a. The rules are a step in the right direction since they extensively cover many aspects of drone sector. These rules, once approved, would play a big role in facilitating the drone revolution as well as Industrial Revolution 4.0 in India.

b. The CAR 1.0, which was notified in 2018, was simply an extension of current aviation regulation. However, the proposed draft rules1, is a bold regulatory step by the Ministry of Civil Aviation to recognize drones as an industry in itself and not merely an extension of civil aviation in the country.

c. The recommendations of the draft Drone Policy 2.0 (which was released in January 2019), such as dropping of article and BVLOS operations are not envisaged in the Draft UAS Rules. It is requested that certain applications be treated differently owing to their nonurban or low altitude applications and also considering their extreme social value - Agricultural Spraying and Medical Delivery are two such applications. Furthermore, in utilities and infrastructure sectors such as oil & gas, railways etc., BVLOS operations for inspection & monitoring could prove to be extremely beneficial and prevent from any manmade disasters.

d. Due to the unprecedented scenario created by the COVID-19 pandemic, industry cannot afford the time and cost overrun due to delay in approvals. FICCI recommends setting-up a single window mechanism to enable applicants to obtain clearances / approvals from ministries such as the Ministry of Home Affairs, WPC Department of Telecommunication etc. Without such a mechanism the application process could prove to be a cumbersome process. The MoCA and DGCA may also consider setting up an appeal system for applicants through the single window mechanism.

e. Many Indian innovators and researchers are not able to develop world-class drone products, as they do not have access to infrastructure for testing facility. Industry is dependent on few labs and testing sites overseas. It would be ideal, if:

i. The MoCA and DGCA could notify wide range of testing sites under the jurisdiction of the MoCA as well as of the other Central or State Govt. Departments (which has adequate infrastructure to test drones) in each and every part of the country. The Govt. has already allowed private sector to use ISRO2 facilities and other relevant assets to improve their capability. On similar lines, the other govt. agencies could also be notified.

ii. Design Standard Operating Procedure (SOPs) for use of Government owned testing sites.

iii. Furthermore, new world class drones testing infrastructure could be developed in PPP mode. Since, India has world-class airports, creating similar world-class infrastructure for Drone Ports and Testing Facility is also possible.

f. Insurance regulator IRDA has recently set-up a working group to study and make recommendations on various aspects of insurance cover for drones. FICCI would be happy to work with IRDA and MoCA for the design and development of products that meet the needs of RPAS owners and operators, including Third Party liability. A taskforce comprising Govt. and Industry representatives could be set-up to ensure that suitable products come into market at the time of finalisation of the draft rules.

g. Students and hobbyist mostly use nano category UAS. They may not be able to afford the costly nano drones, as adding more equipment to the nano category drone will increase its cost manifold. It is recommended that Nano Drones for educational, recreational and experimental purposes could be considered as Model RPAS in 'Designated Areas'.

h. The DGCA may further enhance the Indian drone training eco system by considering the following suggestions:

i. DGCA may consider setting up an expert committee, supported by FICCI, for charting way forward steps to set-up more drone training institutes across India.

ii. MoU with other government bodies such as the training institutes under the Survey of India (SoI), under the Ministry of Science & Technology, could be leveraged.