Next Article in Journal
The Global Emergence of Community Drones (2012–2017)
Previous Article in Journal
UAV-g 2019: Unmanned Aerial Vehicles in Geomatics
 
 
Font Type:
Arial Georgia Verdana
Font Size:
Aa Aa Aa
Line Spacing:
Column Width:
Background:
Article

A Comparative Analysis of the Legislation Evolution for Drone Use in OECD Countries

by
Nikolaos Tsiamis
*,
Loukia Efthymiou
and
Konstantinos P. Tsagarakis
Business and Environmental Technology Economics Lab, Department of Environmental Engineering, Democritus University of Thrace, 67100 Xanthi, Greece
*
Author to whom correspondence should be addressed.
Drones 2019, 3(4), 75; https://doi.org/10.3390/drones3040075
Submission received: 4 August 2019 / Revised: 19 September 2019 / Accepted: 25 September 2019 / Published: 1 October 2019

Abstract

:
Drones have been employed for multiple uses, such as for military, surveillance, recreational, scientific, and research purposes. Their presence inside civil areas has necessitated the need to regulate their use. Towards this direction, many countries worldwide have issued national legislations, which vary on vehicle categorization according to the size, weight, flight altitude, purpose of use, and restrictions. In this study, we pursued the first comparative analysis of the Organization for Economic Co-operation and Development (OECD) countries’ national legislations, in order to explore the similarities and differences in drone use and recommend improvements and homogenization. Some of the examined countries issued legislation during recent years of drone application, while others amended their existing legislative framework in order to catch up with drone technology evolution. Although from the 35 OECD countries 22 belong to the European Union, we observed much diversity among national legal frameworks. The intensive use of drones has led to severe ethical dilemmas that policy makers will need to address in the near future. We conclude with a proposal regarding the basic legislation for different uses according to the criteria that have been developed so far, followed by limitations and restrictions.

1. Introduction

An unmanned aerial vehicle (UAV), commonly known as a drone, is an aircraft without a human operator on board that can be operated and be guided from a distance [1,2] using either fixed (airplane) or rotating (helicopter) wings. A UAV consists of a vehicle, ground control, and a data recording system [3]. UAVs may have several sensors (e.g., chemical, acoustic, GPS, thermographic, thermometer, altimeter, hydrometer, and camera) along with sensors of communication and recording instruments (e.g., hard disc, PC, tablet). All these together compose an unmanned aerial system (UAS) [4,5,6,7]. Drones vary in shape and size [8], and they are classified according to weight, flight range, flight altitude, autonomy, and purpose of use [7,9].
Recently, drones have become an important enforcement tool. Except for weapon machines [8,9,10,11,12,13,14], they are also employed for commercial purposes [2,8,10,11], research [15], and other purposes [16]. Drones have been used by the police in order to deal with illegal immigration [17], for border surveillance in USA [17,18,19], and in Europe by Frontex [16,20]. Furthermore, in some US states, the police use drones for crowd control, in accidents, crime tracing, for the monitoring of crime suspects [3], and in search and rescue operations [21]. Drones can also be used for commercial purposes [22], for example, delivery [23]. Drone deliveries are more environmentally friendly compared to vehicle ones [24]; thus, several companies (e.g., Amazon and Google) are preparing to offer drone delivery services [25].
Other recent drone applications include environmental protection, environmental law enforcement, and environmental crime prevention [26]. For example, in Africa, drones have been used to deal with illegal poaching, which threatens the extinction of mammalian species [27], while in Italy, the police launched the “DroMEP” project, which involves the use of drones in environmental monitoring [28]. Drones have found applications in forest monitoring [29], illegal logging, deforestation, and smoke detection to prevent forest fires [15,30,31]. Small drones can be used for low-cost data collection for biodiversity [15], natural disasters [17,18], and wildlife monitoring and assessment [32]. Drones with executive programs can also be used for the detection of soil pollution and unknown perpetrators [33].
We find several other applications in sports [34]; search and rescue; identification of victims [35]; monitoring, analysis, and management of road traffic [36]; or for monitoring pedestrian behavior and accident prevention [37]. Low-cost drones with a camera on board have been used for public health purposes by detecting water spots to reveal mosquito breading areas responsible for malaria [38,39]. Drones can also be used to identify people with dementia much faster and more efficient than traditional methods [40]. They have also been used in construction to gather information for manufacturers [41]. Furthermore, drones can be used in agriculture for different applications such as: midseason crop health monitoring, irrigation equipment monitoring, and midfield weed identification [42,43]. Drones can be used by farmers for data acquisition and analysis and for continuously monitoring fields for learning and developing modern farm management skills [44].
In order to address the needs for managing the widespread use of drones, many countries worldwide have issued legislations on their use, by setting rules and restrictions for ensuring the safety and privacy of the population [45]. Towards this direction, this study consists of a comparative analysis of the respective legislations in the countries of the Organization for Economic Co-operation and Development (OECD). OECD countries are able to exchange opinions and practices on economic, social, and environmental issues, aiming to improving the quality of life and the world’s economic and social situation [46]. The aim of this paper is to explore differences and similarities for the drone legal framework of the examined countries. We also conclude with legal recommendations, which can be a point of reference for future research on the subject.
The rest of the paper is structured as follows: Section 2 consists of the research methodology. Section 3 is an overview of the legislation for each examined country followed by an analysis of the published research regarding drone technology and applications. In Section 4 the legal frameworks are discussed, and recommendations for their harmonization are provided, while Section 5 consists of the overall conclusions and future research suggestions.

2. Materials and Methods

We selected all OECD countries, which are listed in alphabetical order as follows: Australia, Austria, Belgium, Canada, Chile, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Israel, Italy, Japan, Korea, Latvia, Luxembourg, Mexico, the Netherlands, New Zealand, Norway, Poland, Portugal, Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Turkey, the United Kingdom, and the United States of America [46]. The data were collected from official government websites of countries, ministries, civil aviation, and transport authorities.
A discussion is made based on size, weight, flight altitude, purpose of use, and restrictions with reference to legal documents and to the authority in charge. Typical characteristics reported in legislation are briefly presented as follows:
  • Weight: the maximum mass of the aircraft at take-off;
  • Flight altitude: the flight at an altitude above ground or sea;
  • Purpose: conditions for approval of drone use including business, recreational, research, or other;
  • Restrictions: prohibitions and limitations on drone use.
A comparative analysis of the legislation for drone use is performed, followed by recommendations for harmonizing and updating the legal framework.

