Urban Air Mobility - Part 1: Parcel drone as Smart City approach

Smart city is a trend theme that is giving rise to numerous new concepts, especially in the area of urban mobility. Approaches in the field of smart city aim to ensure that the urban area is designed in line with the age of digitalization. Urban Air Mobility is often cited as a particularly innovative approach.

Urban Air Mobility

The term Urban Air Mobility covers transport concepts for opening up airspace in urban areas. A distinction can be made between parcel drones, which are used to transport goods, and cab drones. In addition, Urban Air Mobility falls into the area of civil unmanned aviation, which has an impact from a legal perspective due to the associated requirements. From an economic point of view, Urban Air Mobility is considered a future market with great market potential, which has triggered competition among industry giants. Prominent examples include Google's Project Wing and Amazon's Prime Air.

Parcel drones: Advantages and disadvantages

The use of parcel drones in urban areas has both advantages and disadvantages. The main advantages are considered to be the reduction of urban road traffic and the associated positive environmental aspects. Parcel drones are also more efficient, as they do not have to stand in traffic jams. They can also be used more flexibly and have the potential to save costs.

However, the reduction of urban road traffic means at the same time additional load on the urban airspace. Furthermore, parcel drones may also have a negative impact on the environment and cause noise problems. Finally, not all safety risks associated with the use of parcel drones in urban areas have yet been resolved, such as the risk of damage in the event of parcel drone crashes.

Challenge: Designing the legal framework

Given the blurring boundaries between the advantages and disadvantages of using parcel drones, the design of a legal framework for their (safe) operation is already a challenge. At the European level, there are two EU regulations that govern the field of civil unmanned aviation and are therefore also important for the operation of parcel drones.

On the one hand, there is Regulation (EU) 2018/1139 (EASA-GVO). However, this regulation does not constitute a conclusive legal framework for the operation of (parcel) drones, as it hardly allows conclusions to be drawn regarding any operational requirements. On the other hand there is the Implementing Regulation (EU) 2019/947 (UAS-DVO). Unlike the EASA-GVO, this regulation specifies concrete approval scenarios with corresponding rules, to which the operation of parcel drones can also be assigned.

Accordingly, their operation generally requires an operating license. In addition, depending on the applicable approval scenario, any restrictions such as the regulations of the Commission Implementing Regulation (EU) No. 923/2012 must be complied with. In addition, there are other aspects to consider, such as registration obligations for the operator, but also for the drone itself, if applicable.

Current legal situation in Germany

The previous German law already contained requirements for unmanned aircraft. However, these had to be adapted with regard to the UAS-DVO, with the German government's May 2020 action plan on the subject of unmanned aviation systems and innovative aviation concepts playing a key role. Only time will tell whether the new regulations found in the process are suitable for practical application.

Data protection and liability

Finally, challenges also arise in the areas of data protection and liability. For example, the commercial operation of (parcel) drones involves the processing of personal data to a large extent. Therefore, one must ask whether the operation of parcel drones is compatible with the high data protection requirements of the GDPR. Their operation also raises the usual question of liability, which arises in particular in the event of damage caused by collisions or crashes.


From a legal perspective, the trend theme of Urban Air Mobility still raises a number of aspects in need of clarification in the area of parcel drone operations. The further development towards a comprehensive legal framework is strongly linked to the collection of further empirical values. In addition to the legal requirements for the operation of parcel drones as such, their integration into current air traffic also represents a further challenge, which will be considered in the continuation of this article.

Eva Ametsbichler