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How To Regulate Drones

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Hovering Over Opportunities

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In the relatively brief space of the last 10 years,

the market for unmanned aircraft systems (UAS),

commonly referred to as “drones,” has seen rapid

evolution and exponential growth.

Earlier generations of drones were like early computers; large, rare, expensive and reserved for exclusive use by the military, mainly due to the specialized skills required to operate them. Now, in the same way that improved technology continues to make computers and cell phones smaller, cheaper and easier to use, the use of drones has expanded massively in the civil and commercial sectors thanks to similar advances in technology and accessibility. As these devices become increasingly embedded into the fabric of everyday life, applications for their use will continue to grow, spurred on by increasingly sophisticated functionality and the imagination of those who would make use of them.

Here at Zurich, we are particularly excited about the opportunities drones offer to both our customers and our own loss control specialists to improve the efficiency and effectiveness of a variety of risk management tasks. A drone equipped with just a basic camera is ideally suited to carry out visual inspection, surveillance and reconnaissance chores that might otherwise be tedious, difficult or even dangerous for humans to do. More sophisticated equipment can perform detailed mapping tasks, support

Like many new technologies that have started to gain widespread public acceptance in recent years, users may be tempted to rush in and seize the benefits offered at the expense of gaining a full appreciation of the new risks the technology may introduce. In the case of drones, the overarching risk is a lack of understanding that operating a drone is a serious aviation activity, which requires training, staffing and operational procedures that may lie outside an organization’s core competencies.

One of our aims at Zurich is to support our customers that want to embrace new and emerging technologies in their businesses by helping companies understand and protect themselves from the risks that these technologies create. In line with this goal, this white paper was created to serve as a conversation starter for insurance brokers, risk managers and chief financial officers interested in exploring risk mitigation strategies with drones. The fast-evolving nature of this technology means that the drone-related risks outlined here, along with the recommendations for mitigating them, are by no means comprehensive. Finding the right solution for a particular organization will require a thorough analysis of the exposures to be

Foreword

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Once limited to military applications, unmanned aerial vehicles (UAVs), commonly known as drones, are now a viable aviation tool used by individuals, businesses, governments and non-governmental organizations. Rapid development of technology has created a global industry for commercial and civil unmanned aircraft systems (UAS) that one European consulting firm projects will be worth USD$777.7 million in global spending in 2015.1

Drones are already in widespread civil and commercial use in many parts of the world in a variety of industries. In Japan, an estimated 2,500 drones are currently in operation in the agricultural sector to monitor and fertilize crops.2 Oil and gas

companies employ drones to monitor pipelines; mining firms use them to survey topography; film and television crews affix cameras to small drones, in lieu of

helicopters, to gather aerial footage. In the first few months of 2015 alone,

government-approved drones were used in emergency response efforts in 43 disasters across 13 different countries.3 Even Internet

mammoth Facebook has found a way to employ UAVs. The company announced in July 2015 the roll-out of its solar-powered drone program that will be capable of providing 10 gigabit per second Internet service to remote areas, where fiber optics aren’t available.4

As drones have become smaller, cheaper, more intelligent and more accessible, they now offer unprecedented opportunities as

a risk mitigation tool. Payloads can be used to collect data and conduct reconnaissance and monitoring. Maneuverability and low capital cost of these airborne robots makes them a compelling alternative to human labour and traditional aircraft in dangerous or remote situations. Besides their

serviceability to regularly monitor everything from rail lines to the integrity of bridges and buildings, drones can be quick to deploy to verify the safety of environments and structures in the wake of a catastrophe.

With the rapid growth in the civil and commercial drone market, new risks have emerged, particularly in light of

undeveloped or underdeveloped regulations around their use in various jurisdictions.5 National and international

aviation regulators are struggling to strike a balance between supporting the integration of this valuable technology into airspace formerly reserved for traditional manned aircraft, while at the same time guaranteeing the safety of people and property, as an ever-growing number of small drones fly less than 500 feet from the ground. Lack of skilled operators, untested technology, liabilities associated with use of UAVs in crowded areas and privacy concerns present new types of risk that companies must be prepared to measure, assess and manage as we prepare for the ubiquity of drones in our lives.

