Functional Hazard Assessment (FHA) Report for Unmanned Aircraft Systems

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1 Distribution: EUROCONTROL Ebeni Holger Matthiesen Hayley Burdett Unmanned Aircraft System (UAS) Safety Case Development Chris Machin Joanne Stoker Don Harris Alan Simpson Functional Hazard Assessment (FHA) Report for Unmanned Aircraft Systems Reference: Date: 04 September 2009 Issue: v1.0 Prepared by: Hayley Burdett Checked by: Joanne Stoker Authorised by: Alan Simpson Commercial in Confidence

2 Mike Strong Project File Commercial in Confidence Page 2 of 81

3 Copyright The layout, style, logo and contents of this document are copyright of Ebeni Limited No part of this document may be reproduced without the prior written permission of Ebeni Limited. All rights reserved. Configuration Control Issue Date Comments v June 2009 Initial draft for internal review v July 2009 Draft issue following internal review v July 2009 Provisional issue for EUROCONTROL review v Sept 2009 Definitive issue incorporating EUROCONTROL review comments Commercial in Confidence Page 3 of 81

4 Table of Contents 1 Introduction Background UAS Safety Assessment UAS Today Aim Scope Structure 8 2 Functional Hazard Assessment Overview Introduction FHA Process FHA Objectives UAS Safety Assessment Workshop 10 3 System Definition and Scope of Analysis UAS Operational Scenarios Defining the Scope for the FHA Activity Air Traffic Management Concept Separation Provision Component Collision Avoidance Component Operational Perspectives UAS Characteristics Scoping Statements Assumptions Unmanned Aircraft System Models Flight Profiles Functional Models 21 4 Function Hazard Assessment Results Overview Hazard Identification Approach Hazard Identification Results Consequence Analysis Mitigations for HAZ Mitigations for HAZ Mitigations for HAZ Mitigations for HAZ Mitigations for HAZ Mitigations for HAZ Mitigations for HAZ Mitigations for HAZ Mitigations for HAZ Mitigations for HAZ Analysis Conclusions 33 Commercial in Confidence Page 4 of 81

5 4.6 Safety Objectives 33 5 Conclusions 35 6 References 36 Appendix A UAS Safety Assessment Workshop Agenda and Participants 37 A.1 UAS Workshop Agenda 37 A.2 UAS Workshop Participants 38 Appendix B Unmanned Aircraft System Models 39 B.1 Flight Profiles 39 B.2 Functional Models 41 Appendix C Functional Failure Analysis 42 Appendix D UAS Fault Trees 50 D.1 UAS Scenario 1 Fault Trees 50 D.2 UAS Scenario 2 Fault Trees 62 Appendix E Severity Classification 69 Appendix F Consequence Models 70 F.1 HAZ001 Inability to comply with Separation Provision Instruction from ATC 70 F.2 HAZ002 Incorrect response to Separation Provision Instruction from ATC 71 F.3 HAZ003 Intentional deviation from Separation Provision Instruction from ATC 72 F.4 HAZ004 Delayed response to Separation Provision Instruction from ATC 73 F.5 HAZ005 Loss of Separation Provision from ATC 75 F.6 HAZ006 ATC Separation Provision Error 77 F.7 HAZ007 Loss of Separation Provision from the Pilot in Command 78 F.8 HAZ008 Pilot in Command Separation Provision Error 79 F.9 HAZ009 Pilot in Command Separation Provision Instruction too late 80 F.10 HAZ010 Separation Provision minima is breached by other aircraft 81 Commercial in Confidence Page 5 of 81

6 1 Introduction 1.1 Background The evolution of aerospace technologies in the field of Unmanned Aircraft Systems (UAS), including automatic/autonomous operations, will impact European Air Traffic Management (ATM) as regards new military and civil UAS applications. UAS will represent new challenges as well as new opportunities for ATM design in the future in the context of both SESAR and beyond (vision 2050), for the benefit of both manned and unmanned aviation. The EUROCONTROL Agency, in executing its responsibilities associated with the management of the pan-european ATM network, must ensure that UAS do not negatively impact overall levels of ATM security, safety, capacity and efficiencies. This work will result in the development of an ATM safety assessment for UAS that will identify a set of ATM safety requirements, over and above existing ATM regulatory safety requirements, which, if implemented, will ensure that the introduction of UAS into non-segregated airspace will be acceptably safe. 1.2 UAS Safety Assessment The primary aim of this task is to develop an ATM safety assessment for UAS so as to identify a set of ATM safety requirements, over and above the existing ATM regulatory safety requirements, which, if implemented, will ensure that the introduction of UAS into non-segregated airspace will be acceptably safe. The safety assessment is to consider two defined UAS operating scenarios in order to provide a realistic context into which UAS will be operated. Scenario 1 covers UAS operations in Class A, B or C en-route airspace flying Instrument Flying Rules (IFR) beyond the visual line of sight of the pilot-incommand Scenario 2 covers UAS operations in Class C G airspace operating under Visual Flying Rules (VFR) and the pilot-in-command has direct visual line of sight of the Unmanned Aircraft (UA) The work currently being undertaken by EUROCAE Working Group 73 on Unmanned Aircraft Systems will also provide input and review effort to the safety assessment work. A UAS Safety Assessment Workshop was carried out to satisfy the process requirements of the EUROCONTROL ANS Safety Assessment Methodology (SAM) [1] which provides a means of compliance with the EUROCONTROL Safety and Regulatory Requirement (ESARR) 4 [2]. 1.3 UAS Today Current UAS operations are largely constrained to designated areas or within temporary restricted areas of airspace, commonly known as segregated airspace, or are flown under special arrangements over the sea or high altitude. On some occasions, UAS operations are permitted in an extremely limited environment outside segregated airspace. To exploit fully the unique potential of UAS there is a desire to Commercial in Confidence Page 6 of 81

