The new EU drone regulation divides flights into different operating categories. This means that as of this year, a distinction is made between flights in the categories “open”, “specific” and “certified”. The “open” category covers most (private) flights, for which authorities do not require a separate permit if all requirements are met.
However, the commercial use of UAS is growing steadily. As these flights generally fall into the “specific” category, commercial operations are, therefore, flights requiring a permit with a few exceptions. Thus, flights in this category require a flight authorization, which can be applied for in the form of an operating declaration, operational permit, or operator’s certificate. In the last article, we already dealt with the operating declaration.
This article is about the application for an operational permit. For this, an operating concept must be prepared, and a risk assessment of the project must be carried out. There are several options for the risk assessment, which we will explain in the following.
How to proceed and what you need for an application
Anyone planning a flight in the “specific” category must first describe their operation in detail in the form of an operating concept (also known as ConOps). In the next step, a risk assessment is to be carried out to determine what risk the operating concept entails. Predefined scenarios have been created to reduce the workload for operators and authorities.
The Standard Scenarios (STS) are the lowest-risk flight scenarios with firmly defined specifications, e.g., for flight altitude. The first step should always be to check whether one of the STS applies to the flight. If the project corresponds to one of the STS, a (detailed) risk assessment is not necessary. If this is the case, only an operating declaration must be submitted, containing the rough operating concept with the prescribed contents according to Appendix 5 of the Commission Implementing Regulation 2020/639.
However, Standard Scenarios are not applicable until December 3, 2023. If Standard Scenarios do not apply, as it is currently the case, an application for operational permission must be submitted to the responsible national aviation authority in the form of the elaborated operational concept and a risk assessment as PDRA (Predefined Risk Assessment) or SORA (Specific Operational Risk Assessment). The PDRA represents an extension of the STS with a somewhat higher risk. Therefore, only an abbreviated SORA risk assessment is required.
THE CONCEPT OF OPERATIONS (CONOPS)
The authority approves drone flights in the category “specific” in principle based on a concept of operations (abbreviated ConOps or also called operating manual), which is subjected to detailed risk analysis (more on this below). According to Article 11 of the new EU Drone Regulation, all relevant technical and operational details must be provided within a ConOps to apply for a permit.
The Concept of Operations is a process description that details everything about the flight plan and risk mitigation. Everything from the team to the equipment of the UAS is included. A detailed concept decisively increases the chances of a positive operational authorization. Important: An operational authorization is always applied in the federal state where the person or company is located. A permit is issued by the aviation authority responsible for the federal state (here, you can find a list of the State Aviation Authorities in Germany).
For an operational permit, a risk assessment must be carried out, the results of which can, in turn, determine the content of the operational concept. Accordingly, if the risk assessment still identifies potential risks that have not yet been addressed in the operating concept, the concept must be subsequently adapted.
What does a ConOps contain?
In cooperation with several state aviation authorities, the Federal Aviation Office (Luftfahrt-Bundesamt; LBA) has prepared a detailed template for the creation of a ConOps and a risk assessment. The template including the risk assessment according to SORA is available here (only in German available).
An excerpt from the template as an example of the structure and content of a ConOps (in German:)
A complete and comprehensive list of all possible content items with explanations can be found under “Annex A to AMC1 to Article 11 (p. 57 ff.) of the Easy Access Rules for Unmanned Aircraft Systems (June 2021) published by the EASA.
THE RISK ASSESSMENT
As explained above, the ConOps must be analyzed for its risk. This allows a classification of the risk and determination of appropriate safety measures. There are three options for risk assessment with increasing effort: STS, PDRA, and SORA.
We have explained the Standard Scenarios (STS) required for an operational declaration in more detail in this article. They are predefined and describe a rather low risk, which is why a simple declaration of operation according to an STS to the authority is sufficient (only possible from 03.12.2023). Accordingly, no separate risk analysis needs to be performed here, as the risk parameters within the various scenarios are already defined.
A continuation of the STS is the PDRA (Pre-Defined Risk Assessment). As these are also predefined scenarios, they are also referred to as PDRAs (scenarios). Compared to the STS, these have a higher risk factor, which must thus be considered during operation. Due to the higher risk, a more comprehensive operating concept and risk assessment are also required here, although some steps can be skipped since these parameters are already defined in the individual PDRAs.
