Civil aviation has, traditionally, been based on the notion of a pilot operating the aircraft from within the aircraft itself and more often than not with passengers on board. Rapid technological innovations have enabled pilotless aircraft which can be designed for specific applications that require precision or long duration which have been considered near impossible hitherto. These aircraft also enable applications considered dull, dirty or dangerous, in other words, tasks that entail monotony or hazard for the pilot of a manned aircraft. Such pilotless aircraft make use of a ground-based or pre-programmed automatic controllers to manoeuvre the aircraft in flight and are generally termed as drones, although a better term is Unmanned Aerial Systems (UAS). Traditionally, drones had been limited to military use due to high costs and technical sophistication. However, there is a far broader scope for UAS use, including, inter alia, commercial, scientific and security applications. These potential applications have driven innovations in UAS technology; especially in areas of control, navigation and energy storage; which have provided consumers with suitably small-sized cutting-edge products that are easy to operate and maintain at affordable prices. Today, due to economies of scale, consumers can purchase drones for less than a thousand rupees. Even sophisticated drones with advanced cameras and sensors are available for under fifty thousand rupees. Large aircraft manufacturers such as Boeing and Airbus, on the other hand, are investing billions of dollars in building pilotless aircraft that are regarded safe enough for passenger long-distance intercontinental trips. The main goal of building a Concept of Operations for India on the way to a thriving drone ecosystem in India was to allow consistent policymaking that would guide technological standards in the near future. We intend to establish a discussion with stakeholders and continue to improve our vision by holding Open House Sessions. Guiding Principles, Specs, Key Resources: https://sayandeep-ai.github.io/pushpaka/work-items/i01/ Entire Playlist of the Open House Recordings: https://youtube.com/playlist?list=PL9dBcOUIsjz8FNN_FesZiD2WlFAQW-I01

1. Concept of Operations
for Unmanned Aircraft Systems
in
India
An Interactive Session by iSPIRT Foundation
Team Pushpaka
Amit Garg, George Thomas, Hrishikesh Ballal, Manish Shukla, Sayandeep
Purkayastha, Siddharth Ravikumar, Siddharth Shetty.

2. 2
30 yr Architects
10 yr Planners
5 yr Doers
• Think Tanks
• Universities
• Research Labs
• VCs
• Policy Makers
• Incumbents
• Challengers
iSPIRT Foundation: a non-profit Tech Think-and-Do Tank
Driving 30-year Orbit Shifts
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3. PUSHPAKA
Outline
1. Introduction
Speaker: Sayandeep
Applications, evolving regulations, missing pieces and addressing these
2. Concept of Operations
Speaker: George
A piece that should inform policy making, categorisation
3. Implementation
Speaker: Hrishikesh
From concept to practice, short and long term roadmaps
4. Q&A with Pushpaka team
Coordinator: Hrishikesh
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4. PUSHPAKA
For Q&A
⬆Concept of Operations article
Scan ➡ to send us your queries
suggestions and notes
via our Feedback form
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5. PUSHPAKA
Drones for the Indian Society
► Geospatial Mapping: Drones can be a decisive force multiplier for
resource/ infrastructure planning for India’s growing needs through
geospatial surveys. Besides providing enhanced accuracy and safety,
drone surveys:
● Reduce the cost and time for a survey
● Provide increased data accuracy
● Provide easier access to hard reach areas
● Enable Automatic pre-programmed 2D and 3D mapping
● Enable specific applications such as mining through special sensors.
► Precision Agriculture: These practices allow fine-scale monitoring and
mapping of yield and crops providing more intense and efficient cultivation
methods by adjusting fertilizer or pesticide prescriptions. In turn, significant
cost and environmental savings can be made making Indian agriculture
globally competitive besides enhancing the quality of crops for domestic
consumption.
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6. PUSHPAKA
Drones for the Indian Society
► Efficient Last Mile Logistics: Drones can arguably be considered
the best solution for India’s last mile logistics issues given the traffic
congestion in our urban areas and limited infrastructure in the
hinterland. Cost effective and timely delivery of critical items such
as medical supplies, besides the promise of urban air mobility, are
veritable boons for India.
► Security Applications and Innovations: India has lagged in
defence research and development which has been the driver for
many new age technologies through agencies such as DARPA. We
are slow off the mark but our technological base is well positioned
to provide an ideal launchpad for cutting edge innovations in this
field which will help not only address our unique security challenges
but also establish market leadership for global sales.