7 1.4 Aim be able to access all classes of non-segregated airspace and operate across national borders and airspace boundaries. Such operations must be acceptably safe but regulation should not become so inflexible or burdensome that the benefits are unnecessarily lost. The viability of the civil market for UAS especially, is heavily dependent on unfettered access to the same airspace as manned civil aircraft operations, at least on like for like operations, for example in aerial surveillance applications. Whilst it is essential that UAS demonstrate an equivalent level of safety compared to manned operations the current regulatory framework has evolved around the concept of the pilot-in-the-cockpit. There is a need to develop UAS solutions that assure an equivalent level of safety for UAS operations, which in turn could require some adaption of the current ATM regulatory framework to allow for the concept of the pilotnot-in-the-cockpit without compromising the safety of other airspace users. This document comprises the for Unmanned Aircraft Systems operation in non-segregated airspace and provides an independent assessment of the hazards related to operating UAS in non-segregated airspace. The aim of this FHA is derived from the following top level safety argument claim, which implies a relative safety argument approach: UAS operations in ECAC Airspace are and will be acceptably safe; where ECAC airspace is defined as the airspace of the 44 ECAC Member States, and acceptably safe is defined as risks to other airspace users are: o o No higher than for equivalent manned operations; and Reduced to As Far As Reasonably Practicable (AFARP), as required by ESARR 3 [3] and European Air Traffic Management Programme (EATMP) Safety Policy [4]. 1.5 Scope The initial step in addressing the above claim is to specify safety requirements such that, subject to complete and correct implementation, UAS operations in nonsegregated airspace are acceptably safe. The aim of this FHA is therefore to understand the risk of UAS via the derivation of hazards and an analysis of the consequences of those hazards. The Functional Hazard Assessment work will support the development of a UAS Preliminary System Safety Assessment Report (PSSA) which will document UAS safety requirements and provide traceability to detailed safety requirements. This report covers the safety assurance activities undertaken to assess the safety of UAS operation in non-segregated airspace using two operational scenarios, up to the point where hazards have been identified and the consequence of those hazards assessed. Commercial in Confidence Page 7 of 81

8 Scenario 1 covers UAS IFR operations in Class A, B or C en-route airspace only. The mode of operation considered for this baseline scenario uses a command and control system architectures known as Radio Line Of Sight (RLOS) or Beyond Radio Line Of Sight (BRLOS). Scenario 2 covers UAS VFR operations based upon VLOS command and control systems in classes of airspace where VFR flight is permitted (Class C- G). VLOS operation requires the PIC to keep the UA in direct visual observation for the duration of the flight. This safety assessment work is carried out from an Air Traffic Management (ATM) perspective with the aim of requirement setting but is not concerned with the implementation of any such safety requirements. 1.6 Structure The Functional Hazard Assessment Report is structured as follows: Section 1 Introduction presents the scope and purpose of the report. Section 2 Functional Hazard Assessment Overview documents the objectives of the Functional Hazard Assessment along with the hazard identification and risk assessment methodology. Section 3 System Scope and Scope of Analysis provides an overview of the system under consideration and defines the scope of the analysis. Section 4 Functional Hazard Assessment Results documents the results of the Functional Hazard Assessment activity. Section 5 Conclusions presents the conclusions of the Functional Hazard Assessment. Section 6 References provides a list of referenced documents used in the report. Commercial in Confidence Page 8 of 81

9 2 Functional Hazard Assessment Overview 2.1 Introduction The EUROCONTROL Air Navigation Services (ANS) Safety Assessment Methodology [1] defines the objectives of a FHA as: 2.2 FHA Process a top-down iterative process, initiated at the beginning of the development or modification of an Air Navigation System. The objective of the FHA process is to determine: how safe does the system need to be? The process identifies potential functional failures modes and hazards. It assesses the consequences of their occurrences on the safety of operations, including aircraft operations, within a specified operational environment. The FHA process specifies overall Safety Objectives of the system, i.e. specifies the safety level to be achieved by the system. This FHA was performed in order to support a relative safety argument. The analysis aims to derive a set of hazards relating to UAS operating in non-segregated airspace. The first step in performing the FHA was to establish the scope and boundary of the system, understanding that the system covers all aspects of the ATM environment including people, procedures and equipment. In the context of the defined scope and system boundary, the analysis has focused specifically on the identification of: A Functional and Logical Safety Model representing UAS operations in each Scenario. Hazards that could arise from inter alia; functional failure, inadequacies, limitations, etc. The potential consequences of those hazards. The FHA process began with the construction of a number of models. Given the requirement to present a relative safety argument, it was important to fully appreciate the current situation with no UAS (referred to as without-uas ) as compared to the proposed situation with UAS flying in non-segregated airspace (referred to as with- UAS ). The models were constructed to aid the identification of potential hazards for which mitigation is required, see section 3.8 for more detail. The models along with the proposed scope, boundary and assumptions for the analysis were presented at a UAS Safety Assessment Workshop for validation and verification by domain experts. A hazard identification verification activity was also carried out as part of the UAS Safety Assessment Workshop. A number of issues, statements and discussion points were raised at the UAS Safety Assessment Workshop which were minuted in [5]. A number of these points have been used to justify or substantiate analysis decisions; these are referred to specifically throughout this document as originating from the workshop participants. Commercial in Confidence Page 9 of 81

