GM2 UAS.SPEC.030(2) Application for an operational authorisation

‘GENERIC’ VERSUS ‘PRECISE’ OPERATIONAL AUTHORISATION

According to Article 12 of the UAS Regulation, a competent authority may decide to grant a ‘generic’ operational authorisation, i.e. an operational authorisation that is applicable to an indefinite number of flights taking place in locations generically identified, during the period of validity of the operational authorisation. (Contrary to the ‘generic’ operational authorisation, an operational authorisation that is limited to the number of flights and/or to known locations identified by geographical coordinates will be called ‘precise’ operational authorisation.)

CONDITIONS FOR ISSUING A ‘GENERIC’ OPERATIONAL AUTHORISATION

A ‘generic’ operational authorisation does not contain any precise location (geographical coordinates) but applies to all locations that meet the approved conditions/limitations (e.g. density of population of the operational and adjacent area, class of airspace of the operational and adjacent area, maximum height, etc.). The UAS operator is responsible for checking that each flight they conduct:

— meets the mitigations and operational safety objectives derived from the SORA and the requirements listed in the operational authorisation; and

— takes place in an area whose characteristics and local conditions are consistent with the GRC and ARC classification of the SORA as approved by the NAA.

The UAS operator should anyhow check whether their MS has published a geographical zone in the area of operation according to Article 15 of the UAS Regulation, requiring a flight authorisation (e.g. this may be the case for the areas covered by U-Space). A flight authorisation should not be confused with an operational authorisation.

The criteria to determine whether a UAS operator is eligible for a ‘generic’ operational authorisation are the following:

1. The limitations regarding the operational scenario, the operational volume and the buffers defined by the operational authorisation are expressed in such a way that it is simple for the UAS operator to ensure compliance with those limitations.

It will usually be easier for the UAS operator to ensure compliance when the conditions are unambiguous and not open to interpretation. This is the case, for instance, when:

— a controlled ground area is required, or the density of population is very low;

— the operation takes place in segregated airspace.

In this regard, ‘generic’ operational authorisations may be relevant for operations conducted according to PDRA-Sxx, since the conditions are similar to the ones of the declarative STS and it is relatively easy for the UAS operator to ensure compliance with those conditions.

As a rule of thumb, a ‘precise’ operational authorisation rather than a ‘generic’ one may be more appropriate when the iGRC ≥ 4 or the iARC ≥ ARC-c.

2. The strategic mitigation measures, if any, are not open to interpretation or difficult to implement.

The use of some strategic measure mitigation (M1 for GRC or Step 5 for ARC) often prompt debate between the UAS operator and the NAA regarding the relevance/validity of the data sources (density of population, density/type of traffic in given airspace, etc.), and the efficiency of the proposed strategic mitigation measures. Furthermore, some of these measures are difficult to implement and it is not always possible for the NAA to simply trust the capacity of the UAS operator to do so.

For instance, the following examples show measures that are difficult to implement / open to interpretation:

— achieving a local reduction of the density of population;

— ensuring the absence of uninvolved persons in very large, controlled ground areas, or reserving large, controlled ground areas in densely populated environments;

— starting an operation in airspace that requires a new protocol with the ANSP/ATSP, etc.

Note: In the future, qualified service for strategic deconfliction (U-space) may be a valid mitigation measure for a ‘generic’ operational authorisation.

3. The NAA has assessed the capacity of the UAS operator to identify/assess the local conditions

The UAS operator should have a diligent and documented process to identify/assess the local conditions and their compliance to the limitations given by the authorisation (in the operations manual (OM)). The UAS operator should train its personnel to assess the operational volume, buffers and mitigations in order to prepare for the next operations. The UAS operator should also document and record the assessment of locations (e.g. in mission files), so that adherence to this process can be verified by the NAA on a regular basis.

For simple operations where Criteria 1 and 2 are met, the NAA may decide to issue the ‘generic’ operational authorisation first and assess the robustness of the procedures through continuous oversight.

For complex operations where Criteria 1 and 2 are not met, then the third criterion is paramount. While the NAA may be confident enough to directly issue a ‘generic’ operational authorisation, it may also decide to add some restrictions for the locations that are valid for the first one (or more) operations. The UAS operator should provide evidence to the NAA that the process defined in Criterion 3 has been followed, and the area and local conditions identified by the UAS operator comply with the authorisation. The NAA will review the evidence (as for a ‘precise’ authorisation) and confirm in written to the operator that their analysis is satisfactory.

Once the NAA has enough evidence or confidence that the UAS operator is able to complete the assessments on its own, the restrictions on the location may be withdrawn.

Eventually, a LUC may be appropriate to demonstrate this capacity (see below).

DIFFERENCES BETWEEN A ‘GENERIC’ OPERATIONAL AUTHORISATION AND A LUC

An operational authorisation where the locations are generically identified may to some extent be traced to some privileges granted to a LUC holder: the UAS operator can schedule new flights without receiving a new operational authorisation for each of them. However, a LUC offers more flexibility than a generic operational authorisation by allowing a UAS operator to have different level of privileges, including the possibility to start new types of operations or use previously non-validated types of UASs.

On the other hand, a ‘generic’ operational authorisation does not require the UAS operator to formally implement a management system. Such a management system would be disproportionate for low‑risk operations (such as PDRA-Sxx) (see Criterion 2). However, the more requirements are derived from the SORA and the conditions of the operational authorisations are difficult to check and to comply with, the more robust and reliable the processes and the organisation of the UAS operator need to be to ensure the absence of deviation.

Eventually, a LUC becomes necessary when the risk of deviation from these procedures is high and when deviating from the validated conditions greatly increases the risk of the operation. The LUC management system will be needed to ensure compliance with the procedures of the UAS operator through an independent process.

In this regard, a LUC may be more relevant than a ‘generic’ operational authorisation in the following cases:

— for SAIL ≥ 4 operations (due to OSO#1 ‘Ensure the UAS operator is competent and/or proven’ with a ‘high’ level of robustness); or

— for SAIL ≥ 3 operations, when strategic ground risk mitigation (M1) or strategic air risk mitigation (Step 5) is applied, to make sure that the applicant exhibits the right safety culture to perform a location risk assessment.