Introduction

Know Your Acronyms

UAV – Unmanned Aerial Vehicle

A UAV is an aircraft without a human pilot onboard. UAV is a broad term that can include a wide variety of piloted or autonomous aircraft of any size and design.

UAS – Unmanned Aircraft System

A UAS encompasses the drone vehicle, its payload and all the components that work together in the operation of an unmanned aircraft, including everything on the ground. The list can include radio transmitters and receivers, and a ground control station.

Source: ACUAS, “UAS, UAV, drone… What’s in a name?” November 2014.

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Until the early 2000s, drones mostly consisted of heavy, fix-winged aircraft. Much like early computers, drones were big, rare and expensive, and reserved for elite use by the military. The invention of Global Positioning System (GPS) and micro-computing allowed for more sophisticated uses of drones that were smaller and smarter. In the wake of the 9/11 terrorist attacks, the United States Department of Defense funneled massive resources into the development of military drones, at the same time Internet and mobile technology was taking off in the private sector. Prior to 2002, only 200 drones had ever been employed by the U.S. military.6 By 2013,

the military had deployed more than 11,000 drones,7 and UAVs started to

make headway into civil and commercial markets as well.

“While the United States and Israel were the sole producers of UAVs only 15 years ago,” notes a 2014 market report by UK-based firm INEA Consulting, “today China, Russia, Iran, Australia, Brazil, Germany, Turkey and Canada have stepped up their development programs and have begun exporting systems internationally.”8

According to INEA’s 2013 market breakdown, North American (mostly the U.S.) manufacturers were responsible for 61 percent of global drone sales, followed by Asia-Pacific at 20 percent and Europe at 17 percent.9

At the current rate of development, the Teal Group projects global spending on drones will represent USD$91 billion by 2024, largely driven by civil and commercial use.10

Figure 1: Regional breakdown of the global commercial and civil UAV market in 2013

History – From Military to

Commercialization

USA – 62% Asia Pacific – 20% Europe – 17%

Middle East & North Africa – 2%

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There are a number of things that will contribute to the growth of the civil and commercial UAS market. At the crux of market expansion is the implementation of regulatory frameworks in individual nations that can be harmonized internationally to integrate civil and commercial drones into broader use safely. Regulations for drones have been developing at a variable pace in different jurisdictions, as demonstrated by a comparison of Canada, Europe and the United States.

Canada has had some form of regulatory safety rules in place since 1996,11 and has

been praised by experts as a “world leader” for its framework governing commercial drone use.12 Commercial use of

drones in Canada is growing rapidly. In 2014, Transport Canada issued 1,672 Special Flight Operations Certificates (SFOCs), compared to 345 SFOCs in 2012, an increase of 485 percent in just two years.13 Since November 2014, drones

weighing less than 25 kg no longer require operators to obtain an SFOC but they must meet Transport Canada’s exemption requirements.14 However, despite its

positive reputation as an early adopter of regulations that foster commercial drone use, Transport Canada has recently been criticized on multiple fronts. UAS boosters that want to expand the applications for drones would like quicker action on developing rules for beyond-visual-line-of-sight flights, in part by encouraging drone manufacturers to include new collision-prevention technology such as geofencing transponders. Additionally, the regulator has been called out for a lack of enforcement of the existing rules with recreational drone users.15

Various European countries, including the UK, Sweden and France, have been governing drone use under what the European Commission calls a “fragmented regulatory framework.”16 UVS International

data shows there were a little more than 1,300 licensed drone operators across 28 EU countries in 2014, yet only 12 of those countries have UAV-governing regulations in place.17

Although the European Aviation Safety Authority (EASA) will not release new UAV guidelines until the end of 2015, it has outlined the intentions behind what it calls “a risk-based approach toward regulation of unmanned aircraft.” Despite this, small drones will not be regulated by aviation authorities, providing they are flown “under direct visual line of sight (VLOS): 500 m; at an altitude not exceeding 150 m above the ground or water; [and] outside of specified reserved areas (airport, environmental, security).”

