Third Country Operators

Third country operators are those operators outside of the EU who wish to operate within Single European Sky airspace.

• UAS operators that have their principal place of business, are established, or reside in a third country, shall comply with all the rules documented in the IR

• The competent authority for the third-country UAS operator shall be the competent authority of the first Member State where the UAS operator intends to operate

• Competency from 3rd country is valid if the Commission, after consultation of EASA, has ensured that the requirements on the basis of which such certificates have been issued provide the same level of safety as this Regulation

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.

Other rules of the Delegated Regulation

There are so many other rules documented in the DR but as a drone operator, I don’t need to know these in too much detail. I’ve read them but I don’t think it’s worth my time to understand them in detail. However, for future reference the following is a list of the areas I’ve not covered (or do not intend to cover) in this Blog:

SECTION 3 Conformity of the product

• Article 12 Presumption of conformity

• Article 13 Conformity Assessment Procedures

• Article 14 EU declaration of conformity

• Article 15 General principles of the CE marking

• Article 16 Rules and conditions for affixing the CE marking, the identification number of the notified body, the UAS class identification label and the indication of the sound power level

• Article 17 Technical documentation

SECTION 4 Notification of conformity assessment bodies

• Article 18 Notification

• Article 19 Notifying authorities

• Article 20 Requirements relating to notifying authorities

• Article 21 Information obligation on notifying authorities

• Article 22 Requirements relating to notified bodies

• Article 23 Presumption of conformity of notified bodies

• Article 24 Subsidiaries of and subcontracting by notified bodies

• Article 25 Application for notification

• Article 26 Notification procedure

• Article 27 Identification numbers and lists of notified bodies

• Article 28 Changes to notifications

• Article 29 Challenge of the competence of notified bodies

• Article 30 Operational obligations of notified bodies

• Article 31 Appeal against decisions of notified bodies

• Article 32 Information obligation on notified bodies Article

• 33 Exchange of experience

• Article 34 Coordination of notified bodies

SECTION 5 Union market surveillance, control of products entering the Union market and Union safeguard procedure

• Article 35 Market surveillance and control of products entering the Union market

• Article 36 Procedure for dealing with products presenting a risk at the national level

• Article 37 Union safeguard procedure

• Article 38 Compliant product which presents a risk

• Article 39 Formal non-compliance

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.

Importer and Distributor Obligations

The requirements don’t stop at the manufacturer, the new delegated regulation puts some onus and responsibility on the Importer too:

• Ensure manufacturer has completed their obligations (e.g. labeling, CE Marking etc.)

• Provide trading name, address, website etc on product, packaging or accompanying documentation

• Ensure while under their responsibility it is stored and transported such that it doesn’t jeopardise compliance

• Where appropriate (with regards to the risks of the product) carry out sample testing

• Keep copies of Declaration of Conformity for 10 years

• Take corrective actions when known to not be compliant and respond to audits

Distributor obligations are largely the same (except the need for adding trading name and details), however, if a product is placed on the market under the trading name of a distributor then they take on the responsibility of fulfilling the manufacturer obligations.

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.

Manufacturer Obligations

Current regulations for selling in europe are quite exhaustive in terms of product safety but don’t specifically cover drones. The classes I have previously covered fills that gap and will form part of the requirements to CE mark drones to be sold in the EU. The following are the responsibilities of the Manufacturer in respect to drones they sell:

• Ensure software, design or characteristic changes are only be issued if they don’t affect compliance with the DR

• Ensure compliance with the DR, provide technical information and conformity assessment

• Produce Declaration of Conformity and CE Marking and they should keep this for 10 years

• Put procedures in place to ensure series production remain compliant

• Ensure drone / remote ID add on has the type/class (drone only) and unique serial number

• Provide trading name, address, website etc on product, packaging or accompanying documentation

• Ensure product has User Manual and EASA Information notice in language that can be understood

• Take corrective actions when known to not be compliant and respond to audits

• They may delegate certain aspects of this to an Authorised Representative (i.e. data retention, audits, and/or non-conformity actions).

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.

Remote ID Add On Requirements

There’s really little difference between the requirements of a remote ID system already built into a drone vs the requirements of a separate add on remote ID device. Here’s a reminder:

The Remote ID shall work in realtime and with direct periodic broadcast (using open and documented protocol that can be received directly by existing mobile devices within range) of the following:

• the UAS operator registration number

• ANSI/CTA-2063 serial number

• the geographical position and height above the surface or take-off point

• true course and ground speed

• the geographical position of the remote pilot or, if not available, the take-off point;

It shall also prevent user from modifying last 4 bullets above.

