission, other stakeholders, as described in this document, are
also required to play their part, ranging from European entities, such as EASA and the European
Investment Bank, to national authorities, including ministries and regulatory bodies, regional and
local governments, military and law enforcement bodies, as well as private entities such as U-
space service providers and manned and unmanned aviation industry alike.
List of Actions and means to be implemented by the European Commission to further build
the European drone services market
Action
Means
- adopt amendments to the Standardised Putting forward proposal to amend the Standardised
European Rules of the Air and the Air
European Rules of the Air (Regulation
Traffic Management/Air Navigation
(EU)923/2012)
84
, and common requirements for
Services Regulation to safely integrate
providers of ATM/ANS (Regulation (EU)2017/373)
85
,
drone and piloted eVTOL operations.
to allow safe, orderly, and efficient drone operations in
the ‘specific’ and ‘certified’ category, and piloted
eVTOL operations.
- promote coordinated research on
The research undertaken at EU level in the following
integrated Communication, Navigation fields should be coordinated: CNS (ICNS)
and Surveillance technologies.
technologies, including all current CNS technologies
used for ATM, but also those needed to support U-
space, IAM, drone integration and Higher Airspace
Operations, including technologies from other
domains, such as the telecommunications and the
space industries.
- adopt new European standard scenarios There are currently 2 European standard scenarios
for low to medium risk aerial operations. annexed to Regulation (EU) 2019/947, further
standard scenario should be developed in order to
allow commercial drone operators to declare their
operations instead of seeking a prior authorisation.
- adopt rules for the ‘certified’ category New common rules for the ‘certified category’ and
of drone operations and the operational VTOLs should be rolled out covering the certification
requirements applicable to manned
of aircraft, of operators and remote pilots.
VTOL-capable aircraft.
- adopt rules for the design and
A new regulatory framework applicable to the design
operations of vertiports under the scope of and operations of vertiports under the scope of EASA
EASA Basic Regulation.
Basic Regulation will facilitate the development of
intermodal transport.
- develop balanced economic and
Regulation (EC) 1008/2008 should ensure fair market
financial requirements for drone operators access for new drone operators with more suited
84
Commission Implementing Regulation (EU) No 923/2012 of 26 September 2012 laying down the
common rules of the air and operational provisions regarding services and procedures in air navigation
(OJ L 281 13.10.2012, p. 1)
Commission Implementing Regulation (EU) 2017/373 of 1 March 2017 laying down common
requirements for providers of air traffic management/air navigation services and other air traffic
management network functions and their oversight (OJ L 62, 8.3.2017, pp. 1-126)
85
Page 53 / 86
 kom (2022) 0652 - Ingen titel
2639143_0055.png
in the context of its legislative proposal to economic and financial conditions and consider using
revise Regulation (EC) 1008/2008.
other instruments to adequately protects the strategic
autonomy of the EU when necessary.
- fund the creation of an online platform As a pilot project proposed by the European
support a sustainable IAM
Parliament, the Commission will fund the creation of a
implementation by authorities, cities,
sustainable IAM Hub by EASA as an online platform
industry and stakeholders.
that supports authorities, cities, industry and
stakeholders with the implementation of UAM;
- adopt training and competences
New skills and competences such as those of drone
requirements for remote pilots and pilots specialists should be developed to ensure that remote
of VTOL aircraft.
pilots have the requisite level of knowledge and skills
in line with continuous advancing technological
development.
List of Actions and means to be implemented by the European Commission in order
to strengthen European civil, security and defence industry capabilities and
synergies
Action
- continue to provide funding for R&I on
drones and their integration into the
airspace under the Horizon Europe
programme and the European Defence
Fund.
- set up a coordinated series of calls of
existing EU instruments and EIB loans to
support a new flagship project on ‘drone
technologies.’
Means
The drone sector is still at is early stages requiring
further financial support for R&I in order to reach
economically sustainable maturity.
In implementation of relevant proposals in the
Synergies Action Plan and the Analysis of defence
investments gaps meant to support critical
technologies and industrial capacities by developing
strategic projects, - set up a coordinated series of
calls of existing EU instruments and EIB loans to
support a new flagship project on ‘drone
technologies’ that can prove the concept of synergies
along the pathway from R&D to deployment
through public procurement.
- consider possible amendments to the
In order to facilitate exchanges between civilian and
existing financing/funding framework to
defence communities, especially in the area of
ensure a consistent approach in support of critical technologies, - prepare an approach for
dual-use research and innovation to improve encouraging dual-use RTD&I at EU level to be fully
synergies between civil and defence
implemented in the medium to long term across EU
instruments.
programmes and instruments. This work will also
feed into the mid-term evaluation of relevant sectoral
programmes.
- develop a Strategic Drone Technology
A Strategic Drone Technology Roadmap should
Roadmap in order to identify priority areas further set out priorities for R&I, identifying critical
to boost research and innovation, reduce
strategic drone technologies such as AI, detect and
existing strategic dependencies and avoid Avoid (DAA) robotics, semi-conductors, hybrid and
the emergence of new ones.
electric propulsion systems, safe, secure and resilient
Command and Control link and energy storage,
batteries and cloud technologies should be defined at
EU level, in collaboration with the Observatory of
Critical Technologies.
- coordinate a common approach with the Coordinating a European approach to ensure that
aim of providing sufficient radio
radio frequencies and protected spectrum are
frequencies spectrum for drone operations. available for drone operations, in cooperation with
EUROCONTROL at ICAO and ITU level.
- set up an EU network on civil-defence
Developing a network of joint civil-defence
Page 54 / 86
 kom (2022) 0652 - Ingen titel
2639143_0056.png
drone testing centres to facilitate exchanges collaborative field-testing of drone demonstrators
between civilian and defence sectors.
and in this context seeking deeper cooperation
between civil and military with the aim to optimise
the use of restricted airspaces for civil and military
trials. This would create a flying-safe space to “test
& share” and allow gaining flight hour experience to
prove safety under a “fly-before-certify” approach.
- encourage all relevant actors to further
EASA, EDA, EUROCAE and national military
harmonise certification requirements for
authorities should further harmonise certification
civil and military applications towards those requirements for civil and military applications
set by EASA while considering military
towards those set by EASA while considering
specificities and standards.
military specificities and existing military
certification standards. To the extent possible, this
should be done within existing structures such as
EUSCG.
- adopt new standard scenarios for civil
Further European standard scenarios for the specific
operations that could facilitate
category for operations could have both military and
corresponding military use cases.
civil applications such as surveillance drones.
- adopt a counter-UAS package.
The package could include, but not limited to,
actions to continue the ongoing dedicated support to
MS; a Commission Communication announcing
work towards EU counter-drone guidelines;
increased efforts in the protection of critical
infrastructure and public spaces by publishing a
handbook on the matter; technical guidance on the
physical protection principles of infrastructure
against drones; an enlarged technical expert group
on voluntary standards to cover counter-drone
solutions
- adopt an amendment to the aviation
This legislative amendment should not prescribe
security rules aiming to ensure that aviation specific measures but rather contain a general
authorities and airports increase their
obligation to manage the risks in order to take into
resilience when faced with the risks posed account of the different risk levels that exists at
by drones.
different airports.
- define criteria for a voluntary “European The label would be granted for cybersecurity
Trusted Drone” label.
approved drones in the ‘open’ and ‘specific’
categories. It should build on and be compatible with
the ongoing work to develop horizontal
cybersecurity legislation.
Page 55 / 86
 kom (2022) 0652 - Ingen titel
2639143_0057.png
A Synopsis consultation report
A.1 Introduction
The stakeholder consultation matrix below provides an overview of how 12 defined stakeholder
groups have been consulted, i.e., through interviews (scoping, targeted), survey, stakeholder
meetings and Open Public Consultation (OPC) by the external contractor. Stakeholders for
interviews and survey were selected in close consultation with the Commission. The OPC
enabled the participation of citizens.
Stakeholder group
National and regional
authorities
European institutions and
relevant agencies
Military and Law
enforcement
Commercial and non -
commercial aircraft
operators
Drone operators, service
providers and users
Airport operators and
ANSPs
U-space providers
Manufacturing industry
Inter-governmental
organisations and networks
NGOs
Research and academia
Citizens
Total
number
respondents
Source: Ecorys
of
Scoping
Targeted Targeted Stakeholder OPC
interviews interviews Survey
meetings
1
2
2
6
1
4
2
3
1
3
1
1
1
2
5
25
198
3*
258
Five stakeholders were selected for scoping interviews, one national authority; two from EU
institutions; one drone manufacturer and one stakeholder representing research and academia.
The result provided insights on main issues, which together with desk research established the
basis for drafting the questionnaire survey, and the OPC.
Page 56 / 86
 kom (2022) 0652 - Ingen titel
2639143_0058.png
The members of the Informal Drone Experts Group were, invited to submit their views on the
following topics on the occasion of three hearings on:
Urban Air Mobility (cargo/passengers) and U-space
Enhancing UAS services including the SME dimension
Developing Military/Civil synergies and technology building blocks
A.2 Feedback to the Roadmap
Feedback on the DS2.0 roadmap public consultation includes 45 written contributions provided
by 14 companies/business organisations; 10 Business associations; 8 citizens (of which 7 from
EU); 6 NGOs; 4 Public authorities and 3 research institutions.
A.2.1 Context & Problem the initiative aims to tackle
All contributors agreed that - if regulated properly - drones have the potential to generate
societal, economic, and environmental benefits. They noted that this will depend on the
development of a new strategy that reflect changes and promote safe and responsible drone
operations and addresses related societal concerns such as safety, security, privacy and
environmental protection.
All of them acknowledged that the growth of UAV activity must be addressed urgently in
order to preserve the safety of manned aircraft and to foster the promotion of the drone
industry.
They welcomed the roadmap and shared the EC’s view that the development of a thriving
and competitive drone industry can accelerate Europe’s transition to green and digital
economy, observing that Europe requires a strategy aligned with the latest developments and
the needs and concerns of their citizens.
A.2.2 Objectives
Contributions welcomed the objectives identified by the EC. Notably,
Safety, security, and privacy of people in the air and on the ground
The EC consideration on the importance of the safety objective was acknowledged by the
majority of stakeholders and the ambitions to develop a safe and efficient drone ecosystem
under the forthcoming Drone Strategy 2.0., to ensure the right balance between safety,
security, and other societal concerns, was praised.