Until early 2015, commercial and civil drone operators in the United States that had obtained a Section 333 exemption from the Federal Aviation Administration (FAA) for any non-military drone use— which could be a lengthy process unto itself—were still required to also subsequently apply for a Certificate of Waiver or Authorization (COA) and Special Airworthiness Certificate for every occasion they wanted to actually fly a drone.18 Like

the Section 333 exemption approval process (the necessary first step), the COA application and approval process was also lengthy, taking up to 60 days for a single approval.19 From 2009 to December 2013,

the FAA issued fewer than 1,400 COAs, an average of less than 300 per year.20

Regulatory Environment and Commercialization

In the first three years of

integration, more than 70,000

jobs will be created in the

United States with an

economic impact of more

than USD$13.6 billion.”

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In 2012, the U.S. government signaled a significant shift in its approach to drones when it passed the FAA Modernization

and Reform Act of 2012, mandating the

FAA to introduce a framework that would relax current laws to foster the integration of civil and commercial drones into U.S. airspace by September 30, 2015. Since then, the FAA has celebrated that it has now granted more than 1,000 Section 333 exemption approvals to individuals and companies across a broad range of industries.21 Additionally, in March 2015,

the FAA began issuing “blanket” COAs to Section 333 exemption holders in an effort to streamline the process for operators wishing to access U.S. airspace. This “blanket” COA allows flights anywhere in the country at or below 200 feet except in restricted airspace, close to airports, and other areas, such as major cities where the FAA prohibits UAS operations.22

The FAA’s reform of its rules is moving in the direction of seizing the social and economic benefits that the FAA believes drones do indeed provide.23 The regulator

anticipates that small commercial drones will be the greatest area of UAS growth in the next few years, forecasting that 7,500 small drones will have been approved to fly in U.S. airspace by 2018.24 The Association

of Unmanned Vehicle Systems International (AUVSI) predicts “that in the first three years of integration more than 70,000 jobs will be created in the United States with an economic impact of more than USD$13.6 billion.”25 By 2025, the organization

forecasts 100,000 jobs created and an economic impact of $82 billion in the U.S., alone.

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Drones are already playing an important role in risk mitigation and catastrophe response for large companies that embrace innovative approaches to their risk

management programs. The technology has been moving faster than the

regulations in many jurisdictions that allow commercial entities to fully embrace unmanned aviation. But that hasn’t stopped experimentation and adoption of drones across the globe as a valuable risk management tool. Even some crude estimates of the economic benefits of using drones will be food for thought for many CFOs and CROs looking for quick wins in expense reduction, while still maintaining a robust Enterprise Risk Management (ERM) program for their organizations.

With the potential to reduce human exposure to dangerous situations and the ability to provide unique viewing angles at low altitudes where manned aircraft cannot go, drones are easily deployable and cost-efficient. As a 2015 study conducted by the American Red Cross and Measure32 noted, UAVs are “optimally suited to perform the ‘3-D’ missions, often described as dirty, dull, and dangerous.”26

UAVs come in many different sizes. The smallest drones can be held in the palm of one’s hand and can be maneuvered in tunnels, mines or pipelines to gather data, conduct inspections or do surveillance and monitoring in areas not accessible to humans. Smaller devices, such as the two Draganflyer x6 remote-controlled helicopters that the Los Angeles Police Department acquired in 201427 retail for

around USD$9,000, and weigh less than 2 kg, even when fully loaded with video, camera and infrared technology.28 The

LAPD intends to use the drones for incidents “involving barricaded suspects or hostages in which police need to see inside a building as they decide how to respond.”29

Similarly, a variety of industries are using drones as risk management tools in diverse ways. Unlike CCTV cameras or manned aircraft, “UAVs enable surveillance that is surreptitious, cheap, efficient, persistent and agile.”30 Oil and gas utilities regularly

deploy drones to conduct aerial inspections of equipment such as pipelines in remote areas. In mining and agriculture, UAVs can be fixed with data collection units and mapping tools to conduct aerial surveys for mineral deposits, examine structural integrity of mine shafts, monitor crops and facilitate delivery of water and fertilizer. Commercial construction and civil engineering firms are able to map and monitor land and structures more rigorously with the assistance of drones, making them more resilient in the event of disaster.

