d1.3 rpas regulatory gaps/barriers

Grant Agreement No: 777630 Project Acronym: MOMIT

Project Title:

Multi-scale Observation and Monitoring of railway Infrastructure Threats

A project co-funded by the European Union’s Horizon 2020 – Shift2Rail Programme for research, technological development and demonstration

D1.3

RPAS regulatory gaps/barriers

This Document is composed by 52 pages, including attachments

Last revision date: 2017-10-15

Dissemination Level: PU = Public

Ref. Ares(2018)5330900 - 17/10/2018

MOMIT - Multi-scale Observation and Monitoring of railway Infrastructure Threats GA No: 777630 Project co-funded by the European Union’s under the H2020 – S2R Programme

D1.3 – RPAS regulatory gaps/barriers – v1.1 of 51

Deliverable information

Document Configuration

Programme Name: Shift2Rail

Call: H2020-S2RJU-2017

Topic: S2R-OC-IP3-03-2017

Proposal Number: 777630

Grant Agreement Number: 777630

Project Acronym: MOMIT

Project Title: Multi-scale Observation and Monitoring of railway Infrastructure Threats

Deliverable Number: D1.3

Title of the Deliverable: RPAS regulatory gaps/barriers

Work-Package: WP1

Issue date: 2017-10-15

Revision of the document: v1.1

Dissemination Level: PU = Public

Responsible Beneficiary: NEAT

Prepared by: Davide VENTURUCCI (NEAT)

Reviewed by: Simone CABASINO (NEAT)

Contributors: Terabee SAS , E-GEOS SPA



Revision History

Revision Date Author Organisation Description

v1.0 2017-11-30 Davide VENTURUCCI NEAT First draft issue

v1.1 2017-10-15 Davide VENTURUCCI NEAT Midterm revision

Statement of originality

This document contains original unpublished work except where clearly indicated otherwise. Acknowledgement of previously published material and of the work of others has been made through appropriate citation, quotation or both.

Disclaimer

The information contained in this document and any other information linked therein is confidential, privileged and it remains the property of its respective owner(s). As such, and under the conditions settled in the MOMIT Grant Agreement and the MOMIT Consortium Agreement, it is disclosed for the information of the intended recipients within the MOMIT Consortium and the European Commission / Shift2Rail JU according to its “Dissemination Level”* and may not be used, published or redistributed without the prior written consent of its owner(s). * PU = Public, CO = Confidential, EU-R/R-UE = Classified, information as referred to in Commission Decision 2001/844/EC.



Table of Contents

LIST OF TABLES .............................................................................................................................. 6LIST OF FIGURES ............................................................................................................................ 7ACRONYMS AND ABBREVIATIONS ................................................................................................... 81 EXECUTIVE SUMMARY .......................................................................................................... 122 DOCUMENT CONTEXT ........................................................................................................... 133 RPAS REGULATORY FRAMEWORK ...................................................................................... 14

3.1 DEFINITIONS .............................................................................................................................. 143.1.1 Main components of an RPAS ................................................................................................ 143.1.2 RPAS Operations................................................................................................................... 17

3.2 ICAO PROVISIONS ..................................................................................................................... 183.2.1 RPAS in the Chicago Convention ........................................................................................... 193.2.2 ICAO Standards on RPAS ...................................................................................................... 203.2.3 ICAO Manual on RPAS ......................................................................................................... 21

3.3 EASA AND EU INITIATIVES ....................................................................................................... 223.3.1 EASA Technical Opinion ....................................................................................................... 223.3.2 Proposed Regulation ............................................................................................................. 243.3.3 European Regulation (updated October 2018) ....................................................................... 253.3.4 Unmanned Traffic Management (UTM) and U-Space (updated October 2018) ...................... 25

3.4 NATIONAL REGULATIONS FOR RPAS BELOW 150 KG ................................................................. 263.4.1 JARUS: an initiative for harmonizing national regulations of small RPAS ............................. 263.4.2 RPAS Regulation in Italy ....................................................................................................... 29

3.5 INDUSTRIAL STANDARDS FOR SMALL RPAS .............................................................................. 333.5.1 EUROCAE, RTCA and other Standardization bodies ............................................................. 34

4 RPAS OPERATIONS IN MOMIT ........................................................................................... 364.1 DEFINITION OF MOMIT RPAS OPERATIONAL SCENARIOS .......................................................... 364.2 REGULATORY AND LEGAL ASSESSMENT OF THE OPERATIONAL SCENARIOS ................................ 38

4.2.1 Scenario 1: Demonstrator #4 ................................................................................................. 394.2.2 Scenario 2: Demonstrator #5 ................................................................................................. 424.2.3 General provisions ................................................................................................................ 43

5 CONCLUSION AND RECOMMENDATIONS ............................................................................... 445.1 GUIDELINES AND RECOMMENDATIONS FOR RPAS OPERATIONS IN MOMIT ............................... 445.2 MONITORING THE EVOLVING REGULATORY AND STANDARDIZATION FRAMEWORK .................... 45

5.2.1 Monitoring plan .................................................................................................................... 455.2.2 Monitoring execution ............................................................................................................. 47

PARENT DOCUMENTS ................................................................................................................... 48



APPLICABLE DOCUMENTS ............................................................................................................ 49REFERENCE DOCUMENTS ............................................................................................................. 50ATTACHMENTS ............................................................................................................................. 51



List of Tables Table 3-1: Categorization of aircraft in ICAO ............................................................................... 15Table 3-2: Hierarchy of ICAO documents ..................................................................................... 19Table 3-3: simplified version of table of publications by JARUS (original: http://jarus-

rpas.org/publications) ............................................................................................................ 28Table 3-4: Standardization bodies for RPAS.................................................................................. 35



List of Figures Figure 3-1: RLOS C2L (Picture by ICAO) .................................................................................... 16Figure 3-2: BRLOS C2L (Picture by ICAO) .................................................................................. 16Figure 3-3: VLOS Operations (Courtesy ICAO) ............................................................................ 18Figure 3-4: The three categories of risk for RPAS operations as proposed by EASA ..................... 23Figure 3-5: JARUS working groups (JARUS website) .................................................................. 27Figure 7: the area of operations for Demonstrators #4 and #5 (taken from https://app.d-flight.it) ... 38Figure 8: Prohibited Area close to the field of operations (taken from https://app.d-flight.it) ......... 39Figure 9: Satellite image of the area of operations (tunnel highlighted in yellow) .......................... 40Figure 10: distance of the highway to the area of operations at their closest point .......................... 41Figure 5-1: Process of monitoring of regulatory and standards changes ......................................... 47



Acronyms and Abbreviations

ACP Aeronautical Communications Panel

AGL Above Ground Level

A-NPA Advanced Notice of Proposed Amendment

AOI Area of Interest

ARP Aerodrome Reference Point

ASTM American Society for Testing and Materials

ATC Air Traffic Control

ATM Air Traffic Management

ATM/ANS Air Traffic Management/Air Navigation Services

ATS Air Traffic Services -

ATZ Aerodrome Traffic Zone

BRLOS Beyond Radio Line-Of-Sight

B-VLOS Beyond Visual Line-Of-Sight

C2L Command and Control Link

C3 Command, Control, Communication

CAA Civil Aviation Authority

CPDCL Controller Pilot Data Link Communications

CTR Controlled Traffic Region

DAA Detect And Avoid

DoA Description of Action

EASA European Aviation Safety Agency

EC European Commission

ENAC Ente Nazionale per l'Aviazione Civile (Italian Civil Aviation Authority)

EO Earth Observation

ERA Enhanced RPAS Automation

ESO European Standardisation Organisations



ETSO European Technical Standard Order

EU European Union

EUROCAE European Organisation for Civil Aviation Equipment

E-VLOS Extended Visual Line-Of-Sight

FCL Flight Crew Licensing

FSS Fixed Satellite Service

HD High Definition

ICAO International Civil Aviation Organization

IR Infrared

ISO International Standards Organization

ITU International Telecommunication Union

JARUS Joint Authorities for Rulemaking on Unmanned Systems

LUAS Light Unmanned Aeroplane Systems

LURS Light Unmanned Rotorcraft Systems

MTOM Maximum Take-Off Mass

NAA National Aviation Authority

NOTAM Notice to Airmen

PIC Pilot in Command

QE Qualified Entity

RLOS Radio Line-Of-Sight

RLP Required C2 Performance

RPA Remotely Piloted Aircraft

RPAS Remotely Piloted Aircraft Systems

RPS Remote Pilot Station

RTCA Radio Technical Commission for Aeronautics

SAR Sintetic Aperture Radar

SARPs Standards and Recommended Practices

SC Special Committee

SDR Special Drawing Rights

SESAR JU Single European Sky ATM Research Joint Undertaking

SORA Specific Operations Risk Assessment

TC Technical Committee



UAS Unmanned Aircraft Systems

UASSG Unmanned Aircraft Systems Study Group

UAV Unmanned Aerial Vehicle

UN United Nations

UTM UAS Traffic Management

UV Ultraviolet

VLOS Visual Line-Of-Sight

WG Working Group

WP Work Package

WRC World Radio Communication Conference



RPAS regulatory gaps/barriers



1 Executive Summary One of the main objectives of MOMIT is the demonstration of railway infrastructures monitoring by means of Remotely Piloted Aircraft Systems (RPAS) and satellite technologies. Recently, in the “European Drones outlook” published by the Single European Sky ATM Research (SESAR), commercial RPAS below 25 kg of mass, commonly referred as “drones”, are recognized as a disruptive technology, with a rapid evolution in terms of reference market and types of application. In official communications to the Parliament and the Council, the European Commission itself demonstrated its engagement in fostering the RPAS industry in the Union, including both the design and development of new technologies and innovative applications in the civil domain.