EHA noted that safety was a priority especially for helicopter operations dealing with
emergencies, as they must be able to identify potential incoming and colliding drones and
engage in safe avoidance manoeuvres. To this end, it called for a number of amendments to
the existing regulations.
Wing expressly welcomed the adoption of the risk-based SORA process for evaluating
complex operations, helping to ensure that different operations meet a common target level
of safety. It noted that supporting diverse operations will depend on performance-based
approaches to regulation, recognizing new and innovative ways to achieve a high level of
safety.
Complementing the welcomed EC’s considerations on the safety objective, IAOPA
suggested that the EC should address the liability aspect of drone integration. It complained
that currently a serious lack of liability persisted when a UAV caused damage and
maintained that strict liability for drones’ operators needed to apply in case of collision. The
Page 57 / 86
 kom (2022) 0652 - Ingen titel
2639143_0059.png
Association also suggested that education aspect was for UAV operators further addressed,
implementing consistent training programs with the aim of maximising the safety of people
in the air and increase awareness of the relevant legal framework. Regarding privacy, it
argued that the strategy should put forward specific measures to enforce the respect of
European citizens’ privacy outlined in the already adopted legislation.
CANSO voiced concern for the lack of explicit reference to the need for a comprehensive
policy package that includes the scalable integration of UAS/UAM with manned aviation
operations as an important success factor.
The Czech Association of modellers contended that a less strict regime for aircraft models
should be part of the Drone 2.0 Strategy plan, due to inter alia, their reduced impact on safety
and security and on privacy.
Omega stressed that the most crucial aspect that required a deep and radical change is the U-
space, which should be based on the rethinking of privileges already established in the air
space.
The Swiss Federal Office of Civil Aviation noted that whereas the roadmap pointed to a
broad selection of potential societal concerns, positive societal and political externalities such
as drone applications contributing to the digital transformation of businesses should also put
forward to ensure a fair presentation of the issue.
One citizen and UECNA complained that noise control was not mentioned in the Roadmap
and feared that the development of drones, especially in the mobility and transport sector,
may have a negative impact on citizens health.
Guarantee their widest possible social acceptance
All contributions mentioning social acceptance endorsed this EC objective, as the low social
acceptance of drones is seen as a major challenge.
GAMA stressed the need for supporting the societal but also the local administration
acceptance of UAS operations in urban and non-urban areas and for Regional/Urban Air
Mobility.
All called for effectively engaging and consulting incubators local communities from the
outset, to increase public acceptability, accelerate the ecosystem’s implementation in cities,
and inform on drone regulatory developments. They insisted on the need for a better
communication (e.g. investing in proactive campaigns) to and engagement with citizens,
explaining the drones benefits for the society, while addressing the related concern that affect
social acceptance (from privacy to affordability to environmental and noise concerns).
ACI EUROPE complained that a number of projects with significant potential to foster
development of UAS services struggled to get off the ground due to lack of support from
local, regional and/or national authorities, partly due to the slow evolution of regulations
and/or tried and tested (as well as certified) technology and its use cases. It hence called for
an official European endorsement for companies or consortia working on demonstrators / test
flights aiming to demonstrate the feasibility of UAS, operational procedures and use cases to
secure the necessary support from competent local/national authorities.
The Drone Office company and UAV DACH e.V. suggested that the Strategy expressly
stressed the positive impact on end-users' industries and citizens, thus tackling the social
acceptance hurdle.
Address obstacles to the development of new drone applications and transport services and to
the competitiveness of this industry
Concerns were raised for the lack of support of regional and/or national authorities to
projects with significant potential to foster development of UAS services.
EREA found the link missing with multimodality and link with city infrastructure observing
that the infrastructure in the city (including vertiports) will need to change to support drone
Page 58 / 86
 kom (2022) 0652 - Ingen titel
2639143_0060.png
operations. To reach EC’s goal of developing new types of services and capabilities along the
value chain, multimodality was deemed key, linking drones to other transport modes and
their infrastructure.
SKYPORTS particularly emphasised the necessity to further develop the framework to
enable permanent, commercial drone delivery operations at scale as well as addressing all
aspects of advanced air mobility.
DRONEA welcomed the adoption of the Sustainable and Smart Mobility Strategy and its
Action Plan, which introduced the Concept of Green and Digital transformation in a
European perspective, considering them as valuable complements that will enable drones
contribute to a new Level of sustainable services and transport.
HHLA Sky listed a number of precise obstacles to be addressed, as remaining regulatory and
organizational challenges to realize our drone economy’s full potential, starting from the
need to contribute to the implementation of the European Green Deal.
Synergies between civil, defence and space industries
Contributions welcomed that the roadmap addressed civil/defence and space synergies, C-
UAS & military use of drone as part of the Strategy. Also the fact that counter-drone systems
are explicitly named in the document was positively perceived.
Mixing military and commercial use of drones was identified as a main risk in this regard, as
it could be counterproductive for social acceptance. To avoid that, it was stressed the need to
carefully distinguish the civil and military use of drones in the strategy, but also to foster
close cooperation between military and civilians and include the space sector for the targeted
consultation (WING).
Ensure legal and technical certainty based on a harmonised EU approach / Support technical
harmonisation
Harmonisation was welcomed as it ensured that a drone operator from one Member State
could operate in another as easily as in the country in which it is based. DMAE argued that
harmonisation is not yet achieved.
EBF stressed the need of preventing different
modus operandi
in different EU countries and
was concerned that U-space, if left to the MS, would end up creating competition between
operators because of the different national legislations. It hence called for more central
guidance.
Boeing believed that an international perspective was key, so as to ensure the greatest levels
of harmonisation possible – ensuring that any framework facilitates the free flow of products
and services.
GAMA pointed out that the Strategy should support the development of the required
infrastructure, including vertiports and U-space-enabling ATM capabilities, in a consistent
way across the EU.
Stichting Space53 and KNVvL stressed that national differences in (interpretation of) rules
and legislation withhold cross-border business. The latter complained that differences
between countries would not be solved with the new rules and pointed out that differences
between the countries still existed, especially in the zoning and prices of the various
applications, level of cooperation between military and civilians. It therefore called for
clarification.
Increase cooperation between stakeholders
RATP Group welcomed the objective of increased cooperation, emphasising that new
governance models are needed to set to launch the UAM industry and address its complex
and interdisciplinary needs. Collaboration between manufacturers and industrial partners,
urban public transport operators, infrastructure providers and regulatory authorities and urban
Page 59 / 86
 kom (2022) 0652 - Ingen titel
2639143_0061.png
policies makers is a must. These open pluri-disciplinary collaborations are key in ensuring
the ecosystem launch based on the safest and most secure operational levels.
Support research and infrastructure initiatives
Research institutions particularly welcomed the objective of supporting research,
highlighting the need to provide access to test sites in multiple locations, hence providing the
possibility for gathering field experience in the controlled environment and enhance safety
level and public acceptance.
The use of simulations and flight test centres as well as pilot scenarios was deemed essential
to ensure a sustainable and safe air mobility. It was highlighted the need to foster the use of
existing test centres and the creation of new test sites, support pilot projects to accelerate the
phase of market introduction of technologies, provide a mechanism for technology transfer
from Research Establishment to Research Industry, in particular to SMEs, as well as to adjust
research infrastructure to UAS test-need according to new regulations.
RATP Group purported that in order to transition between testing vehicles prototypes and
flight demonstration into operating a network of vehicles at scale by 2030, real life areas or
incubators were needed.
Stichting Space53 observed that the Strategy 2.0 should create the conditions for research,
development and application of drone technology without unnecessary limitations.
Proposing new legislation
Some contributors identifed areas for legislative actions: EuroUSC Italia ltd suggested that
the Strategy should complete some aspects not yet fully covered to implement the existing
regulations and other Union's policies. To this end, it proposed a number of amendments to
the existing framework.
Skyports, DJI, and DMAE recommended that the Strategy should focus, inter alia, on further
developing the conditions and framework for the operation of UAS in the Specific and
Certified categories, exploring how manned and unmanned aviation could coexist in the same
airspace in the short term, particularly at low levels, and ensuring the regulatory framework
remained risk-based and simple in approach.
DMAE and AME also listed some regulatory gaps/major issues to be addressed.
According to ITG, the forecasts for civil drones’ traffic should be updated frequently in order
to provide a reliable and accurate view at short, medium and long term and the elaboration of
AMCs and guidance material must be speeded up in order to deploy U-space as well as to
develop vehicles compliant with the high-standard performance levels required for safe
operations.
GAMA mentioned the need to focus new rules on increase automation and AI.
EREA contended that rules for emergency/landing spots requirements were necessary, as
well as minimization of risk for people & infrastructures on the ground in case of accidents
by adopting a clear complete framework of norms (prescriptions) and derived procedures. It
also called for assessments on the environmental impact and sustainability of drone
operations to ensure that drone industry was circular.
UAV DACH e.V., ITG, Lukasiewicz, and one EU citizen called for a simplification of UAS
certification and of the procedures to request permission to carry out validations, as the
current requirements made it difficult to conduct proper tests in controlled urban
environments.
Page 60 / 86
 kom (2022) 0652 - Ingen titel
2639143_0062.png
A.2.3 Better regulation: Consultation of citizens and stakeholders & Evidence base
and data collection
The engagement of stakeholders for the Roadmap is widely welcomed. All contributors
appreciated the opportunity to provide their feedback on the proposed Roadmap and wished
to assist with future stages of its development, often demanding to be included in the
consultation process announced in the document.
CER noted that it was of utmost importance to involve the drone users in the regulatory
process in order to ensure the return of experience of the particular domain being
appropriately and comprehensively taken into account and fully understand the market, its
needs and problems.
EUROCONTROL expressed concern that the study as described in the Roadmap was too
narrowly focused and called for actions to ensure that a drone operator from one Member
State could operate in another as easily as in the country in which it is based.
A.3 Open Public Consultation (OPC)
The aim of the Open Public Consultation was to collect views of stakeholders on drone
operations and drone services and to identify possible policy options for the Drone Strategy 2.0.
The public consultation was launched on 8 October and stayed opened until 31 December 2021.
Overall, 258 contributions were submitted, 126 by individuals and 132 by organisations. Most of
the answers were submitted by respondents from Estonia (43: 17%), Germany (41: 16%), Italy
(33: 13%) and Belgium (26:10%).
Respondents were asked to indicate in which category they are engaged. “EU citizen” was the
largest participating group with 48%. “Company/business organization” (25%) was the second
largest participating category, while “Business association” and “Public authority” jointly came
as third largest participating category with 5,86% of the replies. The category of
“Academic/research Institution” followed closely with 5,08%.