A key benefit of drones is that they can remove human presence in dangerous situations. In the U.S., for example, the incredible demand to build and upgrade infrastructure for wireless networks has coincided with a high number of fatalities among communications tower climbers.31

Ninety-five tower climbers died on the job in the U.S. between 2005 and August 2015.32 Drones offer a viable means of

mitigating this human risk by removing the need for a climber in many circumstances, and perhaps saving as much as USD$9.2 million if only a single death is averted.33

Drones are also a valuable first response tool in the event of an emergency. The April 2015 study conducted by the American Red Cross and Measure32

Risk Assessment & Loss Prevention - Applications

concluded that “aerial drones are one of the most promising and powerful new technologies to improve disaster response and relief operations.”34

Drones “can provide needed aerial data in areas considered too hazardous for people on the ground or for manned aircraft operation, such as sites with nuclear radiation contamination or in close proximity to wildfires,” notes the report’s executive summary. “Drones can also deliver needed supplies and relay Wi-Fi and cellular phone service when communications are needed the most.”35

An essential question every business must answer before adopting a significant new technology in its operations is: What are the financial benefits of doing so? As part of the background work to shape its own drone policy and fulfill the mandate of the

FAA Modernization and Reform Act of 2012, the FAA looked for answers from

different industries. According to a February 2015 article in Forbes, a draft of an FAA policy paper—including economic analysis—that was inadvertently published online provides some compelling examples.36

Among the findings: “precision agriculture” applications such as using drones to target fertilizer delivery can reduce costs by USD$5 to $15 per acre for a crop like high yielding corn. This could create a potential savings of billions of dollars across the 309,607,601 acres of harvested cropland in the U.S. Similarly, there are about 45,000 annual bridge inspections in the U.S. that could benefit from a drone application, and thus achieve a significant cumulative benefit through lowering the average cost of USD$3,250 to complete a bridge inspection with a “snooper.”37

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Drones can remove the need

for tower climbers in many

circumstances, and perhaps

save as much as USD$9.2

million if only a single death

is averted.”

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Despite the risk mitigation opportunities drones offer as they become more widely integrated into society, they are viewed by some as a nuisance; to others, they are fraught with risk. The technology of small drones is still developing and relatively untested. Many UAVs currently in

commercial use are the same ones used by hobbyists, weighing less than 25 kg and required to fly under the 400-500 ft operating ceiling that a number of regulators have imposed. Operators are frequently ignorant of regulations or ignore them, and, unlike manned aircraft pilots, they lack training. A technology failure, system hack or operator error could easily cause a drone to collide with other aircraft, fall and injure people or damage property. With almost daily news reports of drone mishaps, the risks associated with their use are becoming more apparent, raising awareness of the need for organizations to have risk mitigation strategies in place. In 2014, for example, a drone operated by a professional photographer taking overhead shots of a sporting event in Australia crashed and injured a triathlete when she was just steps from the finish line. The event triggered an investigation by Australia’s Civil Aviation Safety Authority, which dictates that commercial drone operators obtain a license and must fly at least 30 m away from people.38 In July,

2014 an unidentified drone nearly collided with an Airbus A320 at 700 ft as it approached Heathrow Airport. Aviation authorities in the UK gave the incident an “A” rating, which indicates a “serious risk of collision.”39 More recently, five UAVs in

California got in the way of forest fire

fighting efforts, delaying water-carrying helicopters by 20 minutes, and hindering the rescue of multiple cars burning on an adjacent highway.40 Within days, California

State Senator Mike Gaines introduced a bill that would “grant immunity to any emergency responder who damages an unmanned aircraft in the course of firefighting, air ambulance, or search-and-rescue operations,” and another that would “increase fines and introduce the possibility of jail time for drone use that interferes with firefighting efforts.”41

Regardless of the size of the drone or the regulations by which an operator is governed, the critical thing to remember is that flying a drone is an aviation activity.42

Despite this, drones are not often treated with the same care and consideration as manned aircraft.

