A review of global and regional frameworks for the integration of an unmanned aircraft system in air traffic management

Unmanned aircraft system (UAS) applications have increased exponentially in recent years owing to their low cost, improved performance, and the use of advanced technology in this relatively new and rapidly evolving industry. Despite the advanced technologies used in UASs, the integration of UASs into the air traffic management regulatory framework is lacking, which affects air transport. International and regional air transport regulators, having identified the major technological challenges, are gradually developing fundamental principles for the consolidation of manned and unmanned air traffic. In this review, the development of a common framework and fundamental principles set by major international regulatory authorities (International Civil Aviation Organization and Joint Authorities for Rulemaking on Unmanned Systems) were examined. The related initiatives of major Eastern countries (Russia, China, and Japan) in comparison with Western states (European Union (EU), United States, and United Kingdom) were comprehensively reviewed, focusing on EU activities and projects related to the concepts of operations. Indicative research activities on technology challenges (detect and avoid; command, control, and communication; and artificial intelligence-based unmanned aerial vehicle navigation), jointly identified by all international and national regulatory authorities, were also examined and presented. A comparative analysis of the fundamental principles of the frameworks revealed the similarities and differences between the approaches to the concept and its implementation. In terms of differences, the novel findings and contributions of this review are the different approaches regarding the roles and responsibilities of state authorities in unmanned aircraft traffic management (UTM) as well as approaches for UTM integration into the existing air traffic management systems. Based on this research, scientific groups of regulatory authorities could consider comparing the concepts and frameworks detailed in this review to address the differences and develop a harmonized global UTM framework.