The following is the key difference, a remote Add on should have a user manual with transmission protocol details and instructions to:

• Install on the drone

• change operator registration number

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.

C0/1/2/3/4 Drone and Open Category Mapping Summary

I’ve created a high level summary table which compares the rules applicable to each Class drone side by side. The parts in bold identify key differences I’ve spotted in the regulation. I’ve also mapped the Open Categories at the top of the table.

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.

Class C4 Drones - Defined

In order to maintain some consistency between classes I’m going to cover the following areas of the Delegated Regulation requirements for each class in the same order:

• Weight / Dimension / Speed / Height

• Controllability / Design / Power / Battery Alerting

• Noise Emissions / Serial ID / Lighting

• Remote ID

• Geo-Awareness

• System Intervention and Follow-Me

• Data Link Failure Behaviour

• User Manual and Box Content

Class Marking Symbol

The following symbol will be used to show this class of drone

Weight / Dimension / Speed / Height

The Maximum Take-Off Mass must be no more than 25kg.

There is no maximum size.

There is no maximum speed.

There is no maximum attainable height.

Controllability / Design / Power / Battery Alerting

The drone will need to be safely controllable and maneuverable by an RP following manufacturer instructions and under all anticipated operating conditions including failure of one or more systems.

There are not Design / Power / Battery Alerting requirements.

Noise Emissions / Serial ID / Lighting

There are no Emissions / Serial ID / Lighting requirements.

Remote ID

There are no Remote ID requirements.

Geo-Awareness

There are no Geo-Awareness requirements.

System Intervention and Follow-Me

There are no System Intervention or Follow-Me requirements however the aircraft must not have any automatic control modes except for flight stabilisation (with no direct effect on the trajectory) and lost link assistance.

Data Link Failure Behaviour

There are no Data Link Failure Behaviour requirements.

User Manual and Box Content

The User Manual shall clearly identify:

• Class

• Mass (with reference config) and MTOM

• Allowed payloads (mass, dimensions, interfaces and restrictions)

• Equipment and S/W to control UA Remotely

• Behavior in case of loss of data link

• Clear Operational instructions

• Limitations (including meteorological, day/night)

• Risks related to UAS operation

• Maintenance instructions

• Troubleshooting Procedures

The box shall contain an EASA Info Notice detailing laws etc. applicable to the drone.

Based on the above my interpretation is that these drones are more likely to be traditional uremote-controlled aircraft such as a fixed-wing Super Cub or Spitfire. However, it’s important to know that drones placed on the market prior to these regulations can’t be claimed to fall into any of these Classes. They fall under a different set of rules that have been set up to cover the use of legacy drones.

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.

Class C3 Drones - Defined

In order to maintain some consistency between classes I’m going to cover the following areas of the Delegated Regulation requirements for each class in the same order:

• Weight / Dimension / Speed / Height

• Controllability / Design / Power / Battery Alerting

• Noise Emissions / Serial ID / Lighting

• Remote ID

• Geo-Awareness

• System Intervention and Follow-Me

• Data Link Failure Behaviour

• User Manual and Box Content

Class Marking Symbol

The following symbol will be used to show this class of drone

Weight / Dimension / Speed / Height

The Maximum Take-Off Mass must be no more than 25kg.

The maximum size specified is 3m.

There is no maximum speed.

The maximum attainable Height 120 m above the take-off point OR the height can be user selectable in relation to the TO point or surface of the earth but this must display data to RP about current height.

Controllability / Design / Power / Battery Alerting

The drone will need to be safely controllable in stability, maneuverability, and data link performance by an RP with competency (as per the Implemented Regulation) and under all anticipated operating conditions including failure of one or more systems.

The drone will need to be designed and constructed to minimise injury, minimising sharp edges and if equipped with propellers, limit injury that may be inflicted by them.

The drone must have the mechanical strength (incl. Safety Factor) and stability to withstand stress without breakage or deformation that might interfere with safe flight.

If tethered, the tensile length must be <50m and have the mechanical strength no less than 10x weight of aerodyne at max mass for heavier than air or 4x force exerted by maximum thrust and aerodynamic force of maximum allowed wind speed for lighter than air.

