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Drone Manufacturers Alliance Europe

DMAE

Drone Manufacturers Alliance Europe (DMAE) is an industry coalition of leading global drone manufacturers.

Lobbying Activity

Response to A Drone Strategy 2.0 for Europe

2 Jul 2021

For the past five years, the Drone Manufacturers Alliance Europe (DMAE) had the opportunity to contribute to the creation of the EU’s first set of drone rules. DMAE welcomes the chance to continue being a trusted industry partner and to provide input to this Roadmap. We support the European Commission’s efforts to create the forthcoming Drone Strategy 2.0 for Europe. Since the European Commission’s publication of the Communication on a new era for civil aviation in 2015, the drone industry has changed. It has grown and evolved, with technological advances and innovative applications advancing these developments. Today, drone use has grown beyond recreational operations, with drones becoming key tools during the COVID-19 pandemic, inspections, search and rescue, conservation, public safety, and STEM learning, among others. DMAE echoes the European Commission’s objectives that the “safety, security and privacy of people in the air and on the ground is a priority.” We also believe that a future strategy should be risk-based and technology neutral, support fair access, and be affordable. One of the questions within the Roadmap is on how to find the right balance for EU drone policy between what was achieved, what is happening on the market now and what will happen on the market in the future. The answer to finding the right balance is centred on maintaining the risk-based categories and a stable EU drone regulatory framework. This provides all stakeholders in the drone industry value chain with predictability and stability, key ingredients when it comes to investment and innovation in the European market. DMAE would also like to point out that the Drone Strategy 2.0 should do more than highlight risks and obstacles, but equally if not more important for societal acceptance, the Strategy should illustrate the benefits of drones in society; citizens are not fully aware of the positive benefits drones. We look forward to engaging with the European Commission on this important and exciting continuation of EU drone policy.
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Response to Detailed rules on unmanned aircrafts

5 Nov 2018

The Drone Manufacturers Alliance Europe (DMAE) welcomes the latest revised draft implementing rules laying down technical and operational requirements for drones. It is another positive step towards the roll-out of an EU-wide framework for the operation of drones, further to the recent entry into force of the European Aviation Safety Agency’s (EASA) Basic Regulation (BR). Specifically, DMAE recognises the positive developments on remote electronic identification, the tiered approach to noise level reduction, sensible transition periods and more EU-harmonisation. As drone manufacturers, we strive for reasonable, proportionate and evidence-based EU rules that enable consumers and SMEs to fully benefit from drone technology, while respecting safety standards. It is crucial that drone operators can enjoy the same flight experience after new Regulations enter into force. However, we believe a few elements still need to be addressed. Therefore, we would like to take this opportunity to provide the European Commission and EASA with our comments on: Priority issues: • Remote electronic identification requirement • Machinery Directive applicability • Noise power level measurement methodology • ‘Follow-me mode’ clarification & compromise • Technical requirement on lights Important issues: • Inclusion of a minimum age requirement Please see attachment for more details.
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Response to Detailed rules on unmanned aircrafts

13 Apr 2018

The Drone Manufacturers Alliance Europe (DMAE) believes these key principles should guide the process of EU drone rulemaking: Harmonisation at EU-level increases safety, innovation and acceptance:To unlock the potential and creation of a single market for drones requires a regulatory framework for all civil drones at EU-level to ensure uniform rules and requirements, to create one uniform level of safety, across MS. Instils a culture of compliance amongst operators. Allows manufacturers to communicate the operational rules to their operators or to implement safety features in a harmonised way. Even if drone operations have a limited scope operators should be in a position to use the same unmanned aircraft and the same operating requirements with the same pilot at different places in the EU to develop their businesses especially if they operate in nascent markets. Fragmentation will lead to roadblocks and patches of national regulations, rather than spurring the drone industry and its many applications. Without harmonisation, drone operators are more likely to inadvertently break laws when crossing borders. Similarly European SMEs would be risk averse to developing new applications and services or starting a business altogether. Harmonisation and a campaign will increase public acceptance. If a single market for drones is the goal the means to get there is through harmonised drone rules at EU-level. Open Category – simplification and safety go hand in hand: Drones come in a variety of sizes, weights and performance capabilities, which present challenges when regulating with a one-size-fits-all approach. DMAE reiterates support for the three broad categories in line with the risk associated with operations. Open Category addresses low-risk operations and should reflect that objective with simple, proportionate and evidence based rules. DMAE supports clear and simple categories which are fit for purpose and easy to understand.Complexity undermines this goal. Technology-neural approach to take advantage of fast paced developments: Drones should be equipped with the most appropriate technology features in accordance with the risk of the operations for which they are designed, to help the operator fly the aircraft safely and in line with safety regulations. Drone technology and drone safety features are developing fast. We strongly support the technology-neutral approach that assesses requirements based on specific objectives or performance-based standards, while allowing different means of achieving compliance and offering EASA the flexibility to swiftly adjust targets as technology evolves. We applaud EASA’s efforts to finalise Europe’s first common rulebook for drones. However DMAE asks for clarity on: Geoawareness requirement/existing geofencing solutions: We note the Roadmap mentions geofencing not geoawareness found in the EASA Opinion. DMAE asks for clarification. Already today some of our products use geofencing technology, which should be formally recognized as a means compliance with geoawareness requirements, provided systems are run on validated data by Member States. Geofencing systems currently on the market technically help prevent operators from having their drone enter highly sensitive areas (airports, prisons etc). DMAE urges MS ensure geofencing solutions continue to be allowed on the market to realise the increased safety and security benefits these systems deliver. Call for more research: Drone rulemaking needs to be based on science and evidence. Throughout the EASA Basic Regulation discussion DMAE has called on EU lawmakers to adopt a 2kg registration weight threshold (in line with international standards). We call on EASA to launch and finance a research project on the risk profile of drones. The study should focus on the risk that drones at various weights pose to both manned aviation and ground risk. The study should explore what risk is socially acceptable. DMAE is ready to engage.
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