Ikigai Law (formerly TRA) comments to the Civil Aviation Requirements for Operation of Civil Remotely Piloted Aircraft System (RPAS)

Ikigai Law (formerly TRA) comments to the Civil Aviation Requirements for Operation of Civil Remotely Piloted Aircraft System (RPAS) Issued by the Office of the Director General of Civil Aviation

The draft Civil Aviation Requirements released in November, 2017 provide the terms and conditions for the ownership and operation of UAs in India.

The draft requirements are available here. Our comments are available here.

In brief, our submissions were:

  1. Micro weight category should be enhanced to 3 kg.
  2. Single window clearance facility provided for UIN and UAOP. Further, Police verification certificate and MHA clearance should be applicable for two years.
  3. The DGCA should provide a list of standard, pre-approved RPAS and components of reliable make that may be imported without prior approval of the DGCA.
  4. The altitude limit for Micro RPAs (for flying without UAOP) should be raised to 400 ft.
  5. There should be no age requirement for pilots of Nano RPA and the age of remote pilots for Micro RPA should be relaxed to 13 years.
  6. All RPA operations should be restricted to day operation with the exception of a) Nano RPA; b) Micro RPA intended to be flown upto 50 ft AGL; c) Micro RPA intended to be flown upto 200 ft AGL on private premises, but not over any human population; d) indoor operations, or e) with prior approval of the DGCA.
  7. All RPA operations should be restricted to VLOS except with the prior approval of the DGCA.
  8. Indoor operations need not require any permission from the local police.
  9. Organisations having a UAOP / registered as “Startup” or MSME/ having industrial license from DIPP should be permitted to use the test sites. Eligible foreign organisations should also be allowed to use test sites.
  10. RPAS operators except those operating Nano RPAs should have insurance.

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