The drone will need to be powered by electricity with all voltages (Nominal, Accessible, Internal) <48V DC or AC Equiv. Internally this can be more if the voltage and the current combination has no risk and no harmful electric shock (even when damaged)

The drone must alert the RP when battery of Drone or Control station is low, this must give sufficient time to land.

Noise Emissions / Serial ID / Lighting

Unless fixed wing, it must have an A-weighted sound power level LWA (measured as per Part 13 of Delegated Regulation). There is not specified limit on the sound level. The sound power level indication shall be affixed (as per Part 14 of Delegated Regulation)

The drone shall have a serial number as per the standard - ANSI/CTA-2063 Small Unmanned Aerial Systems Serial Numbers

Lights wll need to be fitted for Controllability and Conspicuity at Night (person on ground should be able to distinguish UA from Manned). From the 1st July 2022 a green flashing light must be activated when flying at night.

Remote ID

The drone shall be equipped with Remote ID that allows upload of the UAS operator registration number.

The Remote ID shall work in realtime and with direct periodic broadcast (using open and documented protocol that can be received directly by existing mobile devices within range) the following:

• the UAS operator registration number;

• ANSI/CTA-2063 serial number

• the geographical position and height above the surface or take-off point;

• true course and ground speed

• the geographical position of the remote pilot or, if not available, the take-off point;

It shall also prevent user from modifying last 4 bullets above.

There is no requirement for Remote ID if the drone is tethered.

Geo-Awareness

The drone shall have Geo-Awareness which shall be equipped with

• an interface to load and update airspace limitation and altitude data imposed by geographical zones. Process of loading/updating must not degrade data integrity and validity

• RP alerts when potential breach detected

• Information to RP on UA status and alert when position/nav systems can’t ensure proper geo-awareness functionality

System Intervention and Follow-Me

Any function limiting access to certain airspace shall interact smoothly without affecting flight safety and this shall provide clear information to the RP when this is happening

Follow-me mode shall not exceed 50m and shall allow RP to regain control

Data Link Failure Behaviour

The drone shall have a reliable and predictable method for the UA to recover the data link or terminate flight in a way that reduces the effect on air and ground 3rd parties

Data link shall be protected against unauthorised access to command and control functions.

User Manual and Box Content

The User Manual shall clearly identify:

• Class

• Mass (with reference config) and MTOM

• Allowed payloads (mass, dimensions, interfaces and restrictions)

• Equipment and S/W to control UA Remotely

• Behavior in case of loss of data link

• Clear Operational instructions

• Limitations (including meteorological, day/night)

• Risks related to UAS operation

• Transmission Protocol of Remote ID

• Sound Power Level

• Procedure to upload airspace limitation

• Maintenance instructions

• Troubleshooting Procedures

The box shall contain an EASA Info Notice detailing laws etc. applicable to the drone.

Based on the above my interpretation is that these drones are going to be professional grade drones, in today’s world this might be a DJI S1000 or Matrice. However it’s important to know that drones placed on the market prior to these regulations can’t be claimed to fall into any of these Classes. They fall under a different set of rules that have been set up to cover the use of legacy drones.

DJI Matrice Series

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.

Class C2 Drones - Defined

Updated 9th June 2020: to reflect the clarification on how night time conspicuity lighting should be achieved.

In order to maintain some consistency between classes I’m going to cover the following areas of the Delegated Regulation requirements for each class in the same order:

• Weight / Dimension / Speed / Height

• Controllability / Design / Power / Battery Alerting

• Noise Emissions / Serial ID / Lighting

• Remote ID

• Geo-Awareness

• System Intervention and Follow-Me

• Data Link Failure Behaviour

• User Manual and Box Content

Class Marking Symbol

The following symbol will be used to show this class of drone

Weight / Dimension / Speed / Height

The Maximum Take-Off Mass must be no more than 4kg.

There is no maximum size specified for this type of drone.

There is no maximum speed but the drone must be fitted with a selectable low speed mode (unless fixed wing).

The maximum attainable Height 120 m above the take-off point OR the height can be user selectable in relation to the TO point or surface of the earth but this must display data to RP about current height.

Controllability / Design / Power / Battery Alerting

The drone will need to be safely controllable in stability, maneuverability, and data link performance by an RP with competency (as per the Implemented Regulation) and under all anticipated operating conditions including failure of one or more systems.

