The Department of Transport is developing a Policy Framework for Unmanned Aircraft Systems. In 2021, the Department established an interdepartmental steering group to facilitate the development of a comprehensive, holistic, and integrated policy. Three key areas were identified:
- Innovation and enterprise
- Planning and the use of airspace
- Compliance and enforcement
Three working groups were set up to focus on these key areas. Informed by the work of the three working groups, the Department held a targeted stakeholder consultation in 2022. The Department now needs wider input to guide the direction of the policy framework and to ensure it provides a balanced and holistic approach.
Input is sought on several key areas, including how to respond to public concerns about the increase in use of UAS, how to position Ireland as a potential front runner in this emerging sector, and how to future proof responsible development of the UAS industry.
This consultation will help inform the development of the Policy Framework for UAS including defining Ireland’s position in the UAS industry and the actions for implementing the Policy Framework. The Department has developed some questions that you can consider when making your submission. Submissions may be made:
By the online form here
By email to: dronesUAS.consultation@transport.gov.ie
The closing date for submissions is Friday 8 March 2024
Use of Airspace
The main element of this consultation affecting General Aviation pilots is the second key area identified: ‘Planning and the Use of Airspace’. The Department is looking for observations in three areas that are listed below. The relevant parts of the public consultation document are included here. Key to the development of U-Space is how it will be funded. Infrastructure will be required that will require significant capital investment.
The paragraphs below have been taken from the public consultation document.
The evolution of UAS technology and the developing EU regulatory approach to UAS indicates significant potential future growth in this sector. The European Union Aviation Safety Agency (EASA) forecasts that by the mid-2030s, the typical European city may see in the region of 30,000 UAS flights per hour.
The European Commission, in conjunction with EASA, developed an enabling regulatory framework that allows for the safe development of a UAS services market. The U-space Regulation (Regulation (EU) 2021/664) provides for a digital system that aims to keep UAS operations safe, secure, and green. For Ireland to be in a position to benefit from the development and uptake of new technologies and services associated with UAS, future planning is required.
The U-space Regulation became applicable on 26 January 2023. The concept of U- space emerged to support commercial operations with UAS, especially those entailing greater complexity and automation. The U-space Regulation outlines the service providers and services required to establish U-space. Essentially, U-space is an area of airspace where UAS operations may only occur with the support of U-space services. At a minimum these must include: network identification, traffic management, flight authorisation and geo-awareness. The purpose of U-space is to achieve automated UAS management and integration, allowing for a large series of operations, many of them simultaneous. This must work alongside the current air traffic management (ATM) system.
The level of operations over Dublin city is already reaching a volume that will necessitate U-space. The volume and complexity of UAS operations in Dublin is moving fast towards the level where we will need to consider putting a UAS traffic management system in place so that we don’t infringe on the current flexible use of airspace policy. There are several commercial companies seeking to gain access to the limited air space over Dublin city with a view to scaling up their operations beyond visual line of sight (BVLOS) to maximise efficiency and cost effectiveness.
Key challenges associated with increased use of UAS, and the implementation of the U-space Regulation include concerns about noise, privacy, safety and security. Minimising environmental impact and ensuring environmental protection are key priorities. There is also the challenge of how U-space should be implemented within the State. Many EU member states are struggling with this challenge and are considering different approaches on funding and delivery of U-space. It is estimated that the implementation of U-space will take two to five years and a significant amount of capital will be required to put in place the necessary infrastructure and services required. Consideration should now be given to the State’s approach to the adoption of U-space or at the very least the establishment of an unmanned aircraft system traffic management system (UTM) and how it should evolve over the next ten years.
The impact of a growing UAS sector needs to be considered in more depth as its volume increases. In particular, the impact to the receiving environment, and whether different considerations may need to apply to urban and rural areas.
A roadmap on integrated spatial planning for UAS use in urban and rural areas should be developed, to include a risk-based process for defining UAS geographical zones. UAS geographical zones can be established by the IAA for the purpose of ensuring safety, security, privacy, or environmental protection. UAS geographical zones are portions of airspace where UAS operations are facilitated, restricted, or excluded. It is proposed that as part of the roadmap, a process be established to allow state agencies, government departments and local government determine and request UAS geographical zones be established by the IAA.
Observations sought:
What concerns do you have about increased UAS use in urban and rural areas? How can these concerns be addressed/alleviated?
What do you think is required to develop a roadmap on integrated spatial planning for UAS use in urban and rural areas? What immediate steps should Ireland be taking to implement the U-space Regulation? How should the development of U- space be funded?
Who should be able to initiate a request for the establishment of UAS geographical zones (on safety, security, privacy or environmental grounds) and on what criteria should one be established?
The full public consultation document is available to read here.