If the requirements for PDRAs cannot be met, a SORA risk assessment must be performed (more on this below).
Important
- The STS refer exclusively to C-classified drones. Therefore, the application of an STS is not possible until December 2023.
- The PDRAs can also be flown with existing drones, i. e. not C-classified drones, and therefore already apply now.
- The STSs were established in the EU drone regulation. The PDRAs, on the other hand, were defined by EASA to shorten the effort of a full risk assessment. In the future, the LBA could also define further scenarios.
The Standard Scenarios (STS)
The standard scenarios (STS) are the lowest risk predefined scenarios. If the flight project falls into one of these described categories, an operational declaration must be prepared. The declaration has to be submitted to the LBA. However, this will not be possible until December 2023. A template for the declaration of operation can be found in Appendix 2 of the Commission Implementing Regulation (EU) 2020/639.
STS are intended to reduce the workload on agencies during permitting processes and cover most use cases. In Germany, we have currently two STS defined (according to Appendix 1 of the Commission Implementing Regulation (EU) 2020/639), which are expected to apply from 03.12.2023:
STS-01 for C5 Drones
- VLOS
- Controlled ground area (flight zone, emergency zone, buffer zone)
- Remote pilot certificate required + practical training for STS1
- Airspace: controlled or uncontrolled with low risk of encountering manned aircraft.
- Maximum flight altitude: 120 m
- Maximum speed: 5 m/s
STS-02 for C6 Drones
- BVLOS (max. 1 km horizontal distance)
- EVLOS (max. 2 km horizontal distance)
- Remote pilot certificate required + practical training for STS1 + STS2
- Airspace: controlled or uncontrolled with low risk of encountering manned aircraft
- Maximum flight altitude: 120 m
- Maximum speed: 50 m/s
Pre-Defined Risk Assessment (PDRA)
The Pre-Defined Risk Assessment (shortened risk analysis) contains some risk parameters that are already predefined and are presented in different scenarios (e.g., PDRA-01). Therefore, as with the STS, the PDRAs (scenarios) are also referred to.
They describe riskier flights, which is why a simple operational declaration is not sufficient. They serve to shorten the SORA process. If it turns out that the project falls into a PDRA after the operating concept has been prepared, some steps of the SORA can be skipped.
The various PDRAs already contain in their definition the corresponding values for the final GRC (Ground Risk Class), the final ARC (Air Risk Class), and for SAIL (Specific Assurance and Integrity Level). These are used to determine the OSO (Operational Safety Objectives) (see SORA).
Below you will find all PDRAs defined so far with the corresponding sections of the Easy Access Rules for Unmanned Aircraft Systems (e.g., AMC2) by the EASA, where all criteria are described in detail again..
Here is a link to the standard scenarios: PDRA-S01 is comparable to STS-01, and PDRA-S02 is comparable to STS-02. The main difference is that the UAS can be an existing drone or a DIY-drone, which is not the case with STS. Prerequisites for the application of standard scenarios include the operation of a C-classified drone.
PDRA-S01
- UAS with maximum dimension of up to 3 m and weight of up to 25 kg
- VLOS
- Overflight of a controlled ground area that might be located in a populated area
- Maximum height: 120 m
- Airspace: Controlled or uncontrolled, with low risk of encounter with manned aircraft
- AMC4 Article 11
PDRA-S02
- UAS with maximum dimension of up to 3 m and weight of up to 25 kg
- BVLOS (max. 1 km horizontal distance)
- EVLOS (max. 2 km horizontal distance)
- Overflight of a controlled ground area that is entirely located in a sparsely populated area
- Maximum height: 120 m
- Airspace: Controlled or uncontrolled, with low risk of encounter with manned aircraft
- AMC5 Article 11
PDRA-G01
- UAS with maximum dimension of up to 3 m and typical kinetic energy of up to 34 kJ
- BVLOS (max. 1 km distance)
- EVLOS (range not limited, but max. 1 km distance between the airspace observer)
- Overflight of a sparsely populated area
- Maximal height: 150 m (operational volume)
- Airspace: Uncontrolled, with low risk of encounter with manned aircraft
- AMC2 Article 11
PDRA-G02
- UAS with maximum dimension of up to 3 m and typical kinetic energy of up to 34 kJ
- BVLOS
- Overflight of a sparsely populated area
- Maximal height: as established for the reserved airspace
- Airspace: as reserved for the operation
- AMC3 Article 11
Specific Operational Risk Assessment (SORA)
The EASA-SORA process is described in Article 11 of the Commission Implementing Regulation 2019/947 and named a suitable, Europe-wide recognized means for risk assessment. Accordingly, the former national SORA-GER is no longer valid.
