This article discusses what sometimes appear to be unique approaches to training and licensing civilian pilots of small remotely piloted aircraft systems (RPAS). By count of aircraft and flights, this is the largest segment of these aircraft within the broader scope of unmanned aircraft systems (UAS).
Training approaches and licence requirements reviewed for this overview, with exceptions, appear less distinctive after a closer look. The overview cites policies and concepts adopted by the International Civil Aviation Organisation (ICAO), the consensus of national aviation authorities in Europe, and insights from their competent-authority counterparts in Australia, Canada and the United States. Questions that sometimes arise about the apparent licence diversity are:
- Is the pilot training rigorous enough to mitigate risks (i.e., equivalent to passing a traditional ground-school exam to fly manned aircraft)?
- Does the pilot training include hands-on flight training on aircraft or simulators and require demonstration of remote pilot competencies to an examiner?
- What level of competency is demonstrated when 90 percent of the remote pilot candidates pass a 60-question knowledge exam after an online presentation covering the rules, where not to fly, etc.?
This article also cites rationales behind the apparent diversity. For example:
- The remote pilot license is considered a starting point designed for the widest range of applicants. Advanced knowledge, skills and attitudes come later in the form of add-on ratings, endorsements and waivers of specific flight limitations;
- The remote pilot licence alone was never intended to be equivalent to the private pilot–commercial pilot–airline transport pilot ladder of manned aviation; and,
- Authorisations for a remote pilot or a remote pilot-in-command to conduct advanced and complex missions require the authorities’ further assessment of the aircraft operator, other crewmembers (such as observers) and similar risk-management factors beyond one remote pilot.
The following definitions come from ICAO’s 2017 concept of operations for future international RPAS flights under instrument flight rules (IFR), as discussed later in this article, and ICAO Doc 9379, Manual of Procedures for Establishment and Management of a State’s Personnel Licensing System (Second Edition, 2012):
- Remotely piloted aircraft — An unmanned aircraft piloted from a remote pilot station. (ICAO sees RPAS as a subset of UAS; UAS includes RPAS, autonomous aircraft and model aircraft);
- Remote pilot station — The component of the RPAS containing the equipment used to pilot the RPA;
- Remote pilot — A person charged by the operator with duties essential to the operation of an RPA and who manipulates the flight controls, as appropriate, during flight time;
- Remote pilot licence — A certificate accepted as tangible evidence that the holders responsible for safety of flight are knowledgeable, trained, experienced and otherwise qualified in their respective duties. “A licence is the means by which a State authorizes a licence holder to perform specific activities which, unless performed properly, could jeopardize the safety of aviation. The licence provides evidence that the issuing State is satisfied that the holder has demonstrated an internationally acceptable degree of competency.”;
- RPAS operator certificate — A certificate from a national aviation authority authorizing an operator to carry out specified RPAS operations;
ICAO’s Expectations of Remote Pilot Training
In October 2017, ICAO published a concept of operations (CONOPS) that focuses on certificated civilian RPAS operating internationally within controlled airspace, under instrument flight rules (IFR), in non-segregated airspace and at aerodromes. Such flight operations could begin in 2031, the authors predicted.
Remote pilot licences are tangible evidence that RPAS personnel responsible for safety of flight are knowledgeable, trained, experienced and otherwise qualified in their respective duties. Coincidentally, the first step toward achieving the CONOPS’ 2031 scenario — consensus on ICAO standards and recommendations for the remote pilot licence — was formalized in March 2019.
The CONOPS proposes that “All remote pilots conducting international IFR operations must possess a remote pilot licence. … The training requirements and degree of competency required depends upon the complexity of the RPA being flown and the purpose of flight. … All remote pilots should possess knowledge of aviation rules, regulations and procedures. However, remote pilot certification qualifications may differ based on the RPA type, size or operational environment.”
The CONOPS also takes for granted that every national aviation authority will issue only one remote pilot licence, which subsequently can be annotated with specific ratings, limitations and endorsements.