3. Results

This section presents the analysis of the legal frameworks and the diachronic research volume trends, as recorded by the published papers in scholarly journals.

3.1. Analysis of the Legal Frameworks

In this section, a concise reference to the legislation of each OECD country is listed. The presented legal framework refers to the time the data for this project has been collected, (i.e., July 2018). However, as this is a dynamic topic, it is continuously being studied, and new legal updates may exist. In Table 1 there is a list of all studied countries, followed by the authorities in charge for drone regulation and the main legal documents that govern their operation.
In Table 2, a reference to 14 criteria, as they have been located in the national legal frameworks, is presented. All countries set the criterion of flying distance restrictions. Among the 35 countries examined, 32 referred to weight classification and 31 to overcrowded flight restrictions, while 29 require flight permissions for drone flights. Several countries have distance restrictions from buildings or infrastructure, safety insurance requirements, drone registration procedures, and certification required for piloting.
Following the classification of the key issues regarding national drone regulations, what has been observed is a different approach in legislation amongst the OECD countries, while in some countries the legislative framework is still under consideration. In some cases, the national regulations classified drones based on the vehicle’s weight, whereas other classifications included flight altitude. All OECD countries, however, classified drones according to weight, with the exemption of Estonia, the Netherlands, and Turkey.
Figure 1 shows the countries on a world map classified according to the number of criteria found in their legislation. Only 2 countries had 4–5 criteria, 13 had 6–7 criteria, 12 had 8–9 criteria, 6 had 10–11, and only 2 countries had 12 criteria.
In Japan and Turkey, the legislation was not advanced compared to the other countries. Some countries issued legislation during the very last years, and others amended their legislative framework in order to cover the needs of technology improvement. Many countries considered privacy seriously and posed restrictions for flights above people and public areas.
In the European Union (EU), where specific guidelines have been released, it is observed that every member state has set its own policy on the use of drones. For example, only Italy, Latvia, and Slovak Republic have legislated air traffic zones for drone use. The EU issued rules on safe use of drones in 2014 (2014/2243(INI)). However, most EU countries have yet to comply with the overall content of this regulation.
In Canada the legislative framework was stricter than in all the other OECD countries. On the other hand, in USA the law follows a more liberal path. OECD countries followed a different approach in legislation about the purpose of flights. For example, Australia, Austria, Canada, Czech Republic, France, Greece, Israel, The Netherlands, Poland, Portugal, Slovak republic, Spain, Sweden, UK, and USA had guidelines with reference to the purpose of flights. All the other OECD countries do not give emphasis to such guidelines.
Figure 2, shows on a world map the requirements for registration and liability insurance for drone operators in all examined countries. Liability insurance for flights with drones was obligatory in all countries, except for Finland, Iceland, Japan, Mexico, New Zealand, Turkey, and USA. In Ireland and Netherlands, liability insurance was required only for flights for commercial purposes. In all countries, flights were permitted during daylight. Different regulations were observed regarding flight or vehicle registration requirements. In Australia, Canada, France, Hungary, Latvia, Luxembourg, Mexico, Portugal, Switzerland, Turkey, and the UK, drone registration was not required.
The increasing use of drones has led several countries to enact new regulations regarding the use of drones and their operators. However, only a small number of countries have legislated regulations with specific restrictions. For example, in Luxembourg, Israel, and Germany, the maximum flight altitude is regulated to 50 m above ground, whereas in Belgium, the maximum flight altitude is 45 m. Said countries have legislated stricter laws than other OECD countries, where the maximum flight altitude is 90–150 m above ground.
Another flight restriction is the maximum distance from the operator, which varied from 30 to 500 m. Australia, Belgium, Estonia, Israel, Japan, Korea, the Netherlands, Poland, Portugal, Slovakia, Slovenia, Sweden, and Turkey had strict regulations on the horizontal distance between the operator and the vehicle (flying drone), contrary to the rest of the countries, where the horizontal distance between the operator and the vehicle was about 100–500 m. The combinations of altitude and horizontal distance limitations per country are presented in Figure 3.
All OECD countries had restrictions for flights near airports, populated areas, and buildings or authorities. While most of the countries have legislated a minimum distance away from airports, Austria, Italy, Korea, Turkey, the UK, Hungary, Estonia, Belgium, and Luxemburg have not determined a specific distance, rather than requiring a “safety distance” (Figure 4).

3.2. Research Trends

To justify the increased interest for drone applications, we ran a search in the Scopus database (as for June 2019) using the keywords “drones” and “unmanned aerial vehicles” between 2009 and 2018. Our research resulted in 2717 published journal papers, as shown in Figure 5. There was an increasing trend, from 11 papers published in 2009 to 851 published in 2018. We also show the ratio of drone-related papers to the total number of papers published per year in the Scopus database, which also followed an ascending trend, from 4.7 × 10−6 in 2009 to 270.0 × 10−6 in 2018.
This boost in published research indicates the current and forthcoming technology and industrial revolution of drone use for several purposes, which needs further regulation.