“The manned aviation world is a highly regulated, highly risk managed environment,” says Chris Proudlove, a senior vice-president at Global Aerospace Underwriting Managers Limited, a leading provider of aviation insurance, which partnered with Zurich on the development of its drones insurance package.43 “Before

each flight, the pilot performs a walk around, checks the fuel, fuselage and all control surfaces. Everything is verified and formally looked at before the engine starts. With the engines running, there are further checks to go through so that by the time the aircraft is sitting at the end of the runway ready for take-off, there is an exceptionally good chance of there not being a technical failure or malfunction during flight.”

Risks Associated with Drones

Flying a drone is an aviation

activity, but drones are not

often treated with the same

care and consideration as

manned aircraft.”

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This is not the case with many of the commercial drones currently in use. A $2,000 UAV purchased on the Internet can “be taken out of the box and be operational within minutes” by operators with no previous training in how to fly it, Proudlove says.

Another major consideration as more drones enter airspace is that collision-avoidance technology has not yet come far enough. Transponders that relay positon to ground radar, such as those used on manned aircraft, exceed the weight-carrying limits of smaller drones; and cameras with object-recognition processors are still line of sight-limited.44

“The technology for the vast majority of drone systems being operated has not been tested to the extent to which we can safely say that it’s acceptable to operate these things over people’s heads in a crowded environment,” says Proudlove. Operator error is another key risk factor. There are vast discrepancies among drone manufacturers about what is required to operate their products. There are some that will not let a drone leave the factory floor until the manufacturer knows that the people operating it have been trained, understand the technology and have the right amount of intricate knowledge of the product to operate it safely. “These manufacturers understand the importance of delivering a product that is safe and that their reputation relies upon it,” Proudlove says.

“due to their unique abilities and flexibility in the way in which they may collect information, ranging from acute and persistent tracking of individual activities to systematic surveillance of a wider area.”45

But for many in the general public, having cameras, thermal imaging devices and biometric recognition46 surreptitiously in

their space is an affront to their rights. As with aviation rules around UAVs, there is a broad variance of privacy rules in different jurisdictions. Compliance with these rules is bound to become more complicated as the technology the drones employ becomes more sophisticated. A report by the Office of the Privacy Commissioner of Canada found that commercial UAVs are covered under Canada’s existing privacy laws, specifically the Personal Information Protection

Electronic Documents Act (PIPEDA), which

governs data collection. Understanding and communicating these laws to civil and commercial operators, however, represents a unique challenge. In Canada, for example, “it is a common misconception that a company does not require permission to take an individual’s photograph in a public place.”47 Further,

the authors warn that advancements in smartphone technology, used in conjunction with UAVs to collect and share information, may reach beyond the scope of current privacy laws.

There are other risk factors that regulators may not have in their purview, such as control over payloads. In April 2015 in

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Although many risks of drone use remain unknown, understanding and preparing for the known or anticipated risks as summarized in this paper can help commercial entities integrate drones into their ERM plans successfully. In developing and launching its drones insurance package, Zurich drew upon the expertise of Global Aerospace and its leadership in this highly specialized market segment. For commercial customers looking to safely integrate drones into their operations, Zurich and Global Aerospace recommend a number of best practices for risk mitigation in five distinct categories:49 1. Training. UAV operators need to

understand the hazards involved with operating an airborne vehicle and be trained appropriately. Ideally, drone pilots should have extensive knowledge of aeronautical charts, meteorology and aerodynamics, as well as exceptional understanding of the aviation system they’re operating. A number of manufacturers offer training courses for potential operators of their products. Others offer in-depth manuals. The level of operator knowledge should be taken into consideration by commercial entities prior to deploying UAVs.

