NAARIC Urges EASA to Review its Position

The NAARIC (National Aviation Authorities Regulation Implementation Coordination) is a group of UAS experts from the main European National Aviation Authorities (NAAs) that was launched in 2019 with the objective of agreeing on a common approach at the European level towards the aspects left to the Member States by the Commission Implementing Regulation (EU) 2019/947 and Commission Delegated Regulation (EU) 2019/945, including their recent amendments regarding standard scenarios.

As of May 2020, the NAARIC group is constituted by NAA representatives from the Austria, Belgium, Denmark, Finland, France, Germany, Italy, Latvia, Luxembourg, The Netherlands, Norway, Poland, Romania, Spain, Sweden, Switzerland, and UK.

On 27 May 2020, NAARIC issued its position document with critical comments on EASA’s NPA 2020-07 on “Unmanned aircraft system beyond visual line operations over populated areas or assemblies of people in the ´specific´ category’’, which included:

  • A significant number of proposed amendments
  • An emphasis of the relevant contribution made to the development, validation, and recognition of the JARUS SORA methodology
  • Its view on social and economic impact assessment of the implementation of the NPA.

 The NAARIC position paper indicated:

“The NAARIC group does not believe that the triggering safety-related issue for this NPA 2020-07 (i.e. the incident involving a small UAS produced by Matternet that took place while overflying a forest in Zurich, Switzerland a year ago) is directly or indirectly linked to the fact that such UAS operation was performed in BVLOS and much less to operating over a populated area or over an assembly of people as this was not the case.

“In fact, operational experience has shown that certain UAS operations are much safer when performed in BVLOS following a pre-programmed trajectory than those flights conducted manually in VLOS. In addition to this, the NAARIC group would like to remark, on the one hand, that, in accordance with ICAO Annex 13 on Aircraft accident and incident investigation and with Article 17 of Regulation (EU) No 996/2010 of the European Parliament and of the Council on the investigation and prevention of accidents and incidents in civil aviation, all safety recommendations from the independent National Transportation Safety Board (NTSB) were implemented, and, on the other hand, that none of the drawn safety recommendations or conclusions questioned the suitability of the SORA methodology or its application. Besides the NTSB’s investigation, EASA also sent an expert investigation team to Switzerland, which reached the same conclusions and did not express either any concerns about the SORA methodology. For these reasons, the NAARIC group sees no evidence for which Europe through EASA should deviate from an internationally agreed standard like JARUS SORA and even less as a result of a single safety incident.

The NAARIC group would like to ask EASA to avoid giving out the impression to the aviation community in general and to the UAS sector in particular that, as a result of the notification and safety investigation of an incident involving a small UAS, a radical set of complex and challenging requirements for UAS operators and manufacturers is subsequently laid down by EASA. In fact, having EASA constantly reported a lack of data in this sense and, thus, of safety lessons, the NAARIC group strongly believes that implementing the amendment proposed by this NPA 2020-07 would not but worsen this situation. For this reason, the NAARIC group would like to discourage EASA from overreacting and from undoing what has been achieved.”

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