The disruptive nature of RPAS in terms of technologies and fields of application poses important challenges to regulation and standardization, both for the authorities and for the industrial stakeholders (manufacturers, operators). A comprehensive, uniform and stable set of rules and standards is far to come, as regulations are continuously evolving and refining their requirements, following the technological progresses and trying to address the most critical issues (mainly related to safety, security, privacy and data protection). A full comprehension of the current regulatory framework and its potential impact on operations is a precondition to build a solid business case, when RPAS are involved.

The work done in this report aims at providing the MOMIT consortium with a common understanding of the state-of-the art of RPAS regulation and standardization. ICAO definitions, guidelines and provisions are covered, as well as the rulemaking initiatives of EU/EASA and other international bodies. An in-depth analysis of the RPAS regulation in Italy is here reported, and the MOMIT demonstration scenarios are assessed against it, as all the foreseen locations for flying demonstrators are in Italy.

The document is concluded by guidelines and recommendations for the consortium. They address both general considerations about a common understanding of RPAS regulation issues that may arise during the whole project, and best practices for approaching the national aviation authorities and getting the needed permits for the flying demonstrators.



2 Document Context A specific task of MOMIT project, i.e. WP1 - Task WP1.3 - Regulatory gaps/barriers, is aimed at identifying the applicable regulatory framework for the envisaged RPAS operations, in order to identify the potential gaps and issues in the overall process. According to the Analyse/Develop/Demonstrate/Exploit approach, the task is developed in the Analyse phase. The output of the task, subject of the current document, will be used as input for the following activities, in order to guide the selection of the most suitable technological solutions and to support the Request of Authorization and/or Permission by the competent Civil Aviation Authorities in the countries in which the demonstration scenarios will be implemented and the flights will be carried out. Since both the regulatory and standardization framework are currently at an evolutionary stage of their development, as widely explained in Section 3, in order to minimize the impact of any regulatory changes that could occur in a relatively short time-frame, a monitoring activity of the evolution of regulatory and standardization framework will be carried out. Further revisions of the current document are so envisaged during the first phase of the project, before the beginning of WP4 - Application cases demonstration, in order to allow the Consortium to face the potential changes in regulatory constraints.



3 RPAS Regulatory Framework

3.1 Definitions Aircraft that are not controlled (during the all flight or parts of it) by a pilot on-board are called Unmanned Aircraft. The inherently distributed nature of such configuration includes several components, so the international community has agreed to refer them as Unmanned Aircraft Systems (UAS, See Section 3.2). A sub-category of UAS is composed by the configurations where the remote pilot (typically on the ground) has a direct control of the flight during all its phases. They are called Remotely Piloted Aircraft Systems (RPAS). UAS with the ability to perform an autonomous flight (or part of it) are not included in the category of RPAS. This document mainly refers to RPAS, as the current international regulatory framework do not cover autonomous UAS (See Section 3.2), and their integration in the civil aviation system is not foreseen on the short term. An in-depth analysis of all the subsystems and technologies composing an RPAS is out of the scope of this document, but a preliminary overview of its functioning and structure, together with some definitions, has a certain importance for understanding the following sections. Different definitions and descriptions of RPAS and their component have been provided in the past years, and the terminology itself may slightly differ from a source to another (e.g. military and civil terminology are not always aligned). In order to provide the MOMIT consortium and the readers with a common understanding and a uniform terminology, the following definitions adhere as strictly as possible to ICAO taxonomy, as provided in the UAS Circular and in the RPAS Manual (See Section 3.2).

3.1.1 Main components of an RPAS

The remotely-piloted aircraft system comprises a set of configurable elements including an RPA (the flying part), its associated remote pilot station(s), the required C2 links and any other system elements as may be required, at any point during flight operation. Other features might include, inter alia, software, health monitoring, ATC communications equipment, a flight termination system, and launch and recovery elements.

3.1.1.1 Remotely Piloted Aircraft

The RPA is the flying part of the system. It is properly considered as an “aircraft” by ICAO, so all the definitions, rules and general provisions about aircraft are applicable (See Section 3.2). The table below reports the categorization of aircraft, following ICAO Annex 7.



A

ircr

aft

Lighter than air Non power driven

Free balloon

Captive balloon

Power-driven Airship

Heavier than air

Non power driven Glider

Kite

Power-driven

Aeroplane

Landplane

Seaplane

Amphibian

Rotorcraft Gyroplane

Helicopter

Ornithopter Table 3-1: Categorization of aircraft in ICAO

All the classes of aircraft mentioned in the table may have their own unmanned (remotely piloted) version. In the ICAO classification, the category of multi-copters falls under the definition of helicopters (“a heavier-than-air aircraft supported ... by ... one or more power-driven rotors on substantially vertical axes”).

3.1.1.2 Remote pilot station

The remote pilot station (RPS) is defined as “…the component of the remotely piloted aircraft system containing the equipment used to pilot the remotely piloted aircraft.” As a general principle, the RPS behaves, or functions, in the same manner as the cockpit/flight deck of a manned aircraft and should, therefore, offer the remote pilot with an equivalent capability to command/manage the flight. There are no common standards for the design of RPS and they may vary significantly in terms of size, functionalities, Human Machine Interface (e.g. joystick, knobs, touch screen), flight control modalities (e.g. fully manual vs. partly automated flight). In general, complexity of the ground station is proportionate to the size and weight of the RPAS and the type of operations to be conducted.

3.1.1.3 Command and Control link

The Command and Control Link (C2L) is the data link between the remotely-piloted aircraft and the remote pilot station for the purposes of managing the flight. Accordingly, the C2L has two main functions:

• to allow the pilot to modify the behaviour of the RPA: o Control the RPA’s flight (Aerodynamics, Propulsion, etc.); o Control Detect and Avoid systems on the RPA (execute manoeuvres); o Control on-board tools and equipment (Transponder, ADS-B1, Radar, etc.)

• to allow the pilot to retrieve info about the RPA status:

1 Automatic Dependent Surveillance – Broadcast is a surveillance technology in which an aircraft determines its position via satellite navigation and periodically broadcasts it



o RPA health and status (Speed, Attitude, Warnings, etc.); o Monitor Detect and Avoid system on RPA (Target tracks, Advisories etc.) o Monitor Flight Data Recording and other data sources.

C2 link architectures are usually classified as radio line-of-sight (RLOS), or beyond radio line-of-sight (BRLOS), which reflect both the type of architecture and the timeframe within which transmissions are completed:

• RLOS refers to the situation in which the transmitter(s) and receiver(s) are within mutual radio link coverage and thus able to communicate directly or through a ground network provided that the remote transmitter has direct radio line-of-sight to the RPA and transmissions are completed in a comparable timeframe;

Figure 3-1: RLOS C2L (Picture by ICAO)

• BRLOS refers to any configuration in which the transmitters and receivers are not in RLOS. BRLOS thus includes all satellite systems and possibly any system where an RPS communicates with one or more ground stations via a terrestrial network which cannot complete transmissions in a timeframe comparable to that of an RLOS system.

Figure 3-2: BRLOS C2L (Picture by ICAO)

No international standards have been currently defined on frequencies and channels for RPAS C2L. This led to a situation where different countries adopt different rules on the topic, so the manufacturers and operators do not have unambiguous references to follow. International Telecommunication Union (ITU), the United Nations specialized agency for information and communication technologies, is in



charge to define and promote a worldwide uniform allocation of communication bands. In current ITU Radio Regulation (2012) following bands are candidates for C2 links:

• 960 - 1164 MHz for RLOS • 1545 – 1555 / 1646.5 – 1656.5 MHz and 1610 - 1626.5 MHz for BRLOS • 5030 – 5091 MHz for RLOS and BRLOS

Other frequency bands, with suitable technical and regulatory provisions, are under consideration. Work is underway in Aeronautical Communications Panel (ACP) WG-F to develop a band plan to allow sharing between the terrestrial and satellite RPAS users of the 5030 – 5091 MHz allocation. Significant interest has been shown in using 12/14 GHz and 20/30 GHz Fixed Satellite Service (FSS) bands.

3.1.2 RPAS Operations

In remote piloted operations, the pilot (and the crew in general) is not “co-located” with the aircraft, so it emerged the necessity to define new categories of operations, with regard to the respective position of the pilot (at his/her RPS) and the RPA (the aircraft).

3.1.2.1 VLOS

Operating within VLOS (Visual Line-Of-Sight) means that the Remote Pilot is able to maintain direct, unaided (other than corrective lenses) visual contact with the RPA, and is able to monitor the whole flight in relation persons, other airspace users and/or fixed obstacles, including ground. Following the above definition, it is not easy to determine precise boundaries or a definite volume for VLOS operations: it strongly depends on the size, colour and shape of the RPA, weather and light conditions, orography, presence of obstacles. As a general provision, ICAO outlined some maximum limitations to VLOS operations:

• Max RPA distance from the pilot: 500 m; • Max altitude: 500 ft Above Ground Level.

These limitations should be taken into account by the competent National authorities, when defining operating limits in their regulation. More restrictive limitations may be defined by the National authorities, and some of them have already done so (see Section 3.4).