10 The output from the UAS Safety Assessment Workshop has been taken and used to perform a more detailed analysis which has included consideration of consequences and mitigations. These hazard models will subsequently be used as the basis of the UAS Preliminary System Safety Assessment, which will derive the safety requirements for UAS operations in non-segregated airspace. 2.3 FHA Objectives The overall aims for the Functional Hazard Assessment as defined in section 1.4 are further refined to specific task objectives as discussed in the following list. Some of the objectives were addressed as part of the pre-workshop and workshop activities and others as part of the post workshop activities. The results of these activities are captured in this report. The objectives listed below apply to both scenarios. The detailed objectives were: review and agree the overarching UAS Safety Argument Strategy verify the scope and boundaries of the analysis being undertaken validate the Scenario, Functional and logical models identify the hazards as applicable to current manned operations (without- UAS) and proposed UAS operations (with-uas) in non-segregated airspace identify, the possible consequences of each hazard, taking into account the available mitigations, using Event Tree Analysis. 2.4 UAS Safety Assessment Workshop A UAS Safety Assessment Workshop was held at EUROCONTROL HQ, Brussels on Wednesday 29th April and Thursday 30th April Minutes from the workshop are recorded in [5]. The Agenda for the UAS Safety Assessment Workshop and a list of participants is provided in Appendix A. With respect to the above objectives, the UAS Safety Assessment Workshop achieved the following: Reviewed and agreed the overarching UAS Safety Argument Strategy. Verified the scope and boundaries of the analysis being undertaken. Validated the Scenario, Functional and Logical models for each UAS scenario. Identified the hazards associated with each scenario and the possible mitigations that are in place. The remaining objectives are all captured as part of the FHA results in section 4. Work from a previous EUROCONTROL project involving Military UAV as Operational Air Traffic (OAT) outside Segregated Airspace [6] was presented at the UAS Workshop as it was felt this was still applicable and provided a good starting point. This is discussed in more detail in section 4.1 Commercial in Confidence Page 10 of 81

11 3 System Definition and Scope of Analysis 3.1 UAS Operational Scenarios The concept of operating UAS in non-segregated airspace is expected to be transparent to the ATM environment. There are obvious differences between manned and unmanned aircraft, but in principle the UAS should operate to the same rules of the air and procedures that apply to manned aircraft. The safety of other airspace users depends on the UAS operations achieving at least an equivalent level of safety to manned aircraft. There are a wide variety of possible UAS operations and the safety aspects across the whole flight profile need to be assessed in order to assure those operations are acceptably safe. However, in order to focus this initial safety assessment, two UAS scenarios have been defined as described below. They were identified by the EUROCAE Working Group 73 as two of the most relevant near-term operational scenarios for UAS. The scenarios cover non-segregated operations but not for all flight stages and are subject to the assumptions listed later in section 3.7. Scenario 1 covers UAS IFR operations in Class A, B or C en-route airspace only. The mode of operation considered for this baseline scenario uses a command and control system known as either Radio Line Of Sight (RLOS) or Beyond Radio Line Of Sight (BRLOS). The operations shall take place beyond visual line of sight (BVLOS) of the UAS Pilot. The duration of any UAS operation is dictated by the demands of the task but under Scenario 1 can range from a few hours to a number of days. Figure 1 below represents Scenario 1 Figure 1 Scenario 1 Commercial in Confidence Page 11 of 81

12 Scenario 2 covers UAS VFR operations based upon VLOS command and control systems in classes of airspace where VFR flight is permitted (Class C- G). Operations in classes C-E airspace could include CTR and/or TMA. Class B CTRs and TMAs, where VFR is also permitted, have been intentionally not considered. VLOS operation requires the PIC to keep the UA in direct visual observation for the duration of the flight. The duration of any UAS operation is dictated by the demands of the task but under Scenario 2 range from a few minutes up to the available hours of daylight. Figure 2 below represents Scenario 2. Figure 2 Scenario Defining the Scope for the FHA Activity Prior to the FHA activity it was important to understand the differences between the without-uas and with-uas situations for each of the defined scenarios above in order to structure the analysis and support the relative assessment of risk. The scope of the safety assessment has thus been defined by: understanding the ATM concept and environment in which UAS will operate, see section 3.3. a number of operational perspectives, see section 3.4. understanding the characteristics of UAS, see section 3.5. Commercial in Confidence Page 12 of 81