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7. PUSHPAKA
Evolution of Drone Regulations in India
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8. PUSHPAKA
Evolution of Drone Regulations in India
STILL AWAITED after 7+ years!!
○ Technical Specifications/Standards
○ Reference Implementations
for
○ Assembly, Design and Manufacturing
○ Pilot Licensing
○ Remote ID
○ Unmanned Traffic Management ecosystem
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9. PUSHPAKA
Food for Thought
► Requirement of Type Certificate: Drone Rules 21 mandate
airworthiness certification for drones whereas, appropriate
standards have not been notified.
► Lack of Airspace Integration Vision: Drone Rules 2021 lack
provisions for eventual integration of drone operations alongside
manned aircraft.
► Business confidentiality must be preserved: The prescribed rules
for access to data are not in consonance with the Supreme Court
Right to Privacy Judgement
► Lack of transparent Import Policy: Places severe restrictions on
the import of critical components thus disincentivizing indigenous
development of drones in India
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10. PUSHPAKA
Food for Thought - Continued
► Insurance & Training must be market-driven: Market forces must drive the
setting up of specialised training schools & insurance products & once
mature they may be mandated & accredited. This will result in the creation of
higher quality services & a safer ecosystem.
► Fostering innovation and becoming Atmanirbhar:
Encouraging R&D: by earmarking airspace for testing for future drones
Encouraging the domestic drone manufacturing industry: through a
system of incentives and disincentivizing imports should be inherent in the
Drone Rules.
Recognition of Hobby flying: Hobbyists are a vital part of the innovation
ecosystem; however, they are not adequately recognised and legitimized
► Encouraging A Just Culture: Effective root cause analysis would
encourage a safety-oriented approach to drone operations. Penal actions
should be the last resort and dispute resolution should be the focus.
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11. PUSHPAKA
Food for Thought - Continued
► Enabling Increased Safety & Security: Clarity on NPNT
operationalisation would enhance safety and security manifold.
► No Clear Institutional Architecture: Like GSTN, NPCI, NHA, ISRO,
etc a special purpose vehicle must be created to anchor the
long-term success of drone operations based on an established
concept of operations
► Lack of a Concept of Operations: Although drone categories have
been defined, they have not been used adequately for incremental
permissions. Failure to adopt an incremental approach can arguably
be considered as one of the root causes of the drone policy failures
till date in India as regulations are being framed for too many varied
considerations without adequate experience in any.
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12. PUSHPAKA
What is a ‘Concept of Operations’?
► A Concept of Operations (ConOps) is a user-oriented document that
describes characteristics for a proposed system from an integrated
point of view to stakeholders.
► It is produced early in the requirements definition phase to describe
what a system will do (not how it will do it) and the design rationale.
► The purpose of a ConOps is to describe the operational needs, desires,
visions, and expectations of the user without being overly technical or
formal.
► It defines any critical objectives and performance requirements.
► ConOps is useful for obtaining consensus among the users and all
other stakeholders on the operational concept of a proposed system.
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13. PUSHPAKA
Why a ConOps for Drones in India Now?
► New field – limited information
► Can have a huge public impact
► Sub-optimal progression of UAS Policy
► No effective operations despite huge market
► Globally, most of the significant policy progress has come based
on defined ConOps e.g. FAA, EASA and ICAO
► Help build consensus for policy faster
► Enable simultaneous addressing of multifarious bottlenecks
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14. PUSHPAKA
A flow that works!
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Concept of
Operations
Policy
Technical
Standards /
Specifications
Reference
Implementation

15. PUSHPAKA
Drones vs UAS vs RPAS vs Model
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► Drones – common/layman terminology for Unmanned Aircraft
(UA)
► There are three subsets of Unmanned Aircraft :
► Unmanned Aircraft
► Remotely Piloted Aircraft, and
► Model Aircraft.
► Unmanned aircraft system (UAS) – an unmanned aircraft and
its associated elements, operated with no pilot on board. Kept
away from manned aircraft by airspace restrictions
► Remotely piloted aircraft (RPA) - unmanned aircraft, actively
piloted from a remote pilot station. Can use same airspace but
subjected to same safety standards as manned aircraft

16. PUSHPAKA
ICAO : UAS vs RPAS
icao.int/safety/UA/UASToolkit/Pages/FAP.aspx
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17. PUSHPAKA
Model Aircraft
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► Model Aircraft - UA without payload used for educational/
recreational purposes only.