Figure 3-3: VLOS Operations (Courtesy ICAO)

3.1.2.2 E-VLOS

Extended Visual Line of Sight (E-VLOS) relates to the operations whereby the Remote Pilot in Command (PIC) relies on one or more Remote Observers to keep the unmanned aircraft in visual sight at all times, relaying critical flight information via radio and assisting the Remote Pilot in maintaining safe separation from other airspace users and/or fixed obstacles, including ground.

3.1.2.3 B-VLOS

Beyond Visual Line of Sight (B-VLOS) operations are the ones conducted in conditions where the VLOS between pilot and RPA is not maintained.

3.2 ICAO Provisions The International Civil Aviation Organization (ICAO) is a UN specialized agency, established by States in 1944 to manage the administration and governance of the Convention on International Civil Aviation (Chicago Convention) [RD3]. ICAO works with the Convention’s 191 Member States and industry groups to reach consensus on international civil aviation Standards and Recommended Practices (SARPs) and policies in support of a safe, efficient, secure, economically sustainable and environmentally responsible civil aviation sector. These SARPs and policies are used by ICAO Member States to ensure that their local civil aviation operations and regulations conform to global norms, which in turn permits more than 100,000 daily flights in aviation’s global network to operate safely and reliably in every region of the world. In addition to its core work resolving consensus-driven international SARPs and policies among its Member States and industry, and among many other priorities and programmes, ICAO also coordinates assistance and capacity building for States in support of numerous aviation development objectives; produces global plans to coordinate multilateral strategic progress for safety and air



navigation; monitors and reports on numerous air transport sector performance metrics; and audits States’ civil aviation oversight capabilities in the areas of safety and security. ICAO has a structure composed of three main bodies, with different responsibilities, duties and functions: the Assembly, the Council and the Secretariat. A detailed description of the bodies is provided in the ICAO website, while for the aims of this document a very schematic representation of the structure is sufficient.

The following table summarizes some useful information about the hierarchy of documents issued and published by ICAO. It can be used as a reference for a better understanding of the information provided in the next sections. Document Adopted by Status Convention States (Assembly) Legally binding for States Annexes Council Standards legally binding (SARPs) PANS Council (for approval) Recommendation Manuals (Doc) Secretary General Guidance material Circulars Secretary General Info

Table 3-2: Hierarchy of ICAO documents

3.2.1 RPAS in the Chicago Convention

Remotely piloted aircraft are one type of unmanned aircraft. All unmanned aircraft, whether remotely piloted, fully autonomous or combinations thereof, are subject to the provisions of Article 8 of the Convention on International Civil Aviation (Doc 7300), signed at Chicago on 7 December 1944 and amended by the ICAO Assembly. The development of the legal framework for international civil aviation started with the Paris Convention of 13 October 1919. The Protocol of 15 June 1929 amending the Paris Convention refers to pilotless aircraft in a subparagraph of Article 15 as follows: “No aircraft of a contracting State capable of being flown without a pilot shall, except by special authorization, fly without a pilot over the territory of another contracting State”.



The Chicago Convention of 7 December 1944 replaced the Paris Convention. Article 8 of the Chicago Convention entitled “Pilotless aircraft” provides that: “No aircraft capable of being flown without a pilot shall be flown without a pilot over the territory of a contracting State without special authorization by that State and in accordance with the terms of such authorization. Each contracting State undertakes to ensure that the flight of such aircraft without a pilot in regions open to civil aircraft shall be so controlled as to obviate danger to civil aircraft”. Uncontrolled (autonomous) aircraft were already in existence at the time of the First World War, operated by both civil and military entities. “Aircraft flown without a pilot” therefore refers to the situation where there is no pilot on board the aircraft, as stated by the 35th Session of the ICAO Assembly in 2004.

3.2.2 ICAO Standards on RPAS

In 2006, the first ICAO exploratory meeting on UAVs agreed that, although there would eventually be a wide range of technical and performance specifications and standards, only a portion of those would need to become ICAO Standards and Recommended Practices (SARPs). It was also determined that ICAO was not the most suitable body to lead the effort to develop such specifications. However, it was agreed that there was a need for harmonization of terms, strategies and principles with respect to the regulatory framework and that ICAO should act as a focal point. The second informal ICAO meeting (2007) concluded that work on technical specifications for UAV operations was well underway within both RTCA Inc. and the European Organisation for Civil Aviation Equipment (EUROCAE) and was being adequately coordinated through a joint committee of their two working groups (see section 3). The main issue for ICAO was, therefore, related to the need to ensure safety and uniformity in international civil aviation operations. The meeting had also suggested that from this point onwards, the subject should be referred to as UAS, in line with RTCA and EUROCAE agreements. Finally, it was concluded that ICAO should serve as a focal point for global interoperability and harmonization, to develop a regulatory concept, to coordinate the development of UAS SARPs, to contribute to the development of technical specifications by other bodies, and to identify communication requirements for UAS activity. In the same year, the Unmanned Aircraft Systems Study Group (UASSG) has been established, with the following Terms of Reference:

a) serve as the focal point and coordinator of all ICAO UAS related work, with the aim of ensuring global interoperability and harmonization;

b) develop a UAS regulatory concept and associated guidance material to support and guide the c) regulatory process; d) review ICAO SARPs, propose amendments and coordinate the development of UAS SARPs

with other ICAO bodies; e) contribute to the development of technical specifications by other bodies (e.g., terms,

concepts), as requested; and f) coordinate with the ICAO Aeronautical Communications Panel (ACP), as needed, to support

development of a common position on bandwidth and frequency spectrum requirements for command and control of UAS for the International Telecommunication Union (ITU)/World Radio Communication Conference (WRC) negotiations.



The UASSG introduced the term “remotely piloted”, after reaching the conclusion that only unmanned aircraft that are remotely piloted could be integrated alongside manned aircraft in non-segregated airspace and at aerodromes. The study group therefore decided to narrow its focus from all UAS to those that are remotely piloted. The UASSG developed the Unmanned Aircraft Systems (UAS) (Cir 328) which was published in March 2011. The circular provided States with an overview of issues that would have to be addressed in the Annexes to ensure remotely piloted aircraft system(s) (RPAS) would be compliant with the provisions of the Chicago Convention. In March 2012, the first significant package of SARPs related to RPAS was adopted for Annex 2 — Rules of the Air and Annex 7 — Aircraft Nationality and Registration Marks. While amendments to Annex 7 do not have a significant impact on RPAS operations, Amendment 43 to Annex 2 is worthy of analysis. The basic principles underlying such an amendment are that:

1. the RPAS has to be airworthy (or at least safe enough for sustained flight), otherwise no flight operation can be initiated in line with Article 31 of the Chicago Convention;

2. the remote pilot shall be competent and, where required, licensed, in accordance with Article 32 of same Convention; and

3. the RPAS operator shall be certified (or hold other form of authorisation) in line with the modern approach to aviation safety (e.g. enshrined by ICAO Annex 19);

4. only after 1, 2 and 3, the RPAS operator may request to access non-segregated airspace. In summary, the ICAO standards require that RPAS are inserted in the ‘total aviation system’ and not just ‘into the airspace’ or Air Traffic Management (ATM). On 2014, ICAO established the Remotely Piloted Aircraft Systems Panel (RPASP) which was tasked with progressing the work begun by the UASSG and given the following objectives:

• serve as the focal point and coordinator of all ICAO RPAS-related work, with the aim of ensuring global interoperability and harmonization;

• develop an RPAS regulatory concept and associated guidance material to support and guide the regulatory process.

3.2.3 ICAO Manual on RPAS

In March 2015 ICAO published the first edition of Doc10019 – Manual on Remotely Piloted Aircraft Systems. This document aims at collecting the state-of-the-art of RPAS integration in the international civil aviation system. Where standards are already available (see previous section) they are included in the Manual, while for the areas where such standards are still under development, general technical guidelines and common definitions are provided. Doc 10019 is made of 15 chapters covering the following topics:

• ICAO regulatory framework and scope of the manual (Chapter 1); • introduction to RPAS (Chapter 2); • special authorization (Chapter 3); • type certification and airworthiness approvals (Chapter 4); • RPA registration (Chapter 5); • responsibilities of the RPAS operator (Chapter 6); • safety management (Chapter 7);



• licensing and competencies (Chapter 8); • RPAS operations (Chapter 9); • detect and avoid (DAA) (Chapter 10); • command and control (C2) link (Chapter 11); • ATC communications (Chapter 12); • remote pilot station (RPS) (Chapter 13); • integration of RPAS operations into ATM and ATM procedures (Chapter 14); and • use of aerodromes (Chapter 15).

A detailed discussion of the Manual is out of the scope of this document, anyway most of the considerations, evaluation and analysis here contained have been conducted and elaborated in compliance with its content.

