Uplink ALPA - The Voice of Aviation

The New Zealand Air Line Pilots' Association Newsletter. As of April 2020 Uplink ALPA is a 6-monthly publication.

Unmanned aircraft – NZALPA policy and international pilot association positions

NZALPA has clear policy on RPAS, which is the official International Civil Aviation Organization (ICAO) term for such aircraft. Every day, whether for commercial or recreational use, more RPAS are being seen and heard above us. 

Our policy, ratified officially at the NZALPA 2017 Conference, is broadly in line with that of the International Federation of Air Line Pilots’ Associations’ (IFALPA), our international representative body’s position, says NZALPA Senior Technical Officer David Reynolds. 

NZALPA’s policy particularly emphasises the following:

  • Recognition that the rapid growth and proliferation of RPAS in New Zealand will continue
  • That it is imperative that the operation of RPAS are conducted safely
  • For any RPAS to operate in navigable airspace on regular operations it will need to operate to the equivalent safety and certification standards required of manned aircraft

“NZALPA also supports positive action to ensure Civil Aviation Authority (CAA) rules are fit for purpose,” Reynolds says. 

“Our policy is clear that we will encourage education, research and implementation of safe RPAS use and technological solutions.

“In addition, NZALPA will work with the Government, aircraft operators, CAA, Airways and other industry stakeholders to promote these goals, and support regulatory enforcement action where required.” 

IFALPA recently released its revised and updated position paper on what they refer to as UAS. 

When setting its position, IFALPA emphasised that it ‘strives for protecting and enhancing aviation safety by the highest standards and promoting a single level of safety worldwide for all users of civilian airspace.’

This is especially important, IFALPA says, when introducing a new technology into civilian airspace such UAS. While IFALPA welcomes and recognises the potential benefits of this new technology, it says that it’s critically important to ensure the safe integration of UAS into civilian airspace.

Size, performance, type of operation and intended use of UAS vary to a much greater extent than in manned aviation. UAS can vary in size from below 250 grams (similar to a model aircraft) up to UAS with a wingspan similar to that of a Boeing 737.

Their use can also vary from local to intercontinental flights and from low altitudes up to very high altitudes. 

IFALPA also points out that UAS often have unconventional shapes, with widely differing operating characteristics and a large spectrum of performance capabilities.

In order to address the use and proliferation of UAS, IFALPA has developed 19 clear positions, which are supported by NZALPA.

POSITION 1:  IFALPA believes that all UAS should be integrated into common airspace. Accommodation should only be a temporary measure.

POSITION 2: IFALPA considers that it is not acceptable to change rules and regulations for manned aviation in order to accommodate UAS integration.

POSITION 3: Every UAS should have at all times a responsible person in command, who is suitably trained and qualified with an independent safety mandate, responsible for the safe operation of the flight, mission or task.

POSITION 4: As a matter of urgency, in-depth research into the impact of collisions between small UA and manned aircraft is necessary to establish the severity of the impact of collisions

POSITION 5: An approved, full and transparent risk assessment should be completed before an operation can be commenced.

POSITION 6: As there is no formal qualification for certain categories of UAS, it cannot be assumed that there is a qualified, trained and competent responsible pilot in command of the UA. For operation in airspace where an encounter of a manned aircraft is possible, mandatory training and a certificate/license should be required.

POSITION 7: Every state should conduct an extensive public awareness campaign about the safety risks, duties, liabilities, insurance requirements, responsibilities and third party privacy issues associated with operations of UAS.

POSITION 8: Registration via a state-system should be compulsory for all UAS. This facilitates enforcement of rules and motivates training within the UAS community.

POSITION 9: The responsible authorities charged with the enforcement of rules to operate UAS should be staffed, trained and equipped sufficiently to increase the effectiveness of enforcement.

POSITION 10: As long as there is no means for manned aviation to safely see and avoid small UA, the responsibility to see and avoid belongs to the pilot of the UA.

POSITION 11: In case of an encounter of a small UA with a manned aircraft, the UA should be conspicuous to the manned aircraft in order to allow ‘Collision Avoidance’.

POSITION 12: Where the proper execution of ‘See and Avoid’ cannot be guaranteed, no operation of an UA should be granted.

POSITION 13: The operation of small UAS in Visual Line of Sight (VLOS) cannot be compared to model aviation, since the intent and the location of operations differs significantly. Therefore, safety comparisons are invalid. Where States intend to integrate recreational UA into national Model Aircraft Flying Regulations, they should establish specific rules for them.

POSITION 14: If the pilot of an UA is not properly qualified and formally licensed, mandatory Technical Performance Limitations such as Geofencing and altitude and range-limitations should be introduced in order to mitigate the risk of collision and airspace-infringement.

POSITION 15: Currently, IFALPA does not believe that autonomous unmanned aircraft can be integrated into common airspace.

POSITION 16: IFALPA rejects the denial of airspace to manned aviation in order to accommodate autonomous UAS.

POSITION 17: IFALPA believes that UAS technology is not capable of replacing all necessary capabilities of a human pilot on board, particularly in complex time and safety critical situations.

POSITION 18: IFALPA does not believe that UAS can perform an operation as complex as air transport with an equivalent level of safety.

POSITION 19: All UAS engaged in non-segregated public airspace should be certified and compliant with the provisions described hereafter [as per the position link below] before being allowed to operate.


IFALPA’s full position (17POS08) can be viewed at: https://www.ifalpa.org/publications/ifalpa-statements.html

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