The drone will need to be designed and constructed to minimise injury, minimising sharp edges and if equipped with propellers, limit injury that may be inflicted by them.

The drone must have the mechanical strength (incl. Safety Factor) and stability to withstand stress without breakage or deformation that might interfere with safe flight.

If tethered, the tensile length must be <50m and have the mechanical strength no less than 10x weight of aerodyne at max mass for heavier than air or 4x force exerted by maximum thrust and aerodynamic force of maximum allowed wind speed for lighter than air.

The drone will need to be powered by electricity with all voltages (Nominal, Accessible, Internal) <48V DC or AC Equiv. Internally this can be more if the voltage and the current combination has no risk and no harmful electric shock (even when damaged)

The drone must alert the RP when battery of Drone or Control station is low, this must give sufficient time to land.

Noise Emissions / Serial ID / Lighting

Unless fixed wing, it must have an A-weighted sound power level LWA (measured as per Part 13 of Delegated Regulation). The level should be limited (as defined in Part 15 of Delegated Regulation - note this gets more stringent with time). The sound power level indication shall be affixed (as per Part 14 of Delegated Regulation)

The drone shall have a serial number as per the standard - ANSI/CTA-2063 Small Unmanned Aerial Systems Serial Numbers

Lights wll need to be fitted for Controllability and Conspicuity at Night (person on ground should be able to distinguish UA from Manned). From the 1st July 2022 a green flashing light must be activated when flying at night.

Remote ID

The drone shall be equipped with Remote ID that allows upload of the UAS operator registration number.

The Remote ID shall work in realtime and with direct periodic broadcast (using open and documented protocol that can be received directly by existing mobile devices within range) the following:

• the UAS operator registration number;

• ANSI/CTA-2063 serial number

• the geographical position and height above the surface or take-off point;

• true course and ground speed

• the geographical position of the remote pilot or, if not available, the take-off point;

It shall also prevent user from modifying last 4 bullets above.

There is no requirement for Remote ID if the drone is tethered.

Geo-Awareness

The drone shall have Geo-Awareness which shall be equipped with

• an interface to load and update airspace limitation and altitude data imposed by geographical zones. Process of loading/updating must not degrade data integrity and validity

• RP alerts when potential breach detected

• Information to RP on UA status and alert when position/nav systems can’t ensure proper geo-awareness functionality

System Intervention and Follow-Me

Any function limiting access to certain airspace shall interact smoothly without affecting flight safety and this shall provide clear information to the RP when this is happening

Follow-me mode shall not exceed 50m and shall allow RP to regain control

Data Link Failure Behaviour

The drone shall have a reliable and predictable method for the UA to recover the data link or terminate flight in a way that reduces the effect on air and ground 3rd parties

Data link shall be protected against unauthorised access to command and control functions.

User Manual and Box Content

The User Manual shall clearly identify:

• Class

• Mass (with reference config) and MTOM

• Allowed payloads (mass, dimensions, interfaces and restrictions)

• Equipment and S/W to control UA Remotely

• Behavior in case of loss of data link

• Clear Operational instructions

• Limitations (including meteorological, day/night)

• Risks related to UAS operation

• Transmission Protocol of Remote ID

• Sound Power Level

• Procedure to upload airspace limitation

• Maintenance instructions

• Troubleshooting Procedures

The box shall contain an EASA Info Notice detailing laws etc. applicable to the drone.

Based on the above my interpretation is that these drones are going to be slightly bigger, in today’s world this might be a DJI Phantom. However it’s important to know that drones placed on the market prior to these regulations can’t be claimed to fall into any of these Classes. They fall under a different set of rules that have been set up to cover the use of legacy drones.

DJI Phantom

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.

Class C1 Drones - Defined

Updated 9th June 2020: to reflect the clarification on how night time conspicuity lighting should be achieved.

In order to maintain some consistency between classes I’m going to cover the following areas of the Delegated Regulation requirements for each class in the same order:

• Weight / Dimension / Speed / Height

• Controllability / Design / Power / Battery Alerting

• Noise Emissions / Serial ID / Lighting

• Remote ID

• Geo-Awareness

• System Intervention and Follow-Me

• Data Link Failure Behaviour

• User Manual and Box Content

Class Marking Symbol

The following symbol will be used to show this class of drone

Weight / Dimension / Speed / Height

The Maximum Take-Off Mass must be no more than 900g unless is can be demonstrated that the drone transfers no more than 80J of energy when colliding with a human head a terminal velocity.