3.3 EASA and EU Initiatives Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, or “EASA basic regulation”, states that “unmanned aircraft with an operating mass of no more than 150 kg” are not under the responsibility of the Agency (Annex II). As a consequence, the regulation of this category of aircraft and their operations is delegate to the National Aviation Authorities (NAAs). In the last years, the number of small RPAS flying in Europe has seen a significant increasing, following the development of a promising market for civil applications. Many countries have adopted, or are about to adopt, rules on some aspects of civil RPAS with an operating mass of 150 kg or less (See next Section). However, the extent, content and level of detail of the rules differ, and conditions for mutual recognition between EU countries have not been reached. This condition impacts cross-border operations directly as RPAS operators have to apply for a separate authorisation in each country. In addition, the opinion of the European Commission is that different rules across the EU may lead to a situation where a number of key safeguards (e.g. safety) are not addressed in a coherent way. As a consequence, the Commission gave the mandate to EASA to start a regulatory initiative, that includes the extension of its mandate to all classes of RPAS. On 31 July 2015 EASA launched a consultation process on a new regulatory framework for RPAS with MTOM<150 kg. This document (A-NPA, Advanced Notice of Proposed Amendment) presented the new regulatory approach for safely operating remotely piloted aircraft. This flexible approach, (based on the ‘Concept of Operations’ [RD4]), provides a set of rules which are proportionate and risk based. In other words, safety requirements are in relation to the risk an activity poses to the operator and to third parties (e.g. general public). The greater the risk the higher the requirements. This is done in order to ensure there is no compromise in safety, but there is a flexible environment for this promising industry to grow. The consultation process ended in September 2015 and the outcome of the consultation process is a Technical Opinion.

3.3.1 EASA Technical Opinion

The EASA opinion “Introduction of a regulatory framework for the operation of unmanned aircraft” [RD5] lays down the foundation for all future work for the development of rules, guidance material,



as wells as, safety promotion to ensure unmanned aircraft are operated safely and their impact on the safety of the aviation system is minimised. The opinion includes 27 proposals for a regulatory framework for low risk operations of all unmanned aircraft irrespective of their mass. The proposals are operations centric, focusing on how the RPAS will be used rather than their physical characteristics. It establishes 3 categories of operation, as follows:

• ‘Open’ category (low risk): Safety is ensured through compliance with operational limitations, mass limitations as a proxy of energy, product safety requirements, and a minimum set of operational rules.

• ‘Specific’ category (medium risk): Authorisation by an aviation authority, possibly assisted by a qualified entity (QE2), following a risk assessment performed by the operator. A manual of operations lists the risk mitigation measures.

• ‘Certified’ category (higher risk): Requirements comparable to those for manned aviation. Oversight by NAA (issue of licences and approval of maintenance, operations, training, ATM/ANS and aerodromes organisations) and by EASA (design and approval of foreign organisations).

This report does not go into the details of the Technical Opinion, while a general view of the three categories and respective duties and requirements for the operators is provided in the below chart:

Figure 3-4: The three categories of risk for RPAS operations as proposed by EASA

In general, the operations falling in the Open category are regarded as non-aviation and the safety is demanded to the manuals provided by the vendors (as for any other consumer technology). In the Specific category, an approval to the Authorization is needed by the competent authority (i.e. National Aviation Authorities or EASA itself), while in the Certified category, where the risk is higher for the

2 The “Basic Regulation” for EASA defines a qualified entity as follows: ‘qualified entity’ shall mean a body which may be allocated a specific certification task by, and under the control and the responsibility of, the Agency or a national aviation authority.



society, a full total system aviation approach is needed (Remote Operator Certification, Certificate of Airworthiness, Pilot License, etc.). The Technical Opinion does no still provide with well-defined and “ready-to-use” thresholds to classify RPAS operations, but some of the evaluation factors are there listed, among the others:

• Mass • Speed • Size • Kinetic Energy • Airspace • Altitude • Exposure (Density of population; density of air traffic) • Proximity to Critical Infrastructure • Second order factors (above or below obstacle protection surfaces; frangibility; energy

absorption; flight termination; etc.). The Technical Opinion comes out with a set of proposed amendments to EASA Basic Regulation, including the extension of EASA’s mandate to RPAS with a MTOM below 150 kg.

3.3.2 Proposed Regulation

In December 2015, the Commission introduced a proposal to adopt EU rules on drones3 and to repeal Regulation 216/2008 [RD6]. The main objective of the proposed Regulation is to establish and maintain the same civil aviation safety standards for manned and unmanned aviation throughout the EU, and at the same time to ensure a high and uniform level of environmental protection (Art. 1). It also seeks to expand the EASA’s competence to include RPAS with a mass below 150 kg. The proposed Regulation would apply, inter alia, to: “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, where such aircraft are operated within the Single European Sky airspace by an operator established or residing within the territory to which the Treaties apply.” (Art. 2). In particular, the following articles of the proposed regulation are of interest for this document:

[45] Requirements for Unmanned Aircraft: the design, production, maintenance, and operation of unmanned aircraft and their engines, propellers, parts, non-installed equipment, and equipment to control them remotely would need to comply with the essential requirements set out in Annex IX.

[46] Compliance of Unmanned Aircraft: The Commission would be given the authority to adopt delegated acts concerning the specifications for the design, production, maintenance, and operation of unmanned aircraft. Drones would be subject to certifications and declarations that they comply with such specifications. A drone’s certificate would specify its safety-related limitations, operating conditions, and privileges.

3 The European Commission and EASA tend to use the word drone in some high level communication, as this word is easier to understand by the general public.



Market Surveillance Mechanisms: Mass-produced unmanned aircraft that pose a very low risk would be subject to the existing market surveillance mechanisms provided in Regulation 765/2008 [RD7] and Decision No. 768/2008 [RD8].

[47] Delegated Acts: For the design, production, maintenance and operation of unmanned aircraft and their engines, propellers, parts, non-installed equipment and equipment to control the aircraft remotely, the Commission shall be empowered to adopt delegated acts (implementing rules) in to lay down detailed rules with regard to:

a) conditions and procedures for issuing, maintaining, amending, suspending, or revoking the certificates for the design, production, maintenance, and operation of unmanned aircraft;

b) conditions for situations in which, with a view to achieving the objectives of the Regulation and while taking account the nature and risk of the particular activity concerned, such certificates must be required or declarations must be permitted;

c) conditions and procedures under which an operator of an unmanned aircraft must rely on the certificates or declarations issued in accordance with airworthiness and environmental standards, and other essential requirements;

d) conditions under which the requirements concerning the design, production, and maintenance of unmanned aircraft and their engines, propellers, parts, non-installed equipment, and equipment to control them remotely shall not need to meet certain other specifications in the Regulation;

e) marking and identification of unmanned aircraft; and f) conditions under which operations of unmanned aircraft must be prohibited, limited, or

subject to certain conditions in the interest of safety. The Regulation outlined here is being discussed in the European Parliament, and it will be presumably promulgated during the year 2018.

3.3.3 European Regulation (updated October 2018)

On 11 September 2018 the European Parliament adopted updated aviation safety rules for Europe including a new mandate for EASA that redefines the Agency’s competences. Regulation (EU) 2018/11394 empowers the Agency to propose to the European Commission the technical expertise to regulate drones of all sizes, including the small ones (below 150kg MTOM). This decision paves the way for a progressive application of the EASA safety rules on a global European scale. EASA implementing rules are still under development and will be based upon the Technical Opinion5, already illustrated in Section 3.3.1.

3.3.4 Unmanned Traffic Management (UTM) and U-Space (updated October 2018)

In recent years, the need for traffic management focused on unmanned aircraft systems (UAS) emerged in many parts of the world. This UAS traffic management system (UTM) would ensure safe operation of a large number of drones at low-altitude (especially in urban areas). As traditional air

4 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32018R1139 5 https://www.easa.europa.eu/document-library/opinions/opinion-012018



traffic management (ATM) ensures the safety of aircraft operations at high altitude, so does UTM at a lower altitude. The Commission mandated the SESAR JU to lead the development of a UTM concept for Europe, called U-Space. A blueprint6 was released in June 2017 with a preliminary vision for the U-space. It consists of a set of services enabling complex drone operations in all types of operational environments. At the moment, U-Space is still under development and its implementation does not have a direct impact on MOMIT. Anyway, the registration to the D-Flight system7 (early stage UTM platform) is mandatory, after the payment of a fee, for every operator wishing to carry out operations in Italy. D-Flight offers useful services like maps and charts with all the useful information about airspace, weather conditions and special prescriptions.

3.4 National Regulations for RPAS below 150 kg As seen, a legislative process aiming at defining a common EU Regulation for all categories of RPAS is under progress and it will take years to be fully accomplished, as it will include all the implementing rules mentioned in the previous section. In the meantime, Member States are recommended to take into considerations the ideas and concepts contained in the Technical Opinion, when developing and amending their own National Regulations. This shall facilitate a smooth transition from national to common rules in the next future. Within and beyond EU, National Aviation Authorities (including European ones) are currently involved in the definition of a harmonised approach to the regulation, with an international perspective. Among the several initiatives currently on-going, JARUS (Joint Authorities for Rulemaking on Unmanned Systems) is worthy of attention in this document.

3.4.1 JARUS: an initiative for harmonizing national regulations of small RPAS

JARUS is a group of experts from the NAAs and regional aviation safety organizations (including EASA and EUROCONTROL). Its purpose is to recommend a single set of technical, safety and operational requirements for the certification and safe integration of UAS into airspace and at aerodromes. The objective of JARUS is to provide guidance material aiming to facilitate each authority to write their own requirements and to avoid duplicate efforts. Participation in JARUS is on voluntary basis and JARUS does not develop law or mandatory standards, while National Aviation Authorities and regional authorities decide how to use harmonised provisions from JARUS. At the moment, more than forty countries are represented in JARUS, including almost the totality of RPAS market worldwide. The group is organized into several working groups, with a competence over the most important topics and areas of interest.