On the right, you will find the entire process of a SORA illustrated. Below, the individual steps are explained again in detail.
Important: The principle of robustness runs through the entire SORA concept and is therefore essential to understand. What is meant by this is that any risk reduction or operational safety objective can be demonstrated at different levels of robustness. The SORA process proposes three different levels of robustness: low, medium, and high. The robustness rating is based on both the level of integrity (the safety gain) and the level of certainty that the claimed safety gain has been achieved. A high level of robustness should therefore be aimed for.
The basis of all risk assessments is a concept of operations. It must be prepared at the beginning and further elaborated during the SORA process so that a complete and fully comprehensive document is produced at the end.
The GRC (ground risk) refers to the risk of a person being hit by the UAS (in the event of a loss of control of the UAV).
The ground risk can be reduced by mitigation measures, i.e., risk reduction measures. A correction factor is determined that indicates the extent to which the risk reductions are available to the operation and the extent to which the GRC can thus be improved. The GRC is then offset against the correction factor, resulting in the Final GRC.
The ARC provides information on the risk of collision with other flying objects in the air. Airspace is divided into 13 collision risk categories based on the factors: Altitude of airspace, controlled or uncontrolled airspace, airport or non-airport, urban or rural airspace, and atypical (e.g., separated) or typical airspace. This then results in ARC classes ARC-a, ARC-b, ARC-c, ARC-d. Only ARC-a is considered an acceptable risk class and requires no further mitigation measures.
This step is optional and only needs to be performed if the applicant estimates that the ARC can be improved with ARC risk mitigation measures in the preceding step. In that case, respective measures can be described in this step, and thus a better classification can be made. This is the Final ARC. If the applicant does not wish to take this step, the ARC from step 4 is automatically the Final ARC.
TMPR stands for Tactical Mitigation Performance Requirement and means tactical risk mitigation requirement. These depend on the respective ARC value. A distinction is made between VLOS/EVLOS and BVLOS flights, whereby VLOS/EVLOS flights do not require a TMPR value and robustness level. They are already considered acceptable tactical mitigation of collision risk for all ARC levels.
For BVLOS flights, the following overview applies:
SAIL combines the ground and air risk analyses (Final GRC and Final ARC) and determines the actions required as a result. SAIL indicates the level of reliability with which UAS operations remain under control.
The SAIL value provides information about the required robustness level of the OSOs. OSO stands for Operational Safety Objective and defines various of them. For example, OSO#4 defines: “UAS developed according to recognised design standards”. The SAIL value would now provide information on the extent to which the specification is to be met.
O = „Optional“; L = Low robustness; M = Medium robustness; H = High robustness
This is about considering the risk of loss of control for the air and ground space. Depending on the flight and flight phase, safety requirements are again imposed here. Since it is not possible to foresee all local conditions, UAS operators should show sound judgment to the competent authority in defining “adjacent airspace” and “adjacent areas”.
The UAS operator should ensure that any additional requirements not identified in the SORA process (e.g., environmental protection) are addressed in this step. Relevant stakeholders should also be identified here. These include, for example, environmental protection agencies, national security agencies, etc.
The time-consuming process of obtaining approval should not deter you from your project. Once the document is created, it only needs to be updated in case of fundamental changes. A permit can thus be issued for repetitive flights.
Do you need help applying for an operating permit? We will be happy to assist you and do the work for you. Click here for our permission service.
We wish you safe flights,
Your FlyNex Team
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