There is no maximum size specified for this type of drone.

The maximum speed allowed is 19 m/s (42 mph or 36 knots)

The maximum attainable Height 120 m above the take-off point OR the height can be user selectable in relation to the TO point or surface of the earth but this must display data to RP about current height.

Controllability / Design / Power / Battery Alerting

The drone will need to be safely controllable in stability, maneuverability, and data link performance by an RP following manufacturer instructions and under all anticipated operating conditions including failure of one or more systems.

The drone will need to be designed and constructed to minimise injury, minimising sharp edges and if equipped with propellers, limit injury that may be inflicted by them.

The drone must have the mechanical strength (incl. Safety Factor) and stability to withstand stress without breakage or deformation that might interfere with safe flight.

The drone will need to be powered by electricity with all voltages (Nominal, Accessible, Internal) <24V DC or AC Equiv. Internally this can be more if the voltage and the current combination has no risk and no harmful electric shock (even when damaged)

The drone must alert the RP when battery of Drone or Control station is low, this must give sufficient time to land.

Noise Emissions / Serial ID / Lighting

Unless fixed wing, it must have an A-weighted sound power level LWA (measured as per Part 13 of Delegated Regulation). The level should be limited (as defined in Part 15 of Delegated Regulation - note this gets more stringent with time). The sound power level indication shall be affixed (as per Part 14 of Delegated Regulation)

The drone shall have a serial number as per the standard - ANSI/CTA-2063 Small Unmanned Aerial Systems Serial Numbers

Lights wll need to be fitted for Controllability and Conspicuity at Night (person on ground should be able to distinguish UA from Manned). From the 1st July 2022 a green flashing light must be activated when flying at night.

Remote ID

The drone shall be equipped with Remote ID that allows upload of the UAS operator registration number.

The Remote ID shall work in realtime and with direct periodic broadcast (using open and documented protocol that can be received directly by existing mobile devices within range) the following:

• the UAS operator registration number;

• ANSI/CTA-2063 serial number

• the geographical position and height above the surface or take-off point;

• true course and ground speed

• the geographical position of the remote pilot or, if not available, the take-off point;

It shall also prevent user from modifying last 4 bullets above.

Geo-Awareness

The drone shall have Geo-Awareness which shall be equipped with

• an interface to load and update airspace limitation and altitude data imposed by geographical zones. Process of loading/updating must not degrade data integrity and validity

• RP alerts when potential breach detected

• Information to RP on UA status and alert when position/nav systems can’t ensure proper geo-awareness functionality

System Intervention and Follow-Me

Any function limiting access to certain airspace shall interact smoothly without affecting flight safety and this shall provide clear information to the RP when this is happening

Follow-me mode shall not exceed 50m and shall allow RP to regain control

Data Link Failure Behaviour

The drone shall have a reliable and predictable method for the UA to recover the data link or terminate flight in a way that reduces the effect on air and ground 3rd parties

User Manual and Box Content

The User Manual shall clearly identify:

• Class

• Mass (with reference config) and MTOM

• Allowed payloads (mass, dimensions, interfaces and restrictions)

• Equipment and S/W to control UA Remotely

• Behavior in case of loss of data link

• Clear Operational instructions

• Limitations (including meteorological, day/night)

• Risks related to UAS operation

• Transmission Protocol of Remote ID

• Sound Power Level

• Procedure to upload airspace limitation

• Maintenance instructions

• Troubleshooting Procedures

The box shall contain an EASA Info Notice detailing laws etc. applicable to the drone.

Based on the above my interpretation is that these drones are going to be again fairly small, in today’s world this might be a Mavic Spark or Air. However it’s important to know that drones placed on the market prior to these regulations can’t be claimed to fall into any of these Classes. They fall under a different set of rules that have been set up to cover the use of legacy drones.

DJI Spark

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.

