The purpose of this document is to analyse how the ISO 21384 series of international safety and quality standards could be applied against a number of real-life issues presented by Network Rail.
The current design authority regulations for UAS is not fit for purpose. The industry is saturated with manufacturers from around the world with a huge number of commercial platforms becoming available on the market with no dedicated product standards available by which to measure their suitability for task in terms of safety and quality. Many platforms continue to advance, introducing further unstandardized technology to enhance safety or performance. Sadly, the CAA is not able to keep pace and so the regulations rely purely on a manual assessment of the pilot’s competence and technology’s suitability for commercial use. This approach relies on CAA officers having an intimate knowledge of all emerging technology which, in an under-funded, over-stretched organisation, is neither practical or realistic.
The following specific issues are real-life consequences of not having an Acceptable Means of Compliance for UAS Operations.
Unlike the military environment, guidance on maintenance of airworthiness for civil UAS is entirely lacking in current UK regulations and guidance. This is causing significant issues for operators who need to ensure:
The current approval process is normally single use case and is too long and drawn out for limited application, only utilised for singular drones per operator (drone in a box/swarm technology hindered) and often set out and approved for limited timeframes, specific dates afforded and within some form of segregation (TDA) which affect the potential of the platforms operating envelopes and normally placed in a benign environment where the goal isn’t easily achievable or realistic.
ISO 21384-3 – UAS Operations has extensive guidance for operators of all classes of UAS and could be used by Government as an acceptable means of compliance. Indeed, CAP 722 could now be reduced in size, existing as a set of exceptions and exclusions to ISO21384-3 and its sister standards which are developing to cover the training of UAS Pilots, maintainers, monitors and operators. This would save valuable CAA time and resources, leaving the industry to rapidly evolve the acceptable means of compliance.
The following specific issues are real-life consequences of not having an Acceptable Means of Compliance for UAS Products.
Noise is a significant concern during operations not just over the rail or by night but within all sectors and to all operators and the public. However, no guidance as to acceptable levels of noise for commercial operations. Coupled with the issue of a lack of minimum product standards for UAS, it is impossible to know what UAS are suitable.
Network Rail faces a significant threat from loss of data to other countries and doesn’t truly understand where this is captured, recorded or how it is utilised. As the rail infrastructure is Critical National Infrastructure (CNI) this is very important issue.
ISO 21384-2 (Parts 1 & 2) covers the safety and quality requirements for manufacturers of UAS (aircraft and sub-systems). This standard has been created to provide an AMC for manufacturers of aircraft and subsystems and, while it is not exhaustive, it includes a number of subsystems including tether technology, attachments requirements and, as per 21384-3, is under constant review so, if it does not cover what you need, I would again urge you to engage with the work ISO WG2 and WG6 are conducting to ensure that it does.
The benefit of complying with these standards is that the CAA will (in time) accept your compliance at this level as an AMC for the technology that you are using. This is, of course, a gross oversimplification and we have some way to go but, if you wish to simplify the processes that you are facing in time, this is the way forward. Not engaging in this work won't mean that it will not be accepted as an AMC by the CAA, it just means that you will not have had an input to it. I hope that makes sense, but I am happy to explore this with you if you would like to discuss it in more detail.
Software risk management (informative)
Electromagnetic environmental effects (E3) (informative)
Over the last few years, the CAA has not had the resources to keep pace with the unprecedented evolution of UAS technology. In general aviation, the military environment and for operations where manned aviation certification is required, maintenance of airworthiness and product requirements are well-documented, and an approval process exists. While this process would not be suitable for operations and technology in the specific class, a comparable Acceptable Means of Compliance is required and the ISO Safety and Quality standards provide an opportunity to achieve this while, at the same time, easing pressure on the CAA.
As has been mentioned in the main paper, changing regulations is difficult at the best of times but, with the CAA not able to cope with demands from a rapidly evolving industry, regulations may never be in a position to support viable commercial operations which could destroy inward investment, driving it instead to those countries who have established more flexible approaches.
Rikke Carmichael is Head of Air Operations at Network Rail and leads a specialist team that manages aerial data surveys using helicopters and drones. This valuable data is used to improve rail safety, plan preventative maintenance and help identify potential issues before they can impact the rail infrastructure.
A native of Denmark, Rikke has extensive experience in aviation. As a professional helicopter pilot in the USA, she flew for various operators and from a business perspective, she spent six years with Boeing Defence UK. During this period, she played a significant role in the development of the training programme for the C17 Globemaster III. Later, as a Campaign Manager, she successfully secured the through-life training contract with the RAF. Rikke has been with Network Rail since 2018 and is always exploring opportunities to improve and implement new technologies that can benefit aerial data capture and exploitation.
Rikke is a member of the following drone groups:
Robert Garbett is a qualified aeronautical engineer who served as the senior engineer for Army Special Forces Helicopters and, later in his career, was responsible in the development of many of the tri-service policies for aircraft maintenance across all three services which included all military UAS. Later, as Airworthiness 1 for the Defence Logistics Agency (DLA) he was the lead for the development and maintenance of the airworthiness policies for all British military aircraft including military UAS.
Since leaving the Army, Robert has been appointed to the following positions:
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