4. Discussion

Despite OECD countries being able to exchange opinions and experiences on many aspects, including emerging technologies, the national regulations on drones demonstrate high diversity. Although among OECD countries there are groups of countries, such as those belonging to the European Union, that have released specific guidelines, it is observed that every member state has set its own policy on the use of drones. It is, therefore, recommended that a single policy on drone use should be implemented among the OECD countries.
This analysis focused on 14 criteria located in the national legislations based on size, weight, flight altitude, purpose of use, restrictions, insurance, and registration requirements. Based on the aforementioned comparative analysis, we identified the differences and similarities between national legislations on the use of drones.
Former studies limited their results to specific countries or groups of countries, or presented the use of drones for commercial purposes, without specific analysis of the relevant legislation. For example, Cracknell [22] presented an analysis on the legislation of drone use in Australia, USA, other countries (UK and China), and the EU. Cunliffe et al. [15] analyzed the safe growth of lightweight drones in UK, whereas Chamoso et al. [12] discussed the use of drones in Spain with reference to Spanish and European legislation. To the best of our knowledge, this is the first time that the legislative framework for the use of drones in so many countries is examined, highlighting major similarities and differences.
We have collected all practices, criteria, and restrictions reported in legislation in OECD countries and have proposed a common legislation framework. This proposal consists of the basic requirements that each country should legislate. This way, all countries will present some basic similarities in legislation for equal opportunities for drone uses and operators. Specific conditions may allow for further detailing a country’s legal framework. This proposed framework suggests reference to the purpose of drone use, necessity for piloting training skills and qualifications, flight registration, classification per weight, permitting authority, insurance, accidents’ record, and penalties, as detailed in Table 3.
Concerning the purpose of use, drones should be classified with reference to at least commercial, recreational, scientific/research, surveillance and security, agriculture, monitoring, search and rescue, first aid, infrastructure, or environmental management categories. Each vehicle could be suitable for one or more categories.
In the case where special permissions for flights are not obligatory, we suggest that drones should fly at a maximum altitude of 120 m and at a distance of 500 m from the operator. The Civil Aviation Authority of each country should regulate and supervise every flight, whereas the operator should immediately report to a special database every accident. Finally, in case of legal violations, criminal penalties and fees should be enforced to the operators of drones.
We suggest that every drone should have a unique number that will be its identity. For this purpose, every owner should register the vehicle’s characteristics online in a database. Furthermore, this unique number should be set on the vehicle in order to be recognized in case of accident or loss. The owner of the vehicle should visit the online database before they start a flight and register data such as: the operator’s license, the flight plan, the type of vehicle, the purpose and the flight duration, the operator’s credentials, and the insurance contract. Flight permission should be issued by the authorities after request by the owner of the vehicle, considering the meteorological conditions (expected pressure, wind, visibility, temperature, precipitation, etc.). The authorities should notify the operator about flight permissions and limitations. This flight permission should be provided with a unique number that will enable the authorities to inspect the flight.

5. Conclusions

The use of drones has been growing fast during the last years, and, to the best of our knowledge, this is the first time a paper has discussed the legislation on their use for a large number of countries worldwide. The purpose of this work was to give a brief presentation and a comparative analysis of OECD countries’ regulations regarding drone use. Among the 35 countries examined, we identified many differences in legislation, which can be attributed to the different timings of enacting the legal framework in relation to tremendous technology improvements. Many countries pay much attention to privacy and set restrictions on flights above people and public areas. Despite the fact EU has issued a single policy on drone use, many countries have legislated different restrictions and piloting requirements, while the criteria to categorize the vehicle’s size, weight, flight altitude, and use also differ per country. Meanwhile, the intensive use of drones raises a lot of ethical dilemmas, such as privacy, personal data, and so on, that people in charge will have to face in the near future. A more detailed legislative framework is necessary, mainly regarding limitations and restrictions per use as well as the way in which security authorities will be able to effectively control drone flights. A homogenous legal framework will provide smooth and safe drone technology use while still being able to revisit and revise the requirements for permissions and restrictions, which is necessary along with technology development and maturation.
We consider this work as a starting point to further look into regulation and legislation for drone use, with an emphasis on the dynamic nature of this technology and a legal framework that will be flexible enough to follow technology improvements.

Author Contributions

Conceptualization, N.T.; Data curation, N.T.; Formal analysis, N.T. and K.P.T.; Methodology, N.T.; Writing—original draft, N.T. and L.E.; Writing—review & editing, N.T., L.E., and K.P.T.

Funding

This research received no external funding

Conflicts of Interest

The authors declare no conflicts of interest.