6 https://www.sesarju.eu/sites/default/files/documents/reports/U-space%20Blueprint.pdf 7 https://www.d-flight.it/



Figure 3-5: JARUS working groups (JARUS website)

JARUS website (http://jarus-rpas.org/) hosts a ‘Publications’ section, where all the already published deliverables are available for download and a Schedule for the forthcoming publication is updated. Although the material produced by JARUS is not legal for the operators, so a direct impact on MOMIT operations is not foreseen. Anyway, JARUS may (and probably will) have influence on the future regulations made by EASA and NAAs, so its activities will be monitored by the Consortium during the project (See Section 5). At the time when this document is being written, the following deliverables have been developed, refined and finally published in their stable version by JARUS:



Title Description Date published Certification Spec for LURS

Certification Specification for Light Unmanned Rotorcraft Systems

30/10/2013

RPAS C2 Link RCP Guidance material to explain the concept of C2 link RCP and identify the requirements applicable to the provision of C2 communications. (See UPGRADED C2 Link RLP document JAR-doc-13)

10/10/2014

FCL Recommendations

The document aims at providing recommendations concerning uniform personnel licensing and competencies in the operation of RPAS

09/09/2015

AMC RPAS 1309 (package)

Document developed as an integral part of a type-certification process. It is a means of compliance to a 1309 airworthiness requirement.

01/11/2015

CS-LUAS It provides recommendations for States to use for their own national legislation, concerning Certification Specification for Light Unmanned Aeroplane Systems. (See JARUS Work Plan)

23/12/2016

SORA (Package) The document recommends a risk assessment methodology to establish a sufficient level of confidence that a specific operation can be conducted safely. Along with the document there are two Annexes; Annex A - Guidelines on collecting and presenting system and operation information for a specific UAS operation and, Annex I - Glossary of Terms

28/07/2017

CPDLC The Controller Pilot Data Link Communications document is meant to summarize the most relevant information about CPDLC and the supported ATS services, and to associate them with RPAS operations.

20/06/2016

FCL GM Guidance material to the JARUS FCL Recommendation

11/04/2017

Required C2 Performance (RLP) concept

RCP acronym has been modified to RLP to avoid confusion between current RCP supporting ATM functions and the required C2 Link performance in support of the command and control functions.

30/05/2016

Table 3-3: simplified version of table of publications by JARUS (original: http://jarus-rpas.org/publications)

It is important to recall that JARUS is an informal working group, based on voluntary participation, therefore published guidelines and recommendation are not legally binding until their possible adoption by Civil Aviation Authorities.



3.4.1.1 Specific Operations Risk Assessment (SORA) (updated October 2018)

JARUS is working on a second release of the SORA (Specific Operations Risk Assessment) Package. This second version of the methodology has been open for external consultation until August 2018 and will be officially released on the JARUS website soon. The Specific Operation Risk Assessment (SORA) is a methodology to support the application for an authorization to operate a RPAS within the specific category. It defines acceptable means to evaluate the risks associated with the operation of a RPAS within the specific category and to determine the acceptability of the proposed operation. Local authority may also apply the methodology to define “standard scenarios” (see Section 3.4.2.3). SORA is a guidance that National Aviation Authorities (and EASA) could adapt to their regulatory framework. Although intended mainly to address the specific category, SORA could be used to evaluate the risks involved with the operation of UAS of any class and size, but in general the carriage of people or non-civil equipment (e.g. weapons) on board the RPAS is explicitly excluded, as well as security and privacy aspects are excluded. May also be used to support activities necessary to determine airworthiness requirements and to show compliance with safety objectives in the certified category. The methodology is made up of a “main body” document (describing the risk assessment process as a whole) and a set of complementary Annexes, providing guidance on specific issues. The methodology consists of a step-by-step procedure for the evaluation of Ground Risk (i.e. the risk of a person being struck by the UAS crashing on the ground) and Air Risk (i.e. the risk of collision between a UAS and a manned aircraft). By combining both Ground and Air Risk, it is possible to determine a general risk parameter (SAIL, i.e. Specific Assurance and Integrity Level), representing the level of confidence that the RPAS operation will stay under control. The SAIL is then directly associated to a list of pre-defined barriers (alias safety mitigations) which shall be implemented with a certain level of robustness. These barriers are addressed to mitigate specific risk areas (such as technical issues with the RPAS, human errors, etc..). The higher the SAIL, the higher the robustness level required for each single barrier.

3.4.2 RPAS Regulation in Italy

The main purpose of this document is feeding the demonstration phase of MOMIT project with useful information about the regulatory environment for RPAS operations. MOMIT demonstrations are foreseen in Italy, so this section will go into the details of the Italian regulatory framework. In Italy, the primary aviation legislation is the Italian Civil Aviation Act or Air Navigation Order. All aviation comes under the jurisdiction of the Ente Nazionale per l'Aviazione Civile, the Italian Civil Aviation Authority (ENAC). The First Edition of the Italian “Regulation on Remotely Piloted Aerial Vehicle” (No. 42/2013) was signed by ENAC on 16th December 2013. It was published on the website on 28th February 2014 and came in force the sixtieth day after the publication, on 30th April 2014. The first version was made of 27 Articles, divided into six sections. It explained some general provisions for Remotely Piloted Aircraft Systems, which are divided into two categories:

1. RPAS with MTOM < 25 kg 2. RPAS with MTOM ≥ 25 kg



A second version of the Regulation made of 37 Articles has been issued in July 2015 (with three reviews, last on March 2017), in order to better address and specify some of the aspects covered in the first version, including some new considerations. It is available in Italian and in a courtesy English translation on the ENAC website (www.enac.gov.it), looking at the section “Sistemi aeromobili a pilotaggio remoto” (Remotely Piloted Aircraft Systems). This Regulation, pursuant to art. 743 of the Italian Navigation Code and the Regulation of the European Parliament and of the Council (EC) No 216/2008, states that «RPAS of maximum take-off mass not exceeding 150 kg and those designed or modified for research, experimental or scientific purposes are under ENAC responsibility». This regulation is not applicable to:

• State RPAS (Art. 744, 746 and 748 of the Italian Navigation Code); • Indoor RPAS operations (albeit some safety requirements for indoor flights over crowds are

outlined); • Balloons used for scientific observations or tethered balloons.

According to this Regulation, the RPAS can be used for specialized operations or research and development activities. In any case, the operator is required to have an appropriate statement by ENAC or provide a self-declaration in accordance with the Regulation. In case of special operations carried out for third parties, moreover, an agreement must be signed between the RPAS operator and the client, by which the parties define their respective responsibilities and agree on the suitability of RPAS for the planned operation and any relevant limitation. The operations are divided into VLOS, EVLOS and BVLOS. Hereinafter the focus will be on Section II of the Regulation, covering Remotely Piloted Aircraft with operating take-off mass of less than 25 kg, in line with the expected categories of aircraft operated in MOMIT.

3.4.2.1 General provisions

Article 8 of the Italian Regulation provides the RPAS operators with a set of rules, worthy of being mentioned here to provide the MOMIT consortium with a common understanding of the legal framework of the envisaged operations:

1. The RPAS shall be identified by a plate installed on the RPA showing the identification of the system and of the operator. An identical plate shall be installed also on the remote ground pilot station.

2. As of the 1st of July 2016, in addition to plates required by the Art 8.1, any RPAS shall be equipped with an Electronic Identification Device that allows the transmission of RPA real time data, its owner/operator and basic flight parameters, as well as the recording of these data. Electronic Identification Device performances and characteristics are defined by ENAC.

3. RPAS shall be supplied with a Flight Manual or equivalent manual. 4. Specialized Operations shall comply with the provisions regarding procedures in air

navigation and airspace use. 5. RPAS shall be equipped with systems/equipment necessary to carry out intended operations

in compliance with the applicable rules of the air and according to the airspace class



engagement. They shall be equipped with systems/equipment intended to indicate the RPA height above ground so to enable a positive check during flight.

6. For VLOS operations within un-controlled airspace, ENAC reserves the right to require the installation of lights or other means to augment the RPA visibility by the remote pilot or by other airspace users.

7. RPAS shall be piloted by a pilot with recognized competences and skills. 8. During VLOS operations, pilot shall be clearly visible and immediately identifiable by proper

means. Pursuant to this Regulation, the pilot shall wear a high visibility vest with the sign “RPA pilot”.

9. RPAS in the scope of this section are operated for specialized operations either “non-critical” or “critical”.

10. RPAS operations with purpose “research and development” are subject to ENAC authorization.

3.4.2.2 Critical and non-critical operations

Article 8 introduces a categorization of RPAS operations into critical and non-critical, basing on their associated risk. Such categorization has a considerable impact on prescribed safety requirements and on the process to be setup by the operator when applying to ENAC for a request to operate. Article 11 of the Regulation describes such requirements and the processes for both critical and non-critical operations into details, while for the sake of this document the following specification is sufficient:

• For critical operations, the capability of the RPAS operator to comply with obligations laid down in this Regulation is recognized by ENAC authorization;

• For non-critical operations, the said capability is declared by the operator in a form and manner established by Art 9.

Critical operations have to be authorized in advance by ENAC, so an explicit request of authorization has to be made to the competent office. Therefore, the operations can be performed only after the formal approval by ENAC. In the case of non-critical operations, the provision of a self-made risk assessment and a declaration of responsibility by the operator to ENAC are sufficient. This distinction implies different procedures, quantity and complexity of documentation and in general a significant difference in the effort to be put in place to comply with the Regulation. It impacts also the safety requirements and operational limitations (e.g. redundant on-board equipment or a very limited area of operations may be mandate when performing critical operations). The classification in critical or non-critical category may have a significant impact on the MOMIT operations, in terms of commitment, costs and time (obtaining an authorization from ENAC requires about twice the time of having a declaration accepted). Therefore, in the following the legal definition of the two category is provided (Article 9 and 10 of the Regulation):

• “Non-critical” operations are VLOS operations which do not over fly, even in case of malfunctions and/or failures:

o Congested area, gathering of persons, urban areas; o Critical infrastructures.