2. Safety management. Just as there are pre-flight checklists, logbooks and standard operating procedures (SOPs) for manned aircraft, an established safety management system (SMS) governing the use of UAVs is an integral part of risk mitigation.

Aviation experts advise that SOPs should encompass the following subjects:

Interaction between the operator and observer

Weather and environmental issues

Maintaining a safe distance from the UAS

Ensuring airworthiness of a drone

Pre and post-flight checklists.

3. Maintenance. In Britain, car drivers are required to get a Ministry of Transport (MOT) inspection annually on every vehicle more than three years old to verify its road worthiness.50 In much

the same way, some regulators are examining the potential of having regular safety checks conducted on commercial UAVs.51 In the absence of

regulation, common sense prevails. Companies need to have a maintenance schedule in place for their fleet of drones.

4. Environmental factors. A number of regulators require drones to maintain a certain distance from restricted areas, such as airports, government buildings and anywhere people gather. Fortunately, the market is on the verge of a technology solution to ensure this happens, in the form of geofencing, a signal that detects restricted areas and prevents UAVs from crossing the fence into them. For now, operators need to be vigilant in staying clear of the no-go zones specified by regulators.

5. Privacy. Inevitably, privacy laws will be adjusted to account for the growing number of UAVs flying overhead. Many current aviation laws prohibit the flight of UAVs in proximity to people. In the meantime, commercial users must respect rules related to maintaining a safe distance from people, capturing images, data or eavesdropping; ultimately, to operate the drones as they relate to privacy in an ethical manner.

Finally, as regulators around the world grapple with the challenge of integrating commercial drones into the airspace, a common feature of these rules is required minimums for liability insurance. Tailor-made insurance products have emerged on the market, in large part because of the exclusions for aviation activities that exist in most general liability policies. Companies that are bringing drones into their operations are advised to work with insurance and risk management providers that can help them understand and protect themselves from these new and evolving risks.

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In the relatively brief space of a little over a decade, drones have moved from the realm of an expensive novelty used almost exclusively by the military to become a highly commercialized and easily accessible commodity. The rapid growth of the technology has forced regulators around the world to try and keep pace with the demands of those looking to make use of UAVs, while still fulfilling their duty to protect public safety. Companies across a wide and growing array of industries have begun to see the many benefits UAVs can provide to their operations, especially in risk management tasks that involve reconnaissance, monitoring and inspection. For many of these companies and

industries, operating drones will mean they are engaging in an aviation activity for the first time, something that is likely outside of their core competencies. To achieve the full range of benefits drones can provide, organizations must gain a full appreciation of the risks they are also introducing to their operations when adopting this technology. Adapting basic procedures from the aviation industry and working with companies that can help customers understand and protect themselves from drone risks are critical factors in ensuring that, where opportunities with drones are concerned, the sky’s the limit.

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Sources

1 INEA Consulting “Global Commercial and Civil UAV Market Guide, 2014-2015,” 2014, p.7. http://renewablemarketwatch.com/news-analysis/170-global-commercial-and-civil-uav-market-guide-2014-2015-drones-in-renewable-energy-sector

2 Japan Times, “Regulating the Drone Revolution,” May 2, 2015.

http://www.japantimes.co.jp/opinion/2015/05/02/editorials/regulating-drone-revolution/#.VcIfpPlViko

3 The American Red Cross and Measure32, “Drones for Disaster Response and Relief Operations,” May 2015, p. 4.

This study was conducted with support from Zurich and seven other corporate sponsors and input from various public sector entities and U.S. state governments. http://www.zurichna.com/internet/zna/sitecollectiondocuments/en/rims/drones-for-disaster-response-relief-operations-study.pdf

