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.

Open Category Competency Requirements

The sub-category you are intending to fly in, determines the level of risk to 3rd parties and therefore the level of safety to be achieved and hence the level competency required. For the open category here’s the differing levels of competency and a brief overview of what type of flights they apply to. See my previous blog post here for more details.

User Manual Familirasation

If flying in A1 with a Class 0, Privately Built, or Pre July 2022 Drone then all you need from a competency perspective is to be familiar with the user manual.

Foundation Test

If you are flying in A1 with a Class 1 Drone or in A3 with any drone then you’ll need to pass a foundation test. This is based on an online theory test with 40 questions, multiple-choice covering things such as air safety, regulations, privacy, insurance, security, etc. This could either be a entirely new test or the CAA may simply increase the number of questions in the existing DMARES test required to get a Flyer ID. The Flyer ID is currently valid for 3 years, hopefully this will remain the same.

Certificate of Remote Pilot Competency / A2 Certificate of Competency

If flying in A1 with a drone <500g (under the transitional arrangement in place until 30 June 2022) OR any aircraft in A2 then you’ll need to hold an A2 Certificate of Competence (A2 CofC). This is an additional course targeted at the extra risks that A2 flying comes with (i.e. flying close to uninvolved persons). This is a 30 question exam conducted by a CAA recognized organization (RAE - recognised assessment entity). To do this assessment you must first have completed the foundation test, obtained a Flyer ID and conducted some practical flight training in A3 but simulating A2 flight. The certificate will be valid for 5 years.

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.

Operator and Pilot Responsibilities in the Open Category

Updated 9th June 2020: to include CAP1789 rules on remote ID for all aircraft post 1 January 2022 and night time flying

It’s important to understand the difference between a drone operator and remote pilot so you know your responsibilities.

• Operator - means any legal or natural person operating or intending to operate one or more UAS. The CAA consider this to be the person who has the management of the small unmanned aircraft

• Remote Pilot - an individual who operates the flight controls by manual use of remote controls or if flying automatically, monitors its course and is able to intervene and change its course by operating its flight controls;

The Operator and Remote Pilot would be the same person if you’re a one-man-band, but bigger organizations may have an operator who doesn’t actually fly the drone. You may also be the parent of a child with a drone, in which case the parent would be the operator and the child the remote pilot.

Operator Responsibilities

• Ensuring operational procedures are in place (commensurate with the risk) and make efficient use of radio spectrum

• Ensure anyone involved in the drone flight is competent to do their task

• Ensure you provide the geographical zone information

• Ensure you update the geo-awareness system

• If using a drone that is compliant with the delegated regulation then ensure that the drone is accompanied with a Decleration of Confirmity, it is CE Marked and Class ID Label affixed to the drone

• If flying in circumstances of A2 or A3 then ensure all persons are informed of the risk and agreed to particpate.

• From 1 January 2022 operators must ensure that each individual unmanned aircraft is installed with an active and up to date remote identification system

Remote Pilot Responsibilities

• Ensure you are competent (unless Class C0; Or Privately built, <250g and max speed of 19 m/s (36 kts / 42 mph); OR Placed on Market < 1 July 2022 and <250g).

• Observe environment for obstacles and uninvolved persons

• Obtain latest geographical zone information

• Ensure drone is safe and remote ID working (if equipped)

• Ensure mass does not exceed limits (manufacturer, open category or class)

• Ensure fit and not under influence

• Maintain VLOS and visual scan

• Comply with geographical zones

• Operate i.a.w user manual and operator procedures

• Avoid areas where an emergency response effort is ongoing unless permitted

• Observer may assist pilot in VLOS if situated alongside

• From 1 July 2022 RP must ensure they activate a green flashing light when operating at night.

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.

Generic rules in the Open Category

Updated 9th June 2020: To reflect CAP1789 minimum age requirements and Lighting requirements.

While I’ve covered the specific rules for the three different scenarios of the Open Categories, I wanted to try and group together the generic ones that apply no matter which of the three Open categories you’re flying in.

Maximum Flying Height

EASA Image explaining the height

As per the current rules and regulations (unless you have an exemption from the CAA), the maximum permitted height in 99% of circumstances* is 400ft above the ground. However, in the new world this looks like it can be extended (without the need for additional CAA authorisation) in two key scenarios:

• Model Gliders - when soaring around hilltops 400ft above the ground, flying horizontally away from yourself the ground can quickly drop away as the terrain of the hill drops. For this reason the new rules permit the 400ft to be from the pilot as opposed to the earth (note: VLOS is still required) when using gliders in this scenario.