References

  1. Clarke, R. Understanding the drone epidemic. Comput. Law Secur. Rev. 2014, 30, 230–246. [Google Scholar] [CrossRef]
  2. Rao, B.; Gopi, A.G.; Maione, R. The societal impact of commercial drones. Technol. Soc. 2016, 45, 83–90. [Google Scholar] [CrossRef]
  3. Stelmack, K. Weaponized Police Drones and Their Effect on Police Use and Force. J. Technol. Law Policy 2014, 15, 276. [Google Scholar] [CrossRef]
  4. Thompson, R.M. Drones in Domestic Surveillance Operations: Fourth Amendment Implications and Legislative Responses; Library of Congress Congressional Research Service: Washington, DC, USA, 2012. [Google Scholar]
  5. Ivošević, B.; Han, Y.-G.; Cho, Y.; Kwon, O. The use of conservation drones in ecology and wildlife research. Ecol. Environ. 2015, 38, 113–188. [Google Scholar] [CrossRef]
  6. Koh, L.P.; Wich, S.A. Dawn of drone ecology: Low-cost autonomous aerial vehicles for conservation. Trop. Conserv. Sci. 2012, 5, 121–132. [Google Scholar] [CrossRef]
  7. Saranya, C.; Pavithira, L.; Premsai, N.; Lavanya, H.; Govindarajan, R. Recent trends of drones in the field of defense. Int. J. Electr. Appl. 2015, 1, 47–55. [Google Scholar]
  8. Balasingam, M. Drones in medicine—The rise of the machines. Int. J. Clin. Pract. 2017. [Google Scholar] [CrossRef]
  9. Klemas, V.V. Coastal and environmental remote sensing from unmanned aerial vehicles: An overview. J. Coast. Res. 2015, 31, 1260–1267. [Google Scholar] [CrossRef]
  10. Luppicini, R.; So, A. A technoethical review of commercial drone use in the context of governance, ethics, and privacy. Technol. Soc. 2016, 46, 109–119. [Google Scholar] [CrossRef]
  11. Finn, R.L.; Wright, D. Unmanned aircraft systems: Surveillance, ethics and privacy in civil applications. Comput. Law Secur. Rev. 2012, 28, 184–194. [Google Scholar] [CrossRef]
  12. Chamoso, P.; González-Briones, A.; Rivas, A.; Bueno De Mata, F.; Corchado, J.M. The use of drones in Spain: Towards a platform for controlling UAVs in urban environments. Sensors 2018, 18, 1416. [Google Scholar] [CrossRef] [PubMed]
  13. Rothe, D.L.; Collins, V.E. The normality of political administration and state violence: Casuistry, law, and drones. Crit. Criminol. 2014, 22, 373–388. [Google Scholar] [CrossRef]
  14. Haidari, L.A.; Brown, S.T.; Ferguson, M.; Bancroft, E.; Spiker, M.; Wilcox, A.; Ambikapathi, R.; Sampath, V.; Connor, D.L.; Lee, B.Y. The economic and operational value of using drones to transport vaccines. Vaccine 2016, 34, 4062–4067. [Google Scholar] [CrossRef] [PubMed] [Green Version]
  15. Cunliffe, A.M.; Anderson, K.; DeBell, L.; Duffy, J.P. A UK Civil Aviation Authority (CAA)-approved operations manual for safe deployment of lightweight drones in research. Int. J. Remote Sens. 2017, 38, 2737–2744. [Google Scholar] [CrossRef]
  16. Marin, L.; Krajčíková, K. Deploying Drones in policing southern European borders: Constraints and challenges for data protection and human rights. In Drones and Unmanned Aerial Systems; Springer: Berlin/Heidelberg, Germany, 2016; pp. 101–127. [Google Scholar]
  17. Roma, A. Drones and popularisation of space. Space Policy 2017, 41, 65–67. [Google Scholar] [CrossRef]
  18. Shishkov, B.; Hristozov, S.; Janssen, M.; van den Hoven, J. Drones in Land Border Missions: Benefits and Accountability Concerns. In Proceedings of the 6th International Conference on Telecommunications and Remote Sensing, Delft, The Netherlands, 6–7 November 2017; pp. 77–86. [Google Scholar]
  19. Brumfield, E. Armed Drones for Law Enforcement: Why It Might Be Time to Re-Examine the Current Use of Force Standard. McGeorge Law Rev. 2014, 46, 543. [Google Scholar]
  20. Tikanmäki, I. Possibilities to Operational Use of Remotely Piloted Aircrafts in Finland. Master’s Thesis, Laurea-ammattikorkeakoulu, Vantaa, Finland, 2011. [Google Scholar]
  21. Villasenor, J. “Drones” and the future of domestic aviation [Point of View]. Proc. IEEE 2014, 102, 235–238. [Google Scholar] [CrossRef]
  22. Cracknell, A.P. UAVs: Regulations and law enforcement. Int. J. Remote Sens. 2017, 38, 3054–3067. [Google Scholar] [CrossRef]
  23. Sky Taxi to Fly in Dubai from July. Available online: https://www.bbc.com/news/av/technology-39003397/sky-taxi-to-fly-in-dubai-from-july (accessed on 24 March 2018).
  24. Goodchild, A.; Toy, J. Delivery by drone: An evaluation of unmanned aerial vehicle technology in reducing CO2 emissions in the delivery service industry. Transp. Res. Part D Transp. Environ. 2018, 61, 58–67. [Google Scholar] [CrossRef]
  25. The Economics of Drone Delivery. Available online: https://spectrum.ieee.org/automaton/robotics/drones/the-economics-of-drone-delivery (accessed on 10 February 2018).
  26. Florescu, E.; Glenn, J.C. Environmental Security Rising on the International Agenda. Dev. Environ. Foresight 2015, 1, 6–23. [Google Scholar]
  27. Cheteni, P. An Analysis of Anti Poaching Techniques in Africa: A Case of Rhino Poaching; University of Fort Hare: Alice, South Africa, 2014. [Google Scholar]
  28. Massarelli, C.; Muolo, M.R.; Uricchio, V.F.; Dongiovanni, N.; Palumbo, R. Improving environmental monitoring against the risk from uncontrolled abandonment of waste containing asbestos. In The DroMEP project. In Proceedings of the FOSS4G Europe Como 2015, Como, Italy, 15–17 July 2015. [Google Scholar]
  29. Manfreda, S.; McCabe, M.F.; Miller, P.E.; Lucas, R.; Pajuelo Madrigal, V.; Mallinis, G.; Ben Dor, E.; Helman, D.; Estes, L.; Ciraolo, G. On the Use of Unmanned Aerial Systems for Environmental Monitoring. Remote Sens. 2018, 10, 641. [Google Scholar] [CrossRef]
  30. Lawlor, K.; Olander, L.; Boyd, W.; Niles, J.; Madeira, E. Addressing the Causes of Tropical Deforestation: Lessons Learned and the Implications for International Forest Carbon Policy. International Forest Carbon and the Climate Change Challenge Series–Brief Number 5. June; Nicholas Institute for Environmental Policy Solutions, Duke University: Durham, NC, USA, 2009. [Google Scholar]
