Introduction
At the beginning of this year Ministry of Civil Aviation (MoCA) announced that it would be mandatory for all Remotely Piloted Aircraft (RPA) operators in India to register their RPAs (generally referred to as drones) by January 31. Apparently, the voluntary disclosure scheme did not elicit adequate response and, on June 8, MoCA notified a reintroduction of the scheme, this time with no deadline! In official Indian terminology, an RPA is an unmanned aircraft, which is piloted from a remote pilot station; a remotely piloted aircraft, its associated remote pilot station(s), command and control links and any other components forms a Remotely Piloted Aircraft System (RPAS). Implicit to the MoCA announcement was the admission that a large number of RPAs were being operated without adherence to the prescribed guidelines in the Civil Aviation Requirement (CAR) issued by Director General Civil Aviation (DGCA). Depending on the source one accesses, the number of unregistered RPAs in Indian skies is at least a couple of lakhs, and may be more than 6 lakhs. Gloomy projections foresee a growth of around 10 lakhs per year for the next five years or so. The numbers do not matter so much as the fact that the proliferation appears to be unbridled with the regulatory mechanism not yet in convincing control of the growth.
Proliferation
What started off as the flooding of Indian markets with remotely controlled toy drones around a decade ago eventually acquired such alarming proportions that the government had to promulgate a complete ban on the use of drones in 2014. The ban was only supposed to be a stop-gap arrangement until a comprehensive regulation could be put into place. However, the various pulls and pushes that manifested themselves in the process of drafting a regulation led to an inordinately long time to do so. DGCA finally issued the CAR, Section 3 - Air Transport Series X, Part I Issue 1, on August 27, 2018. The CAR regulates the use of RPAs in the Indian Airspace and these regulations provide a process for obtaining Unique Identification Number (UIN), Unmanned Aircraft Operator Permit (UAOP) and other operational requirements including identification of civil RPAs and RPA operators. The RPA operators are required to register their RPAs on the online portal after which a RPA Acknowledgement Number (DAN) and an Ownership Acknowledgement Number (OAN) is issued online which would help in validation of operations. However, this does not give RPA operators to fly RPAs in India without permission. Only around 20,000 RPAs are registered with MoCA but there is a large number of them being flown without registration and without permission for various purposes.
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