• Critical operations are operations that do not respect, even partially, such conditions.



A special provision on RPAS lighter than 2 kg have been adopted (Article 12) as follows: operations with RPAS whose maximum take-off mass is less than or equal to 2 kg are always considered non-critical, provided that the RPAS’ design characteristics are of an inoffensive nature, as assessed by ENAC. To overfly gathering on persons during parades, sports events or different forms of entertainment or anyhow areas where there is an unusual concentration of people, is still prohibited. In addition to that specialized operations with RPA with operating take-off mass of less than or equal to 0.3 kg with rotating parts safeguarded against impacts and having maximum speed less than or equal to 60 km/h are to be considered non-critical for any operative scenario.

In the guidance material published by ENAC (not directly in the Regulation) a third situation beyond critical and non-critical has been defined in May 2017, under the name of standard scenarios for critical operations.

3.4.2.3 Standard scenarios

The so-called “standard scenarios” have been defined by ENAC for RPAS below 25 kg of mass. The definition of such scenarios has a twofold rationale: one hand it helps to simplify and standardize the process of authorization for the most common critical operations, and on the other it contributes to move the Italian regulation closer to the European rulemaking process currently under development (see Section 3.3.). Getting an authorization for critical operations may be an onerous process for an operator to carry out (and for the authority to assess), as a target level of safety has to be guaranteed and it may be complicate to understand whether certain mitigation barriers actively contribute to reach such level. The standard scenarios identify accurate technical specification and operational limitations for some specific situations, so leading to a substantial simplification in the process of authorization for critical RPAS operation. Anyway, it is important to notice that operating in a standard scenario do not relieve the operator from any of the legal obligations defined in the Regulation. The following scenarios have been defined and published by ENAC in May 2017:

• S01 – RPAS with a maximum take-off mass (MTOM) below or equal to 2 kg, with an inoffensive nature (art. 12), operated in an urban are;

• S02 – RPAS with a MTOM in between 2 and 4 kg, operated in an urban area; • S03 - RPAS with a MTOM in between 4 and 10 kg, operated in an urban area; • S04 – RPAS with a MTOM below or equal to 4 kg, without an inoffensive nature (art. 12),

operated in extra-urban areas and over construction sites or linear infrastructures, e.g. highways, power lines, railways, gas pipelines;

• S05 – RPAS with a MTOM in between 4 and 25 kg, without an inoffensive nature (art. 12), operated in extra-urban areas and over construction sites or linear infrastructures, e.g. highways, power lines, railways, gas pipelines;

• S06 – RPAS with a MTOM below or equal to 4 kg, without an inoffensive nature (art. 12), operated in extra-urban areas for filming;

• S07 – RPAS with a MTOM in between 4 and 25 kg, without an inoffensive nature (art. 12), operated in extra-urban areas for filming.



Going into the details of the operational and technical limitations associated to each scenario is out of the scope of this document, anyway the scenarios most relevant for MOMIT are analysed and detailed in Section 4. In May 2018 the Italian Civil Aviation Authority (ENAC) published a new issue of the RPAS regulation, that is actually a step forward towards the adoption of the European Regulation. The main innovation brought by this new issue is contained in Article 10: “Before commencing critical operations the operator shall apply for and obtain the authorization by ENAC unless the critical specialized operation does not fall into standard scenarios published by ENAC. In the latter case shall submit the declaration as required by article 9.” A declaration (see 3.4.2.2) is therefore sufficient for operations conducted in standard scenarios. The new provision has a positive impact on the operations foreseen by MOMIT, as it gives the opportunity to take advantage of the simplified regime of declaration to both Demonstrator #4 and #5, which are both conducted in standard scenarios (see Errore. L'origine riferimento non è stata trovata. and 4.2.2).

3.4.2.4 Access to the airspace

Provisions about access to the airspace are mainly collected in Article 24 of the Regulation as follows: VLOS operations are permitted in daylight, up to maximum height of 150 m AGL, within maximum horizontal distance of 500 m, and shall be carried out safely, without causing damages to third parties. Higher distances and heights may be evaluated and authorized by ENAC as appropriate, following submission of an appropriate risk assessment by the RPAS operator. In case of loss of visual contact with the RPA, either horizontally or vertically, the pilot shall terminate the flight as soon as possible RPAS operations shall not be conducted:

a) Within ATZ and beneath take-off and landing paths or at a distance less than 5 km from the airport (ARP or published geographical coordinates) where ATZ is not established;

b) Within CTR (see below); c) Within active restricted areas and prohibited areas.

Operations within CTR are permitted only to RPA with operating take-off mass less than 25 kg, up to maximum height of 70 m AGL and within maximum horizontal distance of 200 m. Beneath take-off and landing paths, beyond ATZ boundaries and up to 15 km from the airport, maximum height shall be 30 m AGL. The special provision about CTRs is important because the Italian territory is crowded of minor airports, therefore a complete interdiction of flights within CTRs might results in significant limitations to RPAS operations. An assessment on the MOMIT operations based on the processes and provisions described in this Section is provided in Section 4 of this document.

3.5 Industrial Standards for Small RPAS The analysis of the regulatory framework for light RPAS (<25 kg) highlighted the current lack of technical standards already adopted by the competent authorities for civil aviation. This has a negative impact on the market, since investors and industrial players are discouraged by a fragmentary



business, where products that are suitable for one market do not comply with the requirements needed by others, and where technological interoperability is not assured. Certification bodies and aviation authorities are putting a joint effort on the topic, in order to fill the gap in the next future. In the following section an overview of such activities is provided.

3.5.1 EUROCAE, RTCA and other Standardization bodies

EUROCAE is the only European organisation exclusively dedicated to the development of technical standards in support of the aviation community and is recognised by:

• The European Commission as the competent body to collaborate with the European Standardisation Organisations (ESOs) in the preparation of European Standards8.

• The European Aviation Safety Agency (EASA) as a major European stakeholder in the development of Technical documents concerning Aviation safety (i.e. ETSO “European Technical Standard Order”).

Within EUROCAE one specific working groups is involved in developing standard for RPAS, namely Working Group 105, that supersedes the former Working groups 73 (Medium and Large RPAS) and 93 (Small RPAS). The work of WG-105 is organised in six Focus Teams working in a specific area. The current Focus Areas are:

• UAS Traffic Management (UTM) • Command, Control, Communication (C3)9 • Detect and Avoid (DAA) • Design and Airworthiness Standards • Specific Operations Risk Assessment (SORA) • Enhanced RPAS Automation (ERA)

One of the main tasks of the group is to liaise with other standardization bodies working to the same topic or to related technologies, aiming at assuring a global interoperability of the proposed solutions. The following tables resumes the activities conducted by various working groups at a global level.

8 Article 4.1 of the Interoperability Regulation (EC) 552/2004. 9 Note that the term C3 link is used here to include communication (with Air Traffic Control or other airspace users).



Organization/Scope Working Group(s) Competences ISO (International Standards Organization)/Global

Technical Committee (TC) 20 (Aircraft and space vehicles) – Special Committee (SC) 16

Requirements, terms and definitions, classification, materials and components, radio frequencies.

RTCA (Radio Technical Commission for Aeronautics)/United States

SC-228 Minimum Operational Performance Standards for Unmanned Aircraft Systems

ASTM (American Society for Testing and Materials)/United States, Global

F38 – Unmanned Aircraft Systems

Airworthiness, Flight Operations, Personnel Training, Qualification and Certification

Table 3-4: Standardization bodies for RPAS

Going into details of all the standards proposed by such organizations is out of the scope of this document, also because no one of them has still been adopted by National and International civil aviation authorities. Anyway, the consideration in this section, together with the technical provisions given by International and National regulations, contribute to the definition of the current state-of-the art of standards for RPAS below 150 kg of mass. Section 4 of this document outlines the potential impact of the evolution of the state-of-the art on the MOMIT project.



4 RPAS Operations in MOMIT

4.1 Definition of MOMIT RPAS operational scenarios The purpose of MOMIT is supporting the maintenance process of railway infrastructures with a solution based on RPAS and satellite technology. This section outlines the main operational scenarios where MOMIT solution will be demonstrated, aiming at defining the regulatory framework applicable to the foreseen RPAS operations. The MOMIT demonstration will be carried out in Italy, so the main reference in analyzing the associated legal and regulatory aspects is the Italian regulation. The following tables recall the MOMIT demonstrators where RPAS are actively involved, namely demonstrator #4 and #5:

DEMONSTRATOR #4 Electrical system monitoring

User RFI

Monitoring challenge Inspecting all components of the railway electrification system with traditional techniques is a costly and dangerous activity. The challenge is to enable RPAS-based accurate, rapid and cost-effective inspections, eliminating risks to personnel.

Demonstrator description

A multicopter RPAS equipped with suitable visible light, UV and IR cameras will be able to take short-distance footage of all elements of the electrical infrastructure, with special focus on detecting hot spots and corona effects.