  31. Paneque-Gálvez, J.; McCall, M.K.; Napoletano, B.M.; Wich, S.A.; Koh, L.P. Small drones for community-based forest monitoring: An assessment of their feasibility and potential in tropical areas. Forests 2014, 5, 1481–1507. [Google Scholar] [CrossRef]
  32. Wallace, P.; Martin, R.; White, I. Keeping pace with technology: Drones, disturbance and policy deficiency. J. Environ. Plan. Manag. 2018, 61, 1271–1288. [Google Scholar] [CrossRef]
  33. Capolupo, A.; Pindozzi, S.; Okello, C.; Fiorentino, N.; Boccia, L. Photogrammetry for environmental monitoring: The use of drones and hydrological models for detection of soil contaminated by copper. Sci. Total Environ. 2015, 514, 298–306. [Google Scholar] [CrossRef] [PubMed]
  34. Tanaka, K.; Tochihara, N.; Sato, T.; Koike, H. A real-time image processing framework with an aerial overhead camera for sports. In Proceedings of the 2018 International Conference on Advanced Visual Interfaces, Grosseto, Italy, 29 May–1 June 2018. Article No. 34. [Google Scholar]
  35. Karaca, Y.; Cicek, M.; Tatli, O.; Sahin, A.; Pasli, S.; Beser, M.F.; Turedi, S. The potential use of unmanned aircraft systems (drones) in mountain search and rescue operations. Am. J. Emerg. Med. 2018, 36, 583–588. [Google Scholar] [CrossRef]
  36. Khan, M.A.; Ectors, W.; Bellemans, T.; Janssens, D.; Wets, G. UAV-Based Traffic Analysis: A Universal Guiding Framework Based on Literature Survey. Transp. Res. Procedia 2017, 22, 541–550. [Google Scholar] [CrossRef]
  37. Sutheerakul, C.; Kronprasert, N.; Kaewmoracharoen, M.; Pichayapan, P. Application of Unmanned Aerial Vehicles to Pedestrian Traffic Monitoring and Management for Shopping Streets. Transp. Res. Procedia 2017, 25, 1720–1739. [Google Scholar] [CrossRef]
  38. Hardy, A.; Makame, M.; Cross, D.; Majambere, S.; Msellem, M. Using low-cost drones to map malaria vector habitats. Parasites Vectors. 2017, 10, 29. [Google Scholar] [CrossRef]
  39. Amenyo, J.-T.; Phelps, D.; Oladipo, O.; Sewovoe-Ekuoe, F.; Jadoonanan, S.; Jadoonanan, S.; Tabassum, T.; Gnabode, S.; Sherpa, T.D.; Falzone, M. MedizDroids Project: Ultra-low cost, low-altitude, affordable and sustainable UAV multicopter drones for mosquito vector control in malaria disease management. In Proceedings of the Global Humanitarian Technology Conference (GHTC), San Jose, CA, USA, 10–13 October 2014; pp. 590–596. [Google Scholar]
  40. Hanna, D.; Ferworn, A.; Lukaczyn, M.; Abhari, A.; Lum, J. Using Unmanned Aerial Vehicles (UAVs) in locating wandering patients with dementia Monterey. In Proceedings of the 2018 IEEE/ION Position, Location and Navigation Symposium (PLANS), Monterey, CA, USA, 23–26 April 2018; pp. 809–815. [Google Scholar] [CrossRef]
  41. Li, Y.; Liu, C. Applications of multirotor drone technologies in construction management. Int. J. Constr. Manag. 2018, 1–12. [Google Scholar] [CrossRef]
  42. Veroustraete, F. The Rise of the Drones in Agriculture. EC Agric. 2015, 2, 325–327. [Google Scholar]
  43. Marinello, F.; Pezzuolo, A.; Chiumenti, A.; Sartori, L. Technical analysis of unmanned aerial vehicles (drones) for agricultural applications. In Proceedings of the Engineering for Rural Development, Jelgava, Latvia, 25–27 May 2016; Volume 15. [Google Scholar]
  44. Mahajan, U.; Raj, B. Drones for Normalized Difference Vegetation Index (NDVI), to Estimate Crop Health for Precision Agriculture: A Cheaper Alternative for Spatial Satellite Sensors. In Proceedings of the International Conference on Innovative Research in Agriculture, Food Science, Forestry, Horticulture, Aquaculture, Animal Sciences, Biodiversity, Ecological Sciences and Climate Change (AFHABEC-2016), New Delhi, India, 22 October 2016. [Google Scholar]
  45. Clarke, R. The regulation of civilian drones’ impacts on behavioural privacy. Comput. Law Secur. Rev. 2014, 30, 286–305. [Google Scholar] [CrossRef]
  46. The Organization for Economic Co-operation and Development (OECD). About the OECD. Available online: http://www.oecd.org/about/ (accessed on 19 January 2018).
  47. Australian Government Civil Aviation Safety Authority. Flying Drones/Remotely Piloted Aircraft in Australia. Available online: https://www.casa.gov.au/aircraft/landing-page/remotely-piloted-aircraft-system (accessed on 22 February 2018).
  48. Australian Government. Federal Register of Legislation. Available online: https://www.legislation.gov.au/Details/F2017C00742 (accessed on 22 February 2017).
  49. Control, A. Welcome to Austro Control! Available online: https://www.austrocontrol.at/jart/prj3/austro_control/main.jart?rel=en (accessed on 22 March 2018).
  50. Austro Control. Operation of Unmanned Aerial Vehicles-Drones. Available online: https://www.austrocontrol.at/jart/prj3/austro_control/main.jart?rel=de&content-id=1374135213843 (accessed on 20 February 2017).
  51. Drones. Available online: https://mobilit.belgium.be/nl/luchtvaart/drones (accessed on 20 May 2017).
  52. Federal Public Service Mobility and Transport Belgian Civil Aviation Authority. Aviation Safety Information Leaflet: Drone Flying. Available online: https://mobilit.belgium.be/sites/default/files/resources/files/asil_2017_01_drone_flying.pdf (accessed on 1 March 2018).
  53. Government of Canada. Flying Your Drone Safely and Legally. Available online: http://www.tc.gc.ca/en/services/aviation/drone-safety/flying-drone-safely-legally.html (accessed on 1 February 2018).
  54. Government of Canada. Canadian Aviation Regulations, SOR/96-433, by Aeronautics Act. Available online: https://laws-lois.justice.gc.ca/eng/regulations/SOR-96-433/FullText.html#s-602.41 (accessed on 1 February 2018).
  55. Department of Transport. Interim Order No.9 Respecting the Use of Model Aircraft. Available online: http://www.gazette.gc.ca/rp-pr/p1/2018/2018-06-16/html/notice-avis-eng.html#ne6 (accessed on 31 May 2018).