• Obstacles - the whole point of 400ft is generally to seperate unmanned aircraft and manned aircraft. However, if there is a man made obstacle that goes above 400ft, let’s say to 500ft, then it’s safe to say the manned aircraft will not be flying below 500ft (in most circumstances). Therefore the regulation allows drones to fly within 15m of that obstance horizontally or vertically.

*I say 99% because currently, when flying within a Flight Restriction Zone, drone operators may fly above 400ft with permission from the Air Traffic Service Provider.

Minimum Age Requirments

Currently, commercial drone operators must be a minimum of 18 years old as this is the minimum age required for a PfCO and Operator ID. Also a pilot (but not an operator) may currently obtain his/her own Flyer ID at 13 years. The new regulations state the minimum age for this is now 16 years (for specific and open), however, the CAA have the power to reduce this by up to 4 years in the open (or 2 years in the specific), the CAA have stated they will do this in order to align with the current situation in the open category (i.e. 13 years) and they will reduce it for the Specific category to 14 years. It’s worth adding that in the new regulations there is no minimum age if the drone is being flown in A1 and it is a C0 drone classed as toy, it is privately built and <250g, legacy <250g OR operating under the supervision of a pilot who already holds the required competency of the flight/drone (e.g. A1/A2/A3).

Airworthiness Requirements

Quite simply the safety of drone design must comply with the delegated regulation unless it is

1. Privately built

2. Covered by a model aircraft club/association framework

3. Placed on the market before 1 July 2022

Registration Requirements

There’s an onus on the Operator (as opposed to the Remote Pilot, but they be the same person) to register the drone when operating in the Open Category if the drone is more than 250g, can transfer a Kinetic Energy of more than 80 Joules OR is capable of capturing personal data. It is not required is the drone is classed as a Toy.

Geographical Zones

This will work in a similar fashion to the Flight Restriction Zones as already displayed on the NoFlyDrones home page. They can be set up for the purpose of safety, security, privacy, or environmental reasons. The key difference is that these are not going to be as black and white as a NO fly zones like we have today. They could restrict certain types of drone operations or drone classes, certain areas may require an OA or they may only allow drones equipped with certain features.

Lighting and Remote ID

From 1 July 2022, a green flashing light must be activated when flying at night.

From 1 January 2022 operators must ensure that each individual unmanned aircraft is installed with an active and up to date remote identification system

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.

The Open Sub-Categories

Update 9th June 2020: CAA have now decided the competency requirements for flying <500g drone as if it was a C1 device. Also added some clarification about distances from vessels, vehicles, and structured. They have also acknowledged that low speed mode privileges don’t apply to legacy aircraft. Text updated below.

I’ve already covered the three main categories (Open, Specific and Certified) but now I’m looking at the three sub categories of Open: A1, A2 and A3. They represent different scenarios of flying your drone:

• A1 - Flying Over People

• A2 - Flying Close to People

• A3 - Flying Far away from People

In all open categories you are not allowed to fly over assemblies of people (in the UK this is usually taken as 1000 people or more).

The CAA has recently clarified that any distances stated should also apply to vehicles, vessels, and structures where you can’t be certain they are not occupied.

There are references in this post to particular classes of drone (e.g. Class C1, C2 etc.) this refers to the delegated regulation and I’ll cover specifically what these mean in another post once I’ve got my head round them.

Open A1 - Flying Over People

Open A1 Overview

Note: *CAA have now set this level to be the A2 CofC.

The drones that fit in this category are generally light in weight (< 900g), if you want to fly anything heavier than those that fit this bill then you’ll need to look at Specific or Certified.

In some circumstances you are allowed to fly over people. If you’re flying a Class C0 Drone (yes yet another category of something to understand), you’ve built it yourself (and it weights <250g with a max speed of 19m/s) or are flying a legacy <250g drone placed on the market before 1 July 2022) then you may overfly people. However if it’s a Class C1 Drone or a legacy drone <500g (until 30th June 2022 only) then you must not plan to intentionally overfly people.