Respondents were asked to indicate in which sector(s) they are engaged. Choosing multiple
sectors was permitted.
‘Individuals’ was the largest participating group with 19% of the respondents. ‘Drones Operator’
was the second largest group with 17%, closely followed by ‘Drone Pilot’ with 13,5%. The
following categories: ‘Aircraft design, manufacturing, or maintenance’, ‘Non-Governmental
Organisations’, Research organisation/university/consultancy’, ‘Recreational aviation’,
Stakeholder/industry association’, and ‘Aviation professional (working in the aviation industry as
a pilot, crew member, controller, etc.)’ – collected similar shares ranging between 6 and 5 % of
respondents.
Sectors
Individuals
Drone Operator
Drone Pilot
Aircraft design, manufacturing, or maintenance
Non Gov Organisations/Research organisation/university /consultancy
Recreational aviation
Stakeholder/industry association
Replies
109
99
78
37
34
33
32
Page 61 / 86
 kom (2022) 0652 - Ingen titel
2639143_0063.png
Aviation professionals (pilot, crew member, controller, etc.)
Aerial work
Commercial Air Transport
Training organisation for aviation professionals
Local or Regional authorities
U-space service providers
Air navigation service providers
Qualified entity, or other organisation officially recognized by the NAA
Aerodrome operators
Business Aviation
Common Information Service providers
National regulators
Telecom operator
31
23
18
16
15
11
9
9
8
7
7
5
2
The questionnaire had 60 questions of which 53 were compulsory and 7 were optional.
Generally, the structure was a series of closed questions followed by optional open-ended
questions to specify the answers provided in the closed questions.
The questionnaire was divided into three subtopics:
(1) Conditions to allow new forms of smart and sustainable mobility and aerial services,
including their social acceptance.
(2) Assessment of the current drone regulatory framework. This subtopic was divided between
the assessment for the ‘open’ category, for ‘specific’ category and finally for both the ‘open’
and ‘specific’ categories.
(3) Additional issues to be addressed in the Strategy.
Each subtopic was presented to the respondents with a preceding section explaining the present
situation and introducing the rationale behind the questions. At the end of each subtopic, the
respondents were given the opportunity to provide further feedback through a free-form text box
if the so wished.
The comments collected in this consultation have been summarised and structured in order of
appearance in the questionnaire. Opinions outlined in the present report do not necessarily reflect
the view of the Commission.
A.3.1 Presentation of responses
A.3.1.1 Conditions to allow new forms of smart and sustainable mobility and aerial
services, including their social acceptance
There was a consensus that safety (98%) and privacy (89%) should be priority.
However, a majority (59%) of respondents believed that the general public did not have sufficient
access to safety and security information related to the use of drones.
Page 62 / 86
 kom (2022) 0652 - Ingen titel
2639143_0064.png
In addition, there was widespread support (79%) that the general public should be more informed
on the environmental aspects related to the use of drones (noise pollution, visual disturbances,
etc.).
A majority of the responders (65%) disagreed that drone operations should initially involve only
non-commercial operations (e.g. air ambulances, disaster relief, firefighting, crowd control, etc.).
A majority of the respondents (54%) disagreed that companies were sufficiently informed of
efficiency gains provided by drone services.
A majority of the respondents (71%) agreed that urban air mobility could provide good
alternatives to ground transportation for goods, persons and should always be integrated in the
overall mobility offer proposed to the public.
A large majority of the respondents (83%) stressed that pilot projects should be run in parallel in
different cities across the EU to enhance public trust.
There was widespread support (67%) that disturbance by noise perception, perceived vibrations
and visual disturbances would negatively impact social acceptance.
There was a general opinion (88%) that drone companies should closely work with regulators,
local governments and communities to ensure community engagement.
A large majority of the participants (78%) agreed that regulatory measures should ensure that
noise related issues are addressed (corridors for drone, hours limits, size of drones, etc.).
A large majority of the participants (84%) also stressed that regulatory measures should ensure
that drones are compatible with EU privacy law.
A majority of the participants (58%) disagreed on the statement that every city could currently
easily accommodate vertical take-off and landing operations.
A majority of the respondents (74%) supported the idea that urban design development should
start taking into account drone operations in order to facilitate their operations.
There was widespread support (74%) that there was a need to develop new types of intermodal
infrastructures, including vertiports, to support Urban Air Mobility operations.
Respondents highly agreed (87%) with the statement that cooperation mechanisms between
various level of authorities should be established for authorisation of operation of drones in urban
area.
A large majority of the participants (84%) considered that U-space airspace services (e.g.
network identification service, a geo-awareness service, an Unmanned Aircraft System (UAS)
flight authorisation service and a traffic information service) should allow the safe integration of
manned and unmanned aircraft operations.
A majority of the participants (72%) supported the statement that U-space airspace services
should be available in every urban area.
There was a general (89%) agreement that drone services would have an impact on skills, and
new training offers adapted to the smart mobility and drone services should be made available.
90 respondents provided additional input in the open-ended question. Many respondents (10)
pointed to the need to create an adequate testing environment and flight approval mechanisms.
On U-space, some respondents expressed the views that measures were needed to ensure safety
and solve externalities while other expressed the concern that such measures would be overly
restrictive. A few respondents also raised the question of the costs of the integration of drones in
the airspace and the interaction with existing airspace users.
Page 63 / 86
 kom (2022) 0652 - Ingen titel
2639143_0065.png
A.3.1.2 Assessment of the current regulatory framework
A.3.1.2.1 The Drone Regulations (R945/R947) from the perspective of operations in
‘Open’ category
A majority of the participants (65%) considered that the new drone Regulations had contributed
to clarify the conditions of operations for small drones of less than 25 kg.
A majority of the responders (60%) agreed that that the national registration system was easy to
use.
46% of the participants disagreed or strongly disagreed that the provision of drone safety
information by the competent authorities and guidance was sufficient while 42% of participants
agree or strongly agreed on this.
A majority of the respondents (61%) shared a view that transition measures allowing the use of
non C-class label drones were useful.
Most respondents (62%) agreed that drones meeting the requirements of the Open Category
would be available.
A small majority of the participants (51%) considered that definition of drone geographical zones
was appropriate
A majority of the respondents (65%) shared the view that the EU drone legislation provided
adequate protection to citizens from risks and concerns related to safety and security.
A majority of the participants (60%) considered that the EU drone legislation provide adequate
protection to citizens from risks and concerns related to privacy.
Most of the participants (55%) considered the EU drone legislation provide adequate protection
to citizens from risks and concerns related to noise.
Most of the respondents (55%) agreed that Provisions regarding remote pilot competency for
recreational operations were easy to apply
70 respondents provided additional input in the open-ended question. A majority of respondents
pointed to a lack of Guidance Material and harmonized implementation of the Regulations across
Member States. In addition, respondents indicated that geographical zones were not ready in
many Member States. Respondents pointed to the issues with standardisation and CE marking.
Respondents indicated the lack of knowledge of the Regulation among drone users, resulting in
the need to reinforce pilot competency, through communication and improved training. In
addition, guidelines on safety should be accompanied with physical protection mechanisms.
A.3.1.2.2 The Drone Regulations (R945/R947) from the perspective of operations in
‘specific’ category
46% of the respondents agreed that the new drone regulations were fit for conducing professional
activities while 34% disagreed with this.
42% of the participants considered that all types of drone services could be fitted under the drone
regulations while 36% disagreed with this.
A majority of the participants (60%) considered that the procedure for receiving an authorisation
for a drone operation was not easy.
36% of the respondents disagreed that drone operators from one Member State could easily
operate in another Member State while 34% agreed with this statement. 30% had no opinion.
40% of the responders disagreed that the availability of drones/equipment meeting the
requirements of the ‘Specific Category’ was adequate while 33% agreed with this statement. 26%
had no opinion.
Page 64 / 86
 kom (2022) 0652 - Ingen titel
2639143_0066.png
44% of the responders considered that the provisions regarding remote pilot competency for
professional operations were adequate. 33% disagreed while 23% had no opinion.
A majority of respondents agreed that the drones rules provided adequate protection to citizens
from risks and concerns related to safety
There was a general agreement that drone rules provided adequate protection to citizens from
risks and concerns related to security.
A majority of stakeholders also agreed that drones rules provided adequate protection to citizens
from risks and concerns related to privacy.
A majority of respondents disagreed on the statement that the system of declarations under the
light UAS Operator Certificate could be used easily.
59 respondents provided additional input in the open-ended question. Respondents pointed to the
lack of drone equipment meeting the requirements of the ‘specific’ category, notably SAIL III
and IV. Respondents expressed concerns regarding the implementation of the Regulation and
varying interpretations among Member States. In addition, respondents pointed to the issue faced
by operators to obtain authorization for flight-tests outside the Member State of registration.
Finally, respondents notified issues in obtaining a light UAS operator certificate and suggested
that the Drone Strategy 2.0 should envisage faster authorisation procedures with Standard
Scenarios.
A.3.1.2.3 Other issues in relation to the ‘Open’ and ‘Specific’ categories in the drones
regulation
66 respondents provided additional input. Some respondents indicated that the Regulations
should to be reviewed once they will have been fully implemented. Other participants stressed
that UAS operations for research and testing ought to be better considered in the Regulations.
Respondents recalled the need to focus on local and regional authorities’ role in facilitating
operations. Respondents also recalled the need to accelerate the creation of industry standards,
facilitate the obtention of a Light UAS Operator Certificate. Respondents also pointed to security
risks stemming from airspace segregation and the necessity of creating convergence between
Unmanned Aircraft System Traffic Management (UTM), U-space and classic Air Traffic
Management (ATM).
A.3.1.2.4 Additional issues to be addressed by the forthcoming Drone Strategy 2.0
A majority of the responders (59%) supported the statement that the use of renewable and clean
energy should be obligatory.
A majority of respondents (54%) stated that the environmental impact of drone operations (noise,
emissions, visual nuisances) was not adequately assessed nor addressed.
There was a strong support (85%) on that the drone industry should be subject to circular
economy principles (reuse of batteries and recycling of equipment).
A majority of the respondents (61%) agreed that drones may posed issues on ethical values in
certain cases (e.g. use of Artificial Intelligence).
A large majority of the participants (82%) agreed that rules for emergency/landing spots
requirements should be established.
A majority of the respondents (73%) agreed that there was a need to generate synergies and
technology transfer between Small and Medium Enterprises.