Demonstrator parameter

AOI Type: electrical infrastructure (conductors, steel towers, insulators, etc.) Size: 1km long test line

Data Source EO Data: HD video with UV/IR overlay for hot spots and corona detection

Monitoring specification Frequency depending on data source type

Output Georeferenced data with detected hot spots and corona overlay

Expected benefits, improvements

a) COST REDUCTION, as no personnel walking along the line or on helicopters b) ELIMINATING RISKS TO PERSONNEL No need for personnel to stay close to power line



DEMONSTRATOR #5

Civil engineering structures monitoring User RFI

Monitoring challenge

Inspecting structural damage to civil engineering structures such as bridges with traditional techniques is a resource-intensive task involving service disruption and some risk to personnel. The same goes for indoor inspections to galleries, maintenance buildings, etc. The challenges are:

• to develop a highly efficient RPAS infrastructure inspection system and protocol, reducing costs and risks to personnel

• integration of data from different sources, importing into a common model of the infrastructure the different measurements and evaluate the structural status.

Demonstrator description

A multicopter RPAS, equipped with state-of-the art anti-collision and indoor autonomous navigation systems, and a HD video camera capable of filming from a short distance all critical parts of the bridge, gallery, building PSP-IFSAR technique applied to satellite HR SAR data will allow measuring eventual differential deformation occurring on the monitored infrastructure, collecting several measurements over the same infrastructure and precisely relocating the measurement points in the 3D space. Some critical infrastructures will be modelled using finite elements methods (FEM) importing the PSI measurements as input, in order to evaluate the structural state.

Demonstrator parameter

AOI Type: Bridge, gallery, maintenance building Size: tens or hundreds of meters long

Data Source High-definition video Satellite HR SAR

Monitoring specification

Frequency depending on data source type

EO data sources Multicopter drone equipped with HD video camera Satellite

Output

a) HD, georeferenced video footage and 3D model of the infrastructure.

b) PSP-IFSAR analysis

I. Delivery of Ground deformation analysis (PSP-IFSAR product), including:

• PS positions

• PS mean velocities

• PS temporal evolutions

II. Technical report

Expected benefits, improvements

a) SAFETY No personnel working at height or in unsafe areas. b) COST SAVINGS c) IMPROVED ACCESS some areas of the infrastructure cannot be thoroughly

inspected with standard techniques due to the difficulty of safe access.



4.2 Regulatory and legal assessment of the operational scenarios Demonstrators #4 and #5 of MOMIT are the ones where RPAS operations are foreseen. The area where the operations will be carried out corresponds to the railway in between the villages of Cerchio and Collarmele, in Central Italy, in the province of L’Aquila (42°03'51"N 13°36'51"E). The RPAS used for the operations will be a DJI Inspire 600, or equivalent. It means that the platform used for the demonstrator will have a MTOM<4kg.

Figure 6: the area of operations for Demonstrators #4 and #5 (taken from https://app.d-flight.it)

The regulatory assessment of the proposed VLOS operations may start from the analysis of the surrounding airspace (see 3.4.2.4): the selected area is outside of controlled areas, well below a couple of temporary restricted areas (starting at FL240). The only concern regards a Prohibited Area North-East of Collarmele (windmills area) starting from ground up to 1500 ft. Although this specific zone is out of the foreseen ground for operations, its presence in the vicinity of the area of interest is a useful information to increase the situational awareness of the operator and avoid any airspace infringement.



Figure 7: Prohibited Area close to the field of operations (taken from https://app.d-flight.it)

4.2.1 Scenario 1: Demonstrator #4

As regarding the situation on the ground and the associated risks for the operations in Demonstrator #4, there are two distinct cases to consider.

4.2.1.1 Operations outside of urban areas

Looking at the chart in Figure 6 it emerges clearly that a large part of the considered railway is outside of urban areas. It means that Standard Scenario S04 can be applied here with no restrictions. It means that a declaration to ENAC for operations in standard scenarios will be sufficient. Standard Scenario S04: RPAS with a MTOM below or equal to 4 kg, without an inoffensive nature (art. 12), operated in extra-urban areas and over construction sites or linear infrastructures, e.g. highways, power lines, railways, gas pipelines

Technical prescriptions: RPAS on-board lights: front-right green light, front-left red light, rear white light (in the case of night VLOS) Operational limitations Flight conditions: VLOS Maximum Altitude: 150 m in daylight VLOS / 50m in night VLOS Maximum distance from the pilot: 500 m from the pilot in daylight VLOS / 100m in night VLOS Maximum speed: 5 m/s Maximum wind speed: 5 m/s



Minimum buffer size: 30 m (from other buildings/infrastructures) Minimum buffer size when “geofencing10” function available: 15 m Minimum buffer size for tethered operations: 5 m Conditions Operations should be conducted:

• In accordance with the operations manual defined by the operator and the flight manual provided by the manufacturer

• By a pilot with adequate qualification • In accordance with the flight rules and access to the airspace

The operator is responsible to check whether flight limitations are in place in the area of the operations.

Figure 8: Satellite image of the area of operations (tunnel highlighted in yellow)

Another important consideration is about the vicinity of part of the railway to the A25 Highway (bottom of Figure 7). As measured in Figure 9, the minimum distance between the two is around 50 meters, that is larger than the buffer provided by ENAC in Standard Scenario S04 (that is 15 or 30 meters respectively with and without geo-fencing protection in place). Anyway, as a general remark, it will be very important to consider this condition when planning and executing the Demonstrator #4.

10 A functionality (e.g. on-board software) able to define a fixed area for the operations, preventing the RPA from infringing a predefined volume



Figure 9: distance of the highway to the area of operations at their closest point

4.2.1.2 Operations in urban areas

Here we consider the possibility to perform MOMIT operations (partly or entirely) in an urban area, that means flying over (or in the immediate vicinity of) the built-up area of either Cerchio or Collarmele. In this case, ENAC standard scenario S02 will apply. Standard Scenario S02: RPAS with a MTOM between 2 and 4 kg, operated in urban areas where no people other than the ones involved in the operations are overflown

Technical prescriptions: RPAS on-board lights: front-right green light, front-left red light, rear white light (in the case of night VLOS) Flight termination system Command and Control system equipped with a recovery function for link loss Operational limitations Flight conditions: VLOS Maximum Altitude: 50 m Maximum distance from the pilot: 100 m Maximum wind speed: 3 m/s Minimum buffer size: 50 m (from buildings, infrastructures and people) Minimum buffer size when “geofencing11” function available: 25 m Minimum buffer size for tethered operations: 5 m Recovery function for data link loss: active

11 A functionality (e.g. on-board software) able to define a fixed area for the operations, preventing the RPA from infringing a predefined volume



Conditions Operations should be conducted:

• In accordance with the operations manual defined by the operator and the flight manual provided by the manufacturer

• By a pilot with adequate qualification • In accordance with the flight rules and access to the airspace

The operator is responsible to check whether flight limitations are in place in the area of the operations.

Some specific operational and technological requirements, here highlighted in yellow, must be met, checked and tested before commencing any operation. When all the conditions are met, the operation can be considered compliant to standard scenario S02, therefore subject to the regime of declaration to ENAC.

4.2.2 Scenario 2: Demonstrator #5

The demonstrator #5 is quite similar to demonstrator #4 from a regulatory point of view. Anyway, it is worth to make some considerations specific to this operational scenario, based also on a distinction between outdoor and indoor operations.

4.2.2.1 Outdoor operations (bridges)

The case of inspecting electric railway bridges with an RPAS is identical to the demonstrator #4, as the bridge itself may be considered a critical infrastructure. Therefore, in general, all the considerations made for that case still apply here. Anyway, an additional consideration may be done by assuming that the operation is conducted:

• under the bridge or over a non-electric railway bridge, • in a non-urban area, • with no possibility to overfly other critical infrastructures, even in case of malfunctions and/or

failures, • with no vehicular/train traffic over/under the bridge.

In the aforementioned case, the operation may be considered non-critical (by Article 9 of the Italian Regulation), as no critical infrastructure is being overflown. Falling under the category of non-critical operations instead of standard scenarios for critical operations do not have a substantial impact on the declaration/authorization process, as most of the documents to be produced and requirements to be met for the two cases are quite similar, and most of the technical conditions to be met are already “standard” equipment for professional RPAS (e.g. command and control link recovery, geofencing). A difference may be found in the requirements for the pilot, as the qualification for critical (even in standard scenarios) and non-critical operations are different, with different training and proficiency requirements (Art. 21).

4.2.2.2 Indoor operations (tunnels)

As already recalled by section 3.4.2, RPAS operating inside indoor space, unless what arranged in art. 10, point 7 the Regulation, are not covered by ENAC. Art. 10, point 7 states that: “to overfly



gathering on persons during parades, sports events or different forms of entertainment or anyhow areas where there is an unusual concentration of people, is prohibited”. MOMIT do not foresee any operation over crowds, so there are no regulatory bindings for the indoor operations. Nevertheless, the development of a risk assessment and its observance during such operations are strongly recommended. The reference materials to perform such risk assessment is the same as for the outdoor case.

4.2.3 General provisions

There are some general provisions that apply to all the identified operational scenarios (and to all the RPAS operations). In the following the ones relevant to MOMIT demonstrators are highlighted:

4.2.3.1 E-VLOS

The operations in MOMIT are assumed to be conducted exclusively in VLOS (see section 3.1.2.1). In the case of operations where the pilot is supported by one or more observers in the duty of avoiding collisions with obstacles and other airspace users, E-VLOS operations may be envisaged (see section 3.1.2.2). Art. 25 of the Italian Regulation on RPAS provides that “EVLOS operations shall be authorized by ENAC”, meaning that flying E-VLOS is not permitted in neither standard scenarios, nor noncritical operations. The possible involvement of observers directly involved in the collision avoidance has to be carefully evaluated and pondered, as it may lead to an impact on authorization processes.