(Note: Types of UAS/RPAS operations not mentioned — such as fully autonomous aircraft and operations; flights limited to visual line-of-sight (VLOS); very low–altitude airspace operations and very high–altitude operations (i.e., above Flight Level 600); transportation of passengers without pilots aboard; and domestic operations — were intentionally excluded by the authors of the CONOPS.)
In March 2015 and September 2018, several presenters described work on remote pilot licensing and competencies during ICAO Remotely Piloted Aircraft Systems Symposiums. Among insights relevant to this article are:
- Henri Rodenburg, flight crew licensing regulations officer at EASA, emphasised that the remote pilot is a new category of aviation professional, for which the competent national authority’s single remote pilot licence suffices for all operational scenarios. The purpose of a practical-skills (RPA flight) test is to ascertain that the remote pilot candidate is capable of performing the procedures and manoeuvres necessary for advanced operations, as the remote pilot-in-command of the appropriate RPA category and associated remote pilot station;
- Patrice Desvallees, programme director, strategic and emerging projects, Civil Aviation Safety Directorate, DGAC-DSAC, France, said that the high-level priority for RPAS training and licensing is first to implementing by 2024 all phases of ICAO’s new RPAS regulatory framework, procedures, and new competency-based training (CBT) and licensing;
- Nicole Barrette, technical specialist, training and licensing standards, ICAO, explained RPAS human factors experts’ strong preference for competency-based training — as opposed to traditional qualification-based training. Barrette said, “CBT and the performance-based regulatory approach to licensing is better adapted to the range and rapid evolution of RPAS operations. … A balance should be sought between simple requirements for low-risk operations and more stringent requirements for heavier UA used for complex operations. … BVLOS [beyond visual line of sight] operations pose higher risk than VLOS and require greater skills.”
- Denis Jauvin, representing the ICAO Air Navigation Bureau’s RPAS Program, said that recent approval of ICAO’s RPAS-revised Annex 1, Personnel Licensing, is the first action completed with these philosophies. In the context of international IFR flights, “The basic framework of the RPAS remote pilot license in Annex 1 is the commercial pilot licence (CPL), but with a Class 3 medical certificate [and] competency-based training,” he said. ICAO is now working to provide updated guidance revising the RPAS Manual (Doc 10019), completing the draft Manual on Competency-Based Training for Remote Pilot Licence, and conducting relevant workshops throughout 2019.
New European rules covering operations of sUAS — signed 24 May 2019, and published on 11 June — have set the stage for major changes to remote pilot training and licensing, according to the European Aviation Safety Agency (EASA). Commission Delegated Regulation (EU) 2019/945 and Commission Implementing Regulation (EU) 2019/947 will replace existing national rules in the European Union’s Member States.
“The new rules cover each operation type, from those not requiring prior [flight] authorisation to those involving certified aircraft and operators, as well as minimum remote pilot training requirements,” EASA said. A timeline of future dates for implementing all provisions begins in June 2020.
European Commission background addresses how training and licensing of remote pilots will apply based whether flights either of two operational risk categories (called the specific category and the certified category). A third category, called the open category, is irrelevant to this discussion because it does not require holding a remote pilot licence because of low risk level.
Specific category — In the specific category, operators should conduct a thorough risk assessment to identify other measures necessary to keep the RPAS operation safe. National aviation authorities also define a standard scenario with detailed risk-mitigation measures. Therefore, no declaration by the UAS operator prior to flight and no operational authorisation by the authority normally is required before the operation takes place — subject to a few exceptions.
Certified category — Operators and remote pilots in the certified category typically are subject to rules on certification of the operator, licensing of remote pilots and certification of the aircraft. The certified category also applies whenever an operation is conducted over assemblies of people; involves transportation of people; or involves the carriage of dangerous goods, which may result in high risk for third parties in case of accident.
Competent authorities also may require a separate certificate for a specific mission of the unmanned aircraft, and grant authorisation based on the operator’s presentation of a satisfactory safety case with adequate risk mitigations.