With respect to keeping the aircraft within Visual Line of Site (VLOS), when flying in A1 you may use follow me mode up to a distance of 50m.

Competency is fairly light touch, for the smaller drones (<250g) you’ll need to be familiar with the drone user manual but if you’re flying a slightly heavier (but still within the A1 scale) you’ll need to have also passed the foundation training and online test (i.e. the CAA DMARES test).

Open A2 Category

Open A2 Overview

This category covers a slightly increased weight and does not allow any overflight of people in any circumstances. I believe the increased weight is linked to a general assumption that if a drone fails it will fall directly down rather than in any particular direction. Therefore this category allows flying close to people to but not directly overhead.

If you’re flying a Class C2 Drone or a legacy <2kg drone (until 30th June 2022 only) you may fly to within 50m (30m of Class C2) horizontally of people. This may be reduced to 5m if in low-speed mode (<3m/s). (Note: any legacy aircraft with a similar low speed mode can not take advantage of this distance reduction).

As with A1, the remote pilot must be familiar with the user manual but to fly close to people the operator will be required to hold an A2 Certificate of Competency (known as an A2 CofC).

Open A3 Category

Open A3 Overview

This category presents the lower end of risks of drone operations. It’s essentially for flights clear of people, buildings etc. Class C2, C3 and C4 drones may be used in this category. It also covers any legacy drones <25kg. Similar to A1, you’ll need to have also passed the foundation training and online test (i.e. the CAA DMARES test).

Next I’ll cover the general rules applicable to all Open Category flights, like heights, age, etc.

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.

Open vs Specific vs Certified

As I said previously, the rules that apply are determined by which category you fall into, so the aim of this post is to help work out which drones/operations fall into which.

Open Category

An off the shelf drone in an safe area may fall in the “Open” category

My current feeling is that this is the most well defined, documented and understood category. I also think this is where the majority of hobbyists and even some commercials (by today’s standards) will operate. Essentially if your drone and operation are compliant with the following then you fall into the Open Category:

• Drone design is Compliant with the Delegated Regulation, Privately Built, or Placed on Market < 1 July 2022

• < 25kg Maximum Take Off Mass

• Remain a safe distance from people and do not overfly assemblies

• VLOS (*caveat for follow-me or observer usage)

• < 120m / 400ft Height (**caveat for obstacles and Model Gliders)

• Not carrying dangerous goods or dropping materials

• No autonomous flight

To expand on some of the Caveats.:

* for certain aircraft and operations in the Open Category the regulations allow flight of up to 50m from the Remote Pilot in “Follow-Me” mode OR when having an Observer situated alongside the Remote Pilot you may delegate VLOS to the observer so you can focus on the camera view.

** for flights within 15m of an obstacle you may fly higher than 400ft if you have permission from the owner of the obstacle and remain within 15m of that obstacle. But my understanding is that VLOS must still be maintained.

That’s the Open Category, in a nutshell. There are a further three sub-categories but I’ll go into these separately as these determine the rules that apply to each specific flight.

Specific Category

A drone flight in a city centre may fall into the “Specific” category

For those operations that site outside of the Open Category but not complex enough to sit in the Certified Category will be classed as Specific. The measures required to ensure safe flight are determined by a risk assessment. These risk assessments may be specific to your operation OR they may be based on standard scenarios already risk assessed. If using your own risk assessment you’ll need an Operational Authorisation (OA) from the UK CAA (caveat for Model Aircraft Clubs and Associations)***. If using a standard scenario (that has already been risk assessed and publised by the commission) then you only need to submit evidence and a declaration of compliance to those rules to the UK CAA.****.

In addition to the Standard Scenarios, the UK CAA are also using the concept of PDRAs (Pre Defined Risk Assessments), these appear to have a similar aim of the standard scenarios, i.e. less paperwork to send to the regulator to review and approve but these will require an OA, rather than just a declaration. I’m not claiming here that a decleration will be “less work” than an OA because you will have to satisfy the CAA that your decleration meets the requirements.

Again, I won’t cover the standard scenarios or pre-defined risk assessment here but will cover in a later post.

To expand on some more Caveats.:

*** Model Aircraft Clubs can operate in the specific category with an Authorisation (as opposed to an OA) if they have their own framework in place for safe operations and they have submitted these to the UK CAA.

