It's been more than 7 years in the making, but as 2022 draws to a close, U-space, the European drone UTM initiative is very nearly reality … and that reality brings with it some urgent issues for Europe's ANSPs. Herve Drevillon explains why.
Figure 1: U-space timeline
U-space is close to becoming a reality.
In April 2021, the European Commission adopted a regulatory package (IR (EU) 2021/664, 2021/665 and 2021/666) that details the requirements around U-space - a set of new services and specific procedures designed to support safe, efficient, and secure access to airspace for large numbers of drones. This regulation enters into force on 26 January 2023 and introduces some important new features:
- A new type of airspace: a UAS geographical zone (as defined in IR (EU) 2019/947) can be designated by States as U-space airspace, where drones will only be able to operate if they use specific services.
- A new set of services for drone operators: in a given U-space airspace, drone operators will be required to use at least 4 mandatory services, and at the discretion of each State, up to 2 additional services. Those services are:
- Geo-awareness - providing drone operators with the information about the latest airspace constraints and information on UAS geographical zones.
- UAS flight authorisation - ensuring that authorised drone operations are free of intersection in space and time with any other notified drone flight authorisation within the same portion of U-space airspace.
- Network identification - providing the identity of drone operators, the location and flight vector of drones, and sharing relevant information with other U-space airspace users.
- Traffic information service - alerting drone operators about other air traffic that may be present in proximity to their drone.
- Conformance monitoring (optional) - providing real-time alerting of non-conformance with the granted flight authorisation and informing the drone operators when they deviate from it.
- Weather information (optional) - providing the drone operator with weather forecasts and actual weather information either before or during the flight.
- New actors: U-space Service Providers (USSPs) will be responsible for delivering the above services to drone operators. USSPs will rely on Common Information Services (CIS) to access some of the elementary data required to build the U-space services. States can designate a single CIS provider (CISP) that will be responsible for providing CIS in all or some of the U-space airspaces within this State on an exclusive basis.
Figure 2: Overview of U-space environment
The current trend in the EU is for States to designate their ANSP as a single CISP for all the U-space airspaces in the country. Given that the U-space regulation applies from 26 January 2023, very limited time remains for future CISPs to align with it.
Challenges for ANSPs.
At the time of writing, the main hurdle in implementing U-space is the unavailability of the Acceptable Means of Compliance and Guidance Material (AMC/GM) documents supporting the U-space regulation. EASA published a draft version in December 2021 (NPA 2021-14) and is still in the process of finalising the documents, after having received a large number of comments during their public review. This is problematic because important clarifications provided in the NPA remain unconfirmed and are needed now by would-be U-space actors, notably ANSPs, as future CISPs, to make critical decisions.
ANSPs thus face many unanswered questions at this point, partly because of missing regulatory guidance and partly because this is a new and immature market. If an ANSP becomes a CISP, what will be the impact on their organisation? What is the best business model to adopt to benefit from existing resources while minimising the risks associated with the new CISP role? How can they make strategic decisions while regulatory compliance is not clear?
A recent Egis study assessed the pros and cons of various business models with different degrees of separation between the ANSP and the CISP: should the CISP be a new department within the current organisation? Should it rather be a distinct legal entity? If the latter, would there be an interest in partnering with a 3rd party? Our study suggested that keeping the ANSP and CISP within the same organisation allows for great synergies, but will require strict accounting processes: charges will be collected from two sets of end users, and because CISPs will operate in a monopolistic position, they can expect their charges to be regulated, just as those of ANSPs, but under a different charging scheme from that of IR (EU) 2019/317.
ANSPs also need to plan investments for their future CISP role, which can be significant. The essential tasks of the CISP are to provide connectivity facilities between U-space actors, collect from external providers the information on which U-space services are built and deliver that information to USSPs. Depending on individual approaches, the information management task can be very limited (i.e., storing raw data and delivering it to USSPs) or involve processing the data into a form closer to that provided by the U-space services.
The areas of costs identified include staff, systems, training, certification of the CISP, operating costs, etc. For example:
- Certification of the future CISP entity will mean implementing a management system and typically receive ISO 9001 certification. Even if ANSPs are familiar with these requirements, defining and documenting processes for a completely new entity, preparing and undergoing a certification audit and implementing any corrective action remains a significant and time-consuming task, that will take at least a year to complete.
- The number of staff required to operate the CISP can be limited, as this role will be highly automated. Nevertheless, staff training will be important, as appropriate training (both initial and recurring) of the operators supporting the service provision will be among the criteria for obtaining a CISP certificate.
- U-space systems are less complex than for ATC, but their lifecycle will be shorter. So, CISPs are considering investments in the order of several million euros over about 10 years, and that investment is ‘front loaded’ to the first year of operation to acquire the system and the supporting IT. The procurement of small-scale systems under usual public procurement laws takes around one year, so any future CISP that is not already in the closing phase of this procurement will not complete it before the U-space regulation enters into force.
Considering the amount to be invested, future CISPs should also look for funding sources, both at European and local levels, and should carefully plan them as they will be recovered from CIS only, not air navigation services.
What should ANSPs be doing now?
Even though the entry into force of the U-space regulation is close, the actual urgency of having a CISP in place is linked to the designation of U-space airspaces and the willingness of USSPs to operate in the country. Setting up the CISP is therefore part of a wider process that should be conducted in close cooperation with all U-space stakeholders, and they are many:
- Governments/Ministries of Transport
- Civil Aviation Authorities
- Local authorities
- Ministries of Defence/military authorities
- MET service providers
Internally, ANSPs that will be designated as CISPs need to progress tasks such as:
- Establishing relationships with the above stakeholders
- Agreeing on the organisational set up and business model of the CISP
- Designating key staff in charge of setting up the CISP
- Defining the budgets for this new entity and identifying funding sources
- Defining a strategy for the acquisition of the CISP system
- Initiating the certification process and developing internal processes.
Be proactive.
Time is running out. The 26th of January 2023 will be here before we know it, and while the U-space community awaits the regulatory guidance materials, ANSPs should use this interval to plan for their possible future as CISPs (organisation, budget, certification/processes). We are still in the very early phases of implementing U‑space, but Egis has gained some insights on what is involved from working with several ANSPs and best practices are already emerging. Our advice to ANSPs at this stage is to be proactive, as they face a long process, and not to work in isolation, but to seek out other local U-space stakeholders, ANSPs and companies with experience in this process.
