Understanding EU Drone Regulations for Docked BVLOS Operations

How can BVLOS drone operations be conducted in Europe, especially using a drone docking station? When it comes to flying drones in Europe, understanding the regulations and its entire architecture is important. The European Union Aviation Safety Agency (EASA) oversees the regulations across 27 European Union Countries and 4 others including Iceland, Liechtenstein, Norway, and Switzerland to ensure safe and standardized drone operations.

Recently, we conducted a webinar featuring Matteo Natale, Technical Standards Manager at DJI, focusing on breaking down EU drone regulations, right from the fundamentals to dock operations, while shedding light on the key components that drone operators need to understand.

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The EU Regulatory Framework 

There are two main regulations that guide drone operations in Europe: Delegated Regulation 945 and Implementing Regulation 947.

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Delegated Regulation (EU) 945/2019:

Delegated Regulation 945 outlines specifications for the design and manufacturing processes of Uncrewed Aircraft Systems (UAS). It sets requirements to ensure the safety, reliability, and compliance of UAS products within the European Union.

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Implementing Regulation (EU) 947/2019:

Implementing Regulation 947 establishes rules and procedures governing the operation of Uncrewed Aircraft Systems (UAS) and personnel such as remote pilots within the EU states. It defines the operational requirements to ensure safe and standardized drone activities across member states.

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Classification of drone operations

The European airspace categorizes aerial operations into three main types. The regulation in Europe follows the concept of proportionality. These categories are tailored based on the level of risk associated with different drone operations. This regulatory framework applies to both, commercial and non-commercial operations.

Open category
The Open category pertains to low-risk aerial operations with minimal involvement from authorities. However, there are several technical restrictions and flight limitations to consider. Operators simply need to register their drones, check state insurance requirements, and fly within the operational limits set by the subcategory. The manufacturer, who needs to provide drones with a class identification label, handles any technical restrictions. However, these operations are limited to Visual Line of Sight (VLOS) only and cannot be used for Beyond Visual Line of Sight (BVLOS) flights. 

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In this category, the drones are restricted to a maximum altitude of 120 meters above ground level and can weigh no more than 25 kilograms. The Open category is further divided into subcategories A1, A2, and A3.-- which may be summarized as follows:

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A1: fly over people but not over assemblies of people 

A2: fly close to people

A3: fly far from people

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Specific category

The Specific category involves a higher level of involvement from authorities. Unlike the Open category, drones in the Specific category can fly Beyond Visual Line of Sight (BVLOS), above 120 meters in altitude, and weigh more than 25 kilograms. Generally, commercial drone operations utilizing docking stations to automate flight operations fall under this category. Operators need to seek operational authorization from the National Aviation Authority (NAA) through the following approvals:

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SORA: It is a risk assessment methodology for drone flights in a specific category that aids in classifying risks, identifying mitigations, and setting safety objectives. SORA helps establish operational limitations, training goals, technical requirements, and operational procedures.

PDRA: The Predefined Risk Assessment (PDRA) is an operational scenario for which EASA has already carried out the risk assessment and has been published as an acceptable means of compliance.

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STS: STS is a predefined operation described in EU regulations. An operator is not required to obtain operational authorization to conduct an operation covered by a STS. Two STSs have been published so far:

• STS 01 – VLOS over a controlled ground area in a populated environment;
• STS 02 – BVLOS with Airspace Observers over a controlled.

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LUC: Light Unmanned Operator Certificate (LUC) is an optional certification that grants privileges, such as starting operations in a specific category without requiring operational authorization. Operators can voluntarily request an assessment from their NAA to evaluate their capability to assess operational risks.

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Certified category
The Certified category is designated as high-risk and operates under a regulatory framework akin to crewed aviation. This category applies to operations involving elevated risks such as transporting passengers, carrying dangerous goods, and flying over assemblies of people with drones positioned above three meters.

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Understanding Class Identification Label

According to EU regulations, Uncrewed Aircraft Systems (UAS) are classified into seven distinct categories known as Class Identification Labels. The specifications and physical characteristics of the drone are what determine its classification. These labels range from C0 to C6, with drones in the C0 class weighing less than 250 grams and those in the C6 class weighing less than 25 kilograms. They apply to both the open and specific categories.

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Following are the technical requirements and limitations for all class-labeled drones:

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These labels provide clarity for drone operators and regulatory authorities alike. They ensure that drones are appropriately matched with the level of risk associated with their operation. By categorizing drones into specific classes, the regulations have been tailored to address the varying levels of risk posed by different types of drones. This approach promotes safety, accountability, and standardization across the drone industry.

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The specific category includes class labels C5 and C6. They require the implementation of a geocaging system, enabling remote pilots to establish a virtual perimeter and a programmable boundary for their operations. Additionally, a flight termination system (FTS) must be available for emergencies.

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Remote ID requirements

According to EASA, starting from January 1st, operations in the open category require drones with a class label. But, if you have already bought a drone without a label before January 2024, you can still fly it in subcategories A1, A2, and A3, depending upon the weight of the drone. Additionally, from January 1st, 2024, all drones in the specific category and those with class labels 1 and above must have an active remote identification system.

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Remote ID allows drones to provide identification and location information while airborne, which can be received through a broadcast signal. This feature is essential for ground safety and security in drone operations. Moreover, Remote IDs help EASA, law enforcement, and regulatory bodies identify whether the drones are operating unsafely or in prohibited areas.

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Obtaining operational approvals for the Specific category operations

The Specific category encompasses a wide range of activities, from commercial endeavors to specialized missions that require a higher level of involvement from regulatory authorities. To ensure compliance and safety, operators must undergo a rigorous process of obtaining approvals. By understanding and following these steps, operators can navigate the complexities of the Specific category.

1. Concept of Operations (ConOps): In the drone industry, ConOps outlines how drone systems are used in specific operational environments. It details the roles of drones, user responsibilities, various flight and mission scenarios, as well as maintenance and support protocols, guiding stakeholders through the development, implementation, and usage stages.
   
   
2. Risk Assessment: This assessment helps evaluate potential hazards and assesses the level of risk associated with the proposed drone operation. These assessments could be in the form of Specific Operations Risk Assessment (SORA), Predefined Risk Assessment (PDRA),  Standard Scenario (STS), or Light UAS Operator Certificate (LUC), as mentioned above.
   
   
3. Training: Operators should undergo specific training to demonstrate proficiency in operating drones within the Specific category. These training sessions could cover topics such as flight planning, emergency response, and compliance with regulations. Training ensures that operators have the necessary skills and knowledge to conduct operations safely and effectively.
   
   
4. Approvals: The national aviation authorities evaluate the proposed ConOps and if all the requirements regarding mitigating potential risks are met, they grant approval for the operation to proceed.
   
   
5. Flight: Once the approvals are completed one can conduct the drone operations.

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Understanding the Specific Operations Risk Assessment (SORA) in detail

According to EASA “SORA is a methodology for the classification of the risk posed by a drone flight in the specific category of operations and for the identification of mitigations and of the safety objectives.” The following 10 steps explain the process of obtaining the SORA approval.
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1. Concept of Operations (ConOps): Presenting an organization's system and operations to relevant authorities for approval.

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2. Intrinsic Ground Risk Class (GRC): Determining inherent ground risk based on factors like the presence of people or buildings.

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3. Final Ground Risk Class (GRC): Assessing ground risk after implementing mitigations to address potential hazards.

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4. Initial Air Risk Class (ARC): Evaluating air risk factors before each operation, such as airspace congestion or weather conditions.

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5. Strategic Air Risk Mitigations: Applying pre-flight measures to mitigate air risk, like ensuring drones are weather-resistant.

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6. Tactical Air Risk Mitigations: Implementing in-flight measures, such as automatic hover or return-home programming.

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7. Final Specific Assurance and Integrity Level (SAIL): Determining the overall safety level by combining ground and air risk assessments.

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8. Operational Safety Objectives (OSOs): Identifying specific safety objectives based on the organization's SAIL.

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9. Adjacent Area and Airspace Considerations: Developing strategies to mitigate risks of encroachment on nearby airspace or ground areas during operations.

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10. Comprehensive Safety Portfolio: Compiling all assessment results into detailed safety documentation.

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SORA categorizes the risk of an operation into six levels, denoted as SAIL levels, ranging from I to VI. This classification is derived from a comprehensive evaluation that combines both Ground Risk and Air Risk factors. Each SAIL level corresponds to specific requirements that operators must adhere to, meticulously tailored to mitigate the identified risks inherent to the operation. By employing SORA, operators can effectively evaluate and manage the risk landscape associated with their drone operations, ensuring safety and regulatory compliance across the board.

SAIL II operations with DJI Dock and FlytBase

DJI Dock operations can be conducted for SAIL II levels, for which it is essential to achieve a Ground Risk level of 3. It depends on factors like drone and dock size, as well as population density. Currently, the Matrice 30, coupled with the DJI Dock can be easily flown Beyond Visual Line of Sight over a sparsely populated area, while the smaller drone Matrice 3D coupled with the recently released, Dock 2 can potentially fly over a populated area.

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However, Ground Risk mitigation, such as parachutes should be integrated to lower the Ground Risk down to a level of 3. Additionally, a Flight Termination System (FTS) is a crucial element to be considered, which might be required to operate the drones close to adjacent areas with a particularly higher level of risk.

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EASA's SAIL III compliance, issued on December 18, 2023, provides comprehensive guidance regarding Flight Termination Systems (FTS) in drone operations. It says that drones must be protected from human errors, particularly in situations leading to a loss of control. These situations encompass various scenarios such as crashes with ground, infrastructure, or people.

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The compliance emphasizes preventing pilots from selecting parameters that could directly result in a loss of control, including actions such as selecting non-active communication links, deactivating safety functions necessary for operation, and activating flight termination systems during normal operations.

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The compliance emphasizes preventing pilots from selecting parameters that could directly result in a loss of control, including actions such as selecting non-active communication links, deactivating safety functions necessary for operation, and activating flight termination systems during normal operations.

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FlytBase offers an enterprise-grade drone autonomy platform for streamlined aerial data collection enabling automated BVLOS flights using docking stations. Users can establish custom Geofences and manage No Fly Zones (NFZs) to ensure safety and compliance with regulations. The platform integrates advanced technologies like Detect and Avoid (DAA) systems and ADS-B for airspace awareness, alongside onboard connectivity options and parachute recovery systems. Also, one can access detailed flight logs with automatic PDF reports for safety demonstration and regulatory compliance. 

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Conclusion and way ahead

In conclusion, the EU drone regulations provide a comprehensive framework to ensure the safe and responsible use of uncrewed aircraft systems. From the Open to the Specific category, each level is tailored to the associated risk, fostering innovation while prioritizing safety.

Looking ahead, recent updates from EASA bring promising changes. SAIL 3 operations, previously requiring a design verification report, now become more accessible. Manufacturers can declare compliance through means of compliance (MoCs), providing a pathway to broader Beyond Visual Line of Sight (BVLOS) operations without the need for extensive verification processes.