► Generally model aircraft must meet the following criteria:
▪ Be capable of sustained flight in the atmosphere
▪ Be flown within visual line-of-sight of the person operating it
▪ Be flown for hobby or recreational purposes
▪ Not be flown over people or near aerodromes
► Payload - All equipment on board a UAV that are not needed
for the flight or its control. It aims exclusively to fulfill a specific
mission. Thus payload has minimal impact on class of drone
except that smaller drones can’t carry larger payloads

18. PUSHPAKA
UAS in India
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● UAS in India are currently categorized in accordance with
MTOW (including payload) as indicated below:
○ Nano : Less than or equal to 250 grams.
○ Micro : More than 250 grams & less than/ equal to 2 kg.
○ Small : Greater than 2 kg & less than or equal to 25 kg.
○ Medium : More than 25 kg & less than/ equal to 150 kg.
○ Large : Greater than 150 upto 500 kg.
However no difference in regulations for Small - Large categories;
no mention of RPAS and no provisions for Models or Operational
categories
● Use of the terms needs serious review in order to align with
the international community and better compliance

19. PUSHPAKA
UAS Applications
⎆ Aerial Photography and Videography
⎆ Survey and Mapping
⎆ Inspections of critical infrastructure
⎆ Surveillance
⎆ Agricultural Services
⎆ Cargo Delivery
⎆ Search and Rescue
⎆ Public Security
⎆ Disaster Relief and Disease Control
⎆ Science and Research
⎆ Entertainment
Majority of these
applications can
be achieved
using small
Rotary Wing
UASs though
some of them
may benefit from
fixed wing or
larger UASs
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20. PUSHPAKA
Guiding Principles for Developing Regulations
⚙ Efficiency
⚙ Safety
⚙ Security
⚙ Infrastructure Constraints
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21. PUSHPAKA
Efficiency
► Regulations need to be UAS-centric and not lean too heavily on
traditional manned aviation.
► Simple regulations with minimal compliance costs needed in order
to
provide a fillip to the industry
attract investments
encourage legitimate use
Provide time for evolution of standards and ensuring compliance
► Efficient regulations enable
development of market capacity and further innovations
reduced gestation period for SMEs
*wider spectrum of users
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22. PUSHPAKA
Safety
► UAS should be progressively integrated into the existing aviation
system in a safe and risk-proportionate manner
► UAS Regulations must
minimize risk to safety of people and assets
meet India’s ICAO obligations towards safety
meet the safety and operational standards applicable to manned aircraft
when operating in non-segregated airspace
► Alternately, initially, UAS operations must be restricted to
specific conditions e.g. visual line-of-sight (VLOS); or
segregated airspace outside the operational ambit of manned aircraft; or
specific areas e.g. away from heavily populated areas
► Rules must express objectives, complemented by industry standards
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23. PUSHPAKA
Security
► India has long history of sub-conventional warfare in the form of
anti-national activities.
► UAS are ideal tool for disgruntled elements
► Potential saturation of our security establishment in
differentiating between the ‘good’ and the ‘bad’ actors
► Use of UAS need initially be limited to categories that are
easily identified
incapable of significant harm
► Protection of public interests, such as personal privacy*
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24. PUSHPAKA
Infrastructure Issues
► Development of UTM concepts and infrastructure is crucial for large
scale UAS use
► UAS Traffic Management based on:
Each UAS transmitting a unique remote ID with a geo tracking feature
Unmanned Traffic Management Systems for Very Low Level segregated
airspace accommodating exclusive UAS traffic
UAS in non-segregated controlled airspace need to additionally meet
manned aircraft standards
► UAS integration in non-segregated airspace will pose challenges
► Development of the UAS market and related technologies needs to
be carefully monitored and the planning adapted, for integration
► Availability of telecom spectrum is fundamental to UTM
infrastructure
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25. PUSHPAKA
Suggested ConOps for India
● Incremental Approach so that
○ Operations commence asap
○ Risks minimized
○ Growth moderated to manageable limits
● Risk and Capability Based Approach
○ Category A – Basic UAS Operations with Least Risk
○ Category B – Productive Operations Minimal Risk
○ Category C – Advanced UAS Operations posing Intermediate Risk
○ Category D – Full Range Regulated UAS Operations with Risk Mitigation
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26. PUSHPAKA
Category A
● Least risk and require the least infrastructure e.g. small UAS for
photography or videography.
