UAV DACH takes a critical view of the Federal Environment Agency’s ‘drone study’
A study recently published by the Federal Environment Agency analyses the ‘opportunities and risks of unmanned aviation for people and the environment’. As the trade association for the UAS industry, UAV DACH generally welcomes scientific examination of the impacts of unmanned aviation. However, from the association’s perspective, the present study exhibits significant shortcomings in terms of content and concept.
1. Title and focus do not align
The title suggests a comprehensive examination of unmanned aviation. In reality, the study focuses largely on urban parcel logistics using a regional model. Important fields of application with high market relevance are left out – such as inspection, surveying, security applications, agriculture, and disaster and crisis response. These areas, however, account for the majority of current usage.
2. International practice is not taken into account
The study ignores the fact that drone-based logistics is already in operational use in several countries. Real-world operational experience would have contributed to a better understanding. Examples are provided by companies such as Zipline, Manna and Amazon Prime Air, which demonstrate that economic viability and acceptance are possible under suitable conditions.
3. Market relevance is inadequately reflected
Around 1 million drone operators are registered in Germany, and approximately 1.6 million across Europe. These figures illustrate the actual market penetration and societal significance of the technology, yet they are not systematically taken into account in the study.
4. Lack of differentiation between system classes
The study does not clearly distinguish between drones for commercial and regulatory applications and eVTOL systems for passenger transport. This differentiation is, however, essential, as passenger transport entails its own risks, timeframes and acceptance issues.
5. Airspace integration as a key challenge
The greatest hurdles to scaling up lie neither in technology nor in the market, but in restrictive airspace integration. Furthermore, there is a lack of a consistent concept for monitoring, identifying and penalising misuse. UAV DACH calls for clear responsibilities, a unified air situation picture and mandatory electronic identification (ADS-L) of all participants in lower airspace.
6. Outlook for the next ten years
UAV DACH sees potential for up to 100,000 drone flights per day in Europe within the next ten years. This potential is not limited by demand or technology, but primarily by avoidable regulatory hurdles.
The study provides important insights but should not be understood as a comprehensive assessment of unmanned aviation. A broader examination of various fields of application, a clear distinction between system classes, and the incorporation of international experience are necessary to enable well-founded conclusions. UAV DACH is open to dialogue with policymakers, authorities and the scientific community and encourages a more in-depth follow-up study.
>> About UAV DACH <<
UAV DACH is the oldest and largest European industry association for unmanned aviation, based in Berlin and with over 250 members from more than 10 countries.
Since its foundation in 2010, the association has actively contributed its expertise to national, European and international bodies.
UAV DACH represents the interests of commercial drone applications in Europe and pursues the following objectives:
- Promoting a competitive national and European UAS industry
- Enabling real-world applications through clear and practical regulation
- Strengthening public acceptance through transparency, visibility and safety
- Combating and penalising the misuse or illegal use of drones