13 a series of identified scoping statement and assumptions, see sections 3.6 and 3.7. a number of UAS models, see section Air Traffic Management Concept There are three main components of ATM, defined within the ATM Operational Concept Document [7] endorsed at ANC/11 in September 2003: Strategic Conflict Management Separation Provision and Collision Avoidance. Strategic Conflict Management encapsulates all pre-flight planning activities that take place to ensure demand, capacity and conflicts are managed prior to the real time situation. Figure 3 below shows the principle interactions between the Strategic Conflict Management, Separation Provision, Collision Avoidance components and the Airspace. Note that [7] also states that any Collision Avoidance System should be separate from but compatible with the Separation Provision component. Collision avoidance systems cannot be included in determining the calculated level of safety required for Separation Provision with regards the ESARR4 Target Level of Safety (TLS), however the Collision Avoidance function has been taken into account within this relative safety assessment due to the significant difference between the with- UAS and without-uas situations. Commercial in Confidence Page 13 of 81

14 Figure 3 High Level Functional Model The use of these terms is important within this analysis and has thus been defined in the following sections in relation to the defined UAS Scenarios Separation Provision Component Separation Provision (SP) is the tactical process of keeping aircraft away from other airspace users, obstacles, restricted airspace, etc. Depending upon the type of airspace and, where applicable the Air Traffic Control (ATC) service being provided, separation provision can be performed either by ATC (as regards separation assurance from other aircraft/airspace by at least an appropriate separation minimum) or by the Pilot in Command, dependent on the class of Airspace, the type of ATC service provided or the flight rules in force. Separation minima are defined for application by ATC in accordance with the airspace classification and the flight rules of each individual aircraft concerned. Manned operations where the PIC is responsible for SP generally have no specified minima, although the overarching rules of the air apply as the basic requirements. However, the MIL UAV specifications [8] have defined minima for unmanned operations whilst the PIC is responsible for SP. Scenario 1 - ATC is responsible for providing Separation Provision between the UAS and other airspace users. The SP Monitoring and Instruction functions are provided by an Air Traffic Controller. The pilot is wholly responsible for Commercial in Confidence Page 14 of 81

15 ensuring the UA Trajectory Compliance function of SP. The pilot is also responsible for separation from obstacles and terrain. Scenario 2 the PIC is responsible for Separation Provision. The Separation Provision monitoring and instruction functions are performed by the PIC, whereas Trajectory Compliance is performed by the UA Collision Avoidance Component The Collision Avoidance (CA) component is responsible for identifying when a potential collision threat is imminent, then identifying and implementing an avoidance action. The CA objective is to ensure that collision threats are avoided. The CA function acts irrespective of airspace classification, flight rules or who is responsible for SP. Scenario 1 - When Separation Provision is the responsibility of ATC, the CA is intended to act independently from the SP functions. In principle, the CA function should only act when SP has failed (i.e. there is a loss of separation) and then only to take collision avoidance action 1 if the actual distance is assessed as representing a collision risk. Equally, loss of separation assurance by ATC may not represent cause for initiation of a collision avoidance manoeuvre. The CA function is the responsibility of the PIC; however, the PIC may be supported by a CA system such as TCAS II 2. Note that ATC may still instigate collision avoidance action from a PIC but the responsibility remains with the PIC. Scenario 2 - When the PIC is responsible for SP then the independence between SP and CA functions is blurred as the pilot is effectively responsible for both. For manned operations the Closest Point of Approach (CPA) and separation minima are effectively the same, as minima are not usually specified. NOTE: The impact of this on mixed UAS and manned operations needs to be further assessed within the PSSA. If found to be problematic a safety issue will be raised. In relation to Scenario 1 SRC Policy Document [9] states that Collision Avoidance systems (referred to as Safety Nets) are not part of Separation Provision so must not be included in determining the acceptable level of safety required for Separation Provision. The SRC Policy Document statement implies that UAS must provide an equivalent level of interaction with the Separation Provision function as provided by Pilots. Furthermore the UAS Separation Provision System must maintain the level of safety (with respect to the scope of ESARR 4 [2]) without the need for a Safety Net. 3.4 Operational Perspectives Consideration of UAS operations in non-segregated airspace can be understood from a number of operational perspectives. Scenario 1 1 There are scenarios where the time needed to identify, resolve and take avoiding action is such that separation minima may not yet have been breached. 2 As a rule TCAS II Resolution Advisories take precedence over ATC instructions. Commercial in Confidence Page 15 of 81

16 o Separation Provision ICAO Airspace Classifications are contained in ICAO Annex 11 Air Traffic Services [10]. Table 1 below shows the level of ATC service provided for each airspace classification. Class Type of Flight Separation provided Service provided Radio communication requirements ATC Clearance A IFR only All aircraft Air traffic control service Continuous twoway Yes B IFR All aircraft Air traffic control service Continuous twoway VFR All aircraft Air traffic control service Continuous twoway Yes Yes C IFR IFR from IFR IFR from VFR Air traffic control service Continuous twoway Yes VFR VFR from IFR 1) Air traffic control service for separation from IFR 2) VFR/VFR traffic information Continuous twoway Yes Table 1 Level of ATC Service Provided o o o o Collision Avoidance is the PICs responsibility regardless of the airspace within which the UA is operating. ATS UAS Operational Flight Planning - it is required that a flight plan be filed to ATS for all Scenario 1 operations as they will be IFR in Class A, B or C airspace. Indication to ATC that the flight is unmanned will be through the use of specific UAS aircraft type designators. Communications voice communications are required between the PIC and ATC. Other airspace users will include manned IFR and VFR aircraft as well as other IFR UA. Scenario 2 o Separation Provision ICAO Airspace Classifications are contained in ICAO Annex 11 Air Traffic Services [10]. Table 2 below shows the level of ATC service provided for each airspace classification. Class Type of Flight Separation provided Service provided Radio communication requirements ATC Clearance C IFR IFR from IFR IFR from VFR Air traffic control service Continuous twoway Yes Commercial in Confidence Page 16 of 81

