The Ministry of Transport has prepared another version of the draft regulatory act, which imposes requirements on unmanned and manned aircraft, allowing for a transition to solving the problem of automatic collision avoidance. The Aeronekst Association of Employers and Enterprises of the Unmanned Aviation Systems Industry commented on the document and discussed some shortcomings in the requirements for mandatory equipment of unmanned aviation systems (UAS) identified in this draft.
The association considers the most critical requirement with an uncertain effect to be the need, starting from March 1, 2030, for the onboard unmanned aerial vehicle (UAV) to have control line equipment with cryptographic information protection means certified in accordance with the requirements of the federal executive authority in the field of security. According to experts, this requirement will lead to a multiple reduction in the data transfer rate over the C2/C3 line.
In addition, all UAVs heavier than 0.25 kg must be equipped with search equipment that will ensure the determination of the location of the aircraft in distress and the transmission of messages about this aircraft. The equipment must perform one of the following functions: calculating the coordinates of the aircraft's location and the horizontal trajectory of its flight based on GLONASS data with the transmission of these data via satellite communication channels, or transmitting the coordinates and parameters of the horizontal trajectory of the aircraft's flight via the COSPAS-SARSAT satellite system. Aeronekst considers these requirements clearly burdensome and unjustified for UAVs, especially with a small maximum take-off weight.
In May 2023, the requirements for UAS equipment were established by paragraph 10.9 of Chapter X of the Federal Aviation Regulations "Preparation and Execution of Flights in Civil Aviation of the Russian Federation", approved by Order No. 128 of the Ministry of Transport of Russia dated July 31, 2009. However, experts also have questions about this paragraph. In particular, there is a requirement that obliges UAVs to be equipped with technical means ensuring the continuity of the control and management line throughout the flight route. At the same time, there is no clear understanding of which means are capable of ensuring the continuity of the C2 line in the presence of external interference.
In addition, according to the new rules, all UAVs must automatically adjust the route and bypass the protected volume. However, in order to implement this, the ATS authorities or other authorized structures need to start broadcasting non-replaceable coordinate information about the establishment of prohibitions and restrictions in the airspace structure in the radio ether.
The new document takes into account a number of proposals and results of practical experiments conducted by Aeronekst, but not all aspects were taken into account. Thus, a number of problems, including technically infeasible points, still remain unresolved.
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