A large majority of the participants (90%) agreed that use of new Information Technologies
should be assessed in terms of cyber security.
Page 65 / 86
 kom (2022) 0652 - Ingen titel
2639143_0067.png
In addition to the closed questions, 57 respondents provided additional input. There was a
contrast between respondents who supported the inclusion of sustainability requirements and
respondents who considered that introducing such requirements would generate burden of costs
that would hinder the development of the sector. As a third way, respondents suggested to
“encourage” rather than making such sustainable requirements mandatory. Respondents recalled
the importance of developing harmonised standards, notably for emergency landing sites and for
vertiports. Respondents noted the importance of addressing cybersecurity threats, AI technology
and 5G interference. Respondents pointed to the need to identify UAS in a drone digital network
to enable remote identification and the exchange of navigational data.
A.4 Drone Leaders’ Group (DLG)
In the wake of the preparation of a ‘A Drone Strategy 2.0 for a smart and sustainable unmanned
aircraft eco-system in Europe’ and in addition to the regular channels of communication, such as
the Drone Informal Experts Group, the Commission called on a group of representatives from 26
organisations and trade associations including Drone manufacturers, U-space Airspace Service
Providers, drone operators, manned aviation, European Parliament, NAA’s, UIC², EASA,
SESAR JU, EUROCONTROL, EDA to give a high-level steer to the development of the Drone
Strategy 2.0 and provide recommendations for its drafting.
The DLG developed a High-Level Vision and an ambitious pathway, with concrete objectives
articulated over 8 thematic areas in order make Europe a global leader in this area. It concluded
its activities on 26 April 2022 delivering a report containing a number of findings and
recommendations which is available here:
Drone Leaders’ Group supports preparation of Drone Strategy 2.0 (europa.eu).
A.5 Targeted surveys and Interviews
The targeted survey conducted by the external contractor was open for two months, with the
launching date on 29 October 2021 and the survey closing on 31 December 2021. A longlist of
respondents was selected and invited to participate in the survey. In addition, the survey was
distributed by some associations (for example: ACI Europe and CANSO) to their members. This
resulted in a total of 198 registered responses of which 103 respondents completed the full
survey.
The survey provided a broad geographical coverage, with respondents from all over Europe. The
following countries were well represented (> 5 respondents): Belgium, Switzerland, Italy,
Lithuania, and Germany. The survey also obtained several responses beyond Europe, from
organisations located in the United Kingdom, United States and Turkey.
The responses provided a good coverage of the stakeholder groups. Responses came from
national authorities (41); manufacturing industry (40); drone operators (22); NGOs (18); airport
operators (17); military (15); research and academia (13); air navigation service providers (12);
aircraft operators (11); U-space providers (9); staff associations (7); EU institutions (5); law
enforcement (4) and inter-governmental institutions and networks (2).
A total of 25 targeted interviews were carried out by the external contractor, as presented in the
Table below, reflecting the distribution over the stakeholder groups. The results of the interviews
were used to complement the survey results, as input for the analysis.
Stakeholder group
National and regional authorities
Interviews
Italian Civil Aviation Authority
Page 66 / 86
 kom (2022) 0652 - Ingen titel
2639143_0068.png
Stakeholder group
Interviews
BMVI (Germany)
Ministry of Infrastructure and Water
Management (The Netherland)
Portuguese Civil Aviation Authority
Norwegian Civil Aviation Authority
PSE S.A. (Polish Government)
Military and Law enforcement
Defence Forces Ireland
Drones4sec
Commercial and non-commercial aircraft
operators
Drone operators, service providers and users
European Air Sports
European Aerospace Cluster Partnership
Platform Unmanned Cargo Aircraft
(PUCA)
Drone Alliance Europe
Wing
Alliance for New Mobility Europe
Airport operators and Air Navigation Service
Providers (ANSPs)
U-space providers
CANSO
ACI Europe
GUTMA
Unifly
Droniq
Manufacturing industry
DMAE
Lilium
Thales
Non-Governmental Organisations (NGOs)
Research and academia
Accirculate SPRL
Joint Research Centre (JRC)
Drones Observatory at Politecnico di
Milano
A.6 Targeted consultations – presentation of responses
A.6.1 European drone ecosystem, value chains and business models
The drone industry and related services are developing rapidly across the entire drone ecosystem.
These developments in the drone ecosystem might open new prospects for using drones and
thereby result in different value chains and business models. These developments are taking place
Page 67 / 86
 kom (2022) 0652 - Ingen titel
2639143_0069.png
in a policy environment that is focused on drones contributing to the digitalisation of the EU
economy and providing a safe and sustainable mode of transport, for both persons and goods.
A.6.1.1 Trends and developments
A.3.1 presents the results of the question “what trends and developments are accelerating the
evolution of the drone market in Europe?”
86
These trends and developments are sorted on a high
to low impact. Participants expected slightly to highly positive impact from all developments that
the sector is facing. Respondents expected the highest impact from technological developments
(83% of the respondents, 123 out of 148) and the development of a regulatory framework (73%,
108 out of 148) of the drone market in Europe.
A.6.1.2 Opportunities in the European drone ecosystem
The drone industry stakeholders were asked to shed their light on the growth opportunities of
different use cases (see A.3.1).
87
The growth opportunities per use case are sorted from high to no
growth. The results revealed on the one hand that respondents expect the highest growth in the
following three use cases: inspection (83%, 119 out of 143), public mission (80%, 115 out of
143) and surveillance (79%, 113 out of 143). On the other hand, the majority of respondents
(62%, 88 out of 142) expected either limited (51%, 72 out of 142) or no growth (11%, 16 out of
142) in the field of person mobility.
Participants were also given the option to fill in the category ‘other’ and provide their growth
expectation. Several respondents (n = 5) indicated that high growth is also expected in the
entertainment industry (e.g. filming, photography, etc) and environmental monitoring (n = 3).
A.6.1.3 Barriers in the European drone ecosystem
The stakeholder consultation process indicated several barriers that the European drone
ecosystem is facing nowadays. The targeted survey has identified the comparative strengths of
the EU drone industry and scored the factors listed below on EU competitive (dis)advantage.
88
Highest in this respect was the presence of an enabling regulatory framework (47%) and lowest
was the effective civil-military collaboration (18%). A large number of respondents perceived
these factors as neither an advantage nor disadvantage, ranging from respectively 22% (24 out of
108)
89
to 45% (50 out of 108)
90
. When asked whether existing or foreseen value chains create
dependencies to third States
91
, a substantial number of respondents (44%, 39 out of 88) were
neutral on dependencies to third States. Stakeholders explained that business development is
rather irrespective of geography, but directly linked to the service and product capabilities. Also,
86
DS 2.0 Targeted Survey (2022), Questions 8: In your view, what trends and developments are
accelerating the evolution of the drone market in Europe?
DS 2.0 Targeted Survey (2022), Questions 9: “In your view, what is the growth potential for drone
applications in the sectors and fields that are listed below?”
DS 2.0 Targeted Survey (2022), Questions 17: “What are the comparative strengths of EU industry in
drones compared to global competition?”
Related to an enabling regulatory framework.
Related to technology readiness.
DS 2.0 Targeted Survey. Question 25: “Are the existing or foreseen value chains creating
dependencies to third states?”
87
88
89
90
91
Page 68 / 86
 kom (2022) 0652 - Ingen titel
2639143_0070.png
the economic system has (to a large extent) outsourced the production of parts and materials
outside Europe. The supply chain of drones is thereby similar to other technology sectors.
A.6.2 Regulatory framework
A.6.2.1 General setting
Stakeholders generally agreed that further development and implementation of the EU regulatory
framework is needed to contribute to delivering the objectives of the DS 2.0. The strategy should
be focused on equalising and minimising drone related rules and legislation across the EU,
without leaving too much space for Member States to divert from the EU principles
92
.
A.6.2.2 Implementation of Regulation 1139/2018, Regulation 945/2019, and Regulation
947/2019
According to a wide majority (71%, 141 out of 198) of the respondents of the targeted survey, the
Regulations facilitated the development of the drone industry and market. However, there are still
issues to be complied with and requirements are considered complex; some remarks made by
respondents were reported as such:
It takes a lot of time for national authorities to implement the regulations; the framework is
incomplete until Acceptable Means of Compliance (AMC) and Guidance Material (GM) are
available.
Airworthiness assessment need to be pushed down to Member State level again
93
.
Enhancement of capacities of national authorization bodies and strengthening of the
governance framework are needed
94
It is widely agreed among respondents of the survey that the new basic aviation safety regulatory
framework and the detailed rules for unmanned aircraft design and operation guarantee the safe
operation of drones (65% ,128 out of 198). Only 8% (15 out of 198) of stakeholders consulted
disagree. Drone operators active in the Open Category consulted through the OPC, widely
recognised positive impacts of the Regulations on the drone industry and market being: having
clarified the conditions of operations for small drones of less than 25 kg (66%, 170 out of 258,
agree); providing useful transition measures allowing the use of non-C-class label drones (61%,
157 out of 258, agree); defining appropriate drone geographical zones (52%, 134 out of 258,
agree); providing adequate protection to citizens from risks and concerns related to safety (66%,
170 out of 258, agree), security (65%, 167 out of 258, agree), privacy (60% , 154 out of 258,
agree), noise (55%, 142 out of 258, agree).
A.6.2.3 Regulations on U-space (664/2021, 665/2021, 666/2021)
Around two thirds of stakeholders (63%, 124 out of 198) consulted with the targeted survey
considered that Regulations on U-space will facilitate the development of the drone industry and
market. Existing obstacles in the implementation of the new framework were underlined as
follows: the Regulations have not provided sufficient clarity on the future evolution of the
92
93
94
As indicated by a Manufacturer and two Drone Service Providers.
Drone Service provider.
Drone Association and Drone Service Operator.
Page 69 / 86
 kom (2022) 0652 - Ingen titel
2639143_0071.png
Unmanned Aircraft System Traffic Management (UTM) service provision framework with
specific reference to U-space in controlled airspace, since safety risk is being managed through
the segregation of manned and unmanned operations with different respective airspace managers.