17 VFR VFR from IFR 1) Air traffic control service for separation from IFR 2) VFR/VFR traffic information Continuous twoway Yes D IFR IFR from IFR Air traffic control service including information about VFR flights (traffic avoidance on request) Continuous twoway Yes VFR Nil Traffic information between VFR and IFR (traffic avoidance on request) Continuous twoway Yes E IFR IFR from IFR Air traffic control service and traffic information about VFR flights Continuous twoway Yes VFR Nil Traffic information as far as practical No No F IFR IFR from IFR as far as practicable Air traffic advisory service; flight information service Continuous twoway No VFR Nil Flight information service No No G IFR Nil Flight information service Continuous twoway No VFR Nil Flight information service No No Table 2 Level of ATC Service Provided o o o o Collision Avoidance is the PICs responsibility regardless of the airspace within which the UA is operating. ATS UAS Operational Flight Planning it may not be necessary that a flight plan be filed with an ATS unit for VLOS operations Communications UAs under VLOS operation will communicate to all relevant parties through appropriate means according to the airspace classification. Other Airspace Users may include many users, such as hot air balloons, gliders, micro lights or other manned VFR as well as other VLOS UA. 3.5 UAS Characteristics UAS encapsulates the Unmanned Aircraft (UA) itself, the entirety of systems, people and procedures involved in the launch, control and recovery of the AV, including the ground station, the UAS crew, operational processes and flight crew procedures. To establish the potential differences in manned and unmanned operations, it is important to understand the specific characteristics of UAS that are potentially relevant to operations in non-segregated airspace. The UAS characteristics are depicted in Figure 4. Commercial in Confidence Page 17 of 81

18 A principle characteristic is that the means of UA Control is functionally separate from the UA. The Pilot in Command (PIC) of the UA will be remote from the UA in a UAS Ground Control Station (GCS). The PIC maintains control of the UA through a UAS Control System (UCS) and a UAS Control Link (UCL). This method of control is the same for Scenario 1 and Scenario 2. Figure 4 UAS Characteristics Model The key characteristics that can effect UAS operations are as follows: Conspicuity - the visibility of the UAV to other airspace users is an important component in the Collision Avoidance component as well as when Separation Provision is the responsibility of the PIC. This could be an issue for UAs that are smaller than manned aircraft, or UAs that present a poor signature for Primary Surveillance Radar. This may be especially relevant for Scenario 2 as the UA will be operating under 2000ft and may be small. Automatic Operations One of the key characteristics of a UAS is the ability to operate under various conditions without human interaction. The necessity for human interaction, along with other factors such as safety, mission complexity and environmental difficulty determines the level of automation that the UAS can achieve.. o o o Fully automatic A mode of operation of a UAS wherein the UA is expected to accomplish its mission, within a defined scope, without human intervention. Semi-automatic - A mode of operation of a UAS wherein the human operator and/or the UAS plan(s) and conduct(s) a mission and require various levels of human interaction. Teleoperation - A mode of operation of a UAS wherein the human operator, using video feedback and/or other sensory feedback, either Commercial in Confidence Page 18 of 81

19 directly controls the actuators or assigns incremental goals, waypoints in mobility situations, on a continuous basis, from off the UA and via a tethered or radio linked control device. In this mode, the UAS may take limited initiative in reaching the assigned incremental goals. o Remote control - A mode of operation of a UAS wherein the human operator, without benefit of video or other sensory feedback, directly controls the actuators of the UAS on a continuous basis, from off the vehicle and via a tethered or radio linked control device using visual line-of-sight cues. In this mode, the UA takes no initiative and relies on continuous or nearly continuous input from the user. Airworthiness the Airworthiness Certification of a UAS is outside scope of this analysis. However, it is assumed within the analysis that UAS will be fitted with certified equipment equivalent to that for manned operation in the intended non-segregated airspace, unless otherwise specifically stated, i.e. the UA will meet the defined minimum equipment requirements for the airspace and flight rules in force. Flight Performance the manoeuvrability of a UA is important to understand. Currently, Air Traffic Controllers are required to understand flight performance characteristics of the types of aircraft that come under their control and provide separation provision instructions based on this understanding. This requirement for understanding will also need to apply to unmanned operations to ensure ATC instructions can be implemented. Flight performance is particularly important when understanding if an UA could comply with an ATC Separation provision instruction or collision avoidance manoeuvre. 3.6 Scoping Statements The following scoping statements have been made to further support the safety assurance activity. Statements S0001 to S0007 were validated during the FHA workshop. Scope S0001 Scope S0002 Scope S0003 Scope S0004 The aim of the safety assessment is for seamless integration of UAS operations into the current European ATM system. Only single (not in formation) UAs in non-segregated airspace are considered. Payload is considered external to the UAS system from an ATM perspective and is therefore outside scope. Only IFR En-Route operations in Classes A, B, or C airspace are considered (Scenario 1). Scope S0005 Only day VFR operations are considered (Scenario 2). Scope S0006 Class G airspace above Classes A, B or C airspace are not considered under Scenario 2. Commercial in Confidence Page 19 of 81