● Suggested operational boundaries :-
○ Operations in Visual Line of Sight (VLOS) only
○ Operations at a safe distance away from people, animals,
infrastructure and aerodromes
○ Operations in segregated airspace only till a specified maximum
height above ground level (AGL)
○ The UAS capability is limited by design within specific
performance limits such as mass, speed, ceiling, rate of climb,
rate of descent etc
○ No UTM support required.
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27. PUSHPAKA
Category B
► Operations unlikely to result in a fatality or cause serious injury/
damage to persons or infrastructure on ground. e.g. small UASs
for survey or agricultural purposes.
► Operations subject to limited regulatory restrictions that protect
other airspace users and life/ property on ground.
► Require supporting UTM infrastructure but can be undertaken
without UTM in a more restricted way.*
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28. PUSHPAKA
Category B - Continued
Cat B operational boundaries defined as follows:-
● Operations by a qualified remote pilot only
● Operations in Visual Line of Sight (VLOS) or extended VLOS only.
● Operations at a safe distance from people, animals, buildings and
aerodromes.
● Operations in segregated airspace only
● Operations not involving carriage of dangerous goods or articles
● UAS must have mandatory identification features
● UAS capability limited by design within specific performance limits e.g.
mass, speed, ceiling, rate of climb, rate of descent etc
● Only in fair weather conditions and away from security sensitive areas
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29. PUSHPAKA
Category C
► Operations utilizing larger and/or heavier UAS with more payload
capacity but posing no challenge to manned aircraft e.g. BVLOS
operations in segregated airspace for package delivery
► Low potential to cause fatality or injury to persons on the ground
► Safety challenges limited by restriction to segregated airspace
► Operations with limits such as payload, pilot qualifications, airspace
restrictions, altitudes, airspeed, proximity to aerodromes and
congested/populated areas
► Specific Risk Assessment based authorisation, that will lead to
specific limitations, adapted to the operation
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30. PUSHPAKA
Category C - Continued
Operational limitations include:-
● Operations by a trained remote pilot only
● Operations at a safe distance from people, animals, buildings and
aerodromes
● Operations in segregated airspace only
● UAS should have mandatory safety, identification and tracking features
conforming to specified standards
● Enhanced UAS capability but limited by design within specific limits
such as mass, speed, ceiling, rate of climb, rate of descent etc
● Operations subject to availability of adequate UTM infrastructure
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31. PUSHPAKA
Category D
► Advanced applications with negligible restrictions on size, the
area or complexity of operation or use of airspace e.g. Air Taxi
operations
► Includes, with appropriate mitigations, BVLOS operations within
controlled airspace.
► UAS should conform to well established design characteristics
► Would require significant risk mitigation measures
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32. PUSHPAKA
Category D - Continued
► Operators to have an adequate management structure to ensure
safe operations
► Licensed remote pilots who are issued licences after successfully
completing practical training requirements, pass knowledge tests,
meet specific medical standards and age requirements
► UAS will need to be maintained in a safe state for flight and be
subject to design standards or other airworthiness certifications
► The aircraft may need to be marked and registered and be able to
be tracked continually
► Operational rules applicable to this category of operations could be
extensive
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33. PUSHPAKA
Implementing the UAS ConOps
Immediate
Permit Cat A and
Restricted Cat B till
UTM in place
VLOS operations in
segregated airspace
with no special
requirements
Enables Hobby, Video/
Photography and limited
agricultural & mapping
activities immediately
Short Term
Establish UTM for
segregated airspace
BVLOS operations in
segregated airspace
CATB + CAT C Operations
Enables large scale mapping,
survey, delivery and full scale
agricultural ops
Medium Term
Integrated UTM/ATM
Specify Design Standards
for Advanced UASs
Full range of UAS Ops
Enables UAM, Large Scale
Cargo and special ops
including by night
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34. PUSHPAKA
Suggested Rules for Cat A Ops
► UA with a gross mass of 2 kg or less, and
► UA is designed to minimise chances of injury to any person in case
of accidental collision; and
► UA is operated always within VLOS; and
► UA is operated at or below 60 m (200 ft) AGL by day only; and
► UA is operated at a safe distance from a person or animal not
directly associated with the operation of the UA; and
► UAS is not operated in a prohibited or restricted area; and
► UA is not operated in an airspace notified for use by manned aircraft
without prior approval of the controlling authority for such airspace;
and
► UAS is used only for hobby flying or photography/ videography.
