NAARIC Urges EASA to
Review its Position
The NAARIC (National Aviation Authorities
Regulation Implementation Coordination) is a group of UAS experts from the main
European National Aviation Authorities (NAAs) that was launched in 2019 with
the objective of agreeing on a common approach at the European level towards
the aspects left to the Member States by the Commission Implementing Regulation
(EU) 2019/947
and Commission Delegated Regulation (EU) 2019/945, including
their recent amendments regarding standard scenarios.
As of May 2020, the NAARIC group is constituted by
NAA representatives from the Austria, Belgium,
Denmark, Finland, France,
Germany, Italy, Latvia, Luxembourg, The Netherlands, Norway, Poland,
Romania,
Spain, Sweden, Switzerland, and UK.
On 27 May 2020, NAARIC issued its position document with
critical comments on EASA’s NPA
2020-07 on “Unmanned aircraft system beyond
visual line operations over populated areas or
assemblies of people in the
´specific´ category’’,
which included:
- A
significant number of proposed amendments
- An
emphasis of the relevant contribution made to the development, validation,
and recognition of the JARUS SORA methodology
- Its
view on social and economic impact assessment of the implementation of the
NPA.
The NAARIC position paper indicated:
“The NAARIC group does not believe that the
triggering safety-related issue for this NPA 2020-07 (i.e. the incident
involving a small UAS produced by Matternet that took place while overflying a
forest in Zurich, Switzerland a year ago) is directly or indirectly linked to
the fact that such UAS operation was performed in BVLOS and much less to
operating over a populated area or over an assembly of people as this was not
the case.
“In fact, operational experience has shown that
certain UAS operations are much safer when performed in BVLOS following a
pre-programmed trajectory than those flights conducted manually in VLOS. In
addition to this, the NAARIC group would like to remark, on the one hand, that,
in accordance with ICAO Annex 13 on Aircraft accident and incident
investigation and with Article 17 of Regulation (EU) No 996/2010 of the
European Parliament and of the Council on the investigation and prevention of
accidents and incidents in civil aviation, all safety recommendations from the
independent National Transportation Safety Board (NTSB) were imple-
mented, and,
on the other hand, that none of the
drawn safety recommendations or conclusions
questioned the suitability of the SORA methodology
or its application. Besides the NTSB’s investigation,
EASA also sent
an expert investigation team to Switzerland, which reached the same conclusions
and did not express either any concerns about the
SORA methodology. For these
reasons, the NAARIC
group sees no evidence for which Europe through
EASA should
deviate from an internationally agreed standard like JARUS SORA and
even less
as a result of a single safety incident.”
“The NAARIC group would like to ask EASA to avoid
giving out the impression to the aviation community
in general and to the UAS
sector in particular that,
as a result of the notification and safety
i
nvestigation of an incident involving a small UAS, a radical set of complex
and challenging requirements
for UAS operators and manufacturers is
subsequently
l
aid down by EASA. In fact, having EASA constantly reported a lack
of data in this sense and, thus, of
safety lessons, the NAARIC group strongly
believes
that implementing the amendment proposed by this
NPA 2020-07 would not
but worsen this situation.
For this reason, the NAARIC group would like to
discourage EASA from overreacting and from
undoing what has been achieved.”
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