1. Feedback on European Legislative Framework on ‘Drones’
Advisory Board Belgian Drone Industry Stakeholders:
Agoria – EUKA – skeyes – Drone Valley - BeUAS

2. FEEDBACK
Based upon advisory board meeting on November 15th and December 12th
Agoria, BeUAS, Drone Valley, Euka, skeyes, Unifly
Offers feedback related to the industry’s views on the October 2018 draft
For a detailed, more technical analysis we refer to the feedback drafted by skeyes, which goes into detail and is also supported by the industry
This feedback will be offered in two tracks:
A general industry consensus about what the ‘spirit’ of the legislation should be
A more detailed feedback on some articles that should be corrected/amended asap before finalizing the proposed texts
14/12/2018

3. FEEDBACK: GENERAL INDUSTRY CONSENSUS
This advisory board, which is representative on all levels (Federal, Flemish and Walloon), should be a permanent advisory channel to the competent authority. This should be reactive AND pro-active.
This advisory board also consists of a large constituency of drone pilots, end users and suppliers, as wel as the major knowledge institutions and trade federations. Therefore, it could support legislative communications towards the industry in one single and clear cut voice.
14/12/2018

4. FEEDBACK: GENERAL INDUSTRY CONSENSUS
The industry expects that fares/costs/taxes related to flight authorisation request would be uniform (no extra charges for exeptions/derogations) or preferably non- existent (to support the industry).Ideally we would like to see a unique European platform with uniform pricing
The industry also expects that standard scenarios (European and National) will be defined as soon as possible (=before the final text is approved), because otherwise the industry will not be able to grow quickly (it will remain as difficult/ambiguous as it is today to get flight authorisations)
Leverage of existing and new industry use cases (working group?)
14/12/2018

5. FEEDBACK: GENERAL INDUSTRY CONSENSUS
The advisory boards also hopes that the to be defined areas/maps of flight zones will take into account:
Opening CTR/HTA zones through usage of airspace layering
Up-to-date online maps (eg droneguide.be) when legislation will be implemented
Minimal exceptions when defining zones
Service Level Agreements and Key Performance Indicators should be defined for the Competent Authority – a dashboard should be publicly consultable to ensure the SLA’s and KPI’s are met
14/12/2018

6. FEEDBACK: OTHER ISSUES
Pilot competences and technological specifications of the drone for the specific category not part of a standard scenario should not be a part of a flight authorisation, but rather defined and known beforehand
Article 11 – the proposed risk assessment for the specific category is going against the economical ‘spirit’ of the text. It is too ridgid for most common drone operations, and will thwart economic growth (economic growth potential already established at length in a PwC study by Agoria)
Light UAS Certificate (LUC) : positive for industrial use – very strict, but economically feasable
14/12/2018

7. FEEDBACK: OTHER ISSUES
Open category: concern on A3 training requierements which do not involve a practical test although it involves the use of a drone up to 25 kilograms potentially operated by a 14 year old pilot; not only a safety issue but potential hazard for dangerous interaction with commercial operations under the specific category which do comply with the proper risk assessments and pilot training requierements
Find a practical solution to recognize and protect the investments made by drone pilots; Belgian training recognized for it’s high quality; suggestion from this group to come up with a strawman proposal
Get clarity on CE marking
14/12/2018