Class C0 Drones - Defined

In order to maintain some consistency between classes I’m going to cover the following areas of the Delegated Regulation requirements for each class in the same order:

• Weight / Dimension / Speed / Height

• Controllability / Design / Power / Battery Alerting

• Noise Emissions / Serial ID / Lighting

• Remote ID

• Geo-Awareness

• System Intervention and Follow-Me

• Data Link Failure Behaviour

• User Manual and Box Content

Class Marking Symbol

The following symbol will be used to show this class of drone

Weight / Dimension / Speed / Height

The Maximum Take-Off Mass must be no more than 250g

There is no maximum size specified for this type of drone, but obviously the weight will limit this quite significantly.

The maximum speed allowed is 19 m/s (42 mph or 36 knots)

The maximum attainable Height 120 m above the take-off point

Controllability / Design / Power / Battery Alerting

The drone will need to be safely controllable in stability, maneuverability, and data link performance by an RP following manufacturer instructions and under all anticipated operating conditions including failure of one or more systems.

The drone will need to be designed and constructed to minimise injury, minimising sharp edges and if equipped with propellers, limit injury that may be inflicted by them.

The drone will need to be powered by electricity with all voltages (Nominal, Accessible, Internal) <24V DC or AC Equiv. Internally this can be more if the voltage and the current combination has no risk and no harmful electric shock (even when damaged)

There are no requirements for battery alerts, but that’s not to say it can’t be included. Many basic drones nowadays have this, even if it’s just a flashing light to say the power is low.

It should be noted that if the drone in this class is being sold a toy (as per regulation 2009/48/EC) then the requirements on Controllability, Design and Power do not apply. I’ve not read into why exactly, but I suspect the regulation for toys is more stringent in terms of ensuring safety to the user.

Noise Emissions / Serial ID / Lighting

There are no requirements specified for Noise, Unique Serial Identification, or Lighting in this category.

Remote ID

There are no requirements specified for Remote ID in this category

Geo-Awareness

There are no requirements specified for Geo-Awareness in this category

System Intervention and Follow-Me

There are no requirements specified for system intervention (i.e. auto control or intervention from the drone itself overriding the human input) in this category

Follow-me mode shall not exceed 50m and shall allow RP to regain control

Data Link Failure Behaviour

There are no requirements specified for data link failure behaviour in this category

User Manual and Box Content

The User Manual shall clearly identify:

• Class

• Mass (with reference config) and MTOM

• Allowed payloads (mass, dimensions, interfaces and restrictions)

• Equipment and S/W to control UA Remotely

• Behavior in case of loss of data link

• Clear Operational instructions

• Limitations (including meteorological, day/night)

• Risks related to UAS operations adapted for the age of the user

The box shall contain an EASA Info Notice detailing laws etc. applicable to the drone.

Based on the above my interpretation is that these drones are going to be quite small, low risk, in today’s world this would be anything ranging from a really simple toy through to a Hubsan x4 or something like a Spark or a Tello. However it’s important to know that drones placed on the market prior to these regulations can’t be claimed to fall into any of these Classes. They fall under a different set of rules that have been set up to cover the use of legacy drones.

DJI Tello

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.

Drone Classes and Categories

At this stage I haven’t covered everything in the IR (particularly the Specific and Certified sections) but it felt like a good time to go to the DR temporarily to understand the Classes of Drones that relate to the Open Category A1, A2 and A3 operations.

The delegated regulation does more than just define the classes of drones, it also sets the rules for:

• production of Remote Identification add-ons in the market

• UAS operators that have their principal place of business, are established or reside in a third country

• supply chain obligations (including manufacturer, distributor, and importer)

For this post I’m going to give a very high-level overview of the drone classes, I’m pointing this out because there is so much more to the definition of a class than weight so please don’t think this is everything. I’ll have to cover each class in an individual post to cover everything. I’ll also cover the other aspects of the DR later. From 1st July 2022, all aircraft placed on the Market targetting the Open Category will need to comply with the DR. I’ve put a summary table together:

	CO	C1	C2	C3	C4
Maximum Take Off Mass (MTOM) including payload	Less than 250g	Less than 900g OR <80J energy transmitted to human head at terminal velocity	Less than 4kg	Less than 25kg	Less than 25kg
Maximum Dimensions	Not Specified	Not Specified	Not Specified	3 metres	Not Specified
Maximum Flight Speed	Less than 19 m/s 42 mph 36 knots	Less than 19 m/s 42 mph 36 knots	No Max Speed Specified but there must be a Selectable Low Speed Mode to <3m/s (Unless fixed wing)	No Max Speed Specified	No Max Speed Specified
Maximum Attainable Height	120 m above take-off point	120 m above take-off point OR Equipped with system that limits height above surface or take-off point to 120 m or value set by RP. If value set by RP clear height shall be provided to RP	120 m above take-off point OR Equipped with system that limits height above surface or take-off point to 120 m or value set by RP. If value set by RP clear height shall be provided to RP	120 m above take-off point OR Equipped with system that limits height above surface or take-off point to 120 m or value set by RP. If value set by RP clear height shall be provided to RP	No Max Height Specified
Lighting	No Lighting Specified	Lighting to support RP Controllability and Night Lights which should be distinguishable from Manned Aircraft.	Lighting to support RP Controllability and Night Lights which should be distinguishable from Manned Aircraft.	Lighting to support RP Controllability and Night Lights which should be distinguishable from Manned Aircraft.	No Lighting Specified
Remote ID	Not Specified	Yes	Yes	Yes	Not Specified
Geo-Awareness	Not Specified	Yes	Yes	Yes	Not Specified
Sound/Noise Restrictions	Not Specified	Yes	Yes	Yes	Not Specified

If I cross-reference back to my post on the Open Categories. A1 was about flying over people and allowed the use of C0 and C1 aircraft which as you can see are the lowest weighted aircraft and have a maximum speed thus reducing the potential kinetic energy of the drone to a safe level, so this mapping makes sense.

A2 was about flying close to people, this permitted the use of C2, now although this is a heavier aircraft don’t forget you’re not allowed to overfly people, just close to them horizontally and only when in low-speed mode. Hence the C2 aircraft must have a low-speed mode embedded.

A3 was about flying far from people, i.e. 150m from a congested area, this allows for C2, C3, and C4. C3 and C4 are considerably heavier and so it makes sense that these would only be allowed far from people. Also, the requirements on C4 are much less rigorous and are more akin to traditional model aircraft hence they are unlikely to have things like height, GPS, lighting, Geo-Awareness, etc.

It’s worth noting that any drones with high-risk operations can not be used in the open category and will be subject to certification this includes situations involving transporting people, dangerous goods, more than 3m in dimension and designed to operate over people or anything else that a risk assessment deems it necessary to seek certification.

One final point. The EC are proposing some additional classes (C5 and C6) I will review this proposal soon and update this as necessary.

Small Print: These posts are a summary only, include my personal interpretation and is not intended to be a replacement for reading the actual rules.

EU Regulation Package Overview

Update: June 2020 - the CAA have now stated the IR will be delayed to apply from 31st December 2020

There are two key regulations published by the European Commission:

1. Commission Implementing Regulation 2019/947 (referred to as the IR)

2. Commission Delegated Regulation 2019/945 (referred to as the DR)

If you are a drone operator or a drone training organisation then the IR (947) is of more interest to you. If you are a drone manufacturer, seller, importer, or perhaps a 3rd country operator then the DR (945) will be of more interest. I’ve put the following image together to give a quick overview of what they cover:

Package summary and pertinent dates.

Both the IR and DR have entered into force already but the IR has not yet become applicable (btw my interpretation is that Entry into Force means the regs formally exist and are legally acknowledged but can’t yet be enforced. Then only when it becomes Applicable are we obligated to follow them as they can be enforced. The time difference gives states, industry, and organizations to get prepared. Other reasons behind having this distinction can be found here).

It’s worth noting that the COVID-19 pandemic has led to the CAA postponing the applicability date of the IR from July to November 2020. This could be delayed further.

At a high level, the new regulations cover much more than currently in the UK ANO, here’s a brief list:

• Registration

• Competency

• Age

• Operator and Pilot Responsibilities

• Aircraft Equippage

• Model Aircraft Clubs

• Safety

• Privacy

• Security

• Toys

• Insurance

• Data Protection

• Environment (noise)

• +more

The extent of how much of these rules and regulations apply to you will depend on which of the three categories your drone or operation falls into:

Three categories of EU Commission Rules

Open covers low risk operations (e.g. using certified aircraft and/or in very low risk areas), Certified covers high risk operations (e.g. carrying people and/or overflying large assemblies of people) and Specific covers everything inbetween with some overlap at both ends. I’ll cover these individually.

Small Print: These posts are a summary only, include my personal interpretation and is not intended to be a replacement for reading the actual rules.