4.2.3.2 Insurance

Currently, in Italy (and in the EU), no RPAS shall be operated unless it has in place a third-party insurance, adequate for the operations and not less than the minimum insurance coverage of the table in Art. 7 of Regulation (CE) 785/2004 is in place for the operations. For aircraft below 500 kg of mass, the European Regulation provides for a minimum coverage of 750,000 SDR (special drawing rights, a standard currency used in international agreements), that is around 900,000€ the day this document is being written.

4.2.3.3 Privacy and Data protection

Art. 34 of the Italian RPAS Regulation refers to privacy and data protection, with the following provisions: “1. When operations carried out by a RPAS could lead to necessity of the treatment of personal data, this fact shall be referred to in the documentation submitted for the application of the authorization. 2. Personal data shall be processed pursuant to Decree 30 June 2013 No 196, as amended (Italian Data Protection Code), with regard to the use of modalities that allow the identification of a person only upon necessity, pursuant to Art. 3 of the referred Code, as well as in accordance with the measures and precautions to protect people concerned as prescribed by the Authority in charge of the protection of personal data.” Other provisions to be considered about collection, storage and use of personal data protection are included in the EU Regulation 679/2016 “Protection of natural persons with regard to the processing of personal data and on the free movement of such data”.



5 Conclusion and Recommendations

5.1 Guidelines and recommendations for RPAS operations in MOMIT One of the main objectives of this document is to provide the MOMIT consortium with some guidelines and recommendations about the regulatory and standardization aspects. They are intended to feed the design, development and deployment of the solutions, as expected in Work Packages 2, 3 and 4. Some recommendations are also provided to the management and communication activities, respectively addressed by Work Packages 6 and 5. The following recommendations and guidelines have been identified during the execution of task WP1.3, that led to the preparation of the present document:

• Use the definitions in Section 3 of this document as a common glossary for the next phases of the project

• Plan RPAS operations in coordination with railway and vehicular traffic in order to minimize the risk of collision with trains or other vehicles

• Consider the regulatory aspects and their evolution during all the design, implementation and deployment phases of MOMIT

• Initiate all the authorization processes in due time (at least two or three months prior to the foreseen operation)

• Allocate adequate resources for the authorization process (around one person/month) • Albeit the analysis of the MOMIT demonstrators in this document (section 4.2) has been

based on the Italian Regulation, most of the considerations remain valid for other EU member States as European CAAs are moving towards a uniform approach to Regulation of drones below 150 kg (see section 3.3 and 3.4.1). Nevertheless, in the case of operations conducted outside Italy, a detailed gap analysis of legal and regulatory requirements should be conducted, as authorization processes may substantially vary from State to State.

• Carry out and keep update a safety risk assessment of all the proposed operations. The preparation of a suitable and convincing risk assessment is a fundamental safety enabler and it is mandatory when applying to the competent authorities for an authorization to operate or a permit to fly. This assessment should be conducted in accordance with the ICAO Doc 9859 Safety management Manual (Chapter 5). Some of the National Civil Aviation Authorities have issued their own guidelines for safety risk assessment, granting in any case the alignment with Doc 9859.

• Establish and consolidate a process and adequate documentation to support the preparation of declarations and/or requests for an authorization from the Competent Authority (i.e. ENAC, Italian CAA).

• When communicating and disseminating project activities and results, some emphasis should be put on regulatory aspects and on the compliance of the proposed solutions to the current regulations/standards. It will increase project’s visibility (as many European initiatives are currently focusing on such topic) and will provide convincing evidences of the robustness of the proposed solutions. Nevertheless, it will demonstrate a certain attention to the aspects of safety, legality and responsibility, with a positive impact on the public perception of the project.



• Consider the information provided by this document when analysing project risks and opportunities, and when defining mitigation actions to tackle the risks and strategies to get the identified opportunities.

• Keep this document alive and establish a process to continuously monitor the evolving standardization and regulation framework, following the guidelines provided in the next section.

5.2 Monitoring the evolving regulatory and standardization framework Sections 3 of this document provided with a general overview of the on-going regulatory and standardization processes and initiatives related to RPAS. Section 4 provides with a demonstration of how these aspects may have an impact on MOMIT, in terms of operational feasibility and requirements. As widely discussed in this document, both the regulatory and standardization framework are currently at an evolutionary stage of their development, where sudden and remarkable changes may occur in a relatively short time-frame, with a short advice and with a substantial impact on the rules of the game. The integration of RPAS within the civil aviation socio-technical system is made of complex mutual interaction with the other components of such system, therefore changes and new provisions in fields other than RPAS, may anyway have an impact (e.g. new provisions on security of satellite communications, new ATM rules and procedures, electromagnetic bands allocation, etc.). This section describes the strategy put in place by MOMIT to tackle the challenges and take the opportunities posed to the project by the evolution and modification of the regulatory and standardization environment.

5.2.1 Monitoring plan

The MOMIT consortium has defined a process to deal with the evolution of regulatory and standardization framework. First of all, a preliminary list of institutions, working groups and initiative worthy of being monitored has been defined. The list is not meant to be fully exhaustive and fixed for the whole project duration, rather it is an alive document to be amended, refined and integrated by the consortium to keep it in-line with the current situation.



Institution/Group/Initiative Activity - Expected date Relevance for the project ICAO Completion of ICAO SARPs on

RPAS – 2019? Very relevant

ICAO Publication of other material (e.g. 2nd version of the RPAS Manual) – Non-predictable

Relevant

NAAs Amendment of national rules in the countries of interest – Non-predictable

Very relevant

ITU Provision of standards about C2L frequencies – Non-predictable

Relevant

JARUS Publication of new deliverables- Non-predictable

Relevant

EU, EASA Extension of EASA mandate to RPAS<150 kg – 2018?

Very Relevant (if accomplished before end of the project)

EUROCAE Deliverables of WG-105 Relevant RTCA, ISO, ASTM New Standards – Non-predictable Maybe relevant

The process is made of three main activities:

1. To monitor all the items in the list, mainly by means of: • official websites and social network accounts of the reference organizations; • specialized newsgroups and newsletters.

2. To assess and evaluate the impact of new (or amended) provisions, rules or standards on MOMIT operations, using the same approach proposed in Section 3;

3. To propose new (or amended) guidelines and recommendation to the project, as described in Section 4 e 5.



Figure 5-1: Process of monitoring of regulatory and standards changes

5.2.2 Monitoring execution

A first iteration of the here proposed methodology was concluded at month twelve of the MOMIT project. For the sake of clarity and coherence of this document, the new considerations and inputs emerged in the process have been integrated within the text of the respective sections. Here is a list of the new contents contained in this version of the document:

• Section 3.3.3 and 3.3.4 added; • Section 3.4.1.1 added; • Section 3.4.2.3 updated (last paragraph added); • Section 4.2 updated (geographic considerations about the RPAS model and the area of the

operations were not available at the time of the first version); • Sections 4.2.1 and 4.2.3 updated according to the new provisions emerged in 3.4.2.3.



Parent Documents

The parent documents establish the criteria and technical basis for the existence of this document. [PD1] Shift2Rail Joint Undertaking (S2R JU) – Multi-Annual Action Plan (MAAP) – Rev. 3 –

26/11/2015 [PD2] Shift2Rail Joint Undertaking (S2R JU) – Annual Work Plan 2017 – Version 1.1–

23/12/2016 [PD3] MOMIT – Description of Action (DoA) –GA 777630



Applicable Documents

Applicable documents are those documents whose content are considered to form a part of this document. The specified parts of the applicable documents carry the same weight as if they were stated within the body of this document. n.a.



Reference Documents

Reference documents are those documents that, although not a part of this document, serve to amplify or clarify its contents, or dictate work policy or procedures. [RD1] ICAO Doc 10019 – Manual on Remotely Piloted Aircraft Systems [RD2] ICAO Circular 328 on UAS [RD3] ICAO Doc 7300 – Chicago Convention [RD4] EASA Concept of Operations for Drones.

https://www.easa.europa.eu/system/files/dfu/204696_EASA_concept_drone_brochure_web.pdf

[RD5] EASA Introduction of a regulatory framework for the operation of unmanned aircraft. https://www.easa.europa.eu/document-library/opinions/opinion-technical-nature

[RD6] European Commission, Proposal for a Regulation of the European Parliament and of the Council on Common Rules in the Field of Civil Aviation and Establishing a European Union Aviation Safety Agency, and Repealing Regulation (EC) No. 216/2008 of the European Parliament and of the Council (Commission Proposal), COM (2015) 613 final (Dec. 17, 2015), http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A52015PC0613, archived at https://perma.cc/8YBW-VFNJ

[RD7] Regulation (EC) No. 765/2008 of the European Parliament and Council of 9 July 2008 Setting Out the Requirement for Accreditation and Market Surveillance Relating to the Marketing of Products and Repealing Regulation (EEC) No. 339/93, 2008 O.J. (L 218) 30, archived at https://perma.cc/4RYJ-FLSA

[RD8] Decision No. 768/2008/EC of the European Parliament and of the Council of 9 July 2008 on a Common Framework for the Marketing of Products, and Repealing Council Decision 93/465/EEC, 2008, O.J. (L 218) 82, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32008D0768, archived at https://perma.cc/PH37-UGVR.



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