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35. PUSHPAKA
Suggested Rules for Restricted Cat B Ops
► UA with a gross mass of 25 kg or less; and
► UA uses primarily vertical axis rotors to generate its propulsion; and
► UA is designed to minimise chances of injury to any person in case
of accidental collision; and
► UAS is operated by a remote pilot authorised for the operation; and
► UA is operated always within VLOS or enhanced VLOS; and
► UA is operated at or below 120 m (400 ft) AGL by day only; and
► UA is operated in suitable weather conditions; and
► UA is operated at a safe distance away from people, animals,
buildings and aerodromes; and
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36. PUSHPAKA
Suggested Rules for Restricted Cat B Ops
► UA is not involved in the carriage of any parcel or jettisonable load
in excess of 5 kgs; and
► UAS is not operated in a prohibited or restricted area; and
► UA is not operated in an airspace notified for use by manned aircraft
without prior approval of the controlling authority for such airspace;
and
► the remote pilot is able to access web-based updates on any flying
restrictions that may have been imposed over the intended area of
operations before commencing the flight; and
► UAS is not operated within 25 kms of India’s international borders or
5 kms of India’s coastline without the prior sanction of the
appropriate law enforcement authority.
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37. PUSHPAKA
Suggested Rules for Design and Manufacturing
► DGCA / QCI follow design standards for UAS in the micro, small, medium
and large categories.
► Standards for micro and small UAS operations in Cat A or Restricted Cat
B on immediate basis
► UAS incapable of infringing stipulated height and permanent geographical
restrictions by design.
► UAS manufacturers, domestic or foreign, to prove that their UAS
conforms to stipulated design and equipment standards for marketing
their UAS.
► Manufacturers accountable in case of any manufacturing or design
defects.
► Manufacturers to imprint a unique ID to ensure traceability of the UAS.
► Manufacturers and traders to maintain record of every transaction of UAS
or components to ensure UAS traceability given our security paradigm.
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38. PUSHPAKA
Suggested Regs for Remote Pilot
Authorisation
► No requirement of remote pilots to undergo any other formal
training for Category A or Restricted Category B operations –
immediate.
► Online examination conducted at authorised centres through
professional organisations with desired level of quality in the
process.
► Need to rationalise training needs and costs based on risk
assessment.
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39. PUSHPAKA
Suggested Regs for Remote Pilot
Authorisation
► Practical training under own arrangements for Category A or
Restricted Category B operations. E.g. Online videos etc.
► Category B operations require pilot to obtain authorisation after
undergoing an online DGCA/ QCI certified course. The course
followed by an online examination enables authorisation – to be
developed in short term.
► Category C and D need specific training and licensing – to be
evolved in medium term.
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40. PUSHPAKA
Action Plan: Enabling the Ecosystem -
Immediate
► Airworthiness Compliance requirements be removed till published
► Operations be permitted for Category A and Restricted Category B
► Remote Pilot training requirements be simplified for Cat A and B as
a priority
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41. PUSHPAKA
Action Plan: Enabling the Ecosystem -
Immediate
► Guiding principles for Import policy formulation be laid out to
incentivise import drone parts and de-incentivise drone models
► Insurance be not mandated for any drone categories
► Enhanced privacy be applied for DigitalSky data access that
restricts abuse technically
► The provision for setting up the Drone Promotion Council be
subsumed by a SPV
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42. PUSHPAKA
Action Plan - Setting up the Long Term
Ecosystem
● NPNT be re-notified as a bedrock requirement for operational control
● An SPV outside of entrenched institutions be set up with a charter to
○ Envision India’s concept of aviation operations for the next few decades
○ Formulate Future Policy including:
■ Maintenance / Development / update of ConOps
■ Track / develop / customize International standards
■ Establish Standards for Airworthiness and Flight Training
○ Develop & operationalise DigitalSky in an open, collaborative fashion
○ Establish an Advisory Committee with equitable membership of stakeholders
○ Address all charter items of the Drone Promotion Council
○ Lay a legal framework for drone data privacy
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43. PUSHPAKA
For Q&A
Scan to send us your queries,
suggestions and notes
via our Feedback form
43

44. PUSHPAKA
References
● Concept of Operations Version 1: https://sayandeep-ai.github.io/pushpaka/work-items/i01
Published Aug 7, 2021 by Pushpaka group
● Commentary on the Draft Rules 2021: https://pn.ispirt.in/ispirt-response-drone-rules-2021
Published Aug 7, 2021 on iSPIRT Blog post: pn.ispirt.in
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