A recent report published by the Government Accountability Office (GAO) concerning FAA activities provides insight into how U.S. drone regulations compare to those in 10 other countries.
The countries compared to the U.S. in the report were Australia, Canada, France, Japan, the United Kingdom, China, Germany, Israel, Poland, and South Africa.
Most countries agree on some of the basics. All of the countries regulate commercial UAS, enforce drone laws in some way, require airspace authorizations for some airspace, and restrict flight near airports.
According to the report, all except Israel allow flight beyond visual line of sight (BVLOS) in some circumstances. All except China and Israel restrict the altitude of drone flights; and all but Japan, China and Germany require some form of pilot training and certification.
An examination of the remaining points reviewed, however, shows more disagreement in how individual countries deal with drones.
In the United States, Section 336 of the federal code protects recreational drones from new FAA regulations. This has been a point of contention between some commercial entities and recreational advocacy groups, as commercial groups and the FAA urge lawmakers to repeal Section 336 and allow the FAA to regulate all drones. Most other countries also differentiate between the two types of operation: but three countries – Japan, China, and Israel – do not distinguish between commercial and recreational use, applying the same laws to all.
The United States, Australia, France, and Poland are the only countries of the eleven compared that do not regulate recreational operators, and it appears that the U.S. has company in asking CBO’s for help. Of those that do differentiate, the report states: “Two of our five selected countries, like the United States, have chosen to rely on community-based organizations—many of whom represented the early UAS pilots before the rapid growth of small UAS manufacturing and sales—for assistance in providing guidelines and education for recreational small UAS pilots.”
The issue of weight-based risk categories for regulation is also a point of comparison. Here, the U.S. is among the few that do not recognize weight-based classification; something drone manufacturers have promoted. Only the U.S., Israel and Poland do not divide small UAS into weight classifications.
While individual countries may differ on individual drone laws and frameworks, they appear to experience many of the same issues when it comes to regulating UAS. The report says that most countries must coordinate and collaborate with other government agencies, and many have had to use “new and reallocated internal resources” to support regulation of drones.