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UK (EU really) EASA's Published Opinion on UAS operations

Main points that jump out to me (No doubt there's a load more in there.. but this's all I can cope with for tonight ;) :p )

Registration of operator
Compulsory for any operator of an UAS weighing between 250g & 25Kg. This is per operator, not per UAS.
Alongside registration, looks like there will be a need to purchase & install a fire-resistant registration plate to be applied to each UAS.

Moreover, a requirement has been added to equip UA with a fire-resistant placard displaying registration information. Deviations are possible for very small UA and for model aircraft.

As requested by several commenters, the 3-year validity of a registration proposed in the NPA has been deleted and transformed into a requirement for the MSs to keep the operator database accurate. GM will suggest a 3-year validity period, based on the considerations that the average lifetime of a small UAS is in the order of 2 years and the small UAS market is very dynamic
Unique Serial No
for each drone, other than ones in class 0

In flight ID.
UAS will need to be able to broadcast operator ID & a 'local-id' along with some other telemetry info and take off point info for security services to interrogate as needed.

requirements related to the use of an electronic identification system have been introduced directly into each appendix, requiring the following information to be broadcast:
o the UAS operator registration number;
o the unique serial number (SN) of the UA or, if the e-identification is provided by a separate module to be added to the UA, the SN of that module;
o the geographical position of the UA and its height;
o the geographical position of the point from which the UA took off; and o the timestamp of the data;


UAS Class:
Determines what you will be allowed to do. Class 0 is anything under 250g which they are treating as a toy, even if it has a camera. Other classes will depend on weight and functionality as to what you can do. It's dependant on a category of area (over/close/far from people). Class C4 is basically designed for model aircraft clubs so they can carry on pretty much as they are at the minute, with the proviso there is no automatic flight capability.

C0 <250g MTOM - no ID or GEO awareness & no UAS Operator registration. No training or tst. Can fly over uninvolved people (but not crowds)
C1 <900g MTOM - ID, GEO Awareness, Operator Registration. Online training & test. Can fly over uninvolved people (but not crowds)

C2 <4Kg - ID, GEO, Operator Reg + online training & test + NQE/NAA theory test. "Can fly at a safe distance from uninvolved people" (safe distance not defined)

C3 <25Kg - ID, GEO, Operator Reg + online training & test - selectable height limit. Fly in area where reasonably expected the no uninvolved person will be endangered & keep a safe distance from urban areas.

C4 < 25Kg - ID & Geo in some areas, operator reg + online training & test. Fly in area where reasonably expected the no uninvolved person will be endangered & keep a safe distance from urban areas.

Privately built <=250g as for C0
Privately built >250g <25Kg - as for C4.

Low Speed Mode
If UAS (in class 2) is fitted with a low speed mode (meeting requirements) then it will be permitted to approach close to people not under your control to as close as 5m (could be as low as 3m as a different section of document contradicts 5m).

- For UAS in class C2, a new requirement has been introduced for a low-speed mode that is selectable by the operator and limits the maximum cruising speed of the UA to a maximum of 3 m/s if the UA is intended to be operated in close proximity to people. This requirement will enhance the controllability of the UA, and allow UAS operators to fly their UA as close to uninvolved persons as 3 m.

- The minimum distance from uninvolved people to be maintained when conducting a UAS operation in subcategory A2 has been reduced to 5 m when a low-speed mode function is installed on the UA. The remote pilot needs to activate this functionality when operating close to people, so that the remote pilot will have enough time to react and alter the trajectory of the UA if it is heading towards people. In addition, the concept of the 1:1 rule (keeping the UA at a distance from uninvolved people that is no less than the height of the UA) has been introduced.


Speed limit
limited to 19m/s for class 0 UAS (the smallest ones under 250g).

For UAS in class C0, a maximum speed of 19 m/s has been added for UAS that do not comply with Directive 2009/48/EC on the safety of toys18. This avoids fast UA, which are typically used for races, being classified as class C0 and operated over people.

Max height
For all UAS classes is 120m. Although they expect that those under 250g (Class 0) will not be legal at that height given the requirement of pilot VLOS at all times. This basically removes the existing ability for hobbyists to fly higher than PfCO holders.
Some exemptions to the height rules may be made for model aircraft clubs flying in specific predefined areas, otherwise they need to fall into line with the rest of us as far as I can see.

Open & Specific Categories of flight
Part of the proposals seek to define an Open and a Specific category of use. These seem to be designed to manage a set of standard everyday permissions to apply to the UAS classes, and to allow for other operations outside of the everyday ones & that may need greater safety to also be classified and standardised. This may allow for the NAA to bring in a set of predefined/standardised risk assessments that people adhere to to gain additional permissions. This could potentially lead to the automation of applying for these additional permissions and a certain degree of self certification for them too.

As a general rule, the ‘open’ category has been defined as operations conducted:

— with a UAS with an MTOM of less than 25 kg;

— below a height of 120 m; and

— in VLOS.


It was decided to further subdivide operations in the ‘open’ category into three subcategories to allow different types of operations without the need for an authorisation. The subcategories were defined according to the risks posed to persons and objects on the ground, keeping in mind that the operations would all be below 120 m in height and far from aerodromes. These subcategories are:

— A1: flights over people but not over open-air assemblies of persons;
— A2: flights close to people, while keeping a safe distance from them;
— A3: flights far from people.


The ‘specific’ category is applicable to all operations that do not comply with the limits of the ‘open’ category. It basically requires the UAS operator to perform a risk assessment and to propose mitigation measures that the competent authority will analyse and approve through an authorisation.

To limit the administrative burden for both UAS operators and the competent authorities, a system of standard scenarios has been proposed. A standard scenario involves a pre-established risk assessment and includes mitigation measures. It may be followed by a declaration submitted by the UAS operator (if the implementation of the mitigation measures is considered to be simple), or by an authorisation issued by the competent authority (when the implementation of the mitigation measures is considered to be more complex).

Cross Border permissions

With the standardisation of the UAS classes and operator permissions, it will be possible for people from one country to operate in another without needing to rectify in that country. How that will apply to the UK when it leaves is open to debate & negotiation b the CAA & EASA I guess. (Just don't let Fleece-Moggy & his palls anywhere near the talks or we're all stuffed :D ). If we don't remain within the EASA rules, then we'd need to gain permissions/certification from the first country you fly in inside the EU (jolly to Ireland anyone?).
 
Timescales
...6 months after the publication of the regulation in the Official Journal of the European Union.
By then member states need to
- Have a registration/authorisation database
- Defined UAS no fly and restricted zones

...after a further 3 months from that date
- Operators required to have registered themselves


... 1 year after publication of regulation
your existing SUA NQE/NAA qualification can remain valid until 1 year after the new regs are published. By then the member states are expected to have converted their existing qualifications to the new ones. It's unclear if that means we'll have to retake all the tests and requalify, or if the NAA's will be allowed to simply re-issue your qualifications (assuming they meet the requirements of the new regs). Guess that's a Question for the CAA to answer...


Authorisations and declarations for UAS operators, as well as certificates of remote pilot competency issued on the basis of national legislation prior to the applicability date of the proposed regulation, may be considered valid until 1 year after the entry into force of the proposed regulation and by that time, the MS should have converted them according the new EU framework.

Existing UAS
It's also unclear if existing UAS will be able to meet the requirements of class C2, thus being restricted to A1 and A3 flights. It looks like only new UAS with C2 abilities will be allowed to fly with A2 permissions...

This timeline will enable UAS operations in the ‘open’ category in subcategories A1 and A3 from the first day of applicability, while operations in subcategory A2 would require the availability of UAS that are complaint with the class C2 technical requirements that may only be available after 2 years.
 
I'm just going to wait and see

Not even going to try and guess what the CAA will do
 
Yeah, I'm not going to lose any sleep over it.
The bumbling baffons at EASA will have to make some tweaks first to justify their own importance.
Member states will have to agree (and they never all agree first time round).
Then it will have to be re-written a couple of times.
I think my estimate of 2021 was being conservative.
These Eurofools will never run to timetable and by the time it's ratified we will probably all be retired.
Brexit will be happening around the same time so who knows what will happen.
The whole document will need to be re-written in any case to make it Gender Fluid......Can't possible be calling them UnMANNED Aircraft. They will need to come up with an androgenous word in case it offends someone. :rolleyes:
 
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