  56. General Directorate of Civil Aviation of Chile (DGAC). Available online: https://www.dgac.gob.cl/ (accessed on 12 February 2018).
  57. DGAC Chile. How to Operate a Drone in Chile? Available online: https://www.dgac.gob.cl/como-operar-un-dron-en-chile/ (accessed on 12 February 2017).
  58. The Civil Aviation Authority of Czech Republic. Available online: http://www.caa.cz/ (accessed on 23 January 2018).
  59. Civil Aviation Authority of Czech Republic. Available online: http://lis.rlp.cz/predpisy/predpisy/dokumenty/L/L-2/data/effective/doplX.pdf (accessed on 20 March 2018).
  60. Danish Transport, Construction and Housing Authority. Available online: http://www.trafikstyrelsen.dk/EN.aspx (accessed on 5 April 2018).
  61. Danish Transport Construction and Housing Authority. Available online: http://www.trafikstyrelsen.dk/da/droneregler (accessed on 5 April 2018).
  62. Republic of Estonia Civil Aviation Administration. Civil Aviation Authority (CAA). Available online: https://www.ecaa.ee/en (accessed on 21 April 2018).
  63. Republic of Estonia Civil Aviation Administration. Aviation Act. Available online: https://www.ecaa.ee/en/how-operate-ua (accessed on 21 April 2018).
  64. Finnish Transport Safety Agency. Available online: https://www.trafi.fi/en (accessed on 5 April 2018).
  65. Finnish Transport Safety Agency. Use of remotely Piloted Aircraft and Model Aircraft. Available online: https://www.trafi.fi/filebank/a/1483970125/4a6ac53bf4b1cb434d7f85a15f36dde0/23661-OPS_M1-32_RPAS_2016_eng.pdf (accessed on 5 April 2018).
  66. Ministry of Ecological and Solidarity Transition. Available online: https://www.gouvernement.fr/en/composition-of-the-government (accessed on 15 April 2018).
  67. Decree of 17 December 2015 on the use of Airspace by Aircraft Operating on Board NO. Available online: https://www.legifrance.gouv.fr/eli/arrete/2015/12/17/DEVA1528469A/jo (accessed on 15 April 2018).
  68. Article L6211-3. Available online: https://www.legifrance.gouv.fr/affichCodeArticle.do?cidTexte=LEGITEXT000023086525&idArticle=LEGIARTI000023075496&dateTexte=&categorieLien=cid (accessed on 15 April 2018).
  69. Federal Ministry of Justice and Consumer Protection. Air Traffic Regulation. Available online: https://www.bmjv.de/DE/Startseite/Startseite_node.html (accessed on 3 February 2018).
  70. Federal Minister of Justice and Consumer Protection. Air Traffic Licensing Regulations (LuftVZO). Available online: http://www.gesetze-im-internet.de/luftvzo/BJNR003700964.html#BJNR003700964BJNG000102308 (accessed on 3 February 2018).
  71. Civil Aviation Authority of Greece. Regulation. Available online: http://epae.elao.gr/index.php/epaegeneralinfo/epaelaw (accessed on 10 March 2018).
  72. Hellenic Civil Aviation Authority Regulation–General Framework for Flights of Unmanned Aircraft. Systems-UAS. Available online: https://dagr.hcaa.gr/docs/HCAA%20UAS%20Regulation.pdf (accessed on 10 March 2018).
  73. National Transport Authority. Available online: http://www.nkh.gov.hu/en/web/english/ (accessed on 2 January 2018).
  74. Ministry of Innovation and Technology Traffic Authority. Rationality, National Interest, Lawfulness. Available online: http://www.nkh.gov.hu/kereses?p_p_id=regenssearch_WAR_mediacenterportlet&p_p_lifecycle=0&p_p_mode=view&_regenssearch_WAR_mediacenterportlet_keywords=unmanned (accessed on 23 February 2016).
  75. Icelandic Transport Authority. Safe, Productive Efficient Transport. Available online: https://www.icetra.is/ (accessed on 28 April 2018).
  76. Icelandic Transport Authority. Remotely-controlled Aircraft (Drones). Available online: https://www.icetra.is/aviation/drones/ (accessed on 28 April 2018).
  77. Irish Aviation Authority. Drones. Available online: https://www.iaa.ie/general-aviation/drones (accessed on 11 March 2018).
  78. Irish Aviation Authority. Irish Aviation Authority Small Unmanned Aircraft (DRONES) and Rockets Order, 2015. Available online: https://www.iaa.ie/docs/default-source/publications/legislation/statutory-instruments-(orders)/small-unmanned-aircraft-(drones)-and-rockets-order-s-i-563-of-2015.pdf?sfvrsn=26f50bf3_6 (accessed on 10 March 2018).
  79. Ministry of Transport Civil Aviation Authority Director of Regulations and Standards. The Civil Aviation Authority of Israel. Available online: http://en.caa.gov.il/index.php (accessed on 28 April 2018).
  80. The Civil Aviation Authority. EN-ROUTE. Available online: http://en.caa.gov.il/index.php?option=com_content&view=article&iotype=w&id=408&Itemid=272&lang_ovrrde=ENG (accessed on 28 April 2018).
  81. Enac, Italian Civil Aviation Authority. Available online: https://www.enac.gov.it/en (accessed on 1 July 2018).
  82. ENAC Italian Civil Aviation Authority. Remotely Piloted Aerial Vehicles. Available online: https://www.enac.gov.it/sites/default/files/allegati/2018-Sep/Regulation_RPAS_Issue_2_Rev_4_eng.pdf (accessed on 2 July 2018).
  83. The Ministry of Land, Infrastructure, Transport and Tourism. Available online: http://www.mlit.go.jp/en/index.html (accessed on 1 April 2018).
  84. Civil Aeronautics Act. Available online: http://www.japaneselawtranslation.go.jp/law/detail/?id=37&vm=02&re=02 (accessed on 14 April 2018).
  85. Ministry of Land Infrastructure and Transport (Korea). Available online: http://www.molit.go.kr/english/intro.do (accessed on 19 April 2018).
  86. The Ministry of Land Transport and Maritime Affairs. Aviation Safety and Security Act. Available online: http://www.moleg.go.kr/english/korLawEng?pstSeq=52720 (accessed on 19 April 2018).
  87. The Ministry for Transport and agriculture of the Republic of Latvia. Available online: https://www.zm.gov.lv/en/zemkopibas-ministrija/statiskas-lapas/minister?nid=1118#jump (accessed on 6 March 2018).
