Union Européenne Contre les Nuisances Aériennes
UECNA
Air transport and airport related activities are responsible for noise pollution and the emission of toxic pollutants.
ID: 932640120950-51
Lobbying Activity
Response to A Drone Strategy 2.0 for Europe
29 Jun 2021
CONTRIBUTION TO THE CONSULTATION ON THE ROADMAP FOR DRONE STRATEGY 2.0 FOR EUROPE
PLEASE SEE DOCUMENT ATTACHED FOR FULL CONTRIBUTION
Thank you for the opportunity to respond to the consultation on the Roadmap for drone strategy 2.0 for Europe.
UECNA strongly supports the initiative, however we are concerned about the somewhat “transport and mobility” coloured perspective that is taken. As an example, in the Context section it is mentioned that daily commuting (by drone we assume) would be an enabler of social life. We think the noise consequences in a society where workers would commute by drones would create a nightmare scenario that is not something to strive for.
We note that the roadmap aims to ensure safe and efficient development of a drone “ecosystem” but considers that societal concerns merely need to be “addressed” while the sentence ends with the aim to ensure that the EU drone industry can grow. In our view safety, security, privacy and in particular environmental protection and health of citizens must equally be ensured. Our position is that if the drone ecosystem would lead to any deterioration of the noise environment, negative health impact or to security and privacy concerns, such development must not be allowed to take place. A cornerstone of the European Union is to protect and promote the wellbeing of European citizens, and as such safety and environmental protection (including reducing, not increasing, environmental noise) should be on equal footing in defining the problems to be attacked.
We think the use of drone-like vehicles for passenger transport in urban environment is a very worrying development that should be made possible only if these forms of transport would be without even the slightest noise impact. We note that the noise in urban environment is often already well above acceptable levels and adding further noise is the last thing one should want. Quiet areas in cities and villages are often protected by natural barriers from ground-based noise sources. Air borne vehicles would seriously threaten such valuable and needed quiet areas. As such the noise from drones should be below noticeable background levels in quiet areas which in our opinion is practically impossible.
We agree that this is a subject that needs to be dealt with at a European level, otherwise the risk exists that individual member states will be competing unfairly by a “race to the bottom” in allowing higher noise impact than elsewhere. We think this is very similar to the situation where airports compete against each other in allowing night flights.
In addition to the above we offer the following items of consideration, which are also partly in response to the quoted study on societal acceptance of Urban Air Mobility by the European Union Aviation Safety Agency.
PLEASE SEE DOCUMENT ATTACHED
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