20 Scope S0007 Scope S0008 Eyeball Visual Line Of Sight (VLOS) operations only are within scope of the safety assessment, no command link VLOS are considered (Scenario 2). If ATC are involved in Scenario 2, they will not give specific trajectory instructions, but may stipulate airspace limitations, such as to remain below a specified level. 3.7 Assumptions The following assumptions have also been made to further scope and support the safety assurance activity: Assumption A0001 Assumption A0002 Assumption A0003 Assumption A0004 Assumption A0005 Assumption A0006 Assumption A0007 Assumption A0008 Assumption A0009 Assumption A0010 Assumption A0011 Assumption A0012 Current equivalent manned operations are tolerably safe. A pilot is only ever in control of one single UA. Airworthiness approval criteria are available and UAS have been approved by a competent authority. UAS operations comply with applicable ICAO standards, except where explicitly stated. All other airspace users intend to be seen. Where an Air Traffic Control (ATC) service is offered to a UAS Pilot, that ATC service is assumed to be fully licensed (Scenario 1 and Scenario 2). The UA Pilot-in-Command and associated Ground Control Station are assumed to be co-located for the duration of UA operations (Scenario 1). TCAS II Version 7 is not available for a UA, as stated by ICAO, but may be in operation with other airspace users (Scenario 1). UA operations are assumed to range in duration from a few hours to a number of days (Scenario 1). UA operations are assumed to range in duration from a few minutes up to the hours of available daylight (Scenario 2). UA Launch and Recovery operations are assumed to take place from locations away from aerodromes/airports (Scenario 2). Where no flight plan is available, an airborne flight plan will be created (Scenario 1). Commercial in Confidence Page 20 of 81

21 3.8 Unmanned Aircraft System Models The following models have been constructed for each scenario based on the defined scope of the FHA for each of the operational perspectives of UAS: Flight Profiles Flight Profiles captures all likely ATM environments and situations in which the UAS may be required to operate. Functional Models derived from the components defined within the ICAO Strategic Conflict Model. The flight profile model for each scenario aims to capture all phases of flight within the scope of analysis and likely ATM environments in which the UAS may be required to operate. Scenario 1 - Flight Profile Model is presented in Appendix B.1.1 and encapsulates IFR En-Route operations, crossing FIR boundaries, emergency operations and early descent. Scenario 2 - Flight Profile Model is presented in Appendix B.1.2 and encapsulates pre-flight planning, launch of the UA, VFR operations, crossing FIR boundaries, approach, recovery and any post landing actions Functional Models The following functional models are presented within the appendices. The aim of these models is to identify the primary functions performed by each system functional element for each of the two scenarios. Scenario 1 Functional Model with ATC Responsible for Separation Provision is shown in Appendix B.2.1. Scenario 2 Functional Model with Pilot in Command Responsible for Separation Provision is shown in Appendix B.2.2. The functional models developed for UAS are based on Figure 3 High Level Functional Model in section 3.2, it should be noted that the primary ATM functions are the same for both the with-uas and without-uas operations. More detailed models identifying logical elements of the with-uas and without- UAS situations will be documented within the Preliminary System Safety Assessment (PSSA) Report. Commercial in Confidence Page 21 of 81

22 4 Function Hazard Assessment Results 4.1 Overview In order to establish the relative change in risk as a result of introducing UAS operations in non-segregated airspace, the initial step in the analysis was to identify the hazards at a common boundary point for the without-uas and with UAS for each of the two scenarios. It was then necessary to establish if these hazards were common the both situations and whether there were any news hazards in the with UAS situation. This was analysed for both scenarios. Previous work involving the safety assessment of Military UAV as Operational Air Traffic outside segregated Airspace [6] had identified a list of hazards that were common to both the without-uas and with-uas scenarios. Due to the experience of the UAS workshop facilitators and the similarities in the two projects, the previous list of hazards was presented to the UAS workshop participants as a starting point. It was agreed that these hazards were considered to be applicable to military and civil operations. Therefore the previous list of hazards was reviewed and discussed during the UAS Workshop to identify if the hazards were still valid for the UAS safety assessment work and to identify any gaps. As a result a full functional analysis was conducted as part of the post workshop FHA activity as detailed below. 4.2 Hazard Identification Approach Each function depicted in the High Level Function Model (Figure 3 in section 3.2) was reviewed against a set of guidewords to ensure that the list of hazards captured all failure scenarios. Each guideword was applied to each function and considered in more detail, as shown in Appendix C. The functions considered are as listed below: Separation Provision 1. Separation Provision Instruction 2. Separation Provision Monitor 3. Trajectory Compliance Collision Avoidance 4. Observe 5. Resolve/Decide 6. Act Other Aircraft 7. Trajectory Compliance UAV Operator 8. Flight Planning Commercial in Confidence Page 22 of 81