In such advanced operations, the remote pilot-in-command — among other expected competencies — must be able to assess the competence of other licensed flight crewmembers for conducting the operation, including their composition, role, responsibilities, training and recent experience.
The regulations also state that “The competent authority shall grant an operational authorisation when the evaluation concludes that: the operational safety objectives take account of the risks of the operation; the combination of mitigation measures concerning the operational conditions to perform the operations the competence of the personnel involved and the technical features of the unmanned aircraft, are adequate and sufficiently robust to keep the operation safe in view of the identified ground and air risks.”
Australian Remote Pilot Licensing
Australia’s Civil Aviation Safety Authority (CASA) also has implemented new standards for remote pilot training, the remote pilot licence and the RPA operators certificate. The revisions primarily affect commercially flying a drone in one of two weight ranges. Remote pilots also must obtain explicit permission from CASA to fly an RPA in some circumstances.
On April 15, 2019, CASA’s RPAS-related rules were published in Part 101 (Unmanned Aircraft and Rockets) Manual of Standards (MOS) 2019. Rules pertaining to the remote pilot licence do not take effect until April 2020, however.
Under the latest scheme, RPA training courses cover the aeronautical knowledge and practical competencies required for the issuance of a remote pilot licence, including how a remote pilot licence may be upgraded to a different category of RPA through ratings, limitations and endorsements.
CASA essentially provides one licensing track for people who have no aviation experience, and one licensing track for people who have aviation experience. The agency explains: “If you have no aviation experience, you will need to complete a training course offered by an approved training organisation that holds a remote operators certificate. These training courses comprise theory and operational training. If you want to operate in controlled airspace or outside visual line of sight, you will also need an aircraft radio operators licence. Some training providers may include this in their training course.”
Applicants with aviation experience must satisfy these requirements:
- “A pass [passing grade] in the theory component of a Part 61 flight crew licence (such as a private pilot licence, commercial pilot licence, airline transport pilot license or remote pilot licence). You satisfy this requirement if you have a flight crew licence, an equivalent military qualification, [or] an air traffic control licence (or equivalent). International qualifications will be recognised where we are satisfied that it is equivalent to the theory component of a remote pilot licence training course;
- “Complete an operational training course with an approved training organisation, or undertake a CASA flight test; [and,]
- “You will also need to complete five hours flying your drone under standard operating conditions. You will need to submit your flight log with your application.”
CASA also explains, “For some operations, you will need permission to fly under the drone safety rules (set out in Civil Aviation Safety Regulations Part 101). Depending on where you intend to fly, [CASA] might require a safety case and risk assessment.”
Remote pilot licence holders also must either obtain their own CASA RPA operators certificate or operate commercially with an operator that has this certificate.
CASA added that consultation with the RPAS industry “is why the standards require knowledge of, and practical competencies to be demonstrated on, the actual type of RPA to be flown in practice rather than some representative model. In some circumstances, there will be no representative model.”
Canadian Licensing Scheme for Remote Pilots
Similar to CASA, Transport Canada’s current training and remote pilot licence standards for RPAS include a theoretical knowledge component and flight training–testing component for designated operations. These are published online in the Canadian Aviation Regulations (CARs, SOR/96-433) but operators/pilots also may obtain waivers by complying with the provisions of a special flight operations certificate–RPAS “if the applicant demonstrates to the Minister the ability to perform the operation without adversely affecting aviation safety or the safety of any person.”
For remote pilots of small RPAs, Transport Canada introduced recency requirements that state: “No holder of a pilot certificate — small remotely piloted aircraft (VLOS) — basic operations or of a pilot certificate — small remotely piloted aircraft (VLOS) — advanced operations shall operate a remotely piloted aircraft system under this [CARs] Division unless the holder has, within the 24 months preceding the flight, been issued a pilot certificate [specified above]; or successfully completed either of the [specified] examinations [or a specified] flight review [or specified] recurrent training activities.” Remote pilots also must maintain a record of all flight operations activities for at least 24 months, and have the licence and recency record in their possession while operating an RPA.