  88. Cabinet of Ministers Regulations Procedures for the Conduct of Unmanned Aerial Vehicles and other Types of Aircraft which do not Qualify as Aircraft. Available online: https://www.vestnesis.lv/op/2016/231.1 (accessed on 6 March 2018).
  89. The Directorate of Civil Aviation (DAC). Available online: https://dac.public.lu/direction/index.html (accessed on 24 March 2018).
  90. Direction de l’Aviation Civile. General Conditions for Unmanned Aircraft System (UAS) Operations Within the Luxembourg Airspace. Available online: https://dac.public.lu/actualites/2016/11/UAS-2016/index.html (accessed on 24 March 2018).
  91. Ministry of Communications and Transportation. Available online: https://www.gob.mx/sct (accessed on 23 February 2018).
  92. Ministry of Communications and Transportation. It Will Regulate the Use of Unmanned Aircraft (Drones), SCT. Available online: http://www.sct.gob.mx/fileadmin/DireccionesGrales/DGAC-archivo/modulo3/co-av-23-10-r4.pdf (accessed on 23 February 2018).
  93. Government of Netherlands. Rules for Recreational Use of Drones. Available online: https://www.government.nl/topics/drone/rules-pertaining-to-recreational-use-of-drones (accessed on 28 April 2018).
  94. Law Bank of Netherlands. Model Flying Arrangement. Available online: http://wetten.overheid.nl/BWBR0019147/2015-11-07#Artikel5,%20http://wetten.overheid.nl/BWBR0019147/2015-11-07 (accessed on 28 April 2018).
  95. Civil Aviation Authority of New Zealand. Available online: https://www.caa.govt.nz/ (accessed on 1 March 2018).
  96. Civil Aviation Authority of New Zealand. Unmanned Aircraft. Available online: https://www.caa.govt.nz/unmanned-aircraft/ (accessed on 1 March 2018).
  97. T The Civil Aviation Authority of Norway’s Main Objective Is to Contribute to Safe Civil Aviation in Norway. Available online: https://luftfartstilsynet.no/en/ (accessed on 16 April 2018).
  98. Civil Aviation Authority -Norway. About drones/RPAS. Available online: https://luftfartstilsynet.no/en/drones/commercial-use-of-drones/about-dronesrpas/regulations-of-drones/ (accessed on 16 February 2018).
  99. The Civil Aviation Office of Poland. Available online: http://www.ulc.gov.pl/pl (accessed on 15 February 2018).
  100. Polish Aviation Centenary. Safe Sky-Regulations on Flying Drones in Poland. Available online: http://dziennikustaw.gov.pl/DU/2013/440/ (accessed on 15 February 2018).
  101. Government Legislation Center. Regulation of the Minister of Transport, Construction and Maritime Economy of June 3, 2013 Regarding Qualification Certificates. Available online: http://www.dziennikustaw.gov.pl/DU/2013/664/1 (accessed on 8 April 2018).
  102. Government Legislation Center. The Act of July 3, 2002-Aviation Law. Available online: http://dziennikustaw.gov.pl/DU/2002/1112/1 (accessed on 9 April 2018).
  103. The Portuguese Civil Aviation Authority. Available online: https://www.anac.pt/vPT/Generico/Paginas/Homepage00.aspx (accessed on 18 April 2018).
  104. Portugese Civil Aviation Authority Tem Mão no teu Drone. Available online: https://www.voanaboa.pt/regulamento (accessed on 18 April 2018).
  105. The Ministry of Transport and Construction of The Slovak Republic. Available online: https://www.mindop.sk/en (accessed on 3 April 2018).
  106. Transport Authority. Register Aircraft. Available online: http://letectvo.nsat.sk/letova-sposobilost/register-lietadiel-slovenskej-republiky/ (accessed on 3 April 2018).
  107. Official Gazette of the Republic of Slovenia. Available online: https://www.uradni-list.si/ (accessed on 2 April 2018).
  108. Official Gazette of the Republic of Slovenia. Rulebook on Ultralight Aircraft Installations. Available online: https://www.uradni-list.si/glasilo-uradni-list-rs/vsebina/89174#kljucna_pravila (accessed on 2 April 2018).
  109. The Safety Aviation Agency of Spain. Available online: https://www.seguridadaerea.gob.es/lang_en/la_agencia/organizacion_y_funciones/default.aspx (accessed on 10 March 2018).
  110. Government of Spain Resolución Directora. Available online: https://www.seguridadaerea.gob.es/lang_en/cias_empresas/trabajos/rpas/marco/resolucion_directora/default.aspx (accessed on 10 March 2018).
  111. The Transport Agency of Sweden. Available online: https://www.transportstyrelsen.se/en/road/ (accessed on 2 May 2018).
  112. Transport Stylersen. New Rules for Drones on February 1, 2018. Available online: https://www.transportstyrelsen.se/sv/luftfart/Luftfartyg-och-luftvardighet/Obemannade-luftfartyg-UAS/nya-regler-for-dronare/ (accessed on 2 May 2018).
  113. The Federal Department of the Environment, Transport, Energy and Communications (DETEC). Available online: https://www.admin.ch/gov/en/start/departments/department-of-environment-transport-energy-communications-detec.html (accessed on 11 February 2018).
  114. The Federal Department of Environment, Transport, Energy and Communication, DETEC Regulation on Aircraft of Special Categories. Available online: https://www.admin.ch/opc/de/classified-compilation/19940351/index.html#a5 (accessed on 11 February 2018).
  115. Directorate General of Civil Aviation Procedures for Permit to Fly (PtoF). Available online: http://web.shgm.gov.tr/en/s/2222-procedures-for-certificate-of-special-flight-permit (accessed on 21 February 2018).
  116. The Directorate General of Civil Aviation of Turkey. Insansiz hava araci Sistemlerinin Ayrilmiş hava Sahalarindaki Operasyonlarinin usul ve Esaslarina Ilişkin Talimat (Sht-Iha). Available online: http://web.shgm.gov.tr/doc5/sht-iha.pdf (accessed on 10 May 2018).
  117. The Civil Aviation Authority of UK. Available online: https://www.caa.co.uk/home/ (accessed on 1 March 2018).
  118. Civil Aviation Authority of UK. Unmanned Aircraft and Drones. Available online: https://publicapps.caa.co.uk/modalapplication.aspx?appid=11&mode=detail&id=415 (accessed on 1 March 2018).
  119. Federal Aviation Administration (FAA). Regulations and Guidelines. Available online: https://www.faa.gov/ (accessed on 15 February 2018).