4 Thomas Claburn, “Facebook Drone is Ready to Fly,” InformationWeek, Aug. 1, 2015 http://www.informationweek.com/mobile/mobile-business/facebook-drone-is-ready-to-fly/d/d-id/1321572

5 INEA Consulting, “Global Commercial and Civil UAV Market Guide, 2014-2015,” 2014. 6 John Horgan, “The drones come home,” National Geographic, March, 2013.

http://ngm.nationalgeographic.com/2013/03/unmanned-flight/horgan-text 7 Ibid

8 INEA Consulting, p.18 9 INEA Consulting, p. 7

10 Teal Group, “Teal Group Predicts Worldwide UAV Market Will Total $91 Billion in Its 2014 UAV Market Profile and Forecast,” Press release, July 17, 2014.

http://www.tealgroup.com/index.php/about-teal-group-corporation/press-releases/ 118-2014-uav-press-release

11 Transport Canada, “New rules for small unmanned aircraft,” Press Release, November 27, 2014

12 Geordon Omand, “Experts disagree on whether Canada’s drone regulations are too permissive,” The Canadian Press, August 16, 2015.

13 Dronelife, “The path to integrating drones into Canada’s skies,” July 16, 2015. http://dronelife.com/2015/07/16/the-path-to-integrating-drones-into-canadas-skies/ 14 *Small commercial drone operators are still required to apply to Transport Canada for

an exemption from the SFOC,*Transport Canada. https://www.tc.gc.ca/media/ documents/ca-standards/Infographic_Permission_to_fly_a_UAV_Print_English.pdf 15 Geordon Omand, “Experts disagree on whether Canada’s drone regulations are too

permissive,” The Canadian Press, August 16, 2015

http://www.canadianbusiness.com/business-news/experts-disagree-on-whether-canadas-drone-regulations-are-too-permissive/

16 European Commission, “European Commission calls for Tough Standards to Regulate Drones,” Press release, April 4, 2014. https://www.easa.europa.eu/system/files/dfu/ Commission_Press%20_release_Drones.pdf

17 UVS International, “RVAS Certification in Europe,” March 2014.

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18 The Federal Aviation Administration, “FAA Streamlines UAS COAs for Section 333 ,” March 24, 2015. https://www.faa.gov/news/updates/?newsId=82245

19 The American Red Cross and Measure, “Drones for Disaster Response and Relief Operations,” May 2015, p. 5.

20 The Federal Aviation Administration, “Fact Sheet – Unmanned Aircraft Systems (UAS),” January 6, 2014. https://www.faa.gov/news/fact_sheets/news_story.cfm?newsId=14153 21 The Federal Aviation Administration, “It’s (a) grand! FAA Passes 1,000 UAS Section 333

Exemptions,” News release, August 4, 2015. https://www.faa.gov/news/ updates/?newsId=83395

22 The Federal Aviation Administration, “FAA Streamlines UAS COAs for Section 333,” March 24, 2015. https://www.faa.gov/news/updates/?newsId=82245

23 Gregory S. McNeal, ”Leaked FAA Document Provides Glimpse Into Drone Regulations,” Forbes, February 14, 2015. http://www.forbes.com/sites/gregorymcneal/2015/02/14/ the-faa-may-get-drones-right-after-all-9-insights-into-forthcoming-regulations/ 24 The Federal Aviation Administration, “Busting Myths about the FAA and unmanned

aviation,” March 7, 2014. http://www.faa.gov/news/updates/?newsId=76240 25 Association for Unmanned Vehicle Systems International, “The Economic Impact of

Unmanned Aircraft Systems Integration in the United States,” March, 2013, p.3. https://

higherlogicdownload.s3.amazonaws.com/AUVSI/958c920a-7f9b-4ad2-9807-f9a4e95d1ef1/UploadedImages/New_Economic%20Report%202013%20Full.pdf 26 The American Red Cross and Measure32, p.12.