Advanced operations require the pilot to hold a Canadian pilot certificate — small remotely piloted aircraft (VLOS) — advanced operations. These operations are defined as flight in controlled airspace, minimum specified height and horizontal distance from uninvolved bystanders, within 3 nm from the centre of an airport, or within 1 nm mile from the centre of a heliport.
The advanced-certificate requirements are successfully completing one of two knowledge examinations, a flight review and presenting documentation demonstrating that the pilot meets the recency requirements and evidence that the RPA brought to the flight review is properly registered. The flight review includes successfully performing pre-flight checks of their RPAS; performing a take-off; demonstrating the ability to navigate around obstacles; demonstrating the ability to recognize distances; and performing a landing.
Characteristics of U.S. Implementation
The U.S. Federal Aviation Administration (FAA) standards for training and licensing remote pilots to fly under Federal Aviation Regulations Part 107, Small Unmanned Aircraft Systems, (sUAS) reflect the government’s high priority to safely expedite and streamline related rule making.
Organizers of the FAA UAS Symposium 2018, for example, said that except for the military drone pilots and manned-aircraft pilots who apply, initial holders of FAA remote pilot certificates constitute “a new group of aviators that may not have gone through the hundreds of hours of training that traditional pilots typically undergo.”
Standards for obtaining FAA’s remote pilot certificate with small UAS rating notably do not require training on flying skills and procedures or any practical (flight) test by a certificated examiner. Instead, case-by-case requirements for such training, practical tests and logged flight experience — typically proposed to FAA by the operators and remote pilots pursuing waivers to standard operating limitations — will be accepted or rejected based on screening and safety-risk oversight by FAA.
This policy must be understood, however, in the context of the FAA’s regulatory-structure model, which has three classes of small UAS–certification standards: low-risk flight operations under Part 107, high-risk flight operations that require full type certification of aircraft and operations by the agency; and middle-risk flight operations that rely on industry-developed aircraft certification standards and industry-based operator-compliance processes, one symposium presenter said.
FAA refers to the low-risk class as “operator-centric” because the operators fly by complying with FAA rules. The high-risk class is called the “third-party validation system,” which involves greater FAA oversight. The middle-risk class is called the “industry-based compliance process.”
FAA’s Drone Zone website, as of July 2019, showed that 2,859 waivers to FARs Part 107 haver been issued since August 2016 through the industry-based compliance process. This public list of waivers does not show which of these waivers led to FAA requiring hands-on flight training, logged flight experience, or assessment of flying skills and procedural knowledge by an FAA inspector or FAA-designated examiner, etc.
According to the FAA Aerospace Forecast, Fiscal Years 2019–2039, “Remote pilots (RPs) primarily facilitate non-model sUAS flights for commercial activities. An important final metric in non-model sUAS is the trend in RP certifications [i.e., remote pilot licences]. As of December 2018, more than 116,000 RP certifications have been issued [since 2016]. Over 90 percent of those who took the exam passed and obtained RP certification. … RPs are set to experience tremendous growth following the growth trends of the non-model sUAS sector. Starting from the base of 116,027 RPs in 2018, non-model activities may require almost 350,000 RPs in five years, a three-fold increase, providing tremendous opportunities for growth in employment associated with commercial activities of UAS.”
- Safe operation of drones in Europe: Update on EASA’s activities, issued by EASA, April 2018.
- ICAO Remotely Piloted Aircraft Sytsem (RPAS) Concept of Operations (CONOPS) for International IFR Operations, ICAO, preapproval Draft Version 3, October 2017.
- The FAA has implemented two standards for training remote pilots:
- Remote Pilot – Small Unmanned Aircraft Systems Airman Certification Standards, FAA-S-ACS-10, July 2016; and,
- Remote Pilot – Small Unmanned Aircraft Systems (Certification and Recurrent Knowledge Testing) Airman Certification Standards, FAA-S-ACS-10A, June 2018.