23 The functional failure guidewords applied to each of the above functions are listed below: Loss complete negation of an intention. No part of the intention is achieved and nothing else happens, i.e. ATC inability to provide separation provision. Error any action that is undesirable regardless of cause, e.g. incorrect response to ATC instruction, partial response to ATC instruction or unintentional actions. Intentional deviation a different action than that intended occurs as a result of an external input i.e. ATC instruction ignored (e.g. due to Traffic Collision Avoidance System (TCAS) Resolution Advisory (RA)). Too early an action occurs earlier than expected either relative to UTC, order or sequence. Too late an action occurs later than expected whether relative to UTC, order or sequence. Other (completeness check). The high level functional model presented in Figure 3 represents a closed loop control system, with the airspace as the element under control. By breaking the control loop at the point where the separation provision compliance function interfaces with the airspace it can be observed that: The primary control function is Separation Provision. Collision Avoidance can mitigate Separation Provision failure (although the Trajectory Compliance function is a potential for common cause failure). Collision Avoidance actions can interfere with Separation Provision. As such the analysis of hazards focuses on the Separation Provision Function, and models the Collision Avoidance functional failure scenarios either as mitigations in the consequence of the SP hazards or as potential causes of the SP hazards. It should also be noted that, for the purpose of the FHA, UA failures subsequent to link loss are modelled as PIC hazards on the basis that the PIC is responsible for defining the contingency action. The following high-level hazards were identified and are common to both the with- UAS and without-uas situation: Loss of Separation Provision. Error in Separation Provision. Delayed Separation Provision. Intentional Deviation from Separation Provision Instruction. Commercial in Confidence Page 23 of 81

24 The Fault Trees in Appendix D show how the functional failure scenarios identified from applying the guidewords relate to the ten hazards identified in the UAS Safety Assessment workshop. The Fault Trees have thus been drawn for the purpose of showing this linking only; more specific, detailed FTAs will be produced to support the causal analysis in the Preliminary System Safety Assessment (PSSA). Each of the hazards has been grouped with one of the high-level hazards outlined above in Table 3 below. UAS Workshop Hazard No. Loss of Separation Provision HAZ001 HAZ005 HAZ007 Separation Provision error HAZ002 HAZ006 HAZ008 HAZ010 Delayed Separation Provision HAZ004 HAZ009 UAS Workshop Hazard Title Inability to comply with separation provision instruction from ATC Loss of separation provision from ATC Loss of separation provision from Pilot in Command Incorrect response to separation provision instruction from ATC ATC separation provision error Pilot in Command separation provision error Separation Provision Minima is breached by other aircraft Delayed response to separation provision instruction from ATC Pilot in Command separation provision too late Intentional Deviation from Separation Provision Instruction HAZ Hazard Identification Results Intentional deviation from separation provision instruction from ATC Table 3 Hazard Identification The functional failure analysis confirmed the conclusion of the UAS Safety Assessment workshop that UAS operations for Scenario 1 and Scenario 2 do not introduce any new hazards at the ATM concept level. The assessment also concluded that the resultant hazards are not all applicable to both scenarios hence the workshop agreed the following scenario assignments. Scenario 1 o HAZ001 - Inability to comply with separation provision instruction from ATC Aircraft is unable to comply with a separation provision instruction from air traffic control. o HAZ002 - Incorrect response to separation provision instruction from ATC Aircraft responds incorrectly to a separation provision instruction from air traffic control. Commercial in Confidence Page 24 of 81

25 o HAZ003 - Intentional deviation from separation provision instruction from ATC Aircraft makes intentional deviation from separation provision instruction provided by air traffic control for reasons such as weather avoidance and RAs (not for malicious reasons) and informs air traffic control of the deviation. o HAZ004 - Delayed response to separation provision instruction from ATC Aircraft delayed response to separation provision instruction from air traffic control, where delay is within the pre determined limit before air traffic control assumes loss and issue new separation provision instructions to surrounding aircraft. o HAZ005 - Loss of separation provision from ATC Loss of separation provision function from air traffic control due to the inability of air traffic control to provide the function to the pilot o HAZ006 - ATC separation provision error Scenario 2 Air traffic control issue a separation provision instruction containing an error. o HAZ001 to HAZ006 These were considered to be applicable to Scenario 2 only in so far as there are certain circumstances where for example initial ATC clearance is required or a temporary operating area is defined by ATC. It should be noted that causes were only found for HAZ006 on the basis of scoping statement S0008 (see Fault Tree Analysis, Appendix D.2) o HAZ007 Loss of separation provision from the Pilot in Command Loss of separation provision instruction from pilot in command due to the inability of the pilot in command to provide the function i.e. no separation provision instruction provided to the UA from the pilot in command. o HAZ008 Pilot in Command separation provision error Pilot in command on the ground issues separation provision instruction containing an error to the UA. o HAZ009 Pilot in Command separation provision instruction too late Pilot in command on the ground provides a separation instruction too late. Commercial in Confidence Page 25 of 81