**** Another scheme exists in the new regulations called a LUC (Light UAS Operator Certificate). I’ve not read this in too much detail but my understanding is that LUC holders can essentially authorize there own flights, but the requirements to get this LUC are very comprehensive and require things like a safety management system, training, manuals, etc. so I can’t imagine too many operators holding this status.

Certified Category

A drone delivering cargo or transporting passengers could be in the “Certified” category

Certified operations present the highest risk and as such have the strictest rules associated with it. Operators require certification, pilots require licenses and aircraft must be certified as per the Delegated Regulation. If the operation sits in any of the following then it must meet the certified requirements:

• over assemblies of people

• transport of people

• carriage of dangerous goods, that may result in high risk for third parties in case of an accident.

• a risk assessment determines that safety can only be maintained if the operation is certified

I hope that’s useful. My next post will look at more detail on the Open Category.

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.

Where are the EU Drone Regulations documented?

I must’ve read hundreds of pages documentation and some of it is not easy to find. I won’t explain what each of them does in this post as this will come later. I’ll add new documents to this post as I find them.

Note these links may not be up to date! Check the official sources for the official version and the latest information.

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COMMISSION IMPLEMENTING REGULATION (EU) 2019/947 of 24 May 2019 on the rules and procedures for the operation of unmanned aircraft

PDF

https://eur-lex.europa.eu/eli/reg_impl/2019/947/oj

COMMISSION DELEGATED REGULATION (EU) 2019/945 of 12 March 2019 on unmanned aircraft systems and on third-country operators of unmanned aircraft systems

PDF

https://eur-lex.europa.eu/eli/reg_del/2019/945/oj

Acceptable Means of Compliance (AMC) and Guidance Material (GM) to Commission Implementing Regulation (EU) 2019-947 - Issue 1

PDF

https://www.easa.europa.eu/acceptable-means-compliance-and-guidance-material-group/amc-gm-implementing-regulation-eu-2019947

Acceptable Means of Compliance (AMC) and Guidance Material to Part-UAS — Issue 1

PDF

https://www.easa.europa.eu/acceptable-means-compliance-and-guidance-material-group/amc-gm-part-uas

Opinion 05/2019 Standard scenarios for UAS operations in the ‘specific’ category

PDF

https://www.easa.europa.eu/document-library/opinions/opinion-052019

Easy Access Rules for Unmanned Aircraft Systems (Regulation (EU) 2019/947 and Regulation (EU) 2019/945)

PDF

https://www.easa.europa.eu/document-library/general-publications/easy-access-rules-unmanned-aircraft-systems-regulation-eu

Opinion 01/2020 High-level regulatory framework for the U-space

PDF

https://www.easa.europa.eu/document-library/opinions/opinion-012020

CAP1789: The EU UAS Regulation Package – Outline

PDF

https://publicapps.caa.co.uk/modalapplication.aspx?appid=11&mode=detail&id=9135

CAP 393: The Air Navigation Order 2016 and Regulations

PDF

https://publicapps.caa.co.uk/modalapplication.aspx?catid=1&pagetype=65&appid=11&mode=detail&id=7523

The Air Navigation Order 2016

PDF (not this does not include any ammendments)

http://www.legislation.gov.uk/uksi/2016/765/contents

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.

Welcome to my EU Drone Regulation Blog

My Inspire 1 contemplating it’s future as a “Legacy” drone!

Hello,

I’ve been maintaining No Fly Drones in my spare time now for over 4 years now and in that time I’ve seen several iterations of drone regulation changes. I always try and keep up with them, review regulatory documentation, legislation and guidance in order to ensure my site is as useful and up to date as possible but also as a drone operator myself, I need to know the rules in an operational context. But in those 4 years I think the biggest change I have experienced is the EU Drone Regulations on the horizon. Flight Restriction Zones come in a close 2nd place though!

There are reams of documentation out there and I’ll be honest, I’m struggling to get my head around it all, so I’m using this blog to try and capture my thoughts and help sort out all this information into something I can digest a bit easier. It’s not intended to be a replacement for reading the actual rules but I hope it will help me (and anyone reading this) know where to look for the information/rules I’m interested in.

At the start, this blog may be quite active in terms of posts but once I’ve covered everything I don’t expect to be posting daily, weekly, or even monthly, just when something new gets published and I’ve had a chance to read it, I’ll update my thoughts and interpretations here.

James