There is no clear legal basis for designation of a single provider of common information services
on which safe operations – manned and unmanned – can be based
95
. Air Traffic Control should
be given the mandate to provide separation for drone flights; the U-space Regulations in their
current versions are not designed to enable scalable traffic. The focus on strategic pre-planning,
which ensures that only one drone operation at a time can take place, is not a viable solution for
drone operations in greater numbers
96
. According to a National Authority interviewed and
‘Other’ stakeholders, the intervention of EASA is necessary, at a framework level, while leaving
some flexibility and room for manoeuvre to Member States. For instance, common criteria, at the
level of AMCs should be defined by EASA, to implement Art. 15 of Regulation 2019/947 and
request the setting of geo-zones in a harmonised way, but then the specific decisions on geo-
zones should be left to Member States.
A.6.2.4 Technological challenges
Drone Service providers consulted (interviews, written contributions) generally consider the
European regulations too strict and complicated to enable easy implementation of experimental
activities. The application processes and the technical requirements are too high in certain areas,
procedures are too lengthy and cost burdensome. The lagging of the development in the
regulation of use cases that are more interesting from the business case point of view is remarked.
More specifically, further development of the rules framework to enable permanent, commercial
drone delivery operations at scale as well as addressing all aspects of advanced air mobility, is
needed. Regulations should be used to create a climate for innovation. National differences in
(interpretation of) rules and legislation withhold cross-border business
97
. It was also remarked
that EASA should become responsible for certification and operation. A clear and complete
framework of norms (prescriptions) and derived procedures are deemed necessary to be adopted
to regulate emergency/landing spots requirements, so as to minimize risks for people and
infrastructures on the ground in case of accidents. A military aviation authority consulted through
the targeted survey, pointed out that AMC and GM for Type 1 ops / 'SORA for certified category
are still missing.
A.6.2.5 Military/Civil coordination and cooperation on drones
Stakeholders consulted through the targeted survey were generally unaware (61%, 120 out of
198) and did not know 15%, 29 out of 198 disagreed) whether Member States and third countries
with a considerable drone industry have a regulatory framework enabling civil-defence synergies.
Stakeholders interviewed stressed out that drone regulations (2019/945 and 2019/947) are not
contributing to the alignment and use of synergies between civil and defence industry; UTM
services and design of airspace are not conceived to fit both military and civil applications
98
.
Some of the stakeholders interviewed
99
mentioned that the military interests on drone are
expected to remain very high in the future and military investments will most likely continue to
95
96
97
98
99
A Service Provider.
Drone Association.
Airport operator, Drone Service Provider, Research Institute.
A representative from the manufacturing sector.
NGOs and other Strategic Business consultants.
Page 70 / 86
 kom (2022) 0652 - Ingen titel
2639143_0072.png
grow. They stated that the military have also expressed a keen interest on Environmental
Sustainability and Circular Economy and this could represent an opportunity for including the
drone sector (EDA is very active in this). With regard to the use of drones for EU border
surveillance needs, Regulation (EU) 2019/1896 enhances the mandate of the European Border
and Coast Guard Agency (‘Frontex’) with respect to external border control. The EU should
explore the possibility of bringing flights carried out in the public interest by EU agencies (such
as Frontex) within the scope of Regulation (EU) 2018/1139.
A.6.2.6 Other regulatory challenges
Enquired as to whether the existing regulatory framework restricts the drone industry and market,
37% (73 out of 198) of the respondents to the survey, indicated this as an obstacle which hinders
lawful drone use, 29% (57 out of 198) mentioned unclear allocation of liability and insurance
rules, insufficient level of protection on privacy and data (15%, 29 out of 198), insufficient level
of protection of the environment (12%, 23 out of 198), and not being able to maintain a high level
of safety and security (12% 23 out of 198). OPC respondents confirmed that further actions are
needed at the regulatory level in the following areas: to improve the cooperation of drone
companies with regulators, local governments and communities to ensure community
engagement (88%, 227 out of 258); address noise related issues (corridors for drone, hours limits,
size of drones, etc.(78%, 201 out of 258); ensure compatibility with EU privacy law (84%, 216
out of 258); allow urban design development to take into account drone operations (74% 190 out
of 258); establish cooperation mechanisms between various level of authorities for authorisation
of operation of drones in urban area (87%, 224 out of 258), .
OPC respondents recommended the following regulatory actions:
Ensure a regulatory framework which fosters innovation, enable confidence in business and
public-support decisions, and ensures safety and security.
Consider the Circular Economy, in particular on Critical Raw Materials (CRMs) and Rare
Earth Elements REEs (REEs) and Waste (e.g. End-Of-Life Vehicle, Waste Electronics).
Work on GDPR regulations and anti-drone systems.
Provide regulatory and funding certainty to the emerging mobility industry.
Reach a first step of regulation to enable first levels of business services; regulate share
airspace use.
Stakeholders
100
stated that rules in place on environment protection do not seem to cope with
environmental concerns linked to the use of drones. An interview with a stakeholder revealed that
the expected major direct and long-term environmental impacts of the drone industry are not yet
sufficiently and properly addressed by the European legislation and the industry standards. In
particular concerning the need of alignment of the drone sector to the Circular economy
principles.
In relation to obstacles identified in the EU wider regulatory framework having an impact on the
deployment of drones, market operators interviewed and consulted through the survey expressed
concerns about the existing privacy frameworks (GDPR), which does not consider drones and
non-consented data collection
101
; the Product Liability Directive which is considered a
100
Interviews with Service providers and other stakeholders (business and strategic consultants), and
respondents to the Survey and OPC,
A drone service operator.
101
Page 71 / 86
 kom (2022) 0652 - Ingen titel
2639143_0073.png
cumbersome instrument that does little in relation to new technologies and increasing relevance
of software
102
.
Respondents stated that the Regulations should permit the use application of drones to the
phytopharmaceuticals sector, which would, in their opinion, be a major step forward for smart
farming, thus towards compliance with the European Green Deal
103
.
A.6.3 Technology building blocks
A.6.3.1 Technological development and components
The targeted survey shows that supporting technological development is ranked third (65%, 79
out of 122) in terms of priority action areas for the development of the DS 2.0. Over half (54%,
36 out of 67) of the survey respondent considered that technological requirements are required
today to improve drone operators. The top 5 technological drone components mentioned by the
survey respondents were: detect and avoid (80%, 49 out of 81); flight control systems (70%, 43
out of 61); command and control link (67%, 41 out of 61); embedded AI platforms (62%, 38 out
of 61); and GNSS (59%, 36 out of 61).
A.6.3.2 Barriers towards technological development
Barriers to technological development were identified as a mix of technological aspects (maturity
level too low, reliability), production aspects and legal aspects related to the use of the
technologies, operational problems and new needs. Some barriers mentioned were as follows:
Difficulties to develop, implement and deploy technologies that need regulations to be used;
BVLOS and counter drones are two technologies that are often mentioned by stakeholders
104
.
Technical requirements are not harmonized between countries, both in civil and military
domains. This is seen as a competitive disadvantage for European companies.
Having different standards, including in the civil and military markets, results in market
limitations.
Technical requirements are too complex, there is a need to simplify requirements
105
.
Having different standards in the civil and military market results in market limitations.
Raw material shortage, electronic parts mostly, is considered by stakeholders as a barrier
106
.
A.6.3.3 Civil-military collaboration
28 % (16 out of 58) of the respondents to the targeted survey both agreed and disagreed (equal
score)
107
that there are barriers to the development of dual-use drone technology. Respondents
often mention the lack of common standards between the civil and military world as a current
barrier. Besides barriers, recommendations were made by survey respondents. In general,
102
103
104
105
106
107
Other (Business Strategic consultants, Research Academy.
Other: Farmers Association.
See OPC, DS 2.0 Targeted Survey (2022),
Ministry of Transport from European Member State.
OPC.
The balance (44%, 26 out of 58 did not know).
Page 72 / 86
 kom (2022) 0652 - Ingen titel
2639143_0074.png
stakeholders stated that drone technology has often been pioneered in military settings; providing
valuable input for civil-military collaboration. The vast majority (68%, 40 out of 59) of
respondents consider that military technology development would benefit civil technological
development. The following military to civil technology transfers were mentioned: counter-
drones, communications, sensors, DAA, swarming and UTM. On the other hand, 62% (36 out of
59) of the respondents mentioned that the military sector could benefit from civil technological
developments.
Multiple stakeholders in the targeted survey mentioned that although the background and culture
(between the civil and military sectors) may be different, civil-military collaboration could bring
benefits to both sides. The following recommendations were made by stakeholders: (i) mandate
an organisation to take the lead in the standardisation process of technical requirements, with the
objective to bring interoperability; (ii) exchanges of hardware parts from military systems and
dual use civil-military hardware could reduce the costs on both sides by increasing the production
capabilities; and (iii) grant innovation military budgets only if the targeted technologies are for
dual use.
A.6.3.4 Future considerations for technological developments
Stakeholders indicated a range of considerations for future technological developments
108109
:
Many comments from the survey respondents focused on the need to developing
technologies and the associated regulatory framework in parallel, as these aspects are
interrelated
Stakeholders indicated that the development of the EU drone industry and market is
dependent on external components and know-how. As such, the EU is lacking strategic
autonomy (45% agreed or strongly agreed, 44 out of 98, while 21% disagreed or strongly
disagreed, 21 out of 98).
The current lack of standards needs to be addressed in order to support economic activities
and promote interoperability.
In order to further develop drones as means of passenger transport, the following
technological developments should be pursued: propulsion, situation awareness systems,
advanced detection and collision avoidance with existing flying objects.
Stakeholders indicated the need to focus on innovative projects where on-board fused data is
developed. This will help several fields, such as surveillance (detection, cross-cueing) and
reduce datalink weakness (mix between GNSS, cellular, radar).
BVLOS is an important aspect that needs to be further developed to facilitate use cases, such
as inspections, surveillance and transport of goods. These use cases are currently restricted
because of risks related to low altitude and high-speed flights.
A.6.4 System resilience and non-cooperative drones
Drones are a new, fast-growing, and affordable technology, which pose various risks and are of
major public concern due to potential unsafe operation, damage to people and property.
110
Almost
108
Many considerations were mentioned in the targeted survey, with a dedicated section on technology
building blocks.
This constitutes a selection of future considerations mentioned by stakeholders in the targeted survey.
OPC.
109
110
Page 73 / 86
 kom (2022) 0652 - Ingen titel
2639143_0075.png
all stakeholders
111
were aware of the risks and threats that non-cooperative drones pose.