26 o HAZ010 - Separation Provision Minima is breached by other aircraft 4.4 Consequence Analysis Separation provision minima are reduced due to the actions of other aircraft. The next step in the analysis is to assess the consequences associated with each hazard for both in without-uas and with UAS situations for both scenarios. The relative impact of the change was then assessed with respect to risk. The FHA considered the consequence of hazards associated with UAS operation in nonsegregated airspace. The consequence analysis was conducted to the point where there is the potential for an accident. The columns in the event tree are defined as follows: First Column Initiating Hazard. Middle Columns potential mitigations that would prevent the hazard resulting in an end consequence. Last Column the end consequence. A number of mitigations within the event trees are generic to all hazards; these are highlighted in the appropriate place. Given the requirement to present a relative qualitative safety argument for UAS operations in non-segregated airspace and the justification for an improved level of risk reduction than the current without-uas situation, the table in Appendix C presents a qualitative severity classification scheme applicable for this safety analysis. The scheme is based on ESARR 4 [2] for ATM and JAR [11] for aircraft related consequences Mitigations for HAZ001 The event tree for HAZ001 (Inability to comply with Separation Provision Instruction from ATC) is shown in Appendix F.1, Figure 5. The mitigations for this hazard are explained in Table 4 below. Note that whilst Air Traffic Control may be involved with UAS operations within Scenario 2, it is unlikely this will be the case as the UA will be flown under VLOS operation. The descriptions provided within the following tables are based on the output from the UAS Safety Assessment Workshop. The FHA workshop also identified a PIC mitigation for this hazard and HAZ002 and HAZ004; PIC notices error. This was removed from the Event Tree as some of the causes identified in the Functional Failure Analysis (FFA) would negate this mitigation. The PIC mitigation will be remodelled in the FTA as part of the PSSA activity. Commercial in Confidence Page 26 of 81

27 Event Tree Mitigation Description Scenario 1 Air Traffic Control awareness Revised ATC Instruction An Air Traffic Controller may be able to identify an aircraft that has failed to comply with a separation provision instruction. If the Air Traffic Controller is made aware, or notices, the Pilot in Command s inability to comply with a separation provision instruction, it was considered very likely that ATC would provide an amended instruction or attempt to reinforce the instruction. This could be to either that specific aircraft, or dependent upon the circumstances, i.e. an inability to control the aircraft, provide appropriate instructions to surrounding aircraft. The likelihood in the ability of an Air Traffic Controller to identify that an aircraft has failed to comply with a separation provision instruction will remain the same for without-uas and with-uas situations. Although Air Traffic Controllers in the future may be provided with information to enable them to distinguish between manned and unmanned aircraft, this should not change their ability to provide separation provision. There is no change in the likelihood for either without-uas or with-uas situations for this mitigation. Generic Mitigations applicable to all hazards without-uas and with-uas Other Aircraft Collision Avoidance Once all the mitigations listed above have failed, and assuming worst case that there is another aircraft in close vicinity, the immediate mitigation is that the other aircraft takes avoiding action. It should be noted that the use of remote observers was discussed but it was decided that the use of a remote observer was a possible variant in scenario 2 and not considered as a mitigation, therefore is not included in the consequence analysis. The CA function is not provided (whether with-uas or without-uas when it is required. This mitigation is stated in the negative as it is the top gate of the corresponding Fault Tree. Ideally CA should function in all scenarios, however in reality there are limitations on any CA system in terms of how many CA scenarios can be detected e.g. TCAS when fully working will not resolve all CA correctly and sometimes may indeed create an accident situation which may not have previously existed. As part of the success case argument the conditions under which CA is required to operate must be defined, this will be drawn out further within the Preliminary Safety Case. It was considered that there will be little or no change in the likelihood of another aircraft taking avoiding action for the without-uas to the with-uas situation. However, this may depend on the conspicuity of the UA itself in the with-uas situation and wither the other aircraft is able to move at speed to avoid the UAV. Collision Avoidance Systems - See Fault Tree analysis in Appendix D.1.1. Commercial in Confidence Page 27 of 81

28 Table 4 HAZ001 Event Tree Mitigations Mitigations for HAZ002 The event tree for HAZ002 (Incorrect response to Separation Provision Instruction from ATC) is presented in Appendix F.2, Figure 6. The mitigations for this hazard are explained in Table 5. Event Tree Mitigation Description Scenario 1 Air Traffic Control awareness Revised ATC Instruction An Air Traffic Controller may be able to identify an incorrect response from an aircraft to a separation provision instruction. Although Air Traffic Controllers in the future may be provided with information to enable them to distinguish between manned and unmanned aircraft, this should not change their ability to provide separation provision. If the Air Traffic Controller is made aware, or notices, the Pilot in Command s incorrect compliance with a separation provision instruction, it is very likely that ATC would query the Pilot in Commands response and provide an amended instruction. The likelihood in the ability of an Air Traffic Controller to identify that an aircraft has incorrectly complied with a separation provision instruction will remain the same for without-uas and with-uas situations. There is no change in the likelihood for either without-uas or with-uas situations for this mitigation. Other Aircraft and Collision Avoidance mitigations as per HAZ Mitigations for HAZ003 Table 5 HAZ003 Event Tree Mitigations The event tree for HAZ003 (Intentional deviation from Separation Provision Instruction from ATC) is presented in Appendix F.3, Figure 7. The mitigations for this hazard are explained in Table 6. Commercial in Confidence Page 28 of 81

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