Most countries agree on some of the basics. All of the countries regulate commercial UAS, enforce drone laws in some way, require airspace authorizations for some airspace, and restrict flight near airports.
According to the report, all except Israel allow flight beyond visual line of sight (BVLOS) in some circumstances. All except China and Israel restrict the altitude of drone flights; and all but Japan, China and Germany require some form of pilot training and certification.
An examination of the remaining points reviewed, however, shows more disagreement in how individual countries deal with drones.
In the United States, Section 336 of the federal code protects recreational drones from new FAA regulations. This has been a point of contention between some commercial entities and recreational advocacy groups, as commercial groups and the FAA urge lawmakers to repeal Section 336 and allow the FAA to regulate all drones. Most other countries also differentiate between the two types of operation: but three countries – Japan, China, and Israel – do not distinguish between commercial and recreational use, applying the same laws to all.
The United States, Australia, France, and Poland are the only countries of the eleven compared that do not regulate recreational operators, and it appears that the U.S. has company in asking CBO’s for help. Of those that do differentiate, the report states: “Two of our five selected countries, like the United States, have chosen to rely on community-based organizations—many of whom represented the early UAS pilots before the rapid growth of small UAS manufacturing and sales—for assistance in providing guidelines and education for recreational small UAS pilots.”
[EDIT] As a valued reader from Australia points out, recreational operators in these countries are not entirely unregulated. To clarify: recreational operators must, in fact, follow the safety regulations for flight, and in some countries are only authorized to fly while operating within the safety guidelines of a recognized community based organization. However, recreational operators in these countries may not be required to adhere to the same certification and authorization standards as commercial operators.
The issue of weight-based risk categories for regulation is also a point of comparison. Here, the U.S. is among the few that do not recognize weight-based classification; something drone manufacturers have promoted. Only the U.S., Israel and Poland do not divide small UAS into weight classifications.
While individual countries may differ on individual drone laws and frameworks, they appear to experience many of the same issues when it comes to regulating UAS. The report says that most countries must coordinate and collaborate with other government agencies, and many have had to use “new and reallocated internal resources” to support regulation of drones.
Miriam McNabb is the Editor-in-Chief of DRONELIFE and CEO of JobForDrones, a professional drone services marketplace, and a fascinated observer of the emerging drone industry and the regulatory environment for drones. Miriam has penned over 3,000 articles focused on the commercial drone space and is an international speaker and recognized figure in the industry. Miriam has a degree from the University of Chicago and over 20 years of experience in high tech sales and marketing for new technologies.
For drone industry consulting or writing, Email Miriam.
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