Unauthorized drone flights remain a problem, especially around commercial airports, and critical
infrastructures. They endanger passengers and aircraft crews and can lead to short-term
disruptions of air traffic, closures of entire airspaces or airports, and even to the total loss of an
aircraft. Unauthorized drone flights in the approach and departure areas of an airport pose the
greatest potential hazards and risks. There are cyber and physical security issues that are being
addressed effectively enough in traditional aviation but pose many challenges for drones. Drones
can easily bypass existing security measures applicable to aviation security. Protecting drones
from cybersecurity risks is another important challenge since they can be targets for a cyber-
attack themselves just as they risk being used as potential attack vector.
112
A.6.5 Main threats of drones
The main threats and/or risks posed by non-cooperative drones were perceived to be those of
‘illegal and criminal intent’ with 72% (71 out of 89 responses) of respondents indicating the risks
arising from these uses. The risks from reckless use and terrorist attacks were lower with 63%
(62 out of 89) and 62% (61 out of 89) respectively. On the other hand, 56% (55 out of 89) of the
respondents suggested that amateur use was also a risk posed by non-cooperative drones.
However, there was no clear distinction amongst the respondents between reckless use and
amateur use.
A.6.6 Types of risks
As regards types of risks and levels of threats, it was suggested that these are the 'inability of
operators to decode, comprehend and comply to the overly complex EASA regulations; system
failures, untrained pilots or even an unsafe condition for flights; espionage, state sponsored as
well as Inability to comply to overly complex EASA regulations.
113
The main consequence of the
threats around airports and other critical infrastructures is the disruption of activities/air traffic,
with 92% (90 out of 98) of respondents indicating such consequence, while the second highest
consequence 54% (53 out of 98) was interference.
114
As regards the threat trends and patterns, the survey respondents 46% (37 out of 81) stated that
the threat levels have increased over the past three years with 32% (26 out of 81) suggesting that
the threat level stayed the same and 15% (12 out of 81) stating that the threat has significantly
increased. Only 7% (6 out of 81) mentioned that the threat level has decreased. The trends in the
increase of the threat level were mainly due to drones being much for accessible amongst the
population hence more incidents of reckless and amateur use are administered as well as
professionals not abiding by the rules set. Stakeholders also mentioned that the ‘number of
incidents with drones interfering in air traffic at airports rose tremendously’ and an increase of
near misses between helicopters and drones are seen.
115116117
111
OPC, Interviews and DS 2.0 Targeted Survey (2022),
Views from OPC, interviews and DS 2.0 Targeted Survey (2022),
DS 2.0 Targeted Survey (2022),
DS 2.0 Targeted Survey (2022),
European Aerospace Cluster Partnership (EACP).
Research Institutes.
DS 2.0 Targeted Survey (2022).
112
113
114
115
116
117
Page 74 / 86
 kom (2022) 0652 - Ingen titel
2639143_0076.png
A.6.6.1 Barriers
Almost half of the respondents 48% (26 out of 54) suggested that there are either technical or
legal, or technical and legal barriers to using certain types of technological solutions to detect,
track, identify, neutralise, and mitigate threats from non-cooperative drones. These are mostly
said to be regulations that prevent the use of technologies.
118
Stakeholders stated that current
regulations that allow very light and small drones, make it harder to provide them with more
reliable technical systems (such as the lack of efficient and mature detect and avoid systems).
Furthermore, technical regulations, requirements and means of compliance are not fully existing
in the detect and avoid solutions areas, especially for AI based systems. It was also envisaged that
it is quite challenging to control air space where large aircraft are operating. Therefore, all
activities in this domain should be well coordinated.
A.6.6.2 Impacts
The consultation results showed that there are indeed potential impacts of the limitations in
mitigating the threat and risks of non-cooperative drones. For example, the limitation might result
in a ‘slower adoption of drone services’
119
, as well as drone jamming, spoofing and guns.
120
Furthermore, there were concerns that due to the strict regulatory framework, new drone-related
protective technology onboard of helicopters can’t yet be installed.
121
A.6.6.3 Capacity of current EU regulation
Only 18% of the respondents (9 out of 51) mentioned that the current policies and regulations are
either sufficient or very sufficient to mitigate the threat from non-cooperative drones, with 22%
(11 out of 51) suggesting that the current policies/regulations are insufficient and 12% (6 out of
51) saying they are extremely insufficient. The respondents mentioned the need for neutralisation
of non-cooperative drones as the detection is not sufficient to secure facilities.
122
Furthermore,
stakeholders said that regulations need to mature on various aspects (for example,
communication, environmental, security etc.)
123
Accordingly, 52% of the respondents (37 out of
71) mentioned that an EU regulatory intervention is needed to help mitigate the threats posed by
non-cooperative drones around critical infrastructure, while only 10% (7 out of 71) stated that
such an intervention is not needed.
124
As regards soft measures used, almost all stakeholders
stressed the importance of the implementation of soft measures such as awareness campaigns
71% (12 out of 17 respondents), better coordination and information sharing platforms 53% (9
out of 17), the use of various apps 41% (7 out of 17), and other measures such as patrolling,
equipment for signal blocking.
A.6.6.4 Opportunities and good practices
118
DS 2.0 Targeted Survey (2022) and Interviews
.
Aerospace, defence and security company.
Views from airports
.
An air rescue representative
An Industry representative.
ADR; Air navigation services; CAA; Aviation Security Department
DS 2.0 Targeted Survey (2022).
119
120
121
122
123
124
Page 75 / 86
 kom (2022) 0652 - Ingen titel
2639143_0077.png
The consultation phase revealed that over half of the respondents 56% (10 out of 18 respondents)
were not able to identify some good practices that are used at the EU level which can help
mitigate the threat posed by non-cooperative. Only 17% (3 out of 18) mentioned that there were
some good practices used in some Member States.
125
As regards specific training offered for law
enforcement or relevant authorities in drone detection/tracking/identification and neutralisation
17% (9 out of 54) of the respondents mentioned that their Member State offers such training,
which is in line with the rapid technological development of the drones market, while half of the
respondents 50 % ( 27 out of 54) said there was not such a training.
A.6.7 Developing airspace capabilities: U-space development and integration with
ATM
A.6.7.1 Importance, opportunities and challenges
Around two thirds (68%, 102 out of 150) of the respondents in the targeted survey identified air
traffic management (ATM) systems, supporting drones as potentially having a high impact (the
most severe category) on the evolution of the drone market in Europe.
126
U-space is viewed
generally as a critical enabler for realisation of drone market projections in Europe by all
stakeholder groups.
127
A.6.7.2 Governance arrangements
Stakeholders contended that the regulatory framework as well as the upcoming DS 2.0 should put
a stronger emphasis on the multi-level governance dimension of drone and U-space regulation. In
general industry and national government stakeholders are content with the Commission (as a
multinational political body) steering EASA to deliver technically sound proposals.
128
One of the
points raised here is that the Commission plays an important role in making sure that even during
implementation of critical systems, drone policy remains integrated with all relevant EU policies,
in particular associated with the digitalisation/ automation and decarbonisation agendas.
129
Metropolitan governments and local authorities indicated that they should be involved directly in
setting up U-space systems, geographical drone zones and operational requirements.
130
Industry
stakeholders seem particularly focused on the role of the EU regulatory framework avoiding
fragmentation in implementation.
131
Stakeholders also talk about the important role of the
125
For example, the EASA repository data base as well as annual training sessions with the law
enforcement authorities (police, gendarmeries) are being provided by some Member States.
DS 2.0 Targeted Survey (2022) and Interviews
.
October 2021 Drone Leaders Group meeting; November 2021 Drone Expert Group meeting; DS 2.0
Targeted Survey (2022); interviews with a global UTM representative body.
National and regional authority respondent to the DS 2.0 Targeted Survey (2022)
An NGO, national and regional authority, manufacturing industry and multiple drone operators,
service providers and users respondents to the to the DS 2.0 Targeted Survey (2022); supported by
participants at the October 2021 Drone Leaders Group meeting
Position papers and interviews with a global UTM representative body
In written responses and during the meeting of the October 2021 Drone Leaders Group
126
127
128
129
130
131
Page 76 / 86
 kom (2022) 0652 - Ingen titel
2639143_0078.png
Commission in encouraging and facilitating cooperation during implementation between Member
States.
132
The role of competition in U-space is a key discussion.
133
At least one U-space provider and one
national regulator questioned the potential for service provider competition in the short term (i.e.
close to 2023) given the current high barriers to entry.
134
There is a desire (particularly from the
private sector actors) for simple and efficient rules.
135
They recognise competition as a key driver
of: technological innovation; the effective introduction of technologies from outside of the
traditional aviation sector; and price setting.
136
A.6.7.3 Funding and financing
Following on from governance and regulatory discussions are views on future funding and
financing. Stakeholders (especially those directly involved in U-space implementation efforts)
stated that more central sources of funding are needed to facilitate roll out of U-space in the
timeframes identified by regulator.
137
Moreover, they indicated the need for funding and
financing streams to target technological development and innovation practices outside the
traditional aviation sector.
138
There is a group of policymakers at the national level and
researchers who are particularly interested in defining payment U-space service payment
systems, optimal prices/fees, revenue models and the costs to regulators.
139
These discussions are
generally immature and focus on the relationship between service price, market development
(towards potential) and levels of innovation in drone services.
A.6.7.4 Identified benefits
The opportunity at the centre of ongoing U-space conversations is the shift from air traffic
control centric approaches to operations centric (automated) approaches, although the details of
integration with existing ATM remains a key issue.
140
Most groups of stakeholders see the
openness of the system as fundamentally important and very different to the natural monopolies
132
In written responses from U-space service providers and during the meeting of the October 2021
Drone Leaders Group
October 2021 Drone Leaders Group meeting; November 2021 Drone Expert Group meeting; DS 2.0
Targeted Survey (2022) and Interviews; interviews with a global UTM representative body and U-
space service providers involved in implementation activity.
November 2021 Drone Expert Group meeting and interviews with U-space service providers
Interviews with U-space service providers, infrastructure managers and a global UTM representative
body
October 2021 Drone Leaders Group meeting; November 2021 Drone Expert Group meeting; DS 2.0
Targeted Survey (2022); interviews with U-space service providers, infrastructure managers and a
global UTM representative body
DS 2.0 Targeted Survey (2022); interviews with U-space service providers involved in early
implementation activities around cities and ports in particular
Interviews with a global UTM representative body and with U-space service providers involved in
early implementation activities around cities and ports in particular
See for example: independent policy research discussed in the European Parliament in 2021
October 2021 Drone Leaders Group meeting; November 2021 Drone Expert Group meeting; DS 2.0
Targeted Survey (2022); interviews with a global UTM representative body and with U-space service
providers
133
134
135
136
137
138
139
140
Page 77 / 86
 kom (2022) 0652 - Ingen titel
2639143_0079.png
that have dominated ATM.