  120. United States Department of Transportation. Unmanned Aircraft Systems. Available online: https://www.faa.gov/uas/getting_started/ (accessed on 15 February 2018).
Figure 1. Criteria in the national legal frameworks for each OECD country.
Figure 1. Criteria in the national legal frameworks for each OECD country.
Drones 03 00075 g001
Figure 2. Registration and liability insurance requirements for drone operators in OECD countries.
Figure 2. Registration and liability insurance requirements for drone operators in OECD countries.
Drones 03 00075 g002
Figure 3. Maximum altitude and horizontal distance for drone flights according to national legislations.
Figure 3. Maximum altitude and horizontal distance for drone flights according to national legislations.
Drones 03 00075 g003
Figure 4. Minimum distance of drone flights from airports.
Figure 4. Minimum distance of drone flights from airports.
Drones 03 00075 g004
Figure 5. Evolution of papers published on drones per year.
Figure 5. Evolution of papers published on drones per year.
Drones 03 00075 g005
Table 1. Legal authorities per country in charge of drone regulation.
Table 1. Legal authorities per country in charge of drone regulation.
CountryAuthorityLegal Framework
AustraliaCivil Aviation Safety Authority [47][48]
AustriaAustro Control [49][50]
BelgiumCivil Aviation Authority [51][52]
Canada Transport Canada [53][54,55]
Chile General Directorate of Civil Aviation [56][57]
Czech Republic Civil Aviation Authority of Czech Republic [58][59]
DenmarkDanish Transport, Construction and Housing Authority [60][61]
EstoniaThe Civil Aviation Authority of Estonia [62][63]
Finland Finnish Transport Safety Agency [64][65]
FranceMinistry of Ecological and Solidarity Transition [66][67,68]
GermanyFederal Minister of Justice and Consumer Protection of Germany [69][70]
GreeceHellenic Civil Aviation Authority [71][72]
HungaryThe National Transport Authority of Hungary [73][74]
IcelandThe Icelandic Transport Authority [75][76]
IrelandThe Irish Aviation Authority [77][78]
IsraelThe Civil Aviation Authority of Israel [79][80]
ItalyThe Italian Civil Aviation Authority [81][82]
JapanThe Ministry of Land, Infrastructure, Transport and Tourism of Japan [83][84]
South KoreaMinistry of Land, Infrastructure and Transport of South Korea [85][86]
Latvia The Ministry for Transport and Agriculture of the Republic of Latvia [87][88]
LuxembourgThe Directorate of Civil Aviation, under the Ministry of Transport in Luxembourg [89][90]
Mexico The Ministry of Communications and Transportation of Mexico [91][92]
The NetherlandsThe State Secretary for Transport, Public Works and Water Management of Netherlands [93][94]
New ZealandThe Civil Aviation Authority of New Zealand [95][96]
NorwayThe Civil Aviation Authority of Norway [97][98]
PolandThe Civil Aviation Office of Poland [99][100,101,102]
PortugalThe Portuguese Civil Aviation Authority [103][104]
SlovakiaThe Ministry of Transport and Construction of Slovak Republic [105][106]
Slovenia The Civil Aviation Agency of the Republic of Slovenia [107][108]
SpainThe Safety Aviation Agency of Spain [109][110]
SwedenThe Transport Agency of Sweden [111][112]
SwitzerlandThe Federal Department of the Environment, Transport, Energy and Communications of Switzerland [113][114]
TurkeyThe Directorate General of Civil Aviation of Turkey [115][116]
UKCivil Aviation Authority of UK [117][118]
USAFederal Aviation Administration of USA [119][120]
Table 2. Reference to the criteria in national legal frameworks.
Table 2. Reference to the criteria in national legal frameworks.
Countries.Flying Distance Restrictions Weight Classification Over Crowed Areas Restrictions Flight Permissions Areas’ Distance Restrictions Drone Registration Buildings’ Distance Restrictions Safety Insurance Piloting Certificate Purpose of Flights Operators’ Age Limitations Operation Plan Air Flight Zones Weather Conditions Sum
Australia+++++ ++ 7
Austria++++++ + 7
Belgium+++++++++ ++ 11
Canada++++ +++++++ +12
Chile+++ + + 5
Czech Republic++++ +++ + 8
Denmark++++ +++ + 8
Estonia+ ++ + 4
Finland+++++++++ + 10
France++++++++++ + +12
Germany+++++ +++ 8
Greece+++ ++++++ 9
Hungary++ + ++ + 6
Iceland+++++++ 7
Ireland+++++++ 7
Israel+++++ +++ 8
Italy+++ +++ + + 8
Japan+++++ + 6
South Korea+++ ++++ 7
Latvia++++++++ + + 10
Luxembourg++++ ++ 6
Mexico+++++ + 6
The Netherlands+ ++ + ++++ 8
New Zealand+++++ + + 7
Norway++ ++++++ + 9
Poland+++++++++++ 11
Portugal+++++ ++ + 8
Slovak Republic++++++++++ + 11
Slovenia+++++++++ 9
Spain++ +++ +++ 8
Sweden++++++ + + 8
Switzerland+++++ + 6
Turkey+ +++ + + + 7
United Kingdom++++++++++ 10
United States++ + ++ + 6
Sum353231292624232322158642
Table 3. Recommendations for a homogenous legal framework.
Table 3. Recommendations for a homogenous legal framework.
Purpose of Use Certification for PilotsFlight Online RegistrationSize ClassificationsFlight Altitude (Without Special License)
100 gr < 4 kg4–25 kg25–150 kg> 150 kg120 m150 m
Commercial and industrial
Recreational and infotainment
Scientific/research
Surveillance and security
Agriculture
Enforcement Monitoring
Search and rescue and first aid
Infrastructure
Environmental management

Share and Cite

MDPI and ACS Style

Tsiamis, N.; Efthymiou, L.; Tsagarakis, K.P. A Comparative Analysis of the Legislation Evolution for Drone Use in OECD Countries. Drones 2019, 3, 75. https://doi.org/10.3390/drones3040075

AMA Style

Tsiamis N, Efthymiou L, Tsagarakis KP. A Comparative Analysis of the Legislation Evolution for Drone Use in OECD Countries. Drones. 2019; 3(4):75. https://doi.org/10.3390/drones3040075

Chicago/Turabian Style

Tsiamis, Nikolaos, Loukia Efthymiou, and Konstantinos P. Tsagarakis. 2019. "A Comparative Analysis of the Legislation Evolution for Drone Use in OECD Countries" Drones 3, no. 4: 75. https://doi.org/10.3390/drones3040075

Article Metrics

Back to TopTop