THE BVLOS TANGO:HOPE FOR NAVIGATING THE UAS-2021 MAZE

Bhupinder S. Nijjar

On the way back from a short official trip to Joint AFB Hickam in 2015, I had picked up a small toy quadcopter at Chicago airport. It joined another small toy RC helicopter at home. Even with their extremely limited endurance, it was a pleasure flying them indoors.
 The quadcopter could even do a “flipping” manoeuvre if the space permitted and correct control inputs were applied. Even though the experience ended with the rotors getting damaged and the Quadcopter becoming a part of a school science project, it was quite a satisfying experience even though flying a real helicopter in operationally challenging environs remains unmatched. However, at the time, anyone could fly these toy drones irrespective of their size or weight. 
As I looked around, the drone had already become a part of the repertoire of a professional photographer. Their applications expanded with the influx of more capable machines with sophisticated payloads and an ever-expanding operational envelope.
The Indian Armed forces have been operating the drones since the late 1990s.The potential impact of this unbridled proliferation on the aviation sector and the prevailing security environment forced the evolution of a regulatory mechanism bye the Directorate General of Civil Aviation (DGCA) under there aegis of the Ministry of Civil Aviation (MOCA). In August 2017 the DGCA issued the first Civil Aviation Requirements (CAR) regarding Civil Remotely Piloted Aircraft Systems (RPAS).
What followed was an extended period of multi-stakeholder consultations aiming to facilitate the civil UAV operations. The output was the “UAS-2021”.
     The initial euphoria among the industry observers quickly evaporated as the Business concerns studied the clauses under various sub-parts. (More about that aspect I hope to cover in subsequent posts) 
  One of the crucial aspects for successful commercial operations in the civil sector where the “Return on Investment” (ROI) dictates the initial investment, are the permissions related to the Beyond Visual Line of Sight (BVLOS) UAV operations.
      In April 2020, DGCA had granted permissions to various consortia to undertake BVLOS experiments under the watchful eyes of the BEAM (BVLOS Experiment Assessment & Monitoring) committee. The BEAM oversight committee is composed of members drawn from the Indian Air Force and Airports Authority of India, among others.  Each consortium has to demonstrate 100 hours of BVLOS operations before a POC (Proof of Concept) is submitted. Here, the experiment /investment cost is to be borne wholly by the concerned consortium with DGCA acting as a facilitator. 
      These experiments are yet to start. 
     On May 7, 2021, the MoCA, using clause 70 of the notified UAS-2021 rules, issued a conditional exemption from following the UAS-2021 rules to the Government of Telangana for conducting Experimental BVLOS flights.    
With hopefully many more to follow, this conditional exemption should act as a trigger for an irreversible chain of events in the Indian commercial/civil BVLOS segment (Some amount of BVLOS operations have been undertaken under the Indian Air Force Sponsored “Mehar Baba Competition” scheme).
    However, of the 18 conditions mentioned in the Annexure, the ones that all the aspiring Drone operators and the support ecosystem need to watch out for keenly, are the ones mentioned in serial number 11.
      For understanding the need for exemptions, a serious “Drone Watcher” would do well to compare the clauses mentioned in  Part IV Manufacture, Import, Airworthiness and Maintenance of Unmanned Aircraft System available here (scroll down for the English version Page 85):
UAS-2021
Even a cursory glance at the section and comparing it with the actual capabilities available in the commercial space, these mandated requirements points to their being of an aspirational nature. This is especially so when viewed from the viability perspective for a purely commercial exploitation.
    Therefore, these  BVLOS experiments in the weight category of 2-25 Kg along with the “exemptions” are important in understanding the accepted need for following a stepped approach in sync with available capacities and technologies.
    Subsequently, such exemptions could also be expanded to various other sub-clauses which have found a mention in the UAS -2021. This would form a part of the stepping stone approach towards meeting the stated aspirational requirements. 
        What would be the icing on the cake and a feather in MoCA/DGCA cap if this BVLOS-“Tango”   experiments also pave a path for at least one dedicated corridor/airspace for all the aspiring Drone enthusiasts, entrepreneurs and innovators  to undertake unrestricted experiments and prove their innovative ideas. This could also aid in developing a practical UAV traffic Monitoring (UTM) concept catering to Indian security and safety requirements. 
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