141
Traditional aviation sector stakeholders (e.g. ANSPs) tend to see
the implementation of U-space differently to new service providers (in particular software based)
entering the market. There is an ongoing discussion amongst stakeholders about whether UTM
should deliver services to an ATM level, or whether that is an overly narrow and restrictive
collective ambition in particular in urban environments.
142
Discussions about the benefits of U-space generally take two forms. The first is the safety and
security benefits associated with having defined procedural and spatial practices.
143
The second is
the role of U-space in facilitating the realisation of value at the drone service level.
144
These
discussions make the identification and explanation of ‘value’ associated with U-space
implementation complicated. An underlying issue is the desire for appropriate designation by
Member States in order to prevent U-space being allocated where it does not bring any
significant added value in safety, security, privacy or environment terms.
145
Effective
implementation of U-space is seen as a critical activity in determining the actual economic value
added, including the transition from viewing drones as transport to viewing drones as an
integrated service in the value chains of companies.
146
Stakeholders (in particular USSPs and
drone operators in fledgling U-space activities) imply the transition can only occur if automated
BVLOS is effectively regulated and priced.
147
The long-term opportunities associated by stakeholders with U-space implementation are aligned
with those identified in current policy and regulatory frameworks. Stakeholders specifically
identify the need for U-space to facilitate:
U-space as infrastructure: enabling and prioritising a diversity of operations
148
Airspace taxonomy and classification based on environmental footprint and market
potential
149
The iterative roll out of connected corridors with a principle of achieving an environment
where operations can start from anywhere (appropriate) and can end anywhere
(appropriate)
150
141
Written submissions; free text comments in the DS 2.0 Targeted Survey (2022); interviews with a
global UTM representative body and with U-space service providers.
Written submissions; free text comments in the DS 2.0 Targeted Survey (2022); interviews with a
global UTM representative body and with U-space service providers (in particular those who come at
the business opportunity from a non-conventional aviation/ software development perspective)
See the majority of SESAR JU and EASA communications in particular.
Written responses and interviews with a global UTM representative body and with U-space service
providers.
DS 2.0 Targeted Survey (2022), in particular responses from national and regional authorities.
See for example: position papers from U-space service providers and independent policy research
discussed in the European Parliament in 2021.
Interviews with U-space service providers and survey responses from drone service providers.
Written responses and interviews with a global UTM representative body and with U-space service
providers.
Written responses and interviews with a global UTM representative body and with U-space service
providers.
Written responses and interviews with a global UTM representative body and with U-space service
providers.
142
143
144
145
146
147
148
149
150
Page 78 / 86
 kom (2022) 0652 - Ingen titel
2639143_0080.png
An environment where a U-space provider safely manages an operation from beginning to
end, using all details on the operator, the aircraft and the operation that a digital system can
generate
151
A requirement for all aircraft and operators to remain connected with the system and
visible
152
Collection and management of valuable data related to drone operations and services
153
Sharing of information where relevant for safety reasons and exchanging information to de-
conflict exclusively with relevant U-space service providers
154
Full automation where services are digitalised so operations are de-conflicted strategically.
155
A.6.7.5 The necessary transition to mature U-space
The dominant stakeholder view is that early U-space applications will develop as relatively
isolated ‘bubbles’, but over time these bubbles will need to be connected into more significant
corridors and areas making use of existing infrastructure and sympathetic natural forms (e.g.
waterways).
156
Stakeholders identify the need for a clear plan on the iterative roll out of U-space
from this perspective. Stakeholders busy with understanding the content and regulations while
implementing them identified that some early applications of U-space are being pursued in very
complicated (often urban) areas and they questioned whether these complicated applications were
indeed a good starting point.
157
Some of the short-term opportunities and challenges identified were:
Developing a whole of sector understanding of how U-space best rolls out and scales,
including where it is possible now and where it should not be applied (e.g. remote
agriculture)
158
Defining the relationship (procedures) between ATM and UTM and establishing dynamic
airspace management – in some rare cases UTM was perceived as a direct competitor to
ATM
159
Clarity on USSP certification processes and how multinational businesses might be
encouraged
160
Written responses and interviews with a global UTM representative body and with U-space service
providers.
DS 2.0 Targeted Survey (2022); content from European Institutions and relevant agencies.
Interviews with U-space service providers; October 2021 Drone Leaders Group meeting.
DS 2.0 Targeted Survey (2022); content from European Institutions and relevant agencies; written
responses and interviews with a global UTM representative body.
Written responses and interviews with a global UTM representative body and with U-space service
providers.
European agency during the November 2021 meeting of the Informal Drone Expert Group; written
responses and interviews with a global UTM representative body and with U-space service providers;
DS 2.0 Targeted Survey (2022) free text response from an NGO.
Written responses and interviews with a global UTM representative body and with U-space service
providers.
DS 2.0 Targeted Survey (2022) free text response from an NGO and a national and regional authority.
DS 2.0 Targeted Survey (2022) free text response and a national and regional authority during the
October 2021 meeting of the Drone Leader Group.
Interviews with U-space service providers.
151
152
153
154
155
156
157
158
159
160
Page 79 / 86
 kom (2022) 0652 - Ingen titel
2639143_0081.png
The data exchange between ANSPs and USSPs needs to become more open and
standardised
161
Systematically building competencies in key institutions (e.g. CAAs) to facilitate the shift, in
particular as it relates to introduction and coordination of new technologies; coordinating
with local authorities; accepting SORAs; certifying USSPs; automating validation and
monitoring
162
Better cooperation between stakeholder groups (including military) and more fora to identify
and share best practices on U-space implementation, including to develop new
competencies
163
Providing more support for city governments and local actors to understand U-space
opportunities, their role in realising them and what other cities or regions are doing
164
Working closely with U-space service providers to make sure they are future proofing by
considering the needs of all potential drone services (in particular urban air mobility)
165
More effort to accept and integrate non-aviation standards/ processes in particular from IT
sector
166
Better encouraging, exploiting and reusing the current IT know how from cloud and
cybersecurity
167
Being clear about how to apply risk management processes in a much wider range of
operations
168
Better defining the role of U-space in ‘fairness’, including what fairness means to regulators
(rules and mechanism for airspace allocation, who will be prioritised, to which conditions,
and when)
169
A.6.8 Developing Urban Air Mobility and Regional Air Mobility; including ground
infrastructure
A.6.8.1 Specific benefits and challenges
Urban air mobility (UAM) is considered to be a good alternative for both ground transport of
goods and persons; 71% (183 out of 257) of the respondents of the OPC indicated that UAM
161
Written responses and interviews with a global UTM representative body and with U-space service
providers.
Written content from European institutions and relevant agencies confirmed in interviews with U-
space service providers.
October 2021 Drone Leaders Group meeting; November 2021 Drone Expert Group meeting confirmed
in written work from a European agency.
Written responses and interviews with a global UTM representative body and with U-space service
provider.
Written responses and interviews with a global UTM representative body and with U-space service
provider.
Written responses and interviews with a global UTM representative body and with U-space service
provider.
Written responses and interviews with a global UTM representative body and with U-space service
provider.
Written content from a European agency.
DS 2.0 Targeted Survey (2022) free text response from an NGO.
162
163
164
165
166
167
168
169
Page 80 / 86
 kom (2022) 0652 - Ingen titel
2639143_0082.png
being a good alternative for transport of goods. This percentage is lower (56%, 143 out of 257)
for transport of persons.
170
This pattern is confirmed by responses from the targeted survey,
indicating combined positive perception for transportation of goods 73% (75 out of 103) and for
passengers 59% (61 out of 103).
171
Main benefits related to the transportation of goods and persons, according to the targeted survey,
included: the ability of drones to service remote areas (93%, 95 out of 102); increased
productivity (69%, 70 out of 101); reducing local emissions (67%, 68 out of 102); and access to
goods (56%, 57 out of 101). For transportation of persons, the following main benefits were
mentioned: faster reaction on emergencies scores highest (87%, 90 out of 104), followed by
access to less accessible areas (71%, 72 out of 102), reducing traffic congestion (55%, 57 out of
103), reducing local emission (53%, 55 out of 103) and changing land-use patterns (48%, 49 out
of 103).
172
The top three challenges for transportation of goods, according to the targeted survey, were
identified as: increased noise pollution (64%, 65 out of 101); increased visual pollution (55%, 56
out of 101) and increased privacy concerns (46%, 46 out of 101). For transportation of persons,
the top three concerns or risks were: noise pollution (63%, 63 out of 101); increased visual
pollution (55%, 56 out of 101) and safety and security concerns of the persons transported (39%,
39 out of 101).
173
Perceptions on noise, vibration and visual disturbances negatively impact the societal acceptance
of UAM. The OPC indicated that 60% (154 out of 257) of respondents agreed to this (negative
impact on societal acceptance), while 27% (69 out of 257) disagree.
174
Societal acceptance was
frequently mentioned by stakeholders as a potential barrier. Based on this, means are proposed to
improve societal acceptance, for example through testing and pilots and developing platforms
and collaboration mechanisms. On societal acceptance, a social contract in which citizens are
consulted was proposed
175
, involving also local governments and citizens to deal with issues,
such as noise, privacy and safety.
Specific challenges were mentioned to further develop and scale up UAM. For instance, the lack
of support from local, regional and national authorities, and their reluctance often linked to slow
evolution of regulations and tried and tested technologies.
176
This also applies to U-space, which
has advanced in terms of having a regulatory basis and technology developed, but at the moment
is still in a testing stage and not yet applied in full in an urban setting. It is expected that in time,
the perceived benefits of UAM or drone services in general, as perceived by society, will increase
and the perceived risks will be reduced, for example by making less noisy and safer drones,
paving the way for a large-scale application of drones.
177
170
171
172
173
174
DS 2.0 OPC (2022), Matrix 7 and 8 (combined agree and strongly agree).
DS 2.0 Targeted Survey (2022), Question 54 and 55.
DS 2.0 Targeted Survey (2022), Question 56 and 57.
DS 2.0 Targeted Survey (2022), Question 58 and 59.
DS 2.0 OPC (2022), Matrix 2 (combined score on agree and strongly agree and combined score on
disagree and strongly disagree
By a representative organisation of the advanced air mobility (AAM) sector.
According to a representative from the airport sector.
According to a representative from the U-space sector.
175
176
177
Page 81 / 86
 kom (2022) 0652 - Ingen titel
2639143_0083.png
A.6.8.2 Ground infrastructure and U-space
There is general consensus that there is a need to develop new types of infrastructures, including
vertiports, to develop UAM. The OPC indicated that 76% (195 out of 257) of respondents either
agreed or strongly agreed to this need and 14% (35 out of 257) disagree.
178
The OPC also
revealed that it takes effort to develop such infrastructure. On the question that “every city can
easily accommodate vertical take-off and landing operations”, 59% (150 out of 256) disagreed or
strongly disagreed, while only 7% (17 out of 256) agreed.
179
74% (190 out of 256) of OPC respondents agreed or strongly agreed - against 7% (18 out of 258)
disagreeing - that urban design development should consider drone operations.
180
A
stakeholder
181
pointed out that infrastructure is needed in cities (vertiports, vertistops) to support
drone operations, which is not an easy topic, given the fact that it involves noise and public
acceptance. Moreover, decisions need to be taken on the location and type of infrastructure and
number of vertiports needed. The vast majority of stakeholders of the OPC, 73% (187 out of 257)
of respondents agreed or strongly agreed, against 15% (39 out of 257) disagreed or strongly
disagreed - consider that U-space services should be available in every urban area.
182
A.6.8.3 Platforms, collaboration and communication mechanisms
A strong majority of respondents to the OPC - 89% (228 out of 255) agreed or strongly agreed
that cooperation mechanisms should be established for authorisation of operation of drones in
urban areas.
183
Involvement of authorities and collaboration mechanisms were mentioned by
many stakeholders as a prerequisite for development of UAM. For example, it is proposed to
incentivise local authorities to take part in developing a vision (on drone operations). This could
result in government procurement to fund innovative solutions. Another stakeholder suggested to
involve European cross sectoral players to support UAM adaptive roadmaps that are supported
by the industry, Member States, local authorities, and the Commission.
184
A.6.8.4 Testing sites and pilots
A strong majority of stakeholders in the OPC, 84% (214 out of 255) agreed or strongly agreed,
that pilot projects should be run in parallel in different European cities to enhance public trust.
185
The link between testing sites and/or pilots and public trust or societal acceptance is made by a
number of stakeholders. For example, a stakeholder representing aviation organisations indicated
that there is a need to provide access to test sites in multiple locations. Test sites are the enabling
factor for unmanned technology development, both digital infrastructure and vehicle technology.
Providing the possibility for gathering field experience in the controlled environment could
178
179
180
181
182
183
184
185
DS 2.0 OPC (2022), Matrix 17.
DS 2.0 OPC (2022), Matrix 15.
DS 2.0 OPC (2022), Matrix 16.
A representative from the research sector in aviation.
DS 2.0 OPC (2022), Matrix 20.
DS 2.0 OPC (2022), Matrix 12.
A representative active in UTM.
DS 2.0 OPC (2022), Matrix 10.
Page 82 / 86
 kom (2022) 0652 - Ingen titel
2639143_0084.png
enhance safety level and public acceptance. A stakeholder representing airports suggested to
create a European endorsement for organisations working on testing sites top demonstrate the
feasibility of drones and their use cases and by doing so, help secure the necessary support from
local and national authorities. This stakeholder indicated that the Urban Air Mobility Initiative &
Network of demonstrators is an effective tool to promote awareness, as well as to develop
technology and know-how for safe drone operations in suburban and urban spaces. A European
transport operator stated that prior to scaling up urban air vehicles deployment and assuming their
integral part within a multi-modal transportation ecosystem, the social acceptability of this new
ecosystem is crucial. By effectively engaging and consulting incubators local communities from
the outset and integrating their feedback into the development of this transportation solution,
UAM stakeholders would bring the ecosystem a step closer to achieving public acceptance and
accelerating the ecosystem’s implementation in cities.
A.6.9 Societal acceptance and dealing with externalities
The perception of a general public interest is a determining factor for acceptance: stakeholder
indicate that use cases where a benefit for the community can be perceived, such as the delivery
of medical or emergency transport or the contact with remote areas, are seen as the most
promising use of UAM.
Civil drones are generally thought of having an impact that stretches into three main areas:
surveillance, pollution (noise and visual), and safety. Regarding surveillance, civil drones
represent a presence in the sky that captures data from people and places. In the OPC, 89% (229
out of 257) of the respondents said privacy should be a priority, and 85% (218 out of 255) agreed
that regulatory measures should ensure that drones are compatible with EU privacy law.
186
The
data collected by drones can have many forms: video, picture, sound, thermal record,
geolocation, etc. Any understanding of the surveillance that drones pose need to consider not
only the platform itself, but also the other payloads than can be used: cameras, thermal cameras,
sound sensors, radars, internet beaming applications, etc. Additionally, drones are big data
collection platforms that contribute to the global data economy.
Regarding pollution, civil drones pose two main problems. Firstly, they contribute to visual
pollution. Secondly, they produce disturbing sounds that are a source of sound pollution. 78%
(201 out of 257) OPC respondents agreed that regulatory measures should ensure that noise
related issues are addressed (corridors for drone, hours limits, size of drones, etc).
187
Both forms
of pollution refer mainly to the drones themselves, but also to the infrastructure that enables them
to fly
188.
This pollution has some implications also in terms of wildlife, given that they interfere
with bird flocks and other forms of livelihood.
Finally, as drone technology has proliferated, concerns have grown regarding the potential safety
and security threat that it poses. In the OPC, 98% (252 out of 257) of the respondents said that
safety should be a priority.
189
Drones can cause all sorts of accidents and they can be used for
criminal purposes of all types, from smuggling of good to industrial espionage, from harassment
to surveillance, from politically motivated action to terrorism. All these risks are exponentiated
by the problems associated with the technology that is meant to address non-cooperative drones,
186
187
188
189
DS 2.0 OPC (2022), Matrix 2 and 14.
DS 2.0 OPC (2022), Matrix 13.
Written contribution.
DS 2.0 OPC (2022), Matrix 1.
Page 83 / 86
 kom (2022) 0652 - Ingen titel
2639143_0085.png
i.e. counter-drone technology – a technology that is often not fully effective and that faces
hurdles with respect to legality, coordination, planning, and safety.
In the 2021 EASA study, safety and noise pollution are on top of EU citizens’ concerns, in a list
that also includes cybersecurity risks and the potential impact on wildlife.
190
Respondents and interviewees highlighted potential positive societal impacts such as commercial,
industrial, and environmental opportunities that can be leveraged and can be both direct and
indirect. Direct opportunities emerge from potential for speeding up commerce and deliveries and
open up new business cases, including air mobility. Regarding industrial, there is the expectation
that a developed drone industry requires qualified jobs and triggers technological development
and R&D. As for environmental, the idea is that future forms of urban air mobility can reduce
traffic congestion and the use of fossil fuels in certain use cases, therefore reducing the general
carbon footprint of metropolitan areas.
It is crucial that public and private institutions collaborate in the development of risk mitigation
and response strategies to minimize the risks. Importantly, and considering the technology’s
evolution, this collaboration should be unfolded on a permanent, regular basis. Current EU efforts
in carrying out this societal engagement are praise-worthy and should be reinforced.
191
As
happens in other areas, there is a potential for the EU to become a standard setter in the area of
technology regulation.
The issue of technology acceptance is not a binary one. Indeed, the citizens make nuanced and
deliberate decisions depending upon the context. The boundary between acceptable and
unacceptable civil drone development are defined by how serious the benefits are, and who the
user is.
The integration of drones in society into the existing air and ground infrastructure must respect
residents’ quality of life and the cultural heritage of old European cities. To reiterate what was
mentioned above, considering the big impact that new forms of air mobility will have on society,
it is fundamental that the whole civil society, and not only end-users, participate in the regulatory
process. Finally, regulators and legislators should consider the full spectrum of the surveillance
issues raised by the integration of civil drones in the airspace, beyond the mere visual and sound
data collection. Rather, civil drones need to be considered big data collection systems that are
integrated with other technologies and participate in the global marketization of data.
The DS 2.0 should do more than highlight risks and obstacles, but equally – if not more –
important for societal acceptance, the strategy should illustrate the benefits of drones in society;
citizens are not fully aware of the positive benefits of drones
192
.
A.6.10 Developing knowledge, training staff and building competence
A.6.10.1 Changing skills needs and building competence
A strong majority of stakeholders of the OPC - 89% (230 out of 257) agreed or strongly agreed
that drone services will have an impact on skills and new training offers adapted to the smart
190
European Union Aviation Safety Agency (2021) Study on the societal acceptance of Urban Air
Mobility in Europe. Available at:
https://www.easa.europa.eu/sites/default/files/dfu/uam-full-
report.pdf.
Interview with European civil aviation authority.
Written contribution, industry representative.
191
192
Page 84 / 86
 kom (2022) 0652 - Ingen titel
2639143_0086.png
mobility and drone services should be made available.
193
Individual stakeholders confirmed the
need for training while a European drones association pointed out the differences in training
between manned and unmanned aviation. A stakeholder representing workers in aviation stressed
the need for an EU pilot training by developing a syllabus for drone pilots, as well as an adequate
training programme. Apart from drone operations, stakeholders mentioned a range of domains in
which capacity needs to be developed such as, legal capacity to deal with implementation of new
legislation. A drone operator indicated the need to invest in skilled workforce at National
Authorities and ANSPs and provide funding for key enabling technologies and Technology
Readiness Level (TRL) research. A European Civil Aviation Authority indicated the
development of a roadmap (2021-2030) including competences development and training
activities in line with technological and regulatory evolution.
A.6.10.2 A dedicated Research and Innovation action
Around two thirds (69%, 82 out of 119) of the respondents to the targeted survey were supportive
of a dedicated Research and Innovation (R&I) action in support of the development of drones.
194
These included, improvement of drone and remote-control technology; protection of geographic
zones and airports; enhancing the potential use of drones; training and education; protection of
the environment; the regulatory framework to make use cases easier. Apart from what should be
covered, stakeholders indicated that the results of research projects are not always optimally
used.
195
Moreover, the focus of such a dedicated R&I action would need to be carefully
coordinated with other initiatives, such as SESAR 3, in order to avoid overlaps or parallel
research programs not converging.
196
193
194
DS 2.0 OPC (2022), Matrix 21.
Whereas 12% (14 out of 119) of the respondents do not agree to such an action and 19% (23 out of
119) does not know.
Drone operator
According to a representative from the U-Space sector.
195
196
Page 85 / 86