27 Joel Ruben, “LAPD adds drones to arsenal, says they’ll be used sparingly,” LA Times, May 30, 2015. http://www.latimes.com/local/lanow/la-me-ln-lapd-adds-drones-to-arsenal-20140530-story.html

28 http://www.draganfly.com/uav-helicopter/draganflyer-x6a/specifications/ 29 Ruben, op cit.

30 Office of the Privacy Commissioner of Canada, “Drones in Canada: Will the

proliferation of domestic drone use in Canada raise new concerns for privacy?” March 2013, p.10. https://www.priv.gc.ca/information/research-recherche/2013/

drones_201303_e.pdf

31 Liz Day, “Feds to Look Harder at Cell Carriers When Tower Climbers Die,” ProPublica, April 1, 2014. http://www.propublica.org/article/feds-to-look-harder-at-cell-carriers-when-tower-climbers-die

32 Wireless Estimator, “U.S. Tower Structure Related Fatalities,” http://wirelessestimator. com/content/fatalities

33 Gregory S. McNeal, ”Leaked FAA Document Provides Glimpse Into Drone Regulations,” Forbes, February 14, 2015. https://docs.google.com/file/d/0B5zlqyqHUl3_

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Zurich Canada www.zurichcanada.com 416-586-3000

The Zurich logo and Zurich are trademarks of Zurich Insurance Company Ltd The information in this publication was compiled from sources believed to be reliable for informational purposes only. All sample policies or procedures, or both, discussed herein should serve as a guideline, which you can use to create your own policies and procedures. We trust that you will customize these samples to reflect your own operations and believe these samples may serve as a helpful platform for this endeavour. Any and all information contained herein is not intended to constitute legal advice and accordingly, you should consult with your own legal counsel when developing programs and policies. We do not guarantee the accuracy of this information or any results and further assume no liability in connection with this publication and sample policies and procedures, including any information, methods or safety suggestions contained herein. Moreover, Zurich Canada reminds you this cannot be assumed to contain every acceptable safety and compliance procedure or that additional procedures might not be appropriate under the circumstances. The subject matter of this publication is not tied to any specific insurance product

38 BBC News, “Australian athlete injured after drone crash,” April 7, 2014 http://www.bbc.com/news/technology-26921504

39 Robert Pigott, “Heathrow plane in near miss with drone,” BBC News, December 7, 2014. http://www.bbc.com/news/uk-30369701

40 Michael Martinez, “Above spectacular wildfire on freeway rises new scourge: drones,” CNN, Jul. 18, 2015. http://www.cnn.com/2015/07/18/us/california-freeway-fire/

41 “Senator Gaines adds new protections for emergency responders from drone threat,” News release, July 20, 2015 http://gaines.cssrc.us/content/senator-gaines-adds-new-protections-emergency-responders-drone-threat

42 As an aviation activity, operating a drone will fall under the aviation exclusions of most general liability insurance policies. See press release “Zurich Canada launches drone insurance package for corporate clients.”

http://www.zurichcanada.com/can/sitecollectiondocuments/english/homepage/ press_release_zurich_drone_insurance_1april2015_engandfr.pdf

43 Zurich’s Drones Insurance Package is currently available in Canada only. 44 The Economist, “The Robot Overhead,” Dec. 6, 2014. http://www.economist.

com/news/technology-quarterly/21635326-after-starting-their-career-armed-forces-drones-are-now-entering-civilian

45 The Office of the Privacy Commissioner of Canada, p. 10. 46 Ibid.

47 Ibid.

48 The Japan Times, “Regulating the Drone Revolution,” May 2, 2015. http://www.japantimes.co.jp/opinion/2015/05/02/editorials/regulating-drone-revolution/#.VcIfpPlViko

49 Chris Proudlove, “Unmanned Aviation Risk Management, Accident Prevention and Insurance,” 2015, Global Aerospace.

50 GOV.UK, “When to get an MOT,” September 11, 2015. https://www.gov.uk/getting-an-mot/when-to-get-an-mot 51 Proudlove, op cit., p. 4.

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