Non-standard and European drone scenarios: good to know.

From December 2, 2021 (this date could be postponed by two years), all new drone operators will be required to use European scenarios within their ConOPs (Contracts of Operations). Existing drone operators may continue to conduct their missions under national scenarios (S1, S2, S3) until December 31, 2023, if they so choose. Today's post aims to reiterate the European drone scenarios defined within the framework of European drone regulations, with a strong focus on non-standard scenarios.

European drone scenarios in the open category

There are three European scenarios: A1, A2, and A3. They concern low-risk operations: visual flights less than 120 meters high outside of public spaces in urban areas with UAS of class C0, C1, C2, C3, C4.

Drones in unclassified production models will be able to operate in the limited open category (A1 limited, A2 limited, A3 limited) during the transition period. These are the same scenarios, but with some stricter restrictions.

European drone scenarios in the specific category

THE standard scenario (STS-1) covers the operations in direct view (VLOS) conducted with a C5 class UAS (CE marked) at a maximum height of 120 m above a ground-controlled area in a populated and/or unpopulated environment. This scenario presents strong similarities with the national scenario S3 (in populated areas).

THE standard scenario (STS-2) covers the operations that can be carried out out of sight (BVLOS) in an unpopulated or sparsely populated environment, The UAS is located at a maximum distance of 1 km from the remote pilot. This distance can be increased to 2 km if airspace observers are present.

The maneuvers take place at a maximum height of 120 m above a controlled ground area in a sparsely populated environment, with a Class C6 UAS (CE marking). This scenario is very similar to the national scenario. S2.

Non-standard European drone scenarios

The open and specific categories cover the vast majority of drone uses. However, in rare cases, it may be necessary to fly outside of these scenarios. Three cases have been identified by the aviation authorities:

• SORA (Specific Operations Risk Assessment)

SORA is a systematic risk assessment methodology for drone operations requiring prior authorization. The method establishes a sufficient level of confidence for the DGAC (French Civil Aviation Authority) to grant operating authorization to the operator.

It allows for the evaluation of the proposed operation concept and its breakdown into 6 specific assurance and integrity levels (SAIL). It then recommends the objectives to be achieved for each SAIL level, in line with the resources to be deployed to make these risks acceptable and therefore the theft possible.

The application for authorization (covering one or more operations) is made to the DSAC/IR.

• PDRA (Pre-Defined Risk Assessment)

PDRAs are used for drones without a class, for drones whose characteristics do not allow them to be classified, or for drones operating in specific high-risk environments.

Its aim is to simplify the authorization procedure insofar as the risks (SAIL) have already been assessed via the SORA methodology by EASA.

There are two types of PDRA: PDRA-S (These PDRAs are modeled on European STSs, except that the drone does not carry a class identification label) and PDRA-G (These PDRAs cover other types of operation that are relatively common in the EU).

• PDRA-S01 (PDRA «mirror» of STS-01), allowing flight under the conditions of this scenario without a CE marked C5 class drone but with similar characteristics, to be demonstrated by the operator;
• PDRA-S02 (PDRA «mirror» of STS-02), allowing flight under the conditions of this scenario without a CE marked C6 class drone (but with similar characteristics, to be demonstrated by the operator);
• PDRA-G01 (formerly PDRA-01). Flight beyond visual line of sight in sparsely populated areas, at less than 120m altitude, less than 1km away from the remote pilot, or at a maximum distance of 1km from a visual observer of the drone (also called "EVLOS": flight within visual line of sight);
• PDRA-G02: flight in sight in a sparsely populated area in airspace reserved for the operation;
• PDRA-G03: beyond visual line of sight flight in "atypical" space (space sufficiently close to the ground or obstacles that the probability of encountering a manned aircraft can be estimated to be very low) in a sparsely populated area.

Possible applications include, for example: autonomous drone surveillance, logistics drone transport over an industrial site, etc.). This PDRA is currently being evaluated by EASA.

• PDRA-G04: long-range beyond visual line of sight flight in non-segregated space and sparsely populated area (applications: long-distance operations, network surveillance, etc.).

Additional traffic detection measures (ADS-B in, FLARM, etc.) and notification systems for other airspace users are implemented to ensure a low probability of collision with a manned aircraft. This PDRA (Plan de Détection et d'Accès aux Risques - Disease and Risk Management Plan) will underpin the continuation of "S4-type" operations after 2021.

This PDRA is currently being evaluated by EASA.

• LUC (Light UAS Operator Certificate)

The LUC is the equivalent of a part of the MANEX. It contains in particular: (i) The operator's privileges; (ii) The types of operations authorized; (iii) The applicable procedures; and (iv) A security management system.

Holders of a LUC (License of Commercial Interest) must meet high standards. In return, this legal entity obtains the right to operate with certain privileges.

It is intended for professional operators who primarily carry out repetitive operations. Operators holding a LUC (License to Operate) can then conduct flights without having to file a declaration or obtain administrative authorization.

It must be approved by a competent authority (DSNA or DSAC/IR), unlike the MANEX we usually use. Holding a LUC is very restrictive and not suitable for small operators. The LUC is primarily intended for large clients.

 

 

Conclusion

The 1^er In January 2021, the MAP disappeared from a national regulatory point of view in favor of the MANEX. This regulatory change thus allowed a French UAS operator to operate in any European state (harmonization of operating procedures between the different member states).

During 2021, the DGAC, in order to support the transition, allowed operators to use their MAP under the name MANEX, subject to: (i) The removal of all references to articles of law from 2012, 2015 and 2017; (ii) Compliance with the decrees of December 20, 2020, particularly regarding night flights, French digital identification systems, etc.

As a drone operator, you will have to revise your MANEX from December 2, 2021 using the European framework defined by EASA which will be put online at the end of July 2021 by the DGAC (Directorate General of Civil Aviation).

This is changing significantly, and you will be required to describe your activity in a much more detailed and structured way, called a Concept of Operations (ConOPS). One of the key points of the regulatory change concerns the fact that the operator must specify, for each of its ConOPS, the list of aircraft and personnel authorized to carry out the operation.

Furthermore, there is considerable uncertainty regarding the time it will take for drone manufacturers to certify their new drones (drone class). It is therefore